EPA91WMS-011
                United States
                Environmental Protection
                Agency
Region 1C •
1200 Sixth Avenue
Seattle WA 98101
                Water Division
Alaska
Idaho
Oregon.
Washington
                                  EPA-10-AK-Chuitna-NPDES-go
                                                    February 1990
                                Chuitna
                Coal Project

                Final Environmental Impact Statement
                Volume II - Appendices

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Chapter 13.0
   Index

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                         13.0  INDEX
ADF&G:   (see Alaska Department of Fish & Game)

Access/haul road:   S-2,  2-21,  2-23, 2-35,  2-40, 2-42,  2-43,
     3-6, 3-13, 3-16, 3-17, 3-19, 3-20, 3-21,  5-3,  5-9,  5-78
     through 5-84, 5-91 through 5-95, 5-101 through 5-121,
     6-3, 10-8, 10-10, 10-11, 10-23, 10-37, 10-38,
     10-39

Action alternatives:  (see Alternatives)

Air quality:   S-4,  S-10,  2-47,  2-48, 3-20, 4-60, 4-65,  5-52
     through 5-63, 5-100, 5-111, 5-112, 5-119,  5-126,  5-130,
     5-135, 5-138, 6-12, 6-24, 10-2, 10-10, 10-11,
     10-34, 10-35, 10-40, 10-41, 10-53, 10-56,  10-58

Airstrip:  S-2, S-6, 2-30,  2-31,  2-37,  3-9,  3-23, 3-24,  3-25,
     3-27, 3-36,  3-38,  3-39,  5-6,  5-9,  5-114  through  5-122,
     6-3, 6-15, 10-35

Alaska Coastal Management  Program:   1-10 through 1-13,  6-3,
     6-11, 6-12,  10-28

Alaska Department of Environmental  Conservation (DEC):   1-11,
     1-12, 1-13,  2-42, 5-31, 5-32,  5-62, 6-3,  6-11,  6-15,
     7-5, 10-6, 10-7, 10-8, 10-20,  10-28, 10-29, 10-30,
     10-31, 10-40, 10-43, 10-47, 10-53, 10-58

Alaska Department of Fish & Game (ADF&G):  1-11, 1-12,  1-13,
     5-71, 6-3, 6-8, 6-9,  6-11,  6-12, 6-14,  6-15, 6-18,  6-23,
     6-24, 7-5, 10-55, 10-56, 10-57

Alaska Department of Natural Resources (DNR):   S-l,  1-4,  1-10
     through 1-13, 2-42, 3-39, 4-3,  6-2, 6-5,  6-7,  6-8,  6-9,
     6-11 through 6-14, 7-5, 7-6, 7-7, 10-50

Alaska Native Claims Settlement Act  (ANCSA):   4-1,  4-80

Alaska Range:  S-4, 1-5, 4-4, 4-5,  4-58

Alaska Surface Coal Mining Control  and Reclamation Act:   S-l,
     1-4, 1-5, 1-10, 1-11,  2-1,  6-1  through 6-10, 6-16,  6-17,
     6-20 through 6-23,  10-2,  10-4,  10-5, 10-7, 10-15,  10-16,
     10-22 through 10-27, 10-31, 10-37, 10-41,  10-42,  10-50,
     10-51, 10-52

Alternatives:  S-6,  S-7, S-8, 2-1, 2-2, 2-3, 3-1  3-25 through
     3-40, 5-1, ,10-12, 10-13

Ammonia nitrogen:  4-34, 5-34 through 5-39,  5-87, 5-88,  5-124,
     5-125, 10-3,  10-46
                          13-1

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Anchorage:  S-2, S-3, S-10, 1-5, 2-2, 2-45,  3-8,  3-23,  3-32,
     4-53, 4-60, 4-65, 4-68, 4-70, 4-71, 4-79,  5-62,  5-64,
     5-66, 5-100,  5-101,  5-112,  5-119,  5-126,  5-131,  5-135,
     5-138, 7-1, 7-2, 10-1, 10-33, 10-53

Animal Crossings:   S-2,  S-10,  2-19,  2-21,  3-20,  5-83,  5-84,
5-107, 5-117, 6-17, 10-7, 10-8, 10-11,  10-12,  10-26

Animal feeding:  6-18

Animal-human interactions:  2-23, 2-27, 2-48,  3-10,  3-14,
     5-11, 5-122, 5-123, 6-17, 6-18, 10-14,  10-57

Archeological sites:  4-92, 4-93, 5-78, 5-103,  5-114,  5-115,
     5-121, 5-127,  5-128, 5-132, 5-136

Bald eagle:  S-3, 3-16, 4-16, 5-12, 5-81, 5-82, 5-84,  5-106,
     5-107, 5-117,  5-123, 5-129, 5-133, 6-18

Barges:  2-26, 2-27, 2-42, 2-44, 3-7, 3-32,  5-97, 5-111,
     5-115, 10-43

Bass, Hunt, Wilson  Group:  1-5

Bathymetry:  4-51,  4-52

Beaver:  4-21, 5-12, 5-48, 5-81, 5-89,  6-23

Beluga airstrip:  2-3, 3-3, 4-3, 4-14,  4-16

Beluga power station:  S-3, 2-31, 3-3,  3-8,  3-16, 3-26, 4-1,
     4-14, 4-60, 5-106, 5-115, 5-117, 5-136

Beluga Region:  S-l, S-2,  1-4,  1-5,  4-1, 4-3,  4-4, 4-14, 5-1,
     5-2, 5-64, 5-72, 5-104, 5-113, 5-115, 5-120, 5-128,
     5-137, 10-36,  10-57

Beluga River:  1-5, 3-8, 4-3, 4-4, 4-14, 4-16,  4-17,  4-51,
     4-57, 4-86, 5-105, 5-114, 5-121

Belukha whale:  (see Marine mammals)

Benthic invertebrates:  4-40, 4-54, 5-98, 5-99

Beshta Bay:  5-99

Birds:   (see  Bald eagle,  Ducks,  Geese,  Peregrine  falcon,
     Sandhill crane, Shorebirds, Songbirds, Trumpeter  swan)

BLM:  (see U.S. Bureau of Land Management)

Black Bear:  S-3,  S-10,  4-13,  4-17,  4-20,  4-22,  4-92,  5-10,
     5-12 through 5-15, 5-82 through 5-85,  5-103, 5-114,
     10-12, 10-57
                          13-2

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Blasting:  2-8, 2-40, 5-64, 5-84, 5-107, 5-117, 10-54

Bonding:  6-10

Borrow sites:  2-40, 2-42, 5-9, 5-84, 6-12, 10-7,  10-8

BOX CUt:  2-7, 2-13, 2-32

Bridges:  2-43

Brown bear:   S-3,  S-10,  3-31,  4-17, 4-19,  4-20, 4-22,  4-92,
     5-10 through 5-15, 5-82 through 5-85, 5-107,  5-117,
     5-122, 5-123, 10-12, 10-57

Causeway:  3-7, 3-10, 3-11

Chakachatna River:  4-3, 4-4, 4-5,  4-85, 4-86

Chugach Electric Association:  S-3, 2-31, 3-25, 4-1, 4-79

Chugach Mountains:  4-58, 4-60

Chuit Creek:  4-16, 4-29, 4-47, 5-37, 10-49

Chuit Flats:  5-111

Chuitbuna Lake:  4-29, 4-48, 5-114, 5-118

Chuitna River:  S-2, S-4, S-10, 1-5, 1-8, 2-15, 2-30, 3-3,
     3-8, 3-21, 3-32, 3-36, 3-38, 4-3, 4-10, 4-11, 4-13,
     4-14, 4-16, 4-17,  4-19,  4-20,  4-21, 4-23, 4-29 through
     4-50, 4-55, 4-85,  4-86,  4-91,  4-92, 5-11, 5-21 through
     5-26, 5-30, 5-39, 5-40, 5-42,  5-43, 5-48,  5-50, 5-51,
     5-52, 5-75, 5-76, 5-77, 5-84,  5-94, 5-96,  5-102, 5-108,
     5-110, 5-111, 5-113, 5-114, 5-115,  5-120,  5-124, 5-125,
     5-127, 5-129, 5-130, 5-131, 5-132,  5-135,  5-136, 5-137,
     5-144, 6-10,  6-11,  6-19,  6-20,  6-23, 10-7,  10-20, 10-29,
     10-36, 10-44, 10-57

Clean Water Act:   (see Section 404)

Clearing:  2-7, 2-40, 5-4, 5-75, 5-79, 5-80, 5-105, 5-116,
     5-121, 5-122, 5-128, 10-42

Coal:  1-4, 1-5, 2-1, 2-2, 2-5, 2-7, 2-15, 2-19, 2-13,  2-25,
     2-26, 2-27, 2-32, 2-44, 2-48,  3-6,  3-7, 3-10, 3-11,
     3-17, 3-19, 3-21, 4-1, 4-3, 4-4, 4-23, 4-24,  4-25,  5-3,
     5-4, 5-19, 5-80, 5-97,  5-139,  5-140,  6-20, 10-3,  10-6,
     10-10, 10-36, 10-43, 10-49, 10-52

Coal-carbon dioxide slurry:  3-6, 3-10,  3-11

Coal-water slurry:  3-6, 3-10, 3-11, 10-54
                          13-3

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Coastal  Zone Management:    (see Alaska  Coastal Management
     Program)

Collection ditch:   (see also Drainage and drainage control,
     RlUlOff) 2-13, 2-15, 2-21

Commercial fisheries:  S-4, S-5,  S-10,  1-9,  3-10,  3-30, 3-32,
     3-34, 3-35, 3-37,  3-38, 4-41, 4-54, 4-57, 4-58, 4-85,
     5-76, 5-98, 5-99,  5-100, 5-111, 5-131, 5-135, 6-23,
     6-24, 10-1, 10-48, 10-49, 10-56

Community facilities:   4-71, 4-72, 4-78, 4-79, 5-68, 5-69,
     5-70, 5-71

Component:  S-5, 1-8, 1-9, 2-1,  2-3, 2-5, 3-1, 3-2, 3-25,
     5-1, 5-9, 5-76

Congahbuna housing site:  S-2, s-8, 2-3, 2-30, 3-8, 3-11,
     3-22, 3-23, 3-26,  3-27, 3-28, 3-36 through 3-39, 5-9,
     5-128 through 5-132, 10-21

Congahbuna Lake:  3-8,  3-23, 4-14, 4-17, 4-20, 4-29, 4-60,
     4-80, 5-72, 5-82,  5-129, 5-132, 10-21

Conveyor:  S-2, S-10, 2-2, 2-7,  2-9, 2-15, 2-19,  2-21, 2-23,
     2-25, 2-35, 2-42,  2-43, 2-47, 3-2, 3-7, 3-11, 3-17,
     3-18, 3-19, 3-22,  3-26, 5-9, 5-78 through 5-87, 5-89,
     5-100, 5-101, 5-102, 5-105, 5-107, 5-108, 5-114, 5-117,
     6-3, 10-2, 10-6, 10-7,  10-8, 10-10, 10-11, 10-12, 10-23,
     10-38, 10-39, 10-41, 10-43, 10-54

Cook Inlet:  S-l, S-3,  S-4,. 1-4, 1-5, 2-2, 2-23,  2-25, 3-32,
     4-4, 4-14, 4-17, 4-19, 4-20, 4-50 through 4-60, 4-65,
     4-71, 4-91,  4-92,  4-93,  5-52,  5-66,  5-72,  5-91,  5-93
     through 5-98, 5-136, 5-138, 10-19, 10-29, 10-33,
     10-47,10-49, 10-57, 10-58

Cook Inlet Region, Inc. (CIRI):  S-3, 4-3, 4-80,  5-74

Cook Inlet Region Native Corporation:  2-3

Corps:   (see U.S. Department of Army Corps of Engineers)

Cost:  (see Economics)

Council on Environmental Quality (CIQ): S-l, 1-4, 6-2

Crusher  (primary):  S-2, 2-7, 2-9, 2-15, 2-47

Crusher  (secondary):  S-2, 2-7, 2-9, 2-15, 2-47

Cultural resources:   4-92,  4-93,  5-78,  5-103,  5-114,  5-115,
     5-121, 5-127, 5-128, 5-132, 6-24
                          13-4

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Culverts:  2-21, 2-25, 2-43, 5-89, 5-92, 5-110, 6-12, 6-14,
     6-15

Cumulative impacts:  s-5, 1-9, 3-19, 5-136, 5-137, 5-138

Currents:  4-51

DICJ  (see Alaska Department of Environmental Conservation)

Denslow Lake:  4-17

Diamond Alaska Coal Company (Diamond Alaska):  S-l, S-3,
     1-4, 1-6, 1-10, 2-1, 2-2, 5-2, 5-70, 6-2, 6-7, 6-16,
     6-20, 7-7, 10-1, 10-9, 10-27, 10-32, 10-48, 10-50,
     10-52, 10-54, 10-58

Diamond Chuitna:   (see Diamond Alaska)

Diamond Shamrock Chuitna Coal Joint Venture:  1-6

Diesel fuel:  2-27, 2-46

Distribution lists:  9-1 through 9-6

DNR:  (see Alaska Department of Natural Resources)

Drainage and drainage control:   2-1,  2-9,  2-11, 2-13, 2-15,
     2-21, 2-23, 2-25, 2-30, 2-32, 4-14, 5-20, 5-30,  5-32,
     5-33, 5-34, 5-36, 5-44, 5-89, 6-4, 6-5, 6-6, 6-9, 6-19,
     6-20, 10-41, 10-42, 10-48

Dredging:  2-42

Drift River:  5-98, 5-136

Ducks:  3-38, 4-14, 4-55, 4-83

Dust:
     road:  2-47,  2-48,  3-19,  3-20,  5-80, 5-93, 5-100, 5-112,
            5-126, 6-24, 10-2, 10-39, 10-40
     coal:  2-19, 2-27, 2-47, 2-48, 5-80, 5-93, 5-100, 6-23,
            10-6, 10-10, 10-11, 10-39, 10-40, 10-41

Dust control:  2-19, 2-27, 2-47, 5-93, 5-95, 5-126, 10-2,
     10-10, 10-11, 10-39, 10-41, 10-42

Earthguakes:  (see Seismology)

Eastern corridor:  2-19, 2-21, 2-40, 3-34, 4-40, 4-48, 5-9,
     5-116 through 5-121, 10-2, 10-8, 10-12

Eastern/Ladd option:  S-6, S-8, 2-3, 2-4, 3-3, 3-11,  3-13,
     3-15, 3-16, 3-17,  3-25 through 3-34, 5-81, 5-116  through
     5-121, 10-12, 10-49, 10-54, 10-55
                          13-5

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Employment:  S-3,  S-70,  2-38,  2-45,  2-46, 3-32, 4-70, 4-71,
     4-74, 4-75,  4-76,  4-77,  4-81,  4-82, 5-64, 5-66 through
     5-72, 5-138, 5-140

Endangered species:  4-10, 4-22, 4-57, 5-8, 5-81, 5-122,
     5-133

Environmental coordinator:  2-48, 10-53

Environmental training program:  2-48

EPA:  (see U.S. Environmental Protection Agency)

Erosion:  2-11, 2-31, 2-32, 2-33, 2-40, 2-43,  2-44, 3-19,
     5-32, 5-33,  5-36,  5-45,  5-89,  5-91, 5-92, 5-97,  5-108,
     6-4, 6-6, 6-7, 6-14, 6-17, 10-10, 10-15

Faults:  4-26, 10-4

Fire:  5-40, 10-42, 10-43, 10-53

Fish:  (see also Marine Fish)  S-10, 1-8, 1-9,  2-32, 2-43,
     3-13, 3-14, 3-15, 3-16, 3-18, 3-19, 3-30,  3-31, 3-32,
     3-36, 3-37, 3-38, 4-13, 4-40 through 4-50, 4-54 through
     4-58, 4-83,  4-85,  4-88,  5-44  through 5-51, 5-76, 5-77,
     5-94, 5-95,  5-98,  5-99,  5-102,  5-109,  5-110, 5-113,  5-
     119, 5-120, 5-130, 5-131, 5-134, 5-137, 5-141, 6-8,
     6-20, 6-21, 6-22, 6-23, 10-9, 10-25, 10-42, 10-52,
     10-55, 10-56

     Anadromous fish:   (see also Salmon)  S-4,  1-8, 2-32,
     3-10, 4-40 through 4-50, 4-54 through. 4-58, 5-44, 5-94,
     5-98, 6-9, 6-12, 6-21, 6-22, 10-55

     Arctic lamprey:  4-44

     Chinook salmon:  S-4, S-10, 4-41 through  4-50, 4-56,
     4-83, 4-91,  4-92,  5-42,  5-43,  5-46 through 5-51, 5-76,
     5-94, 5-109, 5-125, 5-127, 5-131, 5-137,  6-20, 6-21,
     6-23, 10-56

     Chum salmon:  S-4, 4-44, 4-55, 4-56, 10-56

     Coastrange sculpin:  4-41

     Coho salmon:  S-4, S-10, 4-41 through 4-50, 4-55, 4-56,
     4-91, 5-42, 5-43, 5-46 through 5-51, 5-76, 5-94,  5-109,
     5-125, 5-127, 5-137, 6-9, 6-12, 6-20, 6-21, 10-56

     Dolly Varden:  4-41,  4-48,  4-49,  4-50, 4-55, 4-56, 4-85,
     5-42, 5-43, 5-48,  5-49,  5-50,  5-109,  5-114, 5-125, 5-134

     King salmon:  (see Chinook salmon)

     Migration:  3-31, 4-44, 4-48, 4-50, 4-54,  4-55

                          13-6

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     Pacific lamprey:  4-41

     Pink salmon:  S-4, 4-41 through 4-50, 4-55, 4-56,  5-42,
          5-43, 5-46 through 5-51, 6-21, 10-56

     Rainbow trout:  S-4,  4-41,  4-49, 4-50, 4-85, 4-91,  5-42,
          5-43, 5-48, 5-49, 5-50, 5-73, 5-110, 5-114, 5-125,
          5-134, 6-21

     Red salmon:   (see Sockeye salmon)

     Salmon:  S-4,  2-43,  4-16,  4-19, 4-20, 4-40 through  4-50,
     4-54 through  4-58,  4-83,  4-85,  4-88,  4-91,  4-92,  5-11,
     5-12, 5-44 through 5-49, 5-76, 5-98, 5-102, 5-109, 5-110,
     5-111, 5-114,  5-117, 5-125, 5-127, 5-131, 5-134, 6-8,
     6-20 through  6-23, 10-55

     Slimy sculpin:  4-41

     Sockeye salmon:  4-42, 4-43, 4-44, 4-48, 4-55, 4-91,
     5-50, 6-22

     Spawning:  2-43, 3-13,  3-14,  3-31,  4-44  through 4-48, 4-
     50, 4-55, 5-11, 5-12, 5-44 through 5-49, 5-76, 5-94,
     5-109, 5-137,  6-8, 6-9, 6-11, 6-12, 6-20, 6-21, 6-23,
     10-55

     Three-spine stickleback:  4-41, 5-95, 5-110

Flocculation:  5-33, 5-34, 5-36, 5-37,  6-5,  10-17, 10-18,
     10-42

Fuel:  2-27, 2-46,  2-47, 5-80, 5-87, 5-96, 10-8

Furbearer:  5-12,  5-13, 5-81

Geese:  4-14

Geology:  4-3,  4-4,  4-5,  4-23,  4-24,  4-25,  5-3,  5-78,  5-79,
     5-95, 5-97, 5-110, 5-116, 5-121, 5-128, 5-133, 5-140

Glossary:  12-1 through 12-8

Granite Point:  3-3,  3-8,  3-22,  3-33, 4-16, 4-19, 4-52,  4-53,
     4-54, 4-57, 4-58, 4-86, 4-88, 5-72, 5-108, 5-110,  6-14

Granite Point port site:  S-2, 2-23, 2-25, 2-26, 2-27,  2-31,
     3-32,  3-33,   4-3,  4-11,  4-22,  4-51,  4-53,   5-9,   5-78
     through 5-104, 5-108, 5-111, 6-14, 6-15, 10-4, 10-13,
     10-28, 10-29,  10-31, 10-34, 10-35, 10-39, 10-47, 10-52,
     10-53

Gravel:  2-21, 2-40, 5-3, 5-78, 5-84, 5-121, 10-7, 10-37
                          13-7

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Ground water: S-4,  1-8,  2-30,  4-24 through 4-29, 5-10,  5-16
     through 5-20,  5-23, 5-28, 5-29, 5-30, 5-36, 5-37,  5-85,
     5-87, 5-107, 5-123, 5-129, 5-134,  6-9, 6-10, 10-3,  10-4,
     10-19, 10-37

Gulls:  4-56, 4-57

Habitat:

     Fish:  S-4, S-10, 1-8, 1-9, 2-32, 3-13, 3-14, 3-30,
     3-31, 4-13, 4-38 through 4-49, 5-44  through 5-51,  5-109,
     5-110, 5-131, 5-137, 5-138,  6-8,  6-9,  6-12,  6-20 through
     6-23, 10-24, 10-26, 10-52

     Wildlife:   S-3,  S-4,  S-10,  1-8,  1-9,  2-31, 2-32,  3-13,
     3-14, 3-16, 3-27, 3-29, 3-30, 3-31, 3-35,  3-38, 4-13,
     4-17 through 4-23, 5-12 through 5-16,  5-81  through 5-85,
     5-106, 5-107,  5-117, 5-122, 5-123,  5-129,  5-131,  5-133,
     5-137, 5-138,  5-139, 6-7, 10-11, 10-23, 10-26, 10-57

Habitat evaluation:  4-22, 4-23, 5-13, 5-16, 5-85, 10-11

Haul Road:  (see Access/Haul road)

Hazardous wastes:   2-15, 2-25, 2-30, 5-93, 6-13

Herbicides:  2-1, 4-39

Housing:  (see aso Congahbuna housing site,  Lone  Creek housing
     site, and  Threemile housing site)   S-2,  1-9,  2-1,  2-2,
     2-27, 2-30, 2-37,  2-38,  3-7 through 3-11,  3-22 through
     3-28, 3-36 through  3-39,  5-121 through 5-136, 6-3,  6T4,
     6-13, 6-15, 6-19, 10-15,  10-29, 10-29, 10-32, 10-33,
     10-44

Hunting:   (see Sport hunting,  Subsistence)

Hydrology:  S-10,  4-13,  4-14,  4-24 through 4-38, 5-10,  5-16
     through 5-30,  5-41, 5-85, 5-87 through 5-91, 5-107,
     5-108, 5-118,  5-123, 5-124, 5-129,  5-134,  5-137,  6-9,
     6-10, 6-19, 10-4, 10-24,  10-25, 10-26

Ice:  2-26, 2-27, 3-9, 3-10, 4-53, 5-23, 5-64,  5-89, 5-95,
     10-15, 10-15,  10-35

Instream flow incremental methodology:   5-47, 6-21

Interburden:  2-5,  2-7,  2-32,  4-5, 5-3,  5-32, 6-6

Iron:  4-38, 4-39,  5-31  through  5-39, 5-87, 5-88, 10-3,
     10-31, 10-46

Irreversible and irretrievable commitments:  5-140

Japan:  1-5

                          13-8

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Kenai, City of:  3-9, 4-53, 4-59, 4-60, 4-64, 4-65,  4-66,
     4-68 through 4-73, 5-62, 5-64, 5-67, 5-68, 5-96,  5-100,
     5-114, 5-126, 5-131, 5-135

Kenai Peninsula:  S-10, 2-45, 3-23, 3-32, 4-5, 5-2,  5-64,
     5-101, 5-112, 5-119

Kenai Peninsula  Borough:   S-3,  1-13,  2-3, 4-3, 4-68 through
     4-74, 4-78, 4-80,  4-82,  5-64,  5-65,  5-72, 5-74,  5-102,
     5-115, 5-138, 6-16, 7-5, 7-7, 10-1,  10-14, 10-33,  10-52

Knik Ann:  4-54, 4-55

Kodiak Lumber Mills  (KLM):  4-74, 4-82, 4-86, 5-69,  5-70,
     5-126

Korea:  1-5

Ladd port site:  S-2, S-6, 2-3, 2-23, 2-25, 2-26,
     2-27,  2-31, 3-3,  3-27,  3-32,  4-3,  4-48,   5-9,   5-104
     through 5-115,  5-118, 5-120, 5-121,  6-14, 6-15, 10-2,
     10-4, 10-12, 10-13,  10-28,  10-30,  10-31, 10-34,  10-35,
     10-39, 10-47, 10-48, 10-52, 10-53, 10-57

Ladd Road:  3-3, 4-33, 4-35

Landfill:  2-15, 2-25, 2-30, 2-35, 6-15,  10-43

Land status:  4-1, 4-2, 4-3

Lead:  5-35, 5-45, 10-3

Loading facilities:   (see Trestle)

Logical mining unit:  3-3, 5-128, 5-132,  5-137

Logical mining unit  no. 1 (LMU-1):  2-4

Lone Creek:  S-8, 2-11, 2-19, 3-8, 4-17,  4-19, 4-20, 4-27,
     4-29, 4-35, 4-36,  4-40,  4-41,  4-44 through 4-48,  4-50,
     4-86, 5-11, 5-19, 5-21, 5-23, 5-25,  5-26, 5-27, 5-29,
     5-30, 5-37, 5-41,  5-46,  5-49,  5-50,  5-51, 5-76,  5-107,
     5-108, 5-109, 5-117, 5-119, 5-120, 5-121, 5-125,  5-127,
     5-134, 6-8, 6-10, 6-21, 10-49

Lone Creek Coal Company:  1-5

Lone Creek housing site:  S-2, S-6, 2-3,  2-29, 3-8,  3-11,
     3-22 through 3-28,  3-36  through  3-39,  5-9,  5-86,  5-121
     through 5-136,  10-29

Long-term productivity:  5-139, 5-140
                          13-9

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Manganese:  4-38, 4-39, 5-34 through 5-39, 5-87,  5-88,  10-3,
     10-46

Marine biology;  4-54 through 4-57, 5-52, 5-98, 5-99,  5-111

Marine birds:  4-55, 4-57, 5-98, 5-99

Marine fish:  4-54, 4-55, 4-56, 6-23

     Eulachon:  4-54, 4-55, 4-56, 4-85
     Bering cisco:  4-54, 4-55, 4-56
     Smelt:  4-54, 4-55, 4-56, 4-85
     Herring:  4-54, 4-55, 4-56

Marine invertebrates:  4-54, 4-55, 5-99, 5-111

Marine mammals:  1-9, 4-54, 4-57, 4-85, 5-98

     Belukha whale:  S-4, 4-54, 4-57, 4-85, 5-99
     Harbor seal:  4-57, 4-85

Material sites:  (see Borrow sites)

Maxus Energy Corporation:  1-5

McArthur River:  4-4, 4-5, 4-52, 4-83, 4-85, 4-86, 4-92,
     5-75, 5-101

Mercury:  5-35, 10-3

Meteorology:  4-58 through 4-65

Middle River:  4-3, 4-85

Mine:  S-2, S-10, 1-5, 1-9, 1-11, 2-2, 2-5, 2-7,  2-9,
     2-11, 2-31, 3-1, 3-3, 3-10, 3-11, 3-25, 3-26, 3-28,
     3-29, 4-11, 4-58, 5-3 through 5-78, 6-3 through 6-13,
     6-15, 10-6, 10-27, 10-28, 10-30, 10-31, 10-36, 10-37,
     10-44, 10-48

Mine service area:  2-2, 2-3, 2-7, 2-13, 2-15, 2-34, 2-35,
     2-38, 3-10, 3-11, 3-25, 3-26, 3-28, 3-29, 5-5, 5-6,
     5-9, 5-11, 6-3

Mitigation:  S-5,  1-3,  1-9,  2-1,  3-35,  3-40,  4-22, 5-1, 6-1
     through 6-24, 10-2, 10-4, 10-5, 10-6, 10-9,  10-10,
     10-12, 10-22, 10-24, 10-25, 10-46

Mixing zones:  2-9, 2-11, 6-12, 10-2, 10-6, 10-7,  10-16,
     10-21, 10-28, 10-29, 10-30, 10-44, 10-47

Monitoring:  1-3, 1-6, 6-1 through 6-24, 10-3, 10-4, 10-5,
     10-18, 10-25, 10-26, 10-27, 10-31, 10-32, 10-42

Mooring dolphins:  2-24

                         13-10

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Moose:  S-3, S-10, 2-19, 2-21, 3-13, 3-20, 4-13, 4-17, 4-19,
     4-22,  4-83,  4-85,  4-86,  4-87,  4-88, 5-10 through 5-16,
     5-75,  5-76,  5-81 through 5-85, 5-101, 5-102, 5-107,
     5-117, 5-122, 5-123, 5-127, 5-129,  5-133, 6-8, 6-18,
     10-7,  10-8,  10-12, 10-13, 10-14, 10-18, 10-21, 10-23,
     10-26, 10-36, 10-37, 10-57

Moquawkie Indian  Reservation:  4-1, 4-77, 4-80, 10-13

Mount Augustine:  4-52

Mount Spurr:  4-4

National Ambient  Air Quality Standards  (NAAQS):  5-52, 5-53,
     5-100, 10-11, 10-40

National Environmental Policy Act of 1969 (NEPA):  S-l,  1-1,
     1-2, 1-4, 1-11, 1-12, 4-1, 7-2, 10-1, 10-12, 10-50,
     10-57

National Marine Fisheries Services  (NMFS):  7-2

National Ocean Survey (NOS):  4-51

National  Pollutant  Discharge  Elimination  System   (NPDES)
     Permit: S-l, 1-4, 2-25, 5-94,  5-96,  5-124, 6-15, 7-2,
     10-2,  10-6,  10-13, 10-15, 10-16, 10-20, 10-28, 10-29,
     10-30, 10-42, 10-44, 10-45, 10-48

National Wetland  Inventory Program:  4-11, 4-12

Native Village of Tyonek (NTV) :  4-73 through  4-80, 5-74

Navigation:  5-97, 5-98, 5-100

Nickel:  5-34 through 5-39, 10-3, 10-46

Nikiski:  4-54, 5-98

Nikolai Creek:  3-23, 3-24, 4-4, 4-14, 4-16, 4-17, 4-48,
     4-57,  4-85,  4-86, 4-91, 5-76,  5-104, 6-11

Nikolai housing site:  3-8, 3-11, 3-22,  3-23

NMFS: (see  National Marine Fisheries Service)

No Action Alternative:  S-6, S-8, 3-1, 3-40, 5-1, 5-2

Noise:  S-4, 3-18, 3-19, 4-65, 5-11, 5-12, 5-13, 5-64, 6-65,
     5-75,  5-82, 5-83,  5-85,  5-92,  5-99,  5-101, 5-107, 5-112,
     5-117, 5-119, 5-126, 5-130, 5-135

North Foreland:   3-3, 4-3, 4-51, 4-90, 5-96, 5-102, 10-34,
     10-35

                         13-11

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North Foreland port site:  3-9 through 3-12, 10-1, 10-2,
     10-34, 10-35, 10-54

Northern corridor:  2-15, 2-19, 2-21, 2-40, 4-40, 5-9,  5-78,
     5-111, 5-112, 5-113, 10-2, 10-8, 10-48, 10-54

Northern/Ladd option:  S-6,  2-3,  3-3,  3-11,  3-13,  3-15,  3-16,
     3-17, 3-25 through 3-36, 5-81, 5-104 through 5-119,
     5-121, 10-5, 10-11, 10-12, 10-38, 10-39, 10-43, 10-55

Office  of Management  and  Budget  (State  of Alaska):    1-10
     through 1-13, 7-5

Old Tyonek Creek:  s-4, 2-15, 4-4, 4-21, 4-23, 4-29, 4-31,
     4-39, 4-40, 4-48, 4-85, 4-86, 5-90, 5-94, 5-102, 5-129,
     6-11, 6-14, 10-49

Options:  S-6, 2-1, 2-3, 2-5, 3-1, 3-9 through 3-25, 3-27,
     3-36 through 3-39

Options screening criteria:  3-12, 3-14, 3-15

Options screening process:  S-5, S-6, 1-3,  3-9 through  3-39

Overburden:  2-5, 2-7, 2-32, 4-5, 4-26, 5-3, 5-4, 5-7,  5-16,
     5-17, 5-34, 5-52, 5-59, 6-6, 6-7

Overburden stockpile:   2-3, 2-7, 2-13, 2-33,  3-3,  3-10 through
     3-13, 3-25, 3-26, 5-3, 5-6, 5-11, 5-36, 6-6, 6-7,  10-36

Particulates:  (see Air Quality)

Passerines:  (see Songbirds)

Peregrine falcon:  4-22

Permits:  S-8, 1-1 through 1-4, 1-9 through 1-13, 2-1,  2-9,
     2-11, 3-39, 3-40, 6-1 through 6-17, 10-4, 10-5, 10-6,
     10-13, 10-22 through 10-27, 10-28, 10-29, 10-30, 10-32,
     10-44, 10-45, 10-48, 10-52, 10-53, 10-58

Petroleum product spills:  2-46, 2-47, 3-14, 3-29, 5-20,
     5-40, 5-80, 5-87, 5-93, 5-94, 5-96, 5-97, 5-111, 5-118,
     5-122, 5-123, 5-134, 10-41, 10-42

pH:  4-38, 5-11, 5-30, 5-31, 5-35, 5-45, 5-87, 10-3,
     10-31, 10-45

Physiography:  4-3, 4-4, 4-88, 4-90, 4-91, 5-3, 5-78, 5-104,
     5-116, 5-121, 5-128, 5-133

Placer U.S. Center Ridge:  3-33, 5-104, 5-115, 5-121, 5-137

Pneumo-train:  3-6, 3-10, 3-11
                         13-12

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Population  (human):  4-68 through 4-74, 5-66 through  5-72,
     5-113

Port facilities:   (see also Granite Point port  site and  Ladd
     port site)  2-23, 2-25, 2-26, 2-27, 2-35,  3-13,  5-4,
     10-34, 10-35

     Offshore port facilities:  2-26, 2-27, 2-35,  2-38,  5-4,
     5-79,  10-1
     Onshore port  facilities:  2-23, 2-25, 2-35, 2-38, 2-44,
     5-4, 5-59, 5-79

Port site:  (see Granite Point port site, Ladd  port site)

Power generation:  S-3, 2-1, 2-31, 3-3, 3-11, 3-12, 3-25,
     3-28,  5-53, 5-59, 5-62, 5-78

Preferred alternative:  3-34, 3-35, 3-36, 3-39

Prevention of Significant Deterioration (PSD):   10-11,  10-41,
     10-58

Railroad:   3-7, 3-11, 3-17 through 3-22

Raptors: (see Bald eagle, Peregrine falcon)

Reclamation:  S-5, S-8, S-10, 1-3, 2-1, 2-7, 2-31  through
     2-35,  3-14, 3-15, 3-17, 3-18, 3-21, 3-30,  3-37,  5-3,
     5-4, 5-7, 5-8, 5-10,  5-11,  5-13,  5-20, 5-28, 5-41, 5-80,
     5-122, 5-124, 5-131, 6-6 through 6-9, 6-16, 6-17, 6-21,
     6-22,  6-23, 10-2, 10-4, 10-25, 10-37

Record of Decision (ROD):  1-2, 6-15, 10-12, 10-13

Recreation:  3-14, 3-15, 3-18, 3-20, 4-14, 4-91, 4-92, 5-11,
     5-31,  5-64, 5-77, 5-103, 5-114, 5-120, 5-121, 5-126,
     5-127, 5-132, 5-136, 6-24

Red squirrel:  4-13

References:  ll-l through 11-18

Regional use:  3-14 through 3-18, 3-21, 3-30, 3-33 through
     3-36,  3-38, 3-39, 5-78, 5-104, 5-115, 5-121,  5-128,
     5-132, 5-136

Responsiveness summary:  1-1

Revegetation:  2-5, 2-21,  2-31 through 2-35, 2-37,  2-42,  5-4,
     5-7, 5-8, 5-32,  5-124,  6-6,  6-7,  6-8, 6-17, 10-2,  10-10,
     10-15, 10-22, 10-25, 10-50

Riprap:  2-11, 2-32, 2-40, 2-43

River and Harbor Act of 1899:  (see Section 10)

                         13-13

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Runoff:  2-9, 2-11, 2-13,  2-21,  2-25,  2-30,  2-40, 2-42, 2-43,
     2-47, 4-28 through 4-33, 4-52, 5-11, 5-21, 5-32 through
     5-39, 5-89, 5-91, 5-92,  5-108,  5-124, 5-129, 5-134, 6-4,
     6-5, 6-13, 10-15, 10-32, 10-33,  10-41, 10-50, 10-51

Salinity:  4-53

Salmon:   (see Fish)

Sandhill crane;  S-3, 4-13, 4-16, 4-23, 5-12, 5-13, 5-14,
     5-82, 5-84, 5-85, 5-106, 5-107

Scoping  issues:   S-4, 1-1,  1-2,  1-8, 1-9,  3-1,  3-12, 3-22
     through 3-25, 3-27, 6-20

Scoping process:  S-4, 1-1, 1-2, 1-8, 2-1,  2-5, 3-1, 3-9,
     6-1, 7-1 through 7-4

Section 10 (River and Harbor Act of 1899):  S-l, 1-4,  10-13

Section 404 (Clean Water Act  of  1972): S-l, 1-4, 4-11, 6-16,
     10-13, 10-43, 10-45, 10-47

Sediment ponds:  2-9, 2-11, 2-13, 2-15, 2-21, 2-23, 2-25,
     2-30, 2-31, 2-34, 2-40,  2-43,  5-19,  5-26, 5-28 through
     5-39, 5-45, 5-91, 5-92,  5-93, 5-108, 5-124, 5-134, 6-4,
     6-5, 6-15, 10-7, 10-16,  10-19, 10-28,  10-31, 10-32,
     10-33, 10-41, 10-47, 10-50, 10-51

Sedimentation:   2-31, 2-34,  3-14,  3-36,   5-21,  5-45, 5-91
     through 5-95, 5-109, 6-4, 6-5, 6-7, 10-19, 10-45

Seismology:  4-5

Set net fishery:   (see Commercial fisheries)

Sewage:  2-25, 2-30, 4-71, 4-79, 5-87, 5-94, 5-124, 5-125,
     5-130, 5-134, 6-4, 10-2, 10-15,  10-29, 10-43, 10-44,
     10-46, 10-48

Shipping:  2-23, 2-25, 2-26,  2-27, 2-44, 2-45, 3-7, 3-12,
     3-34, 4-52, 5-97, 5-98,  5-110, 5-111,  10-34

Shorebirds:  4-14,  4-16,  4-55, 4-57, 5-12, 5-81, 5-84,  5-106,
     5-111, 5-129

Short-term uses:  5-139,  5-140

Slash burning:  5-40, 10-53

Small mammals:  S-10, 5-12, 5-81 through 5-85, 5-122

Smoke:  5-53, 5-54, 10-53

Snowfall:  4-28, 4-11, 6-18,  10-23

                         13-14

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Socioeconomics:  S-10, 3-14, 3-15, 3-16, 3-23,  3-30,  3-32,
     3-33, 3-37, 3-38, 4-66 through 4-83, 5-64,  5-66  through
     5-75, 5-101,  5-102,  5-112,  5-113,  5-119,  5-120,  5-126,
     5-131, 5-135, 5-137, 5-138, 5-140, 6-24, 10-1, 10-27,
     10-54

Soils:  4-3 through  4-7, 4-9, 4-28, 5-4, 5-5,  5-8,
     5-11, 5-75, 5-78, 5-104, 5-105, 5-116, 5-121,  5-128,
     5-133, 5-140, 6-6, 10-2, 10-9, 10-22, 10-25

Soldotna:  5-67, 7-1, 10-1

Solid waste:  2-15, 2-25,  2-30,  5-40, 6-11, 6-12, 6-13,  6-15,
     10-43, 10-39

Song birds:  4-16, 5-12, 5-81, 5-83, 5-84, 5-122

Sound:  (see Noise)

Southeastern corridor:  3-3

Southeastern/North Foreland option:  3-3, 3-9,  3-10,  3-11

Southern corridor:   2-3,  2-15,  2-19,  2-21,  3-21, 4-3,  4-11,
     4-14, 4-40, 5-9, 5-78 through 5-108, 5-113,  5-116, 5-118,
     6-14, 10-8, 10-45

Southern/Granite Point option:  S-6, 2-3, 3-3,  3-11,  3-13,
     3-21, 3-25 through 3-36, 5-78 through 5-108, 10-12,
     10-39, 10-55

SPCC plan:  (see Spill Prevention,  Control and Counter-measure
     Plan)

Spill Prevention, Control and Countermeasure Plan:  2-46,
     2-47, 5-87, 5-97, 10-9, 10-42

Splitter-hopper:  2-15, 12-5

Sport fisheries:  S-4, S-10, 3-10, 4-41, 4-50,  4-91,  4-92,
     5-64, 5-74, 5-75, 5-77, 5-103, 5-114, 5-120, 5-121,
     5-126, 5-127, 5-132, 5-136

Sport hunting:  3-10, 4-14, 4-91, 4-92, 5-64, 5-74, 5-75,
     5-77, 5-103, 5-114, 5-126, 5-127,  5-132, 5-138,  10-14

Spruce beetle:  5-5, 5-53, 10-9, 10-10

State Historic Preservation Officer (SHPO):  6-24,  7-5

Stream 2002:  (see Lone Creek)
                         13-15

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Stream 2003:  2-9, 2-15, 3-24, 4-19, 4-20, 4-27, 4-29, 4-30,
     4-32, 4-41, 4-42, 4-47, 4-50, 5-11, 5-21, 5-22, 5-23,
     5-26, 5-27, 5-37,  5-41 through 5-46,  5-49, 5-50, 5-94,
     5-118, 5-137, 6-8, 6-10, 6-12, 6-14, 6-15, 6-21, 6-22

Stream 2004: 3-13, 4-19, 4-20, 4-27, 4-29, 4-30, 4-41, 4-42,
     4-43, 4-47, 4-50, 5-21, 5-22, 5-23, 5-24, 5-26, 5-27,
     5-29, 5-46, 5-137, 6-8, 6-10, 6-21, 6-22

Stripping:  2-5, 2-38

Subsistence:  S-4, S-10,  1-9,  3-10,  3-14,  3-15, 3-16, 3-18,
     3-22, 3-23, 3-30, 3-32, 3-35, 3-36, 3-37, 3-38, 4-14,
     4-41, 4-82  through 4-88, 5-75, 5-76, 5-101,  5-102, 5-113,
     5-120, 5-126, 5-127,  5-131,  5-135, 5-138,  5-140, 6-24,
     10-2, 10-18, 10-21, 10-48, 10-49

Sulfur:  4-4, 4-6, 5-52, 5-62, 5-63, 10-3

Surface  Mining  Control  and Reclamation  Act:    (see Alaska
     Surface Mining Control and Reclamation Act)

Surface water:  1-8, 2-9, 2-11, 4-13, 4-28 through 4-40,
     5-10, 5-11, 5-19 through 5-41,  5-89 through 5-94, 5-107,
     5-108, 5-124, 5-129, 5-134, 6-9, 6-10

Susitna Flats State Game Refuge:  4-14, 4-92, 5-99,  5-111

Susitna River:  4-52, 4-57, 5-75, 5-76

Suspended  solids:   S-10,  2-9, 4-38, 4-39,  4-52,  4-53,  5-32
     through 5-45, 6-4, 6-10, 10-3, 10-18, 10-20, 10-31,
     10-32, 10-33, 10-42, 10-46, 10-57

Taiwan:  1-5

Tanaina Indians:  4-1, 4-88, 4-93

Technical  feasibility:   3-14,  3-15,  3-17,  3-30, 3-34, 3-37,
     3-39, 5-78, 5-104, 5-115, 5-121, 5-128, 5-132,  5-136,
     10-34

Threemile Creek:  2-9, 3-8, 3-16, 4-28, 4-29, 4-31,  4-39,
     4-40, 4-48, 4-85, 4-91, 5-108, 5-109, 5-114, 5-118,
     5-120, 5-134, 5-136, 10-49

Threemile housing site option:  S-2, S-8, 2-3, 2-30, 3-8,
     3-11, 3-22, 3-23,  3-25,  3-26,  3-27,  3-36 through 3-39,
     5-9, 5-133 through 5-136, 10-21

Tides:  4-50, 4-51, 5-95, 5-96, 5-97, 5-111, 10-35,  10-58

Topsoil:  2-7, 2-13, 2-32,  2-33, 2-34,   5-5, 5-7, 6-6, 6-7,
     10-2, 10-52
                         13-16

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Trading Bay State Game Refuge:  S-3, 1-5, 3-8, 3-23, 4-3,
     4-11, 4-14, 4-16, 4-54, 4-55, 4-92, 5-99

Transportation corridor:   1-11,  1-12,  1-13, 2-1, 2-3, 2-34,
     3-3, 3-10, 3-11, 3-13, 3-14,  3-15,  3-25,  3-27,  5-9, 5-78
     through 5-121, 6-13,  6-14

Transportation mode (see also pneumo-train, coal-waste slurry,
     coal-carbon dioxide  slurry,  road,  railroad, conveyor):
     3-6, 3-10, 3-17 through 3-22, 10-53

Transportation system:  1-4, 1-9, 2-3, 3-11,  3-25,  3-27

Trapping:  1-9, 4-86, 4-91

Trestle:  S-2, S-5, S-6, 1-9, 2-2, 2-25, 2-26, 2-27, 2-38,
     2-42, 3-7, 3-11, 3-22, 3-25, 5-95 through 5-100, 5-102,
     5-104, 5-105, 5-110,  5-111, 5-115, 6-23, 10-43

Trumpeter swans:  S-3, 3-16, 3-38, 4-14, 4-16, 4-23, 5-12,
     5-13, 5-14, 5-15, 5-82,  5-84,  5-106, 5-107,  5-129, 5-133

Tsunami:  4-52

Tyonek Creek:  2-15,  4-4,  4-21,  4-28, 4-29,  4-39, 4-40, 4-48,
     4-85, 5-90, 5-94, 5-102, 6-14

Tyonek Native Corporation  (TNG):   S-3,  S-8, 2-3, 3-9, 3-16,
     3-34, 4-1, 4-3, 5-74, 5-101, 5-120, 7-6, 10-2,  10-34,
     10-35

Tyonek, Village of:  S-4,  S-10, 1-5, 1-9, 3-3, 3-14, 3-16,
     3-24, 3-32, 3-33, 4-1, 4-57, 4-66, 4-73 through 4-88,
     4-91, 5-2, 5-62, 5-64, 5-69 through 5-76, 5-100, 5-101,
     5-102, 5-112, 5-113,  5-120, 5-126, 5-127, 5-131, 5-135,
     5-137, 5-138, 6-24,  7-1,  7-6,  7-7, 10-1, 10-21, 10-35,
     10-56

Tukallah Lake:  3-16,  4-16,  4-17,  4-28, 4-48, 5-107, 5-110,
     5-114, 5-117, 5-118,  5-119, 5-121, 5-134

Turbidity:  S-4, S-10, 5-32, 5-44, 5-77, 5-98, 6-4,  6-10,
     10-3, 10-6, 10-7, 10-16, 10-17, 10-31, 10-42,  10-45,
     10-47

Unavoidable adverse impacts:  5-139

U.S. Bureau of Land Management  (BLM):  4-90

U.S. Department of Army Corps of Engineers  (Corps):  S-l,
     1-4, 1-5, 1-11, 1-12, 3-39, 4-5, 4-11, 6-3, 6-12, 6-15,
     7-2, 7-6, 10-1, 10-5, 10-6, 10-13, 10-28
                         13-17

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U.S. Environmental  Protection Agency (EPA):  S-l, 1-4,  1-5,
     1-12, 3-39, 4-36, 5-30,  5-31, 5-59, 6-3, 6-12,  6-15,
     6-21, 7-1, 7-2, 7-5, 8-1, 10-1, 10-6,  10-13,  10-16,
     10-17, 10-20,  10-30, 10-37, 10-39,  10-45,  10-46,  10-47,
     10-58

U.S. Fish and Wildlife Service (USFWS):  4-23,  4-50,  5-46,
     6-16, 7-2

U.S. Geological Survey (USGS):  4-38

Vegetation;  2-31,  2-33, 2-34, 2-35, 2-36,  2-40,  3-12,  3-13,
     3-14, 3-15, 3-18, 3-19,  3-21,  4-7, 4-8, 4-10,  4-17, 4-
     19, 4-20, 4-33, 4-88, 4-90, 5-4 through 5-11, 5-16,
     5-75, 5-77 through 5-81, 5-105, 5-116, 5-122, 5-128,
     5-133, 6-7, 6-17, 10-50

Viapan Lake:  3-16, 4-28, 4-80, 5-72,  5-108, 5-110,  5-114,
     5-115, 5-118,  5-119, 5-136, 10-49,  10-52

Vicky Lake:  4-28

Visual resources:   3-10, 3-18, 3-20, 3-22,  4-88,  4-90,  5-76,
     5-77, 5-103,  5-113,  5-114,  5-120, 5-127,   5-131,  5-132,
     5-135

Wastewater:

     Domestic:  2-15, 2-30, 5-30, 5-40,  5-94, 5-96,  5-124,
     5-125, 6-12, 6-13, 6-14, 10-20, 10-29, 10-44
     Washdown:  .2-46, 5-93, 10-28, 10-30, 10-41

Wastewater treatment plant:   2-15, 2-30, 10-20, 10-29,  10-31

Waterfowl:  (see also Ducks,  Geese, Trumpeter swan)  4-13,
     4-55, 4-57, 5-12,  5-81,  5-84,  5-85,  5-106,  5-111,  5-114,
     5-129

Water quality:  S-10, 2-15, 2-25, 2-30,  3-12, 3-13,  3-15,
     3-18,  3-19,  3-29,  3-34,  3-36,  3-37,  4-13,  4-14,  4-36
     through 4-40,  5-16, 5-19, 5-102,  5-109, 5-111,  5-118,
     5-124, 5-125,  5-134,  10-2,  10-15  through  10-20,  10-26
     through 10-31, 10-44 though 10-48,  10-50,  10-51,  10-57,
     10-58

     Surface water:  S-10,  1-8,  4-6,  4-36,  4-39,  4-40,  5-30
     through 5-41,  5-91 through 5-94,  5-102, 5-108,  5-109,
     5-118, 5-124,  5-125, 5-129, 5-130,  5-134,  6-19,  6-20,
     10-15, 10-42,  10-57

     Ground water:  4-36,  4-37,  5-19, 5-40,  5-85,  5-87,  5-88,
     5-118, 5-134,  6-20, 10-3, 10-19,  10-20, 10-25,  10-42,
     10-57
                         13-18

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                       Appendix A
Terrestrial  Habitat Evaluation

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     Marine water:  4-52, 4-53, 5-95, 5-96, 5-104,  10-19,
     10-39, 10-46, 10-57, 10-58

Water supply:  2-30, 3-9 through 3-12, 3-26, 3-28

Waves:  4-50, 4-51, 5-64

Wetlands:  S-3, S-8, 3-13, 3-24, 3-31, 4-10 through 4-14,
     4-28, 4-41, 5-8 through 5-11, 5-81, 5-89, 5-99,  5-105,
     5-106, 5-108, 5-111, 5-116 through 5-119, 5-122,  5-129,
     5-133, 6-7, 6-8, 6-9, 10-24, 10-45, 10-48, 10-49,  10-50

Wildlife:   (see also Bald eagle,  Beaver,  Brown bear,  Ducks,
     Geese, Marten,  Moose,  Peregrine  falcon,  Red  squirrel,
     Sandhill  crane,  Shorebirds, Small  mammals,  Songbirds,
     Trumpeter swans, Waterfowl):  S-4, S-10, 1-8,  1-9,  3-13
     through 3-16, 3-18, 3-19,  3-20,  3-29 through 3-32,  3-35,
     3-37, 3-38, 4-66,  4-81, 4-82, 5-8, 5-10 through  5-16,
     5-64, 5-73 through 5-76, 5-81 through 5-85, 5-102, 5-106,
     5-107, 5-117, 5-118, 5-122, 5-123, 5-126, 5-127,  5-129,
     5-130, 5-131, 5-133, 5-135, 5-137, 5-138, 6-8, 6-17,
     6-18, 10-8 through 10-11, 10-22, 10-23, 10-42,
     10-52, 10-56

Wind:  4-52, 4-58 through 4-65, 5-64, 10-40, 10-41

Wolverine Creek:  4-28, 4-44, 4-47

Zinc:  4-36 through 4-39,  5-34,  5-35,  5-37,  5-38, 5-45,  5-46,
     5-87, 5-88, 10-3,  10-46
                         13-19

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                        APPENDIX A
              TERRESTRIAL HABITAT EVALUATION
                     TABLE OF CONTENTS
                                                     Page

1.0  INTRODUCTION	A-l

2.0  METHODS	A-l

3.0  SPECIES ACCOUNTS  	 A-4

     3.1  LESSER SANDHILL CRANE  	 A-4

          3.1.1  Life History Information	A-4
          3.1.2  Habitat Parameters  	 A-5

     3.2  TRUMPETER SWAN	A-5

          3.2.1  Life History Information	A-5
          3.2.2  Habitat Parameters  	 A-6

     3.3  BLACK BEAR	A-7

          3.3.1  Life History Information	A-7
          3.3.2  Habitat Parameters  	 A-7

     3.4  BROWN BEAR	A-8

          3.4.1  Life History Information  ..... A-8
          3.4.2  Habitat Parameters  	 A-9

     3.5  MOOSE	A-9

          3.5.1  Life History Information  ..... A-9
          3.5.2  Habitat Parameters  	 A-10

4.0  HABITAT ANALYSIS RESULTS  	 A-10

     4.1  LESSER SANDHILL CRANE  	 A-16

          4.1.1  Port Areas	A-16
          4.1.2  Transportation Corridors  ..... A-16
          4.1.3  Mine and Mine Facilities  ..... A-16
          4.1.4  Airport and Housing Facilities  .  . A-16
          4.1.5  Material Sites  .....  	 A-19

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                        APPENDIX h
              TERRESTRIAL HABITAT EVALUATION
                     TABLE OP CONTENTS
                        (continued)
     4.2  TRUMPETER SWAN	A-19

          4.2.1  Port Sites	 A-19
          4.2.2  Transportation Corridors  	 A-19
          4.2.3  Mine and Mine Facilities	A-22
          4.2.4  Airport and Housing Facilities  .  . A-22
          4.2.5  Material Sites	A-22

     4.3  BLACK BEAR	A-22

          4.3.1  Port Areas	A-22
          4.3.2  Transportation Corridors  	 A-25
          4.3.3  Mine and Mine Facilities	A-25
          4.3.4  Airport and Housing Facilities  .  . A-25
          4.3.5  Material Sites	A-25

     4.4  BROWN BEAR	A-25

          4.4.1  Port Areas	A-25
          4.4.2  Transportation Corridors  	 A-25
          4.4.3  Mine and Mine Facilities  ..... A-26
          4.4.4  Airport and Housing Facilities  .  . A-26
          4.4.5  Material Sites	A-26

     4.5  MOOSE	A-26

          4.5.1  Port Areas	 A-31
          4.5.2  Transportation Corridors  	 A-31
          4.5.3  Mine and Mine Facilities	A-32
          4.5.4  Airport and Housing Facilities  .  . A-32
          4.5.5  Material Sites	A-32

     4.6  COMPARISON OF PRE- AND POSTMINING
            HABITAT VALUE  . .  	  ..... A-33

          4.6.1  Vegetation Types	 A-33
          4.6.2  Habitat Values	A-33
          4.6.3  Black Bear	A-33
          4.6.4  Brown Bear	A-35
          4.6.5  Moose (spring/summer/fall  range)   . A-35
          4.6.6  Overall Habitat Quality 	 A-35

5.0  DISCUSSION	A-37

6.0  REFERENCES	A-37
                             11

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                          LIST OF TABLES
Tables                                                   gage


 1   VEGETATION CLASSIFICATION SYSTEM		 A-2

 2   RESOURCE CATEGORIES AND MITIGATION PLANNING GOALS.. A-3

 3   HABITAT PARAMETERS FOR EVALUATION OF SANDHILL
       CRANE HABITAT SUITABILITY		 A-6

 4   HABITAT PARAMETERS FOR EVALUATION OF TRUMPETER
       SWAN HABITAT SUITABILITY	 A-7

 5   HABITAT PARAMETERS FOR EVALUATION OF BLACK BEAR
       HABITAT SUITABILITY	 A-8

 6   HABITAT PARAMETERS FOR EVALUATION OF BROWN BEAR
       HABITAT SUITABILITY	 A-10

 7   HABITAT PARAMETERS FOR EVALUATION OF MOOSE WINTER
       RANGE SUITABILITY	 A-ll

 8   HABITAT PARAMETERS FOR EVALUATION OF MOOSE
       SPRING/SUMMER/FALL RANGE SUITABILITY.	 A-12

 9   HABITAT SUITABILITY OF VEGETATION MAP UNITS FOR
       WILDLIFE SPECIES	 A-13

 lOa DIRECT LOSS OF WILDLIFE HABITAT AND SUITABILITY OF
       HABITATS IN HECTARES (ACRES) FROM MINE
       DEVELOPMENT BY PROJECT COMPONENT	 A-14
 10b DIRECT LOSS OF WILDLIFE HABITAT AND SUITABILITY OF
       HABITATS IN HECTARES (ACRES) FROM MINE
       DEVELOPMENT BY PROJECT COMPONENT	A-15

 11  COMPARISON OF AREAS OF HABITAT LOST TO MINING
       ACTIVITIES AND REPLACEMENT HABITAT	A-34
 12  RELATIVE HABITAT VALUE FOR REPLACEMENT HABITAT FOR
       BLACK BEAR, BROWN BEAR, AND MOOSE	 A-36
 13  COMPARISON OF PREMINING AND POSTMINING HABITAT
       VALUES FOR EVALUATION SPECIES	 A-36
                          111

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                         LIST OP FIGURES
Figure                                            '       Page


  1    SANDHILL CRANE NESTING HABITAT IN STUDY
         AREA	A-17

  2    SANDHILL CRANE NESTING HABITAT IN PROJECT
         AREA	A-18

  3    TRUMPETER SWAN POTENTIAL NESTING HABITAT
         IN STUDY AREA	A-20

  4    TRUMPETER SWAN POTENTIAL NESTING HABITAT
         IN PROJECT AREA	A-21

  5    BLACK BEAR AND BROWN BEAR HABITAT IN STUDY
         AREA	 .	A-23

  6    BLACK BEAR AND BROWN BEAR HABITAT IN PROJECT
         AREA	 A-24

  7    MOOSE SPRING/SUMMER/FALL RANGE IN STUDY
         AREA			A-27

  8    MOOSE SPRING/SUMMER/FALL RANGE IN PROJECT
         AREA	 A-28

  9    MOOSE WINTER RANGE IN STUDY AREA	 A-29

 10    MOOSE WINTER RANGE IN PROJECT AREA....	 A-30
                           IV

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                        APPENDIX A
              TERRESTRIAL HABITAT EVALUATION
 1-0  INTRODUCTION

     This  terrestrial  habitat  analysis  was  done  for  the
 Diamond  Chuitna  Coal Project EIS using  data collected from
 several  sources  including the coal project baseline studies,
 the  Susitna  River Basin  studies conducted by  the Alaska
 Department  of Fish  and  Game  (ADF&G) »  the  U.S. Fish  and
 Wildlife Service (USFWS)  and other  government agencies, and
 the  USFWS  Habitat  Evaluation Program.  The  purpose  of  the
 analysis was  to  identify the  types  and  quantities of habi-
 tats  which  would  be  affected  by   the coal  project,  to
 describe their values  to key wildlife species,  and  to pro-
 vide a quantitative  basis for comparison of habitat impacts
 among  project   alternatives  and   between   premining  and
 postreclamation  conditions.

 2.0  METHODS

     Evaluation  species were selected on the basis of their
 high public interest and/or  because  they serve as indicator
 species  for habitats that have significant ecological value.
 Using  these  criteria,  the  following  species were  chosen:
 moose  (Alces  alces),  brown bear  (Ursus  arctos),  black bear
 (U.  americanus),  trumpeter  swan  (Cygnus  buccinator),  and
 lesser  sandhill  crane    (Grus  canadensis).   Moose,  brown
 bear, and  black  bear are  upland species whereas  swans  and
 sandhill cranes  inhabit wetland and aquatic habitats.

     The basis  for  the  terrestrial  habitat  evaluation  was
 the  composite   vegetation  maps  developed  by   the  Soil
 Conservation Services (SCS)  and  USFWS for  the Beluga region
 and the  vegetation maps developed during the  project base-
 line  study program  (ERT  1984b).    The  ERT maps are at  a
 larger scale than  those  produced by  SCS/USFWS and were used
 for  habitat  delineation  within the mine  area,  southern
 transportation   corridor,  and   Granite   Point   port  area.
 Direct comparisons between the two mapping efforts were dif-
 ficult  due to   the  significant  differences in  vegetation
 interpretation.  The differences are outlined in Table 1.

     The habitat units used in the analyses for each  species
 roughly correspond to the vegetation units delineated on the
 base maps.   The units were then grouped into four categories
which correspond with the  habitat   value  ratings from  the
 USFWS mitigation policy  (Table 2).  The ratings indicate the
 extent  to  which a  particular  habitat  provides  the  life
 requirements for the  species under  consideration.   It is  a
 rating of a habitat's overall  suitability.   A  habitat for  a
 particular species  is considered only as  valuable   as  the
 life factor which is the most limited.
                            A-l

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                                                                      Table 1
                                                     VEGETATION CLASSIFICATION SYSTEM CORRELATION
   Hap
   Unit f
Vierreck et al. (1982)
 Hap
Unit t
U.S. Forest Service (1979)
U.S. Fish and Wildlife Service (1979)
to
     1     Closed Broad leaf Forest/Paper Birch

     2     Open Broadleaf Forest/Balaam Poplar

           Closed Needleleaf Forest/White Spruce2


     3     Open Mixed Forest/Spruce-Birch


     4     Needleleaf Wood land/Black Spruce


     5     Mixed Hbodland/Spruce-Birch


     5     Mixed Noodland/Spruce-Birch
                                   24   Closed broadleaf forest/paper birch

                                   28   Cottonvood, medium aged stands!

                                   25   Coniferous, Mhite spruce, tall stands,
                                         closed forest!
                                   26


                                   41
       Deciduous, mixed, old stands, closed
        forest
                                                   Palustrine -  forested  need lei caved evergreen
                                       Paluatrine -  forested nixed needleleaved
                                        evergreen, broad leaved deciduous'
       Black spruce, short stands, closed foreat    Palustrine -  forested  needleleaved evergreen'*
                                   32   Dec id in us, nixed, median aged, woodland
                                   34   Deciduous, nixed, old stands, woodland
     6     Open Tall  Shrub  Scrub/Millow               61    Alder-willow

     7     Closed Tall  Shrub  Scrub/Alder               60    Alder

     8     Open Low Shrub  ScruVSweetgale-Graas Fen    £8    Sphagnum bog

     8     Open Low Shrub  Scrub/Sweetgale-Graas Fen    69    Sphagnun shrub  bog

           Open Low Scrub/Willow-Grass Tundra2        64    Sedge-grass

           Dry Gaminoid Herbaceous/Midgrass-Shrub2     65    Herbaceous

     9     Mesic Gaminoid  Herbaceous/Bluejoint-Herb    63    Upland grass
                                                   Palustrine -  forested nixed needleleaved
                                                    evergreen broad leaved  decidous'

                                                   Palustrine -  forested needleleaved evergreen
                                                    broadleaved  deciduous'

                                                   Palustrine -  scrub/shrub  broadleaved deciduous4

                                                   Palustrine -  scrub/shrub  broadleaved deciduous-*

                                                   Palustrine -  emergent narroMleaved persistent^*

                                                   Pal ua trine -  scrub/shrub  broadleaved deciduous*1

                                                   Palustrine -  emergent persistent'

                                                   Palustrine -  emergent persistent*

                                                   Palustrine -  emergent persistent^
   1 Not mapped within Diamond-Chuitna study area.
   2 Not identified within lease area or transportation corridor.
   •* Classified aa wetland when located on floodplains.
   4 Classified aa wetland then located on very poorly and  poorly drained  soils or on floodplains.

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                                    Table 2

                  RESOURCE CATEGORIES AND MITIGATION PLANNING GOALS*
Resource
Category
Habitat
 Value
Designation
  Criteria
Mitigation Planning
       Goal
            very high
              high
             medium
              low
              Habitat to be impacted is of
              high value for evaluation
              species and is unique and
              irreplaceable on a national
              basis or in the ecoregion
              section.

              Habitat to be impacted is of
              high value for evaluation
              species and is relatively
              scarce or becoming scarce on
              a national basis or in the
              ecoregion section.

              febitat to be impacted is of
              high to medium value for
              evaluation species and is
              relatively abundant on a
              national basis.

              Habitat to be impacted is of
              medium to low value for
              evaluation species.
                         No loss of existing
                         habitat value.
                         No net loss of
                         in-kind habitat
                         value.
                         No net loss of
                         habitat value while
                         minimizing loss of
                         in-kind habitat
                         value.

                         Minimize loss of
                         habitat value.
•4aken from BWS Mitigation Policy (FR Vol.  46,  No.  15,  23 January 1981).
                                     A-3

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     Models  of species-specific  habitat requirements  have
been constructed by  USFWS  for many Alaskan  wildlife species
using  all pertinent data  available (USFWS  1980).   These
models and the model of moose habitat developed by ADF&G for
the Susitna River Basin were used in this study.

     The habitat parameters used in the models are discussed
below in  the  species accounts.   In addition,  snow accumula-
tion was included as a parameter for this analysis as it was
considered a  habitat factor  of  major importance for several
of the species  under consideration.   From snow accumulation
contours  developed  for  the  Susitna  River  Basin study,  an
estimate of 152 m (500 ft)  was chosen as the elevation above
which moose would encounter  mobility problems in the winter
due to snow depth (ADF&G 1984).   It  also was  considered the
level above which the ice-free season was too short to allow
trumpeter swan nesting (King 1968? Hansen et al. 1971).

     To  provide additional  perspective  to  the  question  of
moose winter  habitat value,  the distribution  of moose based
on actual field observations (Faro 1985a) was delineated on
the winter  range  maps.  A fall rutting  concentration,  not
directly  related  to  vegetation type,  was  also  delineated
based on field observations  (Faro 1985a).

     Location  maps  of  proposed  project  components  were
overlain on the vegetation maps  and  the surface area of the
habitat types within their  boundaries was estimated using a
compensating  polar  planimeter.    Areas  were  rounded  to  the
nearest acre  and  then converted  to  hectares.  The  area  of
affected habitat along the  southern  transportation corridor
was con-sidered to   be the area from the west side  of  the
haul road  to the east side  of  the conveyor  system except
where the  road separates from  the conveyor  at  the Chuitna
River crossing.   The 61  m (200  ft)  undisturbed buffer zone
between the  haul  road and  conveyor  was considered  part  of
the direct habitat loss for this analysis.
3.0  SPECIES ACCOUNTS

3.1  LESSER SANDHILL CRANE

3.1.1  Life History Information

     Sandhill  cranes   are   common  summer   residents   and
breeders in  the  Cook Inlet  Region.  They are most  abundant
during  spring  and  fall  migration and  use  tidal flats  and
muskegs of the area  for  staging and  feeding.  They  are  com-
mon  nesters  in  the  refuges of  upper   Cook  Inlet but  were
found  to  be  uncommon  nesters in  the Beluga  region  (ERT
1984a).

     Sandhill  cranes are  birds  of open  country.   Their
summer  habitat consists  of  tundra areas with short  vegeta-
                            A-4

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tion  such  as mosses, labrador tea  (Ledurn spp.)  dwarf birch
(Betula  spp.)  crowberry  (Empetrum  ni.grurn),  and cloudberry
(Rubus  chanaemorus)   (Walkinshaw 1949).    Cranes roost  at
night  and  during  the  day  between  periods  of   feeding  in
wetlands  and aquatic areas.   They are  opportunistic omni-
vores  and are  able  to  subsist  on a  wide variety  of  food
items  such  as  crowberry,  cloudberry,   mice,   small  fish,
snails,  and flying  insects  (Boise  1977).   Breeding cranes
usually  feed within  close proximity of the nest  (Walkinshaw
1949) .

3.1.2  Habitat Parameters

     Most  habitat  work  related to sandhill cranes in Alaska
has been  done  in the tundra habitats of  the Yukon-Kuskokwim
Delta.  These studies, which primarily addressed suitability
of habitats  for feeding and nesting, indicate that dry sites
near water bodies  appear to be  very  important  for nesting.
Cranes also  prefer sites which  offer  unobstructed  views  of
the  surrounding  terrain.    Habitat  parameters   for  lesser
sandhill cranes are outlined on Table 3.

     Because  data  from  other  geographic  regions  were
lacking,   no attempt   was  made  to  rate  habitat  values
according  to the Table  2  criteria?  rather,  a simple model
was   developed   to   differentiate   between  suitable   and
unsuitable  crane habitat  for  the Diamond Chuitna  project.
Cover  and  suitability   for   reproduction  were  the  life
requirements used  to  delineate overall habitat  suitability.
Habitat above 152  m  (500 ft),  which  might otherwise be con-
sidered suitable,  was  determined to be  limiting for repro-
duction due to late snow melt off.

3.2  TRUMPETER SWAN

3.2.1  Life History Information

     Trumpeter swans are common migrants  and breeders on the
Kenai  Peninsula and  along  the west  coast  of   Cook  Inlet
(USFWS 1980).  Once thought to be endangered, recent surveys
of  trumpeters   on  their  breeding   grounds  indicate  an
expanding  population with a 94 percent increase  between 1975
and 1980.  A high ratio of non-breeding to breeding swans  in
Alaska appears  indicative  of  the fact  that the  swans  are
near the northern limit of their range.

     Breeding trumpeters  require relatively  shallow static
ponds or lakes which  range in size from  2.4  to  14 ha (6  to
35 ac) with  significant  amounts  of  emergent  vegetation  such
as Equisetum fluviatile,  Carex  sp. and  Menyanthes  trifolia
(Hansen  et  al"l1971).   ~A 145-  to  156-day span  between
breakup and  freezeup  is  needed to successfully  complete the
reproductive  cycle  (Hansen  et  al.  1971).   This  suggests
that,  in the project area, most  breeding takes  place below
500 feet elevation (King 1968; Hansen et  al.  1971).
                            A-5

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                           Table 3

        HABITAT PARAMETERS FOR EVALUATION OP SANDHILL
                  CRANE HABITAT SUITABILITY
    Life
  Requisite

    Cover
  Reproduction
           Habitat Suitability
  Suitable

open habitat
low vegetation
good visibility of
  surrounding area

wet with occasional
  raised areas
73 m (80 yd) or less
  to freshwater body
below 152 m (500 ft)
  elevation
     Unsuitable
closed to open forest
tall shrub
poor visibility of
 surrounding area

uniformly wet with no
 raised areas
uniformly dry
greater than 73 m
 (80 yd) to freshwater
 body
greater than 152 m
 (500 ft) elevation
Source:  USFWS 1980
     The range of non-breeding swans is closely tied to that
of the  breeding population.   Ponds and lakes used  by non-
breeders  should provide  adequate  open  water and  emergent
vegetation  should  not  be  used by  breeding pairs  because
territorial  conflicts  may  arise  (USFWS 1980).   Since  the
present  population  is  expanding,   lakes  and  ponds  which
appear  suitable  for  breeding but are not used at  this time
must be considered potential breeding habitat.

3.2.2  Hab i tat Parameters

     The available  baseline data on potential habitats  for
swans in the study area are somewhat limited since the vege-
tation map units are quite  broad  and do not address aquatic
vegetation  or  water depth  along  the   shores  of lakes  and
ponds.   Adult  and  juvenile  swans  feed on  land only to  a
limited  extent?  cygnets feed exclusively  in  the  water.
Therefore,  upland  terrestrial  vegetation   along the  peri-
meters of water bodies was  not considered  in  the  analysis.
Habitat  parameters  for  trumpeter  swans are  presented  in
Table 4.  The 152 m (500 ft) contour was used as  an approxi-
mate  upper  limit   for  breeding  habitat.    The extent  of
aquatic and  emergent vegetation was determined from wetland
maps developed by the USFWS  wetlands inventory.
                            A-6

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                           Table 4

            HABITAT PARAMETERS FOR EVALUATION OF
             TRUMPETER SWAN HABITAT SUITABILITY
 Life Requisite

Size of pond or
  lake

Reproduction
 Elevation above
 sea level

Food and cover
 Aquatic and
 emergent
 vegetation
                              Habitat Suitability
High
2.4 - 14 ha
(6 - 35 ac)
<152 m
(500 ft)
Medium
14.4 - 51.2
(36 - 128 ac)
<152 m
(500 ft)
Low
>51.2 ha
(128 ac)
>152 m
(500 ft)
Abundant
Common
Uncommon to
   none
Source:  USFWS 1980
3.3  BLACK BEAR

3.3.1  LifeHistory Information

     Black  bears  are  common  residents  of  the Cook  Inlet
region and are found in many  different habitat  types.   They
feed  primarily  on  grasses,   sedges  (Carex  sp.),  horsetail
(Equisetum sp.),  and  when available, carrion  (ADF&G 1976).
Late summer and fall food  items  consist  primarily  of salmon
and   berry-producing   plant   species   such  as   blueberry
(Vaccinium sp.),  elderberry  (Sambucus rasemosa),  bearberry
(ArctostaPholos sp.),  crowberry (Empetrum nigrum),  and high-
bush  cranberry  (Viburnum  edule) .   Bears of all ages  avoid
extensive open areas such as grasslands,  low shrublands, and
tundra except when  they are  feeding on alpine  berry patches
or  in tideflats  (Schwartz  and  Franzman  1980; Fame  1974?
Mcllroy  1970).    Black  bears  usually do not range  further
than  315 m  (350  yd)  from cover  to feed  (Pacific  Working
Group  1977).    Females with   cubs  will   often  remain  near
mature trees  so  that  escape  cover  is readily  available for
the cub.

3.3.2  Habitat Parameters

     The  primary  habitat  characteristics  used  to  evaluate
black bear habitat in  the project area were the availability
and diversity  of  preferred herbaceous food  species, avail-
ability of salmon, and the proximity to  mature  trees.  These
parameters are shown on Table 5.
                            A-7

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                          Table 5

            HABITAT PARAMETERS FOR EVALUATION OF
               BLACK BEAR HABITAT SUITABILITY
 Life Requisite

Food

  Diversity of food
    species

  % cover herbaceous
    food species
    spring/early
    summer

  Availability of
    salmon

Cover

  Proximity to
   mature trees
  (Escape cover)
                                  Habitat Suitability
   High
 Medium
     Low
2-4 species
16 - 100%
common to
 abundant
<400 m
(440 yd) to
mature trees
or tall shrub
with >25%
canopy cover
1 species
5 - 15%
uncommon
400 m
(440 yd)
to 8 km
(5 mi)
   < 5%
  rare to
  none
  >5 mile
to mature
trees
Source:  USFWS  unpublished model
3.4  BROWN BEAR

3.4.1  Life History Information

     Brown  bears  are  distributed  throughout  much  of  the
coastal  area  of  Cook  Inlet  including  the Beluga  region.
They are generally  solitary  animals. Brown  bears feed  on
sedges,  grasses  (Calamagrostis sp.  and Arctogrostis  sp.),
and horsetails during  the spring and early summer but will
use  a  wide  variety  of  foods  when available  (Sommerville
1965).    During the  summer and fall, bears feed  on  salmon.
From mid-summer  through  fall,  bears also  rely heavily  on
several types of berries  including  blueberries, soapberries
(Shiphardia   canadensis),   crowberries,  bearberries,   and
lowbush cranberries (Vaccinium vitisideae)  (USFWS 1980).

     Brown bears  are found in a variety of habitat types but
generally  prefer  relatively  open  higher  areas  (Erickson
1965j Sommerville 1965).  They also extensively utilize low-
lying areas free of snow in the  spring  after  emerging from
                            A-8

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their  dens.    Bears  on  Kodiak Island  spent  50 percent  of
their  time in  low-lying  areas, 35 percent in foothills, and
15 percent in uplands (Berns and Hensel 1972).

     Elevation of denning habitats varies in Alaska.  In the
upper   Susitna   Valley,   dens  were   found   at  elevations
averaging 1,468  m (4,818 ft)  (Miller  and McAllister 1982).
On Kodiak Island and the Alaska Peninsula, dens averaged 549
ra  (1,800  ft)  and 396 m (1,300  ft)  in  elevation,  respec-
tively.   Bears  within  the  study area  very  likely den  at
lower  elevations (ERT 1984a).   DOWL  (1981)  suggests  that
much of the Beluga area is unusable or marginal bear denning
habitat  because  it  is  an  elevated  plateau  and  has  con-
siderable lowland tree cover.

3.4.2  Habitat Parameters

     The parameters used  to  evaluate  brown bear habitats  in
the  project  area were  food  value  (by  season)  and  cover
(Table 6).  Reproduction was not used as an evaluation para-
meter.  Brown  bears  have relatively large home ranges.  It
is quite  possible that if vegetation  types  within  the pro-
ject area  were  not  optimum  for  food,  bears would  feed  in
adjacent more suitable areas.

3.5  MOOSE

3.5.1  Life History Information

     Moose are  common  inhabitants of the Beluga region and
constitute an important  economic  resource for residents and
non-residents alike.   Moose  are  primarily  associated  with
habitat types  that  include lowland bog  communities, upland
shrub  areas, and early successional communities  influenced
by fire or flooding (LeResche et al.  1974).

     Calving  occurs  from  late May through  June and  takes
place  primarily  in  lowland  bog  areas.   Cows with calves
often  remain in these areas  throughout the summer  so  that
they can  feed  on the  abundant herbaceous vegetation  found
there.   Moose  move  from their  lowland  wintering areas  into
upland shrub areas throughout  the  summer  and  fall.   In late
fall and  early  winter,   they  move  down  into  willow  com-
munities along  rivers and streams  (LeResche et al.  1974).

     Moose feed mostly on browse-type vegetation.  Of these,
willows (Salix sp.) are  the  most  important species  followed
by birch (Betula  sp.).   Other species consumed are cotton-
wood (Populus  sp.),  aspen (Populus tremuloides)f and  alder
(Alnus sp.).  During  the winter, 80 percent of the  diet con-
sistsof browse  species,  whereas  during the  summer,  grasses
and  forbs  constitute  a  significant  portion  of the  diet.
Important  species  include   sedges,   horsetail,   bluejoint
grass  (Calamagrostis  canadensis),  and  fireweed  (Epilobium
angustifolium)  (USFWS 1980).
                            A-9

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                          Table 6

             HABITAT PARAMETERS FOR EVALUATION
             OP BROWN BEAR HABITAT SUITABILITY
     Life Requisite
Food

  % grasses and horsetail
   (spring/early summer)

  % berry-producing species
   (late summer/early fall)

  Distance to salmon stream
   (late summer/early fall)

Cover

  % tree canopy cover
                                    Habitat Suitability
High
Medium
Low
>20%
>20%
10-20%
 1-19%
<30 mi    30-50 mi   >50 mi
0-60%
60-100%
Source:  USFWS  1980
3.5.2  Habitat Parameters

     Because  habitat  requirements  for  moose  differ  sea-
sonally,  the  criteria  used  for  the analysis were  divided
into  two categories:   winter range  and  spring/summer/fall
range.   Parameters  used were  food  value  and  cover.   Key
variables for both  seasons were browse quality  (i.e., vege-
tation species and percent of total available browse), quan-
tity   (total  available   willow,   birch,   and  alder),  and
presence of lowbush cranberry (Tables 7 and 8).

4.0  HABITAT ANALYSIS RESULTS

     Up to 2,500 ha  (6,175 ac) would be lost as  a result of
the development  of  the mine and  mine facilities, transpor-
tation corridor, airport, housing facilities, and port site.
The area includes seven of the nine vegetation types  located
within the project  area and approximately  40 ha  (99 ac)  of
aquatic habitat  in the  form  of  small ponds.  The vegetation
type sustaining  the  greatest loss would be mixed woodland/
spruce-birch followed  by closed  tall  shrub scrub/alder  and
low shrub/sweetgale-grass fen, respectively.  The latter is
a wetland vegetation type.

     The  habitat  suitabilities  of  the   vegetation  types
according to  the parameters  examined for  the key wildlife
species  are  summarized  in  Table  9.   Table  10   provides  a
                            A-10

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                               Table 7

                HABITAT PARAMETERS FOR EVMiUATION OF
                   MDOSE WINTER RANGE SUITABILITY
   Life Requisite

Food

  Browse quality
   species and % total
   available
  Brcwse quantity
   total available
   Salix sp., Betula sp.r
   Alnus sp.

  % cover of Vaccinium
   yitis-idaea

Coverl

  Availability of
  cover as indicated
  by canopy2 closure
                                      Habitat Suitability
   High
Medium
   Low
Salix sp,
Betula
Salix sp.
Betula
Alnus sp.
  paperifera    glandula
Populus sp.   Betula nana
>300 Ib/ac    100-200 Ib/ac 1-99 Ib/ac
                 1-5%
CL-CF
CL-DF
CL-MF
   QP-CF
   OP-DF
   QP-MF
  T/S
  Cover types - CF - Coniferous forest
                DF - Deciduous forest
                MF - Mixed forest
2 Canopy type - CL - Closed
                OP - Open

Source:  ADF&G 1984
               LS - Low shrub
               TS - Tall shrub
              HSG - Herbaceous
                    sedge/grass
                                A-ll

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                                    Table 8

                  HABITAT PARAMETERS FOR EVAHJATION OF MOOSE
                     SPfOJXS/SlMER/FALL RANGE SUITABILITY
                                         Habitat Suitability
   Life Requisite                High _ Medium _ Low _
Food

  Browse quality                 Salix sp.    Salix sp.     Alnus sp.
   species and % total           Betula       Betula
   available                      paper if era   glandulosa
                                 Populus sp.  Betula nana

  Browse quantity                >300 Ibs/ac  100-299 Ibs/ac 1-99 Ibs/ac
   total available
   Salix sp., Betula sp.,
   Alnus sp.

  Total annual forb              >120 Ibs/ac  300-120 Ibs/ac 0-30 Ibs/ac
    production

Cover

  Availability of cover          CL-CF           -              TG
  as indicated by canopy 2        CL-DF                          LS
  closure                 *       CL-MF                          HSG
                                 OP-CF
                                 OP-DF
                                 OP-MF
•  Cover types -  CF - Coniferous forest     LS - Low shrub
                 DF - Deciduous forest      TS - Tall shrub
                 MF - Mixed forest         BSG - Herbaceous
                                                 sedge/grass

2 Canopy type -  CL - Closed
                 OP - Open

Source:  ADF1G 1984
                                    A-12

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                                  Table 9

       HABITAT SUITABILITY OF VEGETATION MAP  UNITS FOR WILDLIFE  SPECIES
                        High
Med iurn
Low
Species/
Mapping System SCS^-
Sandhill crane
Trumpeter swan
Black bear
Brown bear
Moose
(spring/
summer/
fall)
Moose
(winter)
68,69
68,69
92
24,26,28
41,32,34
60,61,63
68,69
25,26,28
32,34,41
60,61,63
64,65,68
69
24,32,61
24,25,27
31,32,61
Viereck2 Viereck Viereck
et al. 1982 et al . 1982 SCS et al. 1982
8 - ...
8 91 -
1,2,3,4
5,7,8,9
2,3,4 22,24 1
5,6,7
8,9
1,5,6 21,22,25 2,3,7 41,42,43 4
26,27,28 8,9 46
29,31,33
34,35,36
60,62,63
68,69
1,5,6 21,22,26 2,3,4 35,43,46 8,9
28,29,33 7 51,63,68
34,36,41 69
42,60,62
•^•Vegetation classification scheme used in mapping areas outside the project
 area developed by the USDA, Soil Conservation Service (SCS).
P
^Vegetation classification scheme used within the project area developed by
 Viereck et al. (1982).
                                     A-13

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                                                                Table 10a
                                DIRECT LOSS IF  WILDLIFE  HABITAT AW> SUITABILITY OF HABITATS IN HECTARES (ACRES)

                                              FROM MINE  DEVELOPMENT BY PROJECT COMPOtCNT
 I
l->
**
10 Year
Mine Limit

Species

Sandhill
Crane


Trun peter
Swan


Black Bear



Brawn Bear



Moose
Spr ing/ Sinner/
Fall

Moose
Winter



Suitable
X
X
Unsuitable
High
Med
Low
NU2
High
Hsd
Low
NU
High
Had
Low
NU
High
Had
Low
NU
High
fed
Low
NU
Mine Service
Area
0
	
___
22(55)
0
0
0
22(55)
22(55)
0
0
0
22(55)
0
0
0
14(35)
8(20)
0
0
0
0
0
22(55)
Pit
Area
0
0
0
564(1411)
0
0
0
575(1438)
564(1411)
0
0
11(27)
564(1411)
0
0
11(27)
360(950)
85(212)
180(449)
0
0
0
0
575(1438)
Stockpile
Roads and
Areas Settling Ponds
0
0
0
80(200)
t~*m*m
.—
— -™
80(200)
80(200)
0
0
0
. 79(198)
0
0
1(2ac)
47(117)
33(83)
0
0
0
0
0
80(200)
0
—
~_
68(169)
__
_,,
— **
68(169)
64(158)
0
0
4(10)
64(158)
—
__-
4(10)
47(117)
21(52)
0
0
0
0
0
68(169)
30 Year
Mine Limit
Pit
Area
0
0
0
2029(5012)
0
0
0
2029(5012)
1982(4955) '
0
0
23(57)
1982(4955)
0
0
23(57)
1356(3349)
653(1612)
20(49)
0
0
a
0
2029(5012)
                  Total
22(55)
575(1438)
80(200)
68(169)
2029(5012)
                  1   Exact sighting  not finalized.


                  2  Not utilized.

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                                                                                Table IQb





                       DIRECT LOSS OF WILDLIFE HABIIAI AND SUITABILITY Of HABITATS IN HECTARES (ACRES) FROM NINE DEVELOPMENT  BY  PROJECT COMPONENT
01
Port Sites

Speciea
Sandhill
Crane



Trumpeter
Sxan


Black Bear



Bratm Bear



Moose
Spring/SlMDor/
Fall

Moose
Winter



Suitable
X
X
Unsuitable
High
Medium
Low
NU2
High
Medium
Lo«
NU
High
Medium
LOM
NU
High
Madium
LOM
NU
High
Medium
Low
NU
Granite
Point
64(158)
0
0
16 (4i)
0
0
0
80(190)
80(198)
0
0
0
80(198)
0
0
0
0
74(183)
6(15)
0
0
16(41)
64(157)
0
Transportation Corridors
Ladd
6(16)
0
0
111(277)
9(23)
0
0
110(271)
116(287)
0
0
3(7)
116(287)
0
0
3(7)
0
116(287)
0
3(7)
0
110(271)
£(16)
3(7)
Southern
16(00)
0
0
53(131)
0
0
0
69(171)
69(171)
0
0
0
67(166)
2(5)
a
a
22(54)
46(114)
1(3)
0
1(2)
3(8)
38(93)
28(68)
Eastern
14(35)
0
0
40(9?)
2(6)
0
0
52(128)
54(134)
0
0
0
54(134)
0
0
0
4(10)
50(124)
0
0
0.5(2)
29(73)
14(34)
19(47)
Northern
23(56)
0
0
SOU24)
1(3)
0
0
72(177)
73(180)
0
0
0
73(180)
0
0
0
5(12)
68(168)
0
0
2(4)
32(79)
22(53)
18(45)
Housing
Lone
Creek
0
0
0
29(72)
0
0
0
29(72)
29(72)
0
0
D
29(72)
0
0
0
25(62)
4(10)
0
0
0
0
0
29(72)
Facilities
Three-
Mile
0
0
D
29(72)
0
0
0
29(72)
29(72)
0
0
0
29(72)
0
0
0
0
29(72)
0
0
0
29(72)
0
0
and Airport
Congahbuna Material Sites1
Lake1
6(15)
0
0
23(57)
2(5)
0
0
27(67)
29(72)
0
0
0
29(72)
0
0
0
10(25)
19(47)
0
0
10(25)
2(5)
3(6)
14(36)
»5
0
0
0
106(262)
0
0
0
106(262)
106(262)
0
0
0
106(262)
0
0
0
85(210)
21(52)
0
0
0
0
0
106(262)
n
0
0
0
119(294)
0
0
0
119(294)
119(294)
0
0
0
119(294)
0
0
0
119(294)
0
0
0
119(294)
0
0
0
to
15(37)
0
0
119(294)
0
0
0
134(331)
134(331)
0
0
0
134(331)
0
0
0
91(224)
45(111)
0
0
0
0
0
134(331)
Total







'Exact sighting not  finalized.




^ot utilized.
                                      80(198)   119(293)    69(171)    54(134)    73(180)    29(72)    29(72)    29(72)
                                                                                                                      106(262)   119(294)   134(331)

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breakdown by  project component of  the  surface area  of  the
various habitat types according to the value to the key spe-
cies .

4.1  LESSER SANDHILL CRANE

     Distribution  of sandhill crane  habitat for  the study
area is given on Figure 1 and within Diamond  Alaska's pro-
posed project area on Figure 2.

     The  only  vegetation  type  found  to  be  suitable  for
sandhill  cranes  was  open  low  shrub/sweetgale-grass  fen.
These wetland  areas  provide adequate open  space,  food spe-
cies,  and patterned  ground  necessary  for  nesting.   Areas
below the 152 m (500 ft) contour were  classified  as  having
an  overall  habitat   quality  suitable  for   nesting  cranes.
Significantly  better crane  habitat is  found just  southwest
of the study area in the lowlands of Trading Bay Refuge.

4.1.1  Port Areas

     A significant portion  (80 percent)  of  the area of pro-
posed development at the Granite  Point  Port site is classi-
fied  as  having  some  suitability  for  cranes.    Only  a
relatively small portion  (2 percent)  of the proposed  devel-
opment at the Ladd  port  site is classified as  having some
suitability for cranes.

4.1.2  Transportation Corridors

     A total  of  16  ha  (40  ac)  of  suitable  crane  habitat
makes up only  23 percent which will be  lost to the develop-
ment of the  haul road  and  conveyor system  in  the southern
corridor.   Approximately the  same  amount (27 percent-total)
of crane habitat would  be affected  by the eastern  corridor.
The largest amount of crane habitat 23  ha (56ac) or 32 per-
cent, would be lost within the northern  corridor.

4.1.3  Mineand Mine Facilities

     The low  shrub communities in  the  mine area  were con-
sidered of limited  value  for  reproduction  due  to  shortness
of the ice-free  season.  These areas  could  possibly provide
some feeding or roosting habitat  for sandhill cranes.

4.1.4  Airport and Housing Facilities

     Only small  areas  of  suitable open  low  shrub  habitat
would be lost to development at the Lone Creek site.  Use by
nesting cranes would be limited by elevation.

     The  Threemile   housing facility  site  has no  suitable
crane habitat within the area  to  be cleared.

     The Congahbuna  Lake  site is  near  the  152 m  (500  ft)
contour, but would likely receive  some  crane use.   Approxi-
                            A-16

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                                    1   61   2   3  4
                                        BS=Ei^Z
                                        SCALE IN MILES
    SANDHILL CRANE NESTING HABITAT IN STUDY AREA
Diamond Chuitna Environmental Impact Statement
                          A-17
FIGURE 1

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Diamond Chuitna Environmental
     Impact Statement
                500 FT. CONTOUR
             LEGEND
           HABITAT VALUE
            H
SUITABLE

UNSUITABLE
            SCALE IN FEET
          2000 4000
        8000
      SANDHILL CRANE NESTING

      HABITAT IN PROJECT AREA
       FIGURE 2

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mately  20 percent would  be suitable crane habitat.   Since
the  exact  site  has  not  been  delineated,  this  amount  may
vary.

4.1.5  Material Sites

     The  only  material site with  any  significant amount of
potential  crane  habitat is Site  $8  which has approximately
15 ha  (37 ac)  of  low shrub habitat.   This area is proximate
to  the  152 m (500  ft)   elevation  which  suggests  it  has
limited value  for crane reproduction.

4.2  TRUMPETER SWAN

     Within  the  study area, a  total of  14  suitable aquatic
habitats were  identified as having potentially high value as
swan nesting habitat.   Only areas of potentially high value
were  delineated  outside   the  Diamond  Alaska project  area
(Figure 3).  Habitat possibly  suitable for  swans within the
project area is presented in Figure 4.

4.2.1  Port Sites

     No swan nesting habitat was  identified  in  the area of
the Granite  Point port site.   Some wetland  types could con-
ceivably be used by non-breeders but this would be only to a
very small  degree because  of the lack  of open water bodies.
These wetland  types were classified as  "not  utilized".

     At the Ladd port site, two small ponds  will be directly
affected by the proposed development.  The smallest is below
the minimum size  for  swan  nesting habitat,  but  the larger
one would be classified as high quality.  Another small lake
just  north  of  the  port,  also  high  quality,  would  be
indirectly affected by the development  of this site.

4.2.2  Transportation Corridors

     Only  two  lakes  within  the  southern  transportation
corridor  were  classified  as having  a  high suitability  for
trumpeter  swans  (Figure 4).   However,  both  lakes  are  near
the 152 m (500 ft)  elevation which may  limit their use  for
swan breeding  in years with  late  springs.   A  total of three
lakes within the corridor  were classified as  moderate value
based primarily on their size.   The largest  lake, Congahbuna
Lake, ranked  low  because  it  is  larger  than  the  size  pre-
ferred by swans.  It may be used for feeding by non-breeders
since aquatic  and emergent  vegetation  is plentiful  at  the
south end of the lake.

     Two  small lakes  and  one   large  lake,  Chuitbuna  Lake,
within or  adjacent  to the eastern corridor were considered
potential  swan nesting  habitat.   Although  a  final  route
selection  would  likely  go around  these  lakes,  indirect
impact from disturbance would  likely make it  unsuitable  for
nesting.
                            A-19

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                                    .. 'i UEGEJ^D
                          *9^ '!>' ^j/'H^jT^T VALUE

                                      1   0    1   234
                                          ES^S^^a^!^
                                          SCALE IN MILES
TRUMPETER SWAN POTENTIAL NESTING HABITAT IN STUDY AREA
   Diamond Chuitna Environmental Impact Statement
                            A-20
FIGURE 3

-------

-------
Diamond Chuitna Environmental
     Impact Statement
             LEGEND
           HABITAT VALUE
            	- HIGH
            	MEDIUM
            	LOW
           SCALE IN FEET
      0   2000 4000
 8000
        TRUMPETER SWAN
        POTENTIAL NESTING
    HABITAT IN PROJECT AREA
FIGURE 4

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     Three  large lakes  and 4  small  lakes adjacent  to the
northern  transportation  corridor  appear  to  provide  some
degree  of  nesting habitat  for  swans.   The  largest,  Viapan
Lake, would  be classified  as  low quality due to  its large
size, 100  ha (250 ac) .   Tukallah Lake,  on Threemile Creek,
would be ranked  medium  primarily  due  to its  size (39 ha [96
ac]) but it could be used by non-breeding swans for feeding.
Four  small unnamed  lakes adjacent to  this  route  would  be
classified as high quality for nesting swans.

     None  of  these  habitats  would be directly  affected  by
the road or conveyor system.

4.2.3  Mine and MineFacilities

     No suitable  habitat  for breeding swans was located  in
the  mine   area.   The  primary  limiting  factor  is the  low
number  of  ice-free  day due  to the elevation  of   the  mine
area.   Non-breeding swans  may  be  seen  in some open water
areas of the  mine site during the summer  but  use  is  likely
to be insignificant.

4.2.4  Airport and Housing Facilities

     No suitable  swan  habitat occurs within the Lone Creek
site or the Threemile site.

     The Congahbana  Lake  site is adjacent to  high, medium,
and low quality swan nesting habitat but direct habitat loss
would be minor (about  2  ha [5  acj) depending on  the exact
site.   Indirect  impacts from disturbance  would  be signifi-
cantly greater than actual habitat loss.

4.2.5  Material Sites

     No suitable swan habitat occurs within Sites 5 and 7.

     Site  8  is  adjacent to medium quality swan  habitat but
no direct loss of habitat is expected from its  development.

4.3  BLACK  BEAR

     None  of  the habitat  types located within  the project
area were  found to  be  limiting  as  far as availability  of
forage  species.     Cover   was   also  found  to  be   adequate
throughout  the  project area  with the  exception  of  some
grasslands  west  of  Congahbuna  Lake  which are farther  than
400 m (400  yd) from escape cover (Figure 5 and  6).

4.3.1  Port Areas

     All habitat  types within  the  proposed  Granite  Point
port site  were classified  as having high value  for  black
bear as  were  habitats within the Ladd site.
                            A-22

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,'4
                                             LEGEND
                                                  VALUE

                                               BftOWN BEAR
                                                  BROWN
    BLACK BEAR AND BROWN BEAR HABITAT IN STUDY AREA
    Diamond Chuitna Environmental Impact Statement
FIGURE 5
                            A-23

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-------
       0
Diamond Chuitna Environmental
     Impact Statement
              LEGEND
            HABITAT VALUE
                  HIGH BROWN BEAR

                  MEDIUM BROWN BEAR
       NOTE: All black bear habitat
       within the project area is high
       value. There is no low value
       for brown bear.
  SCALE IN FEET
2000 4000
8000
  BLACK BEAR AND BROWN BEAR
     HABITAT IN PROJECT AREA
               FIGURE 6

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4.3.2  Transportation Corridors

     All  habitat types  within the  southern, eastern,  and
northern  transportation  corridors were  classified  as having
high suitability for black bear.

4«3.3.  Mine and Mine Facilities

     All  habitat types were  classified  as high value except
for open water areas.

4.3.4  Airport and Housing Facilities

     Within the  area of the  proposed Lone Creek  site,  all
habitat which  would be  lost  was  classified  as  having  high
suitability  for  black  bear.   The  same was  true  for  the
Congahbuna Lake site and Threemile site.

4.3.5  Material Sites

     Material sites  5, 1, and 8 were all considered to con-
tain high quality black bear habitat,

4.4  BROWN BEAR

     The only habitat type within the project area  which was
found to  be  limiting for forage  species and  cover  was  the
closed broadleaf forest/paper birch.  This forest  type  has
a relatively  low percentage  of berry-producing  species  and
herbaceous forage  species.    Tree canopy  cover  is  over  60
percent and the  habitat was  classified as having  a medium
overall suitability (Figures 5 and 6).

     Bear densities are likely higher in the mine area since
brown bears prefer open areas in the higher elevations.

4.4.1  Port Areas

     All habitat types with  the area to be developed at the
proposed Granite Point  and  Ladd port sites were classified
as having  high overall  habitat suitability  for brown  bear
except for a small amount of  open water habitat  at the  Ladd
port site.

4.4.2  Transportation Corridors

     Ninety-seven percent of the area to be developed within
the  southern  corridor  was   classified  as   having  a  high
overall suitability for brown bear.   The remaining  3 percent
was closed paper  birch forest with  a medium  habitat suita-
bility value.

     All  habitat  types  within the northern  and  eastern
corridor were classified as  high quality for brown  bear.
                            A-25

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4.4.3  Mine and Mine Facilities

     All of the terrestrial habitat within the 30-year limit
of  the  mine,  the  mine  facilities,  and overburden  stock
piles  areas were  considered to have  a high  overall habitat
value  for brown  bears  and provide  good interspersion  of
habitat  types.   Open water areas,  primarily pond habitats,
were considered low  quality habitat but were not delineated
on the maps since all  are relatively small.   Total areas of
aquatic habitat were approximately 24 ha  (59 ac).

4,4.4  Airport and Housing Facili ties

     All habitats which  would  be  lost in development of the
Lone Creek site were  classified as  having  a  high overall
suitability for brown  bear, as were those in the Congahbuna
Lake site and Threemile site.

4.4.5  Material Sites

     All  habitats  within  the three material  sites  were
classified as high quality brown bear habitat.

4.5  MOOSE

     A higher degree of resolution was achievable in deline-
ating  quality of moose habitat in the project area than for
the  other  species.   This was  largely due  to  the discrete
habitat  requirements  of  moose and  the  greater  amount  of
available information on their habitat requirements.

     Suitable spring/summer/fall range for moose is abundant
throughout the  project  area  and does  not  appear to be  a
limiting factor for  the  local  population.  Suitable habitat
is found in low-lying  areas which provide browse and herba-
ceous vegetation in the spring and early summer prior to the
snow melt  in  the higher  elevations.   Once  the  upper  areas
are free of snow, moose  can move  up into extensive areas of
high quality  summer and fall  range  north  of the Chuitna
River  (Figures 7 and 8).

     Moose winter  range   is restricted to areas where  snow
accumulation does  not limit availability of browse or mobil-
ity.   The  152  m (500  ft)  contour was used  in  this area as
the upper elevation limit.  The distribution  of moose winter
range in the study area and project area is given in Figures
9 and 10.

     Some riparian areas  very  likely  receive use dispropor-
tional to  the  size  of the habitat areas.   This  may  occur
along both the Chuitna  River and stream 2003.
                            A-26

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                                           LEGib
•rtlGH}''.;v~ v

MECTUM k  f
s. &
.,«,r-'
                                   .
                       --4 	*.m  ,-•- . ~-"f:;-*«'•»-%,

                                   Cl^
                       -#$•».".••!;••"*•/•'•• ^•"'.'.•«\i»
  MOOSE SPRING/SUMMER/FALL RANGE IN STUDY AREA
Diamond Chuitna Environmental Impact Statement



                             A-27
     FIGURE 7

-------

-------
A-28

-------
        [«:• Af» *
        \ *.'Xi , „   N ,  : -- - J ^ • •  \ ',<,
        S ' -  -* I   *  ".*««• l^ *° Ev '  ',
                T,—*-At»; • »^-1- ,^*
                    •  ~'F- ->fc# '
'  T  -^ry ^ ^'  ^^ x-.-.'  'r-.^,'! v
 . u.-yv- ^^4^Ky?'V  -l.r^vf.f.: .  fi^ V^
»*-^f i  '^KF^X  ^-''  i-:^^«f ••'-•'•".   x>€
* * X-. i -  tfarW  X.. * , x  - !  A *!?**» ,  - i   » M
                 ;4
^^..'"../-L^Q^to,   ,
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*: --.v^^'-^iilfc/^ -r/--
                                                MEDIUM
                                                •-. -4 ;  • •' •• ••  •  • rsO'>-'
                                                •,LQW i.rJ w,':, -r'^_^., if '

                                             "Of cdfjbENTRAflON !  "
                                          101    234
                                              E^«S=E=X
                                              SCALE IN MILES
           MOOSE WINTER RANGE IN STUDY AREA
Diamond Chuitna Environmental Impact Statement
                              A-29
                                                      FIGURE 9

-------

-------
              LEGEND
            HABITAT VALUE

                  HIGH

                  MEDIUM

                  LOW
        AREA OF CONCENTRATION
           (from Faro 1985a)
            SCALE IN FEET
       0   2000  4000       8000
       MOOSE WINTER RANGE
         IN PROJECT AREA
Diamond Chuitna Environmental
     Impact Statement
FIGURE 10

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4.5.1  Port Areas

     No areas  of  high  suitability for either spring/summer/
fall range  or winter  range  occurred within the area  to be
developed at  the proposed Granite  Point port site.   These
areas  would  be  characterized  as  having moderate  spring/
summer/fall values  and low to moderate  winter  range value.
It  should be  noted, however, that  patterns  of  actual  moose
distribution in the winter (Figure  10)  indicate high utili-
zation  of  the  coastal area  including  Granite Point  which
contradicts the results  of  the  habitat modelling  to  some
extent.    Forage  value  of   the  habitat,  which  would  be
directly disrupted  by  port facilities,   is probably  low but
the snow conditions and mix of habitats within  the  coastal
strip as a whole is evidently favorable.
         of  the habitat  types  in  the Ladd port site (except
for  3  ha  [7ac]  of  open water)  were classified as  medium
spring/summer/f all  habitat.    Only  6 ha  (16 ac) were  con-
sidered as having  low  value  for winter  range?  the remainder
received a medium rating.   Actual  utilization by  moose  in
winter is probably high due to its proximity to the coast.

4.5.2  Transportation Corridor

     The southern  transportation  system would  affect  a  wide
range of moose habitat.  Moderate quality spring/summer/fall
habitat would  be  the major type  lost (67 percent)  followed
by high quality habitat (32 percent).

     Winter  range  affected  by the  haul  road  and  conveyor
would  largely  be  areas  of  low  suitability  (90  percent).
High quality moose  winter  range lost to development amounts
to one percent of  the  total  lost  along  the corridor.  Large
areas of high  suitability occur  west of  the  proposed  haul
road.

     The eastern   corridor  alignment would  affect  medium
quality spring/summer/fall habitat  to  the  greatest  degree
(93 percent)  and high  quality  range  to  the lesser extent  (7
percent) .

     No  significant  high quality   winter  range  would  be
affected by  the  eastern route.   Fifty-four percent  of  the
route was  classified as medium quality  and 26 percent  was
low.   Approximately 35  percent of  the  route  would  not  be
used due to its elevation (above 500  ft) .

     The northern  corridor alignment would affect a rela-
tively small  amount of high quality moose spring/summer/fall
habitat  (5  ha  [12  ac])  located  along  Lone  Creek   and
Tributary  2003.    These  habitats  are also  considered  high
quality for  winter range,  but the high  elevation (approxi-
mately 152 m [500  ft]) would  likely preclude  their  use  by
moose.  Most  of the habitat affected  by  this route alignment
                            A-31

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(93 percent)  is  of medium quality  for  moose spring/summer/
fall use.

     Forty-four percent of this  corridor  (32 ha [79 ac])  is
of medium  moose  winter range with  another  30 percent being
classified as low quality.

4.5.3  Mi ne and Mine Facilities

     Terrestrial habitats within the 30-year mine limit area
are  predominantly  high  quality  moose  spring/summer/fall
range  (67  percent) with most  of  the remaining area being  of
moderate quality.   Less than one percent was classified  as
having low suitability.   Since winter  range was defined  as
areas  below  152  m (500 ft) elevation,  this  area would con-
tain no moose winter range.  The possibility does exist that
moose could use some of this area in winters of low snowfall
or  in early  winter before  significant snow accumulation.
However, its significance as winter range would not be great
over time.

4-5.4  airport and Housing Facilities

     A  majority   (86   percent)   of  the  habitat  lost  in
developing  the  Lone Creek  site  is  classified as  having  a
high  overall  habitat  suitability  for  spring/summer/fall
range  but  was  not considered suitable  for winter range due
to the  elevation.   The remaining areas were  considered  of
medium quality for moose summer range.

     The moose habitat  at the Congahbuna Lake  site is pre-
dominately  medium  quality  spring/summer/fall  habitat but
there  is  a significant amount of high quality  habitat  (34
percent).  This area lies near the  152  m  (500 ft) elevation
so it is questionable whether moose are able to use the area
in typical winters.

     All of the habitat at the Threemile site is classified
as being of medium quality for both moose  spring/summer/fall
habitat and for moose winter range.

4.5.5  Material Sites

     A majority of habitats within  material  sites #5 and  #8
provide  high quality  spring/summer/fall  range for  moose.
Site  #7  contains all  high  quality  range.   No  low quality
habitat was found within any of the areas  proposed for use.

     Sites  #5  and #8 are too high in  elevation  to provide
winter  range  in  normal years.   Site  #7  is  located on  a
south-facing slope above Nikolai  Creek within a long band  of
high quality winter range.  All of the habitat types at this
site were characterized as high quality winter range.
                            A-32

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4.6  COMPARISON OF FEE- AND POSTMINING H&BITAT VALUE

4.6.1  Vegetation Types

     The  four  major  vegetation types which  presently occur
within the 10-year mine limit and overburden stockpile areas
would  be  replaced  by  seven  vegetation  types  during  the
reclamation process.  Three  of these vegetation types would
be wooded types,  only one of  which,  the mixed woodland,  is
presently  found  within  the  project  area.   These  include:
mixed  woodland/spruce-birch,  spruce  woodland,  and  birch
woodland.  The mixed woodland/spruce-birch would be the most
extensive  type  reestablished in the  disturbed areas (Table
11).   Smaller  amounts of pure spruce stands and pure birch
stands would replace some of the natural mixed woodland.

     Three shrub types would be developed to replace the low
shrub/sweetgale grass fen  type.   These  include  one natural
type,  closed  tall  shrub  scrub  alder,  and two artificial
types,  open-tall  shrub  scrub/willow  and open  shrub scrub/
mixed shrub.

     The  areas  of vegetation types  removed  and replacement
vegetation types are given in Table 11.

4.6.2  Habitat Values

     The  value  of  these replacement  vegetation types  for
wildlife  species would vary  considerably  depending  upon
several factors  such  as success of  reestablishment, growth
rates of  the trees and  shrubs, annual forage production and
rates of  natural  introductions of  native  species.   Habitat
values would  likely  increase  over  time as  the  communities
mature.

     Since  a  major  factor  in  determining habitat  quality
involves  quantity of  available forage  (i.e.,  percent cover
of berry-producing species)  and  this data is  not  available
for  the  replacement  vegetation types,  the types cannot  be
evaluated  using  the  criteria  used  for   the overall  habitat
analysis.   Only  subjective  values  can  be  assigned  based  on
plant species  composition and professional judgment.

     Sandhill   cranes  and  trumpeter  swans would  not  be
affected  by the  mine  development  so  black bear, brown  bear
and moose habitat only are discussed in  this analysis.

4.6.3  Black Bear

     The overall habitat value of all the revegetation  com-
munity  types  would  likely be  medium  due to  the   lack  of
diversity  of  succulent  herbaceous   understory  species  and
berry-producing species, especially  during the  initial years
after  reclamation.    Lack  of  mature trees  or  dense shrub
                            A-33

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                                   Table 11

                 COMPARISON OF AREAS OF HABITAT LOST TO MINING
                      &CTIVTTI£S AND REPLACEMajr HABITAT
   Vegetation Typesl
Premining Habitat     Replacement Habitat
(hectares [acres])    (hectares [acres])
Mixed Woodland/Spruce Birch

Spruce Woodland

Birch Woodland

Mesic Graminoid Herbaceous/
  Bluejoint Herb

Open Low Shrub Scrub/
  Sweetgale-grass Fen

Open Tall Shrub Scrub/
  Willow

Closed Tall Shrub Scrub/
  Alder

Open Shrub Scrub/kLxed
  Shrub-grass
Opai Water
  398 (984)
   34 (84)


  117 (291)
  105 (262)
                      Total
    7 (18)

  662 (16395
222 (549)

 55 (137)

 83 (206)


125 (310)


    0


 24 (60)


104 (259)


 47 (118)

    0

660 (1639)
*-It should be noted that pranining and postnining habitat types that have
 the same name do not necessarily have the same composition or value to
 wildlife.
                                    A-34

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cover  for  escape may inhibit use  until communities mature.
Relative  values of  each replacement  habitat  are  given  in
Table  12.

4.6.4  Brown Bear

     Brown bears are a  more wide-ranging species than black
bears.   Therefore,  the  effect  of  limited habitat  on brown
bear may  not be as  significant  since  the bears  can compen-
sate by using more suitable habitat outside the mine area.

     Lack  of  diversity  of  forb  and  berry-producing species
may  decrease the  quality  of replacement  vegetation  types.
However, since  grasses  would be a major  component of  most
all types, this may compensate for the deficiency.

     Since brown  bears  are primarily  an  open country  spe-
cies,  habitat values of  wooded  types would decrease as  they
mature and develop a closed canopy.

4.6.5  Moose (spring/summer/fall range)

     Snow depth during the  winter  would limit  the mine  area
for  moose  winter  range so use would occur during  spring
through fall.

     The  major  habitat  parameters determining  the  suita-
bility  of  a  vegetation  type for  moose  during this  time
period  are  browse  quality and quantity, availability  of
cover, and forb production.

     Browse quality should be good in all woodland and shrub
types  with the  possible  exception  of  closed  tall  schrub
scrub/alder  but  browse  quantities are speculative at  this
point.  The open tall shrub scrub/willow would be highest in
habitat value? forb production would  likely be low.  In  all,
very few forbs would be  introduced.  Cover would likely not
be a limiting factor affecting overall  habitat quality.

4.6.6  OverallHabitat Quality

     Surface areas  of habitats  according to value for  key
species are presented in Table 13 for  both the premining and
postreclamation  condition   using the   assumptions  developed
above.   Quality  of  the replacement  habitat  for  wildlife
within  the 10-year  mine  limit would actually  be  highly
dependent on the success of the  reclamation  and  the succes-
sion of the new communities.  It is suspected  that replace-
ment communities would  provide  lower  quality habitat  than
the  existing  community  types  but  would  increase in value
over time  as the  stands mature and  resemble more  closely
premining diversity and  forage species  composition.
                            A-35

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Table 12
RELATIVE HABITAT VALUE FOR REPLACEMENT HABITAT
FOR BLACK BEAR, BROWN BEAR AND MOOSE
Replacement
Community Type
Mixed Woodland/
Spruce-Birch
Spruce Woodland
Birch Woodland

Black Bear
Medium
Medium
Medium
Mesic Graminoid Herbaceous/
Bluejoint Herb Medium
Open Tall Shrub Scrub
Willow
Closed Tall Shrub Scrub
Alder
Open Shrub Scrub/
Mixed Shrubs

Medium
Medium
Medium
Table 13
Species
Brown Bear
High
High
High
High
High
High
High


Moose
Medium
Medium
Medium
Medium
High
Low
High

COMPARISON OF PRSMINING AND POSTMINING
HABITAT VALUES FOR EVALUATION SPECIES
Premining
Evaluation Habitat Habitat
Species Value (Hectares [acres]
Black Bear High
Med
Low
Brown Bear High
Med
Low
Moose High
Summer/Fall Med
Low
660 (1639)
0
0
660 (1639)
0
0
398 (984)
257 (637)
0
Postmining
Habitat
) (Hectares [acres])
0
660 (
0
660 (
0
0
71 (
485 (
104 (
1639)
1639)
178)
1202)
259)
  A-36

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5.0  DISCUSSION

     The  terrestrial habitats  of the  Beluga area  exhibit
very high  diversity  and interspersion.   The small amount of
low quality  habitat  found  for  most species is an indication
of  the quality  of  this area.    None  of the  habitat  areas
affected  by  the  proposed  development  of  the various  com-
ponents were classified as "very high" or critical to the
species considered.

     From  the standpoint of direct habitat loss  and quality
of habitat,  the  southern transportation corridor  to a  port
site at Granite  Point and the  housing  facility  and airport
site at Lone Creek would produce the least adverse impact to
wildlife habitat.  The  use of  material  site #5 would result
in  a  smaller loss  of  habitat  (especially for  moose)  than
either #7  or 18.  The Lone Ridge  site was  not considered in
this analysis due to the remote possibility of its develop-
ment.

     The differences  in direct habitat  loss  between  alter-
natives is not  significant compared to  the  large amount of
habitat which would be lost within the 30-year mine limit.


6.0  REFERENCES

Alaska Dept.  of  Fish and  Game. 1976.   A  fish and wildlife
     resource inventory of  the  Cook  Inlet-Kodiak  areas.
     Anchorage,  AK.

	. 1984.   Fish and wildlife  resources  element  for the
     Susitna  area   planning   study  and   resource   atlas.
     Anchorage,  AK.

Berns, V.D.  and  R.J.  Hensel.  1972.   Radio  tracking  brown
     bears  on Kodiak   Islands.    Internat.   conf.  on  bear
     research and management,  Union  for   the Conserv.  of
     Nature and  Nat.  Resources.  Series  No. 23.

Boise, C.M.  1977.   Breeding  biology of  the  lesser sandhill
     crane   (Grus  canadensis  canadensis)   on   the  Yukon-
     Kuskokwim  Delta,  AK.    M.S.  Thesis,  Univ.  of   AK,
     Fairbanks,  AK.

DOWL.   1981.   Coal   to  methanol  feasibility study,  Beluga
     methanol project.  Vol.  IV-Environmental. Prepared for
     Cook  Inlet  Region, Inc.  and  Placer  Amex,  Inc.    DOS
     grant DE-FG01-80RA-50299.   Anchorage,  AK.

Environmental Research  and Technology,  Inc.  1984a.  Diamond
     Chuitna Project.  Terrestrial wildlife baseline report,
     Vol.   I  and  II.   Prepared for Diamond Shamrock-Chuitna
     Coal  Joint  Venture,  Anchorage,  AK.
                            A-37

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	. 1984b.  Diamond Chuitna Project.  Vegetation baseline
     studies report.   Prepared  for Diamond Shamrock-Chuitna
     Coal Joint Venture, Anchorage, AK.

Erickson, A.W. 1965.   The  brown grizzly bear  in Alaska:  its
     ecology and management.  Alaska Dept. of  Fish and Game.
     Juneau, AK.

Fame, G.W.  1974.   Black bear predation on salmon  at Olsen
     Creek, Alaska.  22 Fierspsychol.  35s23-38.

Faro, J.  1985a.   Moose  studies  for  the proposed  Diamond
     Chuitna coal mine.  AK Dept.  of Fish and Game internal
     report.  Anchorage, AK.

	. 1985b.  Alaska Dept. of Fish and Game,  Anchorage,  AK.
     Personal   communication   to   M.C.T.   Smith,   Terra
     Nord, Anchorage, AK.

Hansen,  H.P., J. Shepard,  J.  King  and  W.  Troyer.  1971.   The
     trumpeter swan in Alaska.  Wildl. Monog.  2C.

King, J.G. 1968.  Trumpeter swan survey, Alaska,  USDI,  Bur.
     Sport Fish and Wildlife, Juneau, AK.

LeResche, R., R. Bishop  and J.W.  Coady.  1974.   Distribution
     and  habitats  of  moose  in Alaska.   Naturaliste  Can.
     101:143-178.

Mcllroy, C.W. 1970.   Aspects of the ecology of hunter  har-
     vest of the black bear in Prince William  Sound.   M.S.
     thesis, Univ.  of Alaska, Fairbanks, AK.

Miller,  S.D. and  D.C. McAllister.  1982.   Big  Game  Studies
     Vol.  VI.  Black  bear   and  brown  bear.    Environmental
     Studies Phase I  Final  Report.   Alaska Power  Authority,
     Susitna Hydroelectric  Project.  Anchorage,  AK.

Pacific  Working Group. 1977.  In:  Burk (editor).   The black
     bear  in  modern  North  America. Proc. workshop on  the
     manager, biol. of No.  Amer. black bear, Kalispell,  MT.

Schwartz, C.C.  and A.W.  Franzman.  1980.   Population ecology
     of  the  Kenai  Peninsula black  bear.   AK  Dept.  of  Fish
     and  Game.  Fed.  aid  in wildlife  restor.,  proj.  prog.
     rept.  W-17-11, Juneau, AK.

Sommerville, R.  1965.  An evaluation of the 1961-1963 Alaska
     brown  bear  and  grizzly  management program.     M.S.
     Thesis, Univ.  of Montana, Missoula, MT.

U.S. Fish  and Wildlife Service, 1980.   Terrestrial  habitat
     evaluation criteria  handbook  -  Alaska   Ecol.  Serv.,
     Anchorage,  AK.
                            A-38

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Viereck,  L.A.,  C.T. Dyrness  and A.R. Batten.  1982.    1982
     revision of  preliminary  classification for  vegetation
     of   Alaska.     Pacific  Northwest  Forest   and   Range
     Experiment Sta., Portland,  OR.

Walkinshaw, L.H. 1949.   The sandhill cranes.  Cranbook  Inst.
     Sci, Bull.  No, 29.
                            A-39

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	Appendix B
U.S. Fish and Wildlife Service
         Mitigation Statement

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                     United States Department of the Interior
                                  \\V\kTii Alaska i-Volngical Services
                                      Sunshine I'la/a, Suite 21!
                                         •Hi W, MhAvc,
                                      Aiidmraiie, Alaska l>'»5<)1
IN HEPLY REFEM TO:

       WAES
       Mr. William M.  Riley                                    - ccp 1885
       EIS Project Officer                                    1B
       U.S. Environmental Protection Agency
       Region X
       1200 Sixth Avenue
       Seattle, Washington 98101

                                       Re:  Diamond Chuitna Coal Project
                                            U.S.  Fish and  Wildlife Service {FWS)
                                            Mitigation Policy Statement

       Dear Mr. RHey:

       As a part of overall planning and participation in the subject project, the
       FWS has prepared  a mitigation statement for your information and guidance.
       This document,  in accordance with the Fish and Wildlife Service Mitigation
       Policy (FR Vol. 46 No. 15, 23 January 1981), establishes  fish and wildlife
       evaluation species, resource categories of habitat and mitigation goals.

       By establishing project and species habitat specific mitigation goals, the
       FWS intends to  protect and conserve the most important and valuable fish and
       wildlife resources while facilitating balanced development of. the nation's
       natural resources.
                                            Sincerely
                                            Field Supervisor
       Enclosure
       cc: Don McKay,  ADF&G, Anchorage
           Jim Hemming,  Dairies & Moore, Anchorage
           Brad Smith, NMFS, Anchorage
           Rich Sumner,  EPA, Anchorage
           Sam Dunaway,  DNR, Anchorage
           Carol Gorbics, CE, Anchorage
           Dan Wilkerson, DEC, Anchorage

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                         Dianond Chuitna Coal Project

                            Mitigation Statement


Under the F1sh and Wildlife Coordination Act (FWCA) and the National
Environment a "I Policy Act  (NEPA) regulations, the Fish and Wildlife Service
(FWS) has responsibilities to Insure that project-related losses to fish and
wildlife resources are identified and mitigated.  As part of our
participation in the planning and evaluation of the Diamond Chuitna Coal
Project> the following mitigation statement has been developed in accordance
with the FWS Mitigation Policy  (FR Vol. 46, No. 15, 23 January 1981) and in
consultation with the National Marine Fisheries Service (NMFS), the
Environmental Protection  Agency (EPA), and the Alaska Department of Fish and
Game (ADF&G).  It has been prepared to provide guidance for evaluating and
mitigating impacts of the proposed project to fish and wildlife.

The Diamond Chuitna Coal  Project, mitigation statement has been developed by
first selecting fish and  wildlife habitats from among the full range of
habitats occurring within the area to be impacted by both direct and
indirect perturbations.   These were chosen either because they represent
resources which are most  characteristic of the area or because FWS has
mandated responsibilities for them.  By narrowing the scope in this way, the
analysis can focus on areas where significant changes are most likely to
occur and not be unduly burdened by inclusion of areas with low fish and
wildlife value.

Evaluation species, which function as indicators of habitat quality and
quantity, were chosen.  Selection of evaluation species has an important
role in determining the extent  and type of mitigation to achieve.  A
combination of two sets of criteria is typically used to choose species for
this purpose.  The first  is to pick species with high public interest,
subsistence, or economic  values, and the second is to select species which
use habitats of significant ecological val ue.

Fish and wildlife habitats were then assigned to one of the four Resource
Categories delineated in  the FWS Mitigation Policy (Table 1).  Designation
of habitat into Resource  Categories ensures that the level of mitigation
recomnended is consistent with the value of that habitat and its relative
abundance on a regional or national basis.

Eleven species have been  selected as the basis for evaluating impacts and
formulating mitigation  requirements for the Diamond Chuitna Coal Project.
Available information indicates that moderate to high value habitat for each
evaluation species is found within the project area but that none is
considered unique or irreplaceable.  Therefore, the habitats for all species
have been assigned to Resource Categories 2, 3 or 4.

The determination of the  relative scarcity or abundance of habitat from the
national perspective is based upon (1) the historical  range and habitat
quality and (2) the current status of that habitat.  A significant reduction
in either the extent or quality of habitat for an evaluation species
Indicates that it is scarce or becoming scarce, while maintenance of
historical quantity and quality is the basis for considering it abundant.

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Specific ways to achieve the mitigation goal for Resource  Category 2 when
loss of habitat value 1s unavoidable include:

         (1) physical modification of replacement habitat  to convert
         it to the same type which was lost; (2) restoration or
         rehabilitation of previously altered habitat;  (3)  increased
         management of similar replacement habitat so that the
         in-kind value of lost habitat is replaced; or (4)  a
         combination of these measures.  By replacing habitat value
         losses with similar habitat values, populations of species
         associated with that habitat may remain relatively stable
         in the area over time.Jj/

The mitigation goal of in-kind replacement of lost habitat, however, cannot
always be achieved.  When opposition to a project on that  basis  alone is not
warranted, deviation from this goal may be appropriate.  Two such instances
occur when either different habitats and species available for replacement
are determined to be of greater  value than those lost,  or  when in-kind
replacement is not physically or biologically attainable in the  ecoregion.
In either case, replacement involving different habitat kinds may be
recommended, provided that the total value of the lost habitat is
compensated.

For Resource Category 3,  in-kind replacement of lost habitat is  preferred,
though not always possible.  Substituting different habitats, or increasing
management of different habitats so that the value of the  lost habitat is
replaced, may be ways of achieving the planning goal of no net loss of
habitat value.

The planning goal associated with Resource Category 4 is to minimize the
loss of habitat value.  Resource Category 4 areas, possessing relatively low
habitat values, have the greatest potential for improvement; their
enhancement may be used to mitigate losses in resource categories 2 and 3.
1/FWS Mitigation Policy.

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Table 1.   Resource Categories flnri mitigation planning goals,*
Resource
Category
Designation
  CM ten' a
Mitigation Planning
       Goal
                       Habitat to be impacted is  of
                       high value for evaluation
                       species and is unique and
                       irreplaceable on a national
                       basis or in the ecoregion
                       section.

                       Habitat to be impacted is  of
                       high value for evaluation
                       species and is relatively
                       scarce or becoming scarce  on
                       a national basis or In the
                       ecoregion section.

                       Habitat to be impacted Is  of
                       high to medium value for
                       evaluation species and is
                       relatively abundant on a
                       national basis.

                       Habitat to be impacted is  of
                       medium to low value for
                       evaluation species.
                         No loss of existing
                         habitat value.
                         No net 1 oss of
                         in-kind habitat
                         value.
                         No net loss of
                         hablta't value whll e
                         minimizing loss of
                         in-kind habitat
                         value.

                         Minimize loss of
                         habitat val ue.
  FWS Mitigation Policy (FR Vol. 46, No.  15,  23 January 1981).

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Table 2.   Evaluation species  for the Diamond Chuitna Coal  Project and
Resource Category designations for associated habitat.
Common Name
Sandhill crane
Trumpeter swan
Black bear
Brown bear
Moose
Beaver
Belukha
Chinook salmon
Coho salmon
Pink salmon
Rainbow trout
Resource Categories of Associated Habitat
4
2
3
2
2/3*
4
3
2/3/4*
2
3/4*
3
*See text

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Project Eva! uation Species

1.  Sandhill  crane (Orus canadensis).  The lesser sandhill  crane, considered
common on a national  basi s, nests throughout Alaska,  as well  as in northern
Canada and the northeastern Soviet Union.  Although uncommon  in the Diamond
Chuitna project area, cranes are abundant in Cook Inlet as  summer breeders
and as spring and fall migrants.  Cranes nesting in Cook Inlet form part of
the Pacific Flyway population.

Human use of Pacific  Flyway cranes is primarily nonconsumptlve (bird-
watching and photography), although in Alaska cranes  are hunted for sport
and subsistence.   Over 30 percent of the cranes harvested for sport in
Alaska in 198? wore taken in Cook Inlet (Campbell 1984).  Subsistence
hunting, which occurs predominantly fn the Yukon-Kuskokwim  Delta, accounts
for approximately 1000 birds every year (FWS 1983).

Boise (1977)  found that "human activity above minimal  levels  appears
incompatible  with crane nesting, as reflected in nest  desertion as a result
of human activity.  Loss of nesting habitat as a result of  land development
is a further  threat to the population's stability."

Preferred nesting habitats are sedge/grass meadow and  wet marsh tundra, with
an unobstructed view  on all sides and with standing water nearby (Konkel et
aK 1980).                                                             ~~

Because nesting has not been documented in the project area and because
significantly better  habitat can be found to the southwest  and northeast
(EPA 1985), the suitable crane habitat in the coastal  reaches of the Diamond
Chuitna project area  is placed in Resource Category 4  (Tables 1 and 2).

2.  Trumpeter swan (01 or buccinator).  Nonconsumptive  interest in this
species is high.   Recently closeto extinction, the trumpeter swan is still
very rare in  the  conterminous 48 states.   Historically,  swans were found
throughout much of northcentral North America in summer and along the
Mississippi River and the Atlantic, Pacific, and Gulf  coasts in winter
(Bartonek 1983).   Their favorable response to management  efforts and perhaps
an amelioration in climate has made possible their removal  from the
Threatened and Endangered Species List.   The 1980 census  indicated that
nearly 8,000 swans, or 90 percent of the world population,  were on breeding
grounds in Alaska (King and Conant 1981).

Swans nest and rear in the southern half of the state,  in wetlands and
shallow ponds and lakes surrounded by emergent vegetation.  They are common
migrants and breeders in Cook Inlet.  The mine permit  area  contains one
active nest,  and  the  coastal reaches of the transportation  corridors and
ports fall within a broad band of nesting habitat.  Trumpeter swan surveys
in Cook Inlet indicate that the population is expanding (EPA 1985).

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Trumpeter swans  are very susceptible to disturbance while nesting and
rearing cygnets,  and the species is being excluded by recreational
developments on  large lakes formerly used for nesting (Timm and Woject
1978).   Approximatey two thirds of all  trumpeter  swan habitat in Alaska is
in private ownership and therefore potentially available for development.  I
key objective of the North American Management Plan  for Trumpeter Swans is
to "Preserve all  current wintering and breeding trumpeter swan habitat
through whatever means necessary to protect habitat  integrity."  Given this
objective and the fact that the Alaskan population is expanding, all
potential and actual nesting habitat in the Diamond  Chuitna project area is
placed in Resource Category 2.
3.  Black bear (Ursus  antericanus).  This species is widespread throughout
North America; black bear habitat is considered abundant on both  a national
and regional basis.  Human interest in black bears has always been high,
particularly in terms  of hunting, photography and wildlife observation.
Black bears would be impacted by coal development through habitat
elimination, reduction in food supply, increased human access and hunting.

Seasonal availability  of foods strongly influences the distribution of black
bears in an area.  Bears move from spring green-up areas to sunnier salmon
streams, and then to berry-producing shrub! and in late summer or early
fall.   Black bears are common throughout the project area but prefer open,
mixed hardwood/spruce  forests at the lower elevations and do not range far
from cover to feed.  None of the habitats in the project area were found to
be limiting in terms of food or cover and all were classified as being of
high value for black bears (EPA 1985).

Because the study area provides good habitat and supports a large population
of black bears,  and because habitat in Cook  Inlet is abundant, habitat in
the project area is placed in Resource Category 3.

4.  Brown bear (Ursus  arctos).  This species is considered a valuable big
game animal and attracts numerous resident and nonresident hunters.  It also
elicits considerable nonconsumptive interest from photographers and wildlife
observers.  Although not considered threatened or endangered in Alaska, the
brown bear is listed as threatened under the Endangered Species Act in the
48 conterminous states.  As such, it is a species of national interest,
whose habitat has been significantly reduced in extent and quality.  It is
considered scarce from the national perspective although it is relatively
common in the project  area.

Brown bears are distributed throughout the project area.  They prefer open
habitats and are most  common in the upland shrub and tundra communities (EPA
1985).  Brown bears have extensive home ranges, with seasonal changes in
availability of food strongly influencing their movements.  In spring and
fall,  the entire project area provides important forage habitat, whereas in
summer and early fall  the bears are drawn to the streams to feed on spawning
salmon (Diamond Shamrock 1985).  Nearly all  of the project area was
classified as being highly suitable as brown bear habitat (EPA 1985).

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                                                                        7

Project impacts to areas  of early green-up, the salmon fishery,  the
berry-rich shrublands,  and prey species will ultimately affect brown bears,
as will more direct human disturbance in the form of easier access and
increased hunting pressure.

Because of the national scarcity of the species and the high value of the
habitat in the Diamond  Chuitna project area, all of this habitat is placed
in Resource Category 2  for brown bears.

5.  Moose (Alces alces).  Relative to its historic range, the species is
considered "aFuncTant on  both a national and regional basis.   Historically,
moose were an important source of food, clothing and implements  along the
major rivers.  The species continues to be an important source of food  and
recreation, and is probably the most widely hunted species in Alaska.
Spending by hunters results in benefits throughout the state's economy.  The
monetary value of moose is compounded by the number of nonresident hunters
attracted to the state.  Moose also have a high nonconsumptive value to
photographers and wildlife observers.

Moose are an important  evaluation species because they are common throughout
the project area, particularly in the impacted riparian zones, and are
generally responsive to mitigative habitat modifications.   They  will also be
subject to increased hunting pressure during and after development of the
project area.

Moose range throughout  the project area.   Calving takes place in the
lowlands, where the cows  and calves remain all  summer, while  bulls and cows
without calves move to  the upland tundra.   The mine permit  area  covers most
of an upland rutting area used every year by moose in  the  region.  Snow
brings the moose down to  the lowlands; moose from the  project area winter
primarily in the vicinity of Granite Point (EPA 1985).

As moose habitat is nationally, regionally and locally abundant, and as
habitat in the project  area is predominantly of medium to high quality,  most
of the habitat in the project area is placed in Resource Category 3.   The
exception is the section  of rutting area that overlaps with the mine permit
area, placed in Resource  Category 2 by virtue of its importance  to the
regional moose population.


6.  Beaver (Castor canadensls).  Abundant both nationally  and regionally,
beaver play important economic and ecological  roles.   Beaver  trapping in
Alaska continues to be  an integral component of traditional lifestyles,
providing a source of revenue for bush residents.   Similarly, trapping
provides recreational benefits to urban residents.   Beavers have an
important ecological  function in modifying habitat,  often in  ways that
benefit other fish and  wildlife species such as coho salmon,  waterfowl and
moose.   Beaver dams may impede the upstream migration  of spawning salmon,
particularly in years of  low flow.

Beavers are cornnon throughout the project area, along  the major  tributaries
of the Chuitna and in backwater sloughs;  concentrations are moderate and
habitat is probably of  medium value (Diamond Shamrock  1985).  Because of the
abundance on the national and regional level of beaver habitat comparable to
that in the Diamond Chuitna project area,  beaver habitat in the  project area
is placed in Resource Category 4.

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7,  Belukha (De 1 phinapteru_s 1 cucas).   While circumpolar In distribution, the
belukha does no t normallyrang e south of Alaska.   It is one of the most
abundant cetaceans  in the north Pacific.   Belukhas are usually migratory,
but the 300-400  whales in Cook Inlet constitutea nonmigratory, relatively
isolated component  of the population (USDI 1983).  They feed on anadromous
fish close to shore and at the mouths of rivers.  The proposed Diamond
Chuitna port facility may be in the  middle of a belukha calving or nursery
area (EPA 1985).

Given the i ndigenousness of the Cook Inlet belukha population and the
probable importance of the Beluga River area as calving grounds, belukha
habitat in the Diamond Chuitna project area is placed in Resource Category 3,


8.  Chinook salmon  (Oncorhynch us tshawytscha).  Hydroelectric projects in
the northwestern U.S. have destroyed a significant portion of the chinook
spawning habitat in the conterminous 48 states.  Because of the species'
high commercial, recreational and subsistence values, there is considerable
national and regional interest in minimizing losses to chinook populations
and expanding existing stocks.

Chinook salmon support an important  fishery in the Chuitna River system;
three percent of the commercial catch in upper Cook Inlet comes from set net
sites in the vicinity of the project area (EPA 1985).  Chinook enter the
Chuitna River in mid-June and spawn  there and in the middle and lower
reaches of streams  2002, 2003 and 2004.  Although suitable spawning and
rearing habitat  is  available in the  upper sections of these streams, the
upstream range of chinook has decreased in recent years, probably because
access has been  increasingly obstructed by beaver dams (EPA 1985).  The
Diamond Chuitna  project would destroy chinook spawning and rearing habitat
in these streams for an unknown length of time, through the mining of
streambeds, increased sediment loads, and altered water flows and water
chemistry.

Because of the national and local emphasis on chinook salmon and the ongoing
loss of good habitat, chinook habitat in the project area that has been
rated as high or very high quality (Chuitna River, 2002, middle and lower
mainstem 2003, middle and loweer mainstem 2004) is placed in Resource
Category 2; all  medium-quality chinook habitat is placed in Resource
Category 3 (upper mainstem 2003, 200304,  200305, upper mainstem 2004,
200403); and all habitat of low quality (200306) is placed in Resource
Category 4 (EPA  1985).


9.  Coho salmon  (Oncorhynchus k i s u t c h).  On a national level hydroelectric
development in the  northwestern U.S.  has resulted in a significant depletion
of coho salmon stocks.  The coho salmon is an important commercial and
subsistence resource and a highly prized sport fish in Alaska.  The average
comnercial harvest  in 1980-1984 for  upper Cook Inlet was 500,000 cohos, 7
percent of which were caught in the  vicinity of the project area (EPA 1985).

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                                                                  9
Coho salmon spawn and  rear throughout streams 2002,  2003 and 2004.  Access
to upper reaches does  not appear to be limited by beaver dams, although
beaver activity has  altered spawning habitat in several tributaries, making
it unsuitable for coho (Diamond Shamrock 1985).  Additional destruction or
degradation of coho  habitat in anticipated as a result of mining in the
project area.

Because of the species' national and regional importance and the increasing
scarcity of good habitat, habitat in the Diamond Chuitna project area (all
rated as being of high or very high quality;  EPA 1985} is placed in Resource
Category 2.


10. Pink salmon (Oncgrhynchus gorbuscha).   Historically, pink salmon were
limited in range tocoastal streams in northwestern  Washington and to the
north.   As no significant reduction in that habitat  has occurred, pink
salmon habitat is considered abundant on a national  and regional  basis.   The
commercial, subsistence and sport value of this species is considered high.
THe commercial  catch in the coastal reaches of the project area Is about six
percent of the catch in upper Cook Inlet (EPA 1985).

Pink salmon spawning has been confined in recent years, possibly as a result
of beaver dan obstructions, to the lower reaches of  the Chuitna River and
streams 2002 and 2003  (EPA 1985).  Additional loss of habitat is anticipated
as a result of coal  mining in the project area.

Because of the abundance of pink salmon habitat nationwide, habitat in the
project area of medium or high value is placed in Resource Category 3
(Chuitna River, 2002, mainstem 2003) and habitat of  low value is placed in
Resource Category 4  (200304, 200305, 200306,  2004; EPA 1985).


11 . Rainbow trout (Salinp gafrdnerf).  This species is one of the most
sought-after sport fishes in North America,  if not in the world.   The
original range of the  rainbow trout is west of the Continental  Divide from
northern Mexico to the Kuskokwim River.   Rainobw trout have been introduced
to every continent except Antarctica.   The species is now present in every
state except Louisiana, Mississippi and Florida and  has been introduced into
several lakes in Alaska (Morrow 1980).  Interest in  this species on a
national and state basis is high.  Habitat is considered abundant in
comparison to historic levels.

The rainbow trout population in the project area is  judged to be in very
good condition (ERT  1985).  Juveniles are distributed throughout the
tributaries in the project area, although they are most abundant 1n the
Chuitna River, the lower mainstem of 2003 and the lower and middle mainstem
of 2002.  Adults are found in the mainstem of the Chuitna (EPA 1985, ERT
1985).

Although the area is capable of supporting a  limited high-quality sport
fishery, inaccessibility and lack of publicity have  limited the sport
harvest (EPA 1985).  Increased human access,  in conjunction with loss of
habitat and prey, will have an impact on the  rainbow population in the
project area.

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                                                                     AD

Because habitat in the project area is of medium to high quality and  similar
habitat is  abundant on a local and national basis, rainbow trout habitat is
placed in Resource Category 3.

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Li tera t ure Ci ted

Bartonek, J.  1983.   Management  plan  for Pacific Coast amd mid-continent
    population of trumpeter swans  (draft).  Pacific Flyway Tech. Comrn.

Boise, C.H.  1977.   Breeding biology  of the lesser sandhill crane, Grus
    can ad en si s c anjade n si s (L. ) on  the Yukon-Kuskokwim Delta, Alaska.  M.S.
    thesi s,Un i v. of AT ask a, Fairbanks, AK.  79 pp.

Campbell, B.H.  1984.  Annual  report  of survey-inventory activities:  Part
    V.  Waterfowl.   Alaska Dep.  Fish  Game, Juneau, AK.

Diamond Shamrock.  1985.   Diamond  Chuitna Mine permit application to
    conduct surface coal  mining.   Part C:  Environmental resources
    information.  Diamond Alaska Coal  Company, Anchorage, AK.

Environmental Research and Technology, Inc.  1985.  Diamond Chuitna Project
    Mine Component aquatic baseline report.  Fort Collins, CO.

King, J.G.  and B. Conant.  1981.   The 1980 census of trumpeter swans  on
    Alaska nesting habitats.  Am.  Birds 35: 789-793.

Konkel, G.W., L.C.  Shea,  K.E.  Bulchis, L.C. Byrne, D. Pengilly, and K.S.
    Lourie.  1980.   Terrestrial  habitat evaluation criteria handbook  -
    Alaska.  U.S. Fish Wild!.  Serv.,  Anchorage, AK.

f^orrow, J.E.  1980.   The  freshwater fishes of Alaska.  Alaska Northwest
    Publishing Co., Anchorage, AK.

Timm, D. and L. Wojeck.   1978.   Trumpeter swans. • Fishtails and Game  Trails,
    Nov; 4-6.  Alaska Dep. Fish  Game,  Juneau, AK.

U.S. Department of the Interior.   1983.  Proposed Navarfn Basin lease
    offering Draft Environmental  Impact Statement.  Alaska Outer Continental
    Shelf Region, Anchorage, AK.

U.S. Environmental  Protection Agency.  1985.  Diamond Chuitna Coal Project
    Peliminary Draft Environmental  Impact Statement.  Seattle, WA.

U.S. Fish and Wildlife Service.   1983.  Alaska regional resource plan.
    Anchorage, AK.

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

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US Army Corps
of Engineers
Public  Notice
of  Application
for  Permit
Alaska District
   Regulatory Branch
   Post Office Box 898
   Anchorage, Alaska 99506-0898
                                   PUBLIC NOTICE DATE: February 2,  1990
                                   EXPIRATION DATE: March  5,  1990
                                   REFERENCE NUMBERS:  2-850259
                                                     2-850260
                                                     2-850261
                                   WATERWAY NUMBERS:  Cook  Inlet 330
                                                    Cook  Inlet 331
                                                    Cook  inlet 332

   This information was previously published on July 15, 1988 as a part of
   the Draft Environmental Impact statement. This information is being
   re^published as part of the Final Environmental Impact statement.  Your
   review and comments are encouraged.  Please refer to page 12 of this
   document for instructions on receiving the full text of the Final
   Environmental impact Statement.

   APPLICANTS;  Granite Point Coal Port, Incorporated (Granite Point port
   component); Tidewater services Corporation (Ladd port, transportation and
   housing components); Diamond Alaska Coal company (mine component).

   APPLICANTS' AGENT:  Dan R. Harlow, President, Diamond Alaska Coal Company,
   1227 West Ninth Avenue, Suite 201, Anchorage, Alaska  99501.  (907)
   276-6868.

   LOCATION:  The proposed project (known as the Diamond Chuitna Project) is
   located on the northwest side of Cook Inlet, approximately 45 miles west
   of Anchorage in the Kenai Peninsula Borough near the village of Tyonek.
   The proposed project is comprised of four separate components:  the
   Diamond Chuitna Mine, the Granite Point or Ladd (alternate) Coal port,
   transportation systems, and housing facilities.

   PORT FACILITY;  Granite Point, Sections 22, 27, T. 11 N., R. 12 W., Seward
   Meridian, Ladd (alternate) sections 19 and 20, T. 12 N., R. 10 W., Seward
   Meridian.

   TRANSPORTATION CORRIDOR TO GRANITE POINT: Sections 3,4,10,15,22,27, T. 11
   N., R.12W., Seward Meridianand sections 3,4,10,15,22,27,34, T. 12 N.,
   R. 12 W., Seward Meridian

   TRANSPORTATION CORRIDOR TO LAPP POINT (ALTERNATE):  Sections 6,7,18,19,20,
   T. 12 N., R. 10 W. Seward Meridian? section 31, T. 13 N., R. 10 W., Seward
   Meridian,- sections 31,32,33,34,35,36, T. 13 N., R. 11 W., Seward Meridian;
   section 36, T. 13 N., R. 12 W., Seward Meridian; sections 2, 3, T. 12 N.,
   R, 12 W. Seward Meridian.

   HOUSING FACILITIES:  Section 14, T., 12 N., R, 12 W., Seward Meridian.

   MINE FACILITY;  Sections 14, 15, 21-28, and 33-36, T. 13 N., R. 12 W.,
   Seward Meridian; section 4, T. 12 N., R. 12 W., Seward Meridian.

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PURPOSE:  Diamond Alaska Coal Company proposes to develop a twelve minion
ton per year  coal Company mine in the Beluga region of upper Cook Inlet.
Racoveraole coal reserves ara estimated to oe a minimum of 330 million snort
tens.

BACKGROUND INFORMATION:  The Environmental Protection Agency (EPA) is
preparing an  Environmental Impact Statement (EIS) for the Diamond Chuitna
project.  The Alaska District Corps of Engineers is a cooperating agency in
the EIS.

A permit decision regarding this project will not be made until after the
Final EIS has been prepared.  This public notice reflects the applicant's
preferred alternative as well as an alternate port site.  Other alternatives
being considered 1n the EIS process and a discussion of their impacts are
found in the  EIS.  The surface mine would be located on State coal leases in
the Chuitna River drainage approximately 12 to 15 miles north of Granite
Point.  Coal  production is scheduled to start at 2 million tons per year
with the planned maximum production of 12 million tons per year in the
seventh year  of operation.  The project life would be approximately 34
years.  The basic surface mining technique would utilize a combination of
trucks, shovels, and draglines supported by the necessary complement of
front end loaders, dozers, graders, and other equipment.

WORK.;  The proposed work can be described in four parts:  port facility,
transportation corridors, housing, and mine facility.

1.  PORT FACILITY (GRANITE POINT COAL PORT, INCORPORATED, APPLICANT,
2-860259, Cool Inlet 330):The port facility would require approximately
198 acres for the construction of the port facilities.  Approximately 173
acres of wetlands would be filled as needed for the coal stockpile of
400,000 to 1,200,000 ton capacity, sediment ponds and buildings.  A total of
approximately 3,360,000 cubic yards (cy) of material would be placed in
wetlands.

The following structures would be placed in the onshore port area:

    a.  Service buildings to house shops, warehouse, change areas, general
        administration offices and interim storage for supplies.

    b.  Heliport including landing pad,  maintenance facilities, hangar,
        office lounge and toilet.

    c.  Main  electrical  control  building.

    d.  Fire  and ambulance station.

    e.  Water treatment plant and storage.

    f.  Sewage treatment plant (port only).

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     g.   Diesel  fuel  storage  tanks  for approximately four month supply to
         support port,  transportation, and  mining  operations.

     h.   Gasoline storage  tanks for approximately  four month supply to support
         port, transportation, and  mining operation.

     1.   Miscellaneous  oil  and coolant storage  tanks to support port,
         transportation, and  raining operations.

     j.   Containerized  and  miscellaneous storage for interim storage of
         materials and  supplies.

     k.   Fuel distribution  station.

     1.   Coil stockpile of  400,000  to  1,200,000-ton capacity with
         stacker/reclaimer, yard conveyor system,  truck dump, hopper feeder
         system,  coal haulage road,  overland conveyor drive house, and
         transfer stations  for overland conveyor to stockpile conveyor and
         stockpile conveyor to port  (approach) conveyor.

     m.   Coal haulage road  to transport coal prior to startup of conveyor
         operations, and several access roads to link various port facility
         components.

     n.   Electrical substation.

     o.   Power distribution system  consisting of overland and underground
         powerlines to  provide power for port equipment and distribute power
         to mine,  transportation, and  housing facilities.

     p.   Diesel fuel electric generating facility  to support mine
         transportation system, port,  and housing  facilities.

     q.   All weather parking area.

     r.   Sediment  control structures to collect surface runoff from the port
         facilities area.

     s.   Barge unloading beach area  to receive supplies, parts, and equipment
         for the port facility, transportation system, mine, and housing
         facility.

Most of  the wetland areas will be filled with gravel aggregate.  Construction
of surface water  runoff ponds located in the wetland areas would require
removal  of dredge material.  The sides of the sedimentation ponds will be
bermed.  Wetlands disturbed by the  coal piles will be filled with surrounding
earth material and covered with gravel aggregate where required.

Construction activities for the onshore facilities will include excavation,
fill, and site preparation work to  establish the designed site elevations for

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placement  of structures  and roads  and to estaolish surfacs drainage.  Site
worx  will  begin  by  clearing and gruobing of all tress and brush.  This
material will  be ausnea  into windrows by crawler tractors and piled for
later burning.   In  arsas where deposits of peat ana .miskeg are found,
drainage ditcnes will  be constructed to drain  the *et boggy arsas and
facilitate removal  or  site development.  The peat material will be hauled to
an  approved disposal site for final placement.

Once  organic surface material Has  been removed from the site, classified
fill  material will  be  hauled from  adjacent borrow areas and placed as
subgrade for building  foundations.  Surface drainage from the area will be
established by the  subgrade material providing an elevated and drained
surface on which structures can be placed.  Final grade would then include
surface material  for the onshore port facilities.  Placement of grade and
subgradt material will incorporate the use of scrapers, crawler tnctors,
water trucks, motor graders, compactors, and other equipment.

The major  offshore  facility would  be an approximately 12,500' trestle with
ship  breasting and  mooring dolphins.  The trestle would consist of
structural  steel  framework used to support the approach conveyor and a 51
wide  roadway which  will accommodate a battery powered maintenance vehicle
and personnel carrier.  The piers  which are required to support the trestle
will  be spaced at approximately 400' intervals along the trestle.  The piers
have  been  designed  to withstand ice, tide, seismic, and wind forces present
during the year  round operation.   Each pier also includes cathodic
protection to withstand the chemical activity of the salt water and climatic
condition.   This  protection method helps to ensure long-term stability and
operation  of the  pier support system.  Approximately 940' of the length of
the trestle would be above the mean high tide line (MHTL), thus reducing the
length of  the trestle extending into the inlet.  The trestle would be a
minimum of  20' above MHHW.

Coal  would  be transported from the onshore port facilities to the shiploader
facility at the end of the approach trestle on a covered conveyor.  Although
production  of 8 million tons per year requires only one 72" wide conveyor
belt,  sufficient room has been included in the trestle to accommodate a
second 72"  wide conveyor when procuction increases.

All coal will be  loaded by use of  a linear shiploader.  The shiploader will
be used to  discharge all  coal  from the approach conveyor into waiting
ocean-going  vessels.  This equipment will be constructed of steel support
beams  and  covered where necessary to protect the equipment and coal from
adverse weather.  The design of the shiploader will have sufficient capacity
to receive  the output of two 72" wide approach conveyors.  In addition,  the
shiploader  will accommodate the tidal variations (approximately 23') and a
variety of  vessel sizes (22,000 to 120,000 tons OWT)  along with the need for
distributing the coal evenly in the ship's hatches.

A system of  breasting and mooring dolphins will be used to hold the
ocean-going  vessel during coal  loading activities to ensure the safety of
the vessel  and the sniploader facilities.  These mooring dolphins have been
specifically designed to accommodate the large tide,  ice, wind, and seismic
forces in  the Cook Inlet.

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 While  tne  vessel  is  moored  at  tne  shiploading  area,  a fenaering  system will
 3e  required to protect  the  vessel  and  the shiploader platform  from  movement
 of  t.ie vessel  during loading activities.   Vessel movement, ooth  vertically
 ana Horizontally,  will  De affectec by  tides, wind,  and  ica 'notion in  the
 COOK  Inlet.  A slicing  fenoer  will  De  used,  supported by piers,  and raised
 ana lowered with  electric wenches.   The sliding fenaer  is used to minimize
 effects  of ice which may be encountered during winter montns by  always
 keeping  the fender approximately 3'  above water.

 The design, faorication, and construction of tne Coal Port will  take
 approximately three  years.  The construction season  will last from  May to
 October  each year, shorter or  longer due  to weather  conditions.  Fabrication
 of  modules will be completed at factory locations.   The modules
 will be  shipped by barge to the port for  offloading, assembling, and
 erection.

 The offshore facilities consist of  1)  above-water equipment used to support
 and convey coal to a shiploader for placement  into ocean-going vessels, and
 2)  below-water structures including piers to support the structure  and
 withstand  effects  of weather,  tide,  and seismic activity.  Construction work
 will begin by  locating each monopile site along the  trestle.  Depending on
 the approach route selected, 18 to  30  piles will be  driven with  hammers to
 predetermined  depths into the  floor of the Cook Inlet for support of  the
 approach trestle.  Similar monopiles will  be driven  at the end of the
 approach trestle to  support the shiploader, platform, and mooring and
 fendering  dolphins.   Once the monopiles are driven,  structural steel  trusses
 will be placed with  barge-mounted cranes.  The trusses serve as the platform
 for containment of conveyor belts  and  shiploading equipment.  This
 equipment,  which has' been fabricated and  pre-assembled, will also be  placed
 with barge-mounted cranes.  As with  all structures,  fabrication  and
 pre-assembly into  easily handled modules  will  take place at a factory
 location prior to  shipment to the port for erection.

 No  site preparation  work is anticipated to be  necessary for either  trestle
 and/or berthing location.  Sufficient  survey work has been completed  to show
 that dredging  ana filling of the offshore area will  not be necessary.  The
 offshore construction activities will  encompass two construction seasons.
 Due to adverse weather, no construction work will be planned for the  winter
 months from November through May.

 Prior to any onsite construction work,  engineering, design,  procurement,
 fabrication, and preassembly of structures into easily handled modular
 components  will be carried out beginning  in year 1 of the project.
 Construction work on site will  be started  in the spring of year 2 after ice
 breakup.

 2.  ALTERNATE  PORT FACILITY  (LAPP COAL PORT, TIDEWATER SERVICES COMPANY,
APPLICAiNT,  2-850260,  Cook Inlet 3311:  Approximately 28 acres of wetlands
would oe filled as needed for the coal  stockpile, sediment ponds and
 buildings.

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Curing  construction  activities  in years  1, 2, and 3 all materials, supplies
ana  swuipment would  oe off-loaded from barges at the Ladd Port location for
transportation to  oc.ner project components.

Tie  port  features  and construction methods and sequences described in  "1"
-Dove all  applicaole for tne Lada Port facility, as well.

3. TRANSPORTATION  CORRIDOR GRANITE POINT  (TIDEWATER SERVICES COMPANY.
APPLICANT.  2-850260, COOK Inlet 331):The transportation system proposed
ror  tn« project consists OT the main haulage/access road and the overland
conveyor  system.   The transportation systems would impact a total of 170
acres with  approximately 45 acres of that being wetlands.

The  hay!  road would  be approximately 11.3 miles long and would generally run
parallel  to the conveyor system.  The haul road would be built in a new
right-of-way  and would not use existing logging roads south of the Chuitna
River.  A total of approximately 2,260,000 cy of material would be placed in
wetlands.   The finished road surface will have two 35* wide traffic lanes
with 12'  wide gravel shoulders on either side, The road surface will be
gravel  surfaced and  crowned to promote drainage from the road surface.
Drainage  ditches would be provided on either side of the road in level and
cut  areas.

All  construction and operational activites related to the operation of the
transportation facilities would be conducted so as to minimize potential
environmental  impacts.  Drainage and sediment control measures would include
the  construction of  ditches to divert runoff from undisturbed areas around
operational areas, construction of collection ditches, installation of
culverts  under roads to collect and control runoff, surfacing of main roads
and  facility  areas with gravel material, revegetation of road cuts,
embankments and disturbed areas, and utilization of specific localized
sediment  control measures in sensitive areas.

Drainage  and  diversion structures have been designed to pass the peak
discharge from a 10-year,  24 hour event.

Bridges or  large culverts will be constructed to carry the road traffic at
five major  drainage crossings:  (a)  an unnamed creek north of the Chuitna
River,  (b)  the  Chuitna River,  (c) an unnamed creek south of the Chuitna
River,  (d) Old Tyonek Creek, and (e) Tyonek Creek.   During road
construction,  temporary pontoon bridges or stream fords will be used to
provide equipment access.   Permanent bridge structures will be of truss and
girder  construction supported  by concrete lower case piers.

There are several locations along the alignment of the haul road where the
presence  of peat or muskeg deposits in combination with saturated or
semi-saturated glacial  outwash ana alluvium result in adverse surface
conditions for road construction.  In these areas,  a special construction
technique will be used which incorporates the following fill sequence:  The

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 natural  vegetative mat; a flotation material typically of wood chips or
 logs;  a  minimally compacted layer of  fill material; geotechnical fabric to
 provide  lateral  stability, drainage and  distribute bearing loads over a
 large  area;  and, finally normal road  construction techniques.

 The overland conveyor system would run roughly parallel to the haul road for
 a  length of  9.3  miles.  A light duty, minimally improved service/access road
 suitable for four-wheel drive vehicles would be built immediately adjacent
 to the conveyor  for maintenance purposes.  The right-of way would be cleared
 for a width of approximately 25'.  A  total of approximately 225,000 cy of
 material would be placed in wetlands.

 Drainage and sediment control measures for the conveyor would be the same is
 those described  for the main haul road.  Brush within the conveyor
 right-of-way would be mechanically controlled; no herbicides would be used.

 Limited cut and  fill work would be required along the alignment of the
 overland conveyor system and the adjacent access road.  Generally both
 conveyor alignments have been selected to avoid major topographic features.
 Construction would be similar to the  haul road construction described
 previously.

 Conveyor support bridges would be constructed at the same five drainages
 briuged by the haul road.  The conveyor  crossing of the Chuitna River would
 require an extended span supported by a  cable suspension structure.  In most
 areas along the conveyor right-of-way the support piers of the conveyor
 would be anchored to poured concrete  footings; however, in those areas where
 unstable surface materials will not provide adequate lateral support,
 pilings, spread footings, or a combination of the two would be utilized in
 the foundation structures.

At ten points, the conveyor would be  buried for a minimum of 200' in large
 diameter culverts or arch spans to permit moose, bear and other animals to
 pass over the conveyor.   There would  also be three places where the conveyor
 would be raised to permit existing roads to pass underneath.

 During construction of the overland conveyor system, both temporary and
 permanent diversion systems would be constructed to divert runoff through
 culverts installed under the access road.

 In certain sensitive areas such as construction areas adjacent to stream
 channels, localized sediment control  measures similar to those such
 disturbed areas would be revegetated and mulched,  if necessary, as soon
 after completion of construction activities as possible to minimize surface
erosion.

4.  TRANSPORTATION CORRIDOR-LAPP (TIDEWATER SERVICES COMPANY, APPLICANT,
2-850260, Cook Inlet 331):The haul  road for this alternate site would be
 approximate1y 13" miles long.   Approximately 69 acres of wetlands would be
filled.  The construction methods  and sequences described in "3" above are
 applicable for this corridor,  as well.

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5. HOUSING  FACILITIES  (TIDEWATER SERVICES  COMPANY, APPLICANT,
2~J502SQ, COOK Inlet 331j:  Because of  the remoteness of tne project  site
from nncnorage ana  otner Aiasxa communities, tne applicants are planning the
construction of a housing complex to  accommodate the wcr< force of 500
employees.   A landing  strip located approximately one nnla north of the
housing  area is also proposed to allow  shuttling of employees between
Ancnorage and the site.  The housing  complex including roads and landing
strip would impact  approximately 72 acres  with 6 acres Seing in wetlands.  A
total of approximately 60,000 cy of fill would be placsa in wetlands.

The housing complex would include:  housing buildings, arctic corridors,
dining building,  recreation builaing  and facilities, access roads, parking,
boiler plant,  maintenance/warehouse facilities, sewer plant, and water
treatment plant.  The landing strip and associated facilities include a
landing  strip, terminal building and  a maintenance building.  A north-south
and east-west runway would be constructed.  A total of approximately 90,000
cy of fill  would  be placed in wetlands for the landing strip.

Access to the housing complex would be provided by a one-half mile road from
the main haul  road.  Another road approximately one-quarter mile in length
would connect the main haul road to the landing strip.  Another short road
would be constructed from the housing area north to the sewage treatment
plant.

The roads would be  all weather roads  suitable for bus traffic and light
vehicle  use.   Sufficient parking would be  provided.  In order to control
dust, access  roads  would be watered on a periodic basis.

During construction of the housing facilities, a series of diversion ditches
and a sediment pond would be constructed.  These ditches and ponds would
serve to control  runoff from the site and  retain sediment.  In order to
control  wildlife  in the area,  protection measures woulc be taken with trash
and garbage in the  area.  Trash and garbage would be incinerated or disposed
of in dumpsters.  The dumpsters would be enclosed to prevent wildlife access.

The sites would be  landscaped  with grasses, shrubs, anc trees native to this
part of Alaska.  The landscaping would serve to minimize erosion and
sediment while being aesthetically pleasing.

6.  MINE FACILITY ^DIAMOND ALASKA COAL COMPANY  APPLICANT  2-850261» Cook
Inlet 332):Fhe mine unit is  approximately 10,000 acrss althoughthe actual
area to be  mined would be 5240 acres in size.   This arga would be divided
into north  and  south pits which would be mined simultaneously but in
separate operations  during the life of the project.  A maximum of 450 acres
of pit would be open at any one time.   An additional  maximum of 150 acres
around the  pit would be disturbed at any one time in  clearing and grubbing
the vegetation  in preparation  for stripping overburden, or recontouring in
preparation for revegetation.   Average pit depth would be approximately 200
feet.
                                      8

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 The  mine  araa would  disturb  approximately  1086  acres of wetlands, while
 sediment  ponas,  naul  roads,  facilities,  and  overburden stockpiles would
 aisturo an  acaitional  approximately  3  acres  of  wetlands.

 M  system  of sediment  ponds and collection  ditches would be constructed to
 ensure that discharges from  drainage alterations and runoff into the pit
 meet applicable  water quality standards.   Where other treatment was
 necessary before discharge,  e.g. flocculation,  additional treatment
 facilities  would be built in conjunction with the sediment ponds.

 At the start  of  operations,  22 million cubic yards of overburden from the
 initial cut would be  excavated and placed  in a  permanent stockpile.  This
 stockpile would  be stabilized, graded  and  then  revegetated to prevent  "
 erosion.

 The  permanent  mine service area would  be located on the southern edge of the
 mining limit.  This area would include the main administration building; a
 service building housing the maintenance,  warehouse and service facilities;
 equipment ready  lines; water, diesel fuel, gasoline and lubricant storage;
 electrical  substation; ambulance and fire  station; water and sewage
 treatment plants; emergency power system;  explosives magazine; heliport; and
 emergency and  safety facilities.  The coal would be crushed in the mine
 serveie area and loaded to the conveyor for transport to the port.  The coal
would not be washed or otherwise processed.

 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 ACT CERTIFICATE:   Section 307(c}(3) of the Coastal
ZoneManagement  Act of 1972, as amenaed 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:  Public hearings were held on this  project on August 17,
1988 in Anchorage, Alaska and on August 18, 1988 in lyonek, Alaska.   No
additional public hearings have been scheduled.  Any person may request,
 in writing, within the comment period of this public notice,  that an
additional public hearing be heldto consider this  application.  Requests
 shall state, with particularity, the reasons for holding another hearing.

CULTURAL RESOURCES:   A cultural resources  study has been done in the area.
If has been determined and coordinated with the State Historic Preservation
Officer that there would  be no effect on cultural  resources.

ENDANGERED SPECIES:   The  project area is within the known or historic range
of the Peregrine Falcon.   However no nest sites have been located and no
impact is  expected to occur.

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F£^£'
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(X) Discharge dredged or fill material into waters of the United States -
Section 404, Clean Water Act (33 U.S.C. 1344).  Therefore, our public
interest review will consider the guidelines set forth under Section 404(b)
of the Clean Water Act (40 CFR 230).

Comments on the described work, with the reference number, should reach this
office no later than the expiration date of this Public Notice to become part
of the record and be considered in the decision.  If further information is
desired concerning this notice, contact Ms. Carol Gorbics at (907)  753-2724.
                                   District Engineer
                                   U.S. Army, Corps of Engineers
Attachments
                                      11

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If you would like a copy of the Environmental Impact Statement,  please fill
this out and return to the address listed below.
    NAME:
    MAILING ADDRESS:

             I would like a copy of the Final EIS for the Diamond AK Coal Project
SEND to:  Mr. Rick Seaborne
          U.S. Environmental Protection Agency - EEB
          1200 Sixth Avenue, WD 136
          Seattle, Washington 98101

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)  "*X.»  . • Tft^"1  -  v •.""• "   *    "'t;  '."vr f- •
*"*;" 
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s.-.^^ TSSK^S^ j  ,i ;
 Hags;-laSsA:?
                                                      requirements for port facilities Including all
                                                 pads, roads, and coal stock piles  - 3,3SO,000 yd3
                                                             —	—  TfOMfK N*?!W UMNB9 KUKMKT
                                                                     «WK3t OtSCHMOC PPt
                                                                     SEDIMENT TONO LOCATION
                                                                     COW. STOCXP'Lf
                                                                     LIMIT OF ELEV4TEO 400BEGATE

                                                        Map     Coal Port Facilities
                                                        Granite Point

                                                        Diamond Chultna Project
                                                        Kenai Peninsula Borough
                                                        Sheet 2 of 15

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                                 O    10   20
                                     SCALE IN MILES
                                        FUTURE PUBLIC DOCK

                                        EXISTING SHOMELIN!

                                        MEAN HIGH WATER LINK

                                        MEAN LOW WATER LINE



                              TRISTLI CONVEYOR TO BARGE DOCK
                                        COAL COLLIER
   PLAN VIEW
  ~™5iS
500  1000
  1": 1OOO*
2000
MAP
PROPOSED COAL LOADING
FACILITY AT LADD

XENAI PENINSULA 3OAOUQM
STATI OF ALASKA
APPLICATION BY:   TtOCWATER
SERVICES CORPORATION
     '4 OF 15           DATE: 5/87

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U.S. S«rv*y No. 4879,Lot  2

U.S., Siiv«y Mo. 127*
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                                                      ALASKA
                    Vicinity Map
                    •     •
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                   SCALE IN MILES
                                                            4O
                                    U.S. Survoy No. 4879,Lot 1
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                            Unloadlnt

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SI-EET sQF  15         DATE: 5/87

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                          r
                     vU!
STiVE COWPBt GOVERNOR
DEPT. OF ENVIRONMENTAL CONSERVATION   /      mmw** ann 465-2600
                                                     I       Address:


                                                            P.O. BOX 0
                                                            Juneau, AK 99811-1800
                           NOTICE OF APPLICATION
                                    FOR
                      STATE WATER QUALITY CERTIFICATION
 Any applicant for a Federal license or  permit  to  conduct  any  activity which
 may result in any discharge into  the  navigable waters must first  apply  for
 and obtain certification from the Alaska Department of Environmental  Conser-
 vation that any such discharge will comply with the Clean Water  Act  of 1977
 (PL 95-217),  the Alaska Water Quality Standards and  other  applicable State
 laws.   By Agreement between the U.S. Army Corps of Engineers  and the Alaska
 Department of Environmental  Conservation application for a Department of the
 Army Permit may  also  serve  a*  application  for State Water  Quality Certifica-
 tion when such certification is necessary.

 Notice is hereby given that the application for a Department of the Army Per-
 mit described in the Corps of Engineers  Public Notice No.2-850259, 2-850260 & 2-8502
 also serves as  application for State Water  Quality Certif1catToti from  the
 Alaska Department of Environmental Conservation, as provided  in  Section  401
 of the Clean  Water Act of 1977  (PL 95-217).

 The Department will review the proposed activity to insure that any discharge
 to waters of  the United States resulting from the referenced project will
 comply with the  Clean Water Act of 1977 (PL 95-217) the Alaska Water Quality
 Standards and other applicable State laws.

 Any person desiring  to comment on the water  quality impacts of the proposed
 project may do so by writing to:

                   Alaska Department of Environmental Conservation
                    3601  C Street,  Suite 1350
                   Anchorage,  Alaska  99503
                   Telephone:   563-6529


 within 30 days of publication  of this notice.

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              OFFICE OF THE GOVERNOR

              OFF/C£ OF MANAGEMENT AND BUDGET
          DIVISION OF GOVERNMENTAL COORDINA TtQN
                                                    STEVE COWPSR, GOVERNOR
CENTRAL OPRCE

P.O. BOX 4W
JUN£AU, 4t4S*4
PHONE (90?) 4«S-3S62
                          STATE OF ALASKA

               DIVISION OP GOVERNMENTAL  COORDINATION

                     Notice of Application  for
               Certification of Consistency with the
                 Alaska Coastal Management  Program
 Notice is hereby given that a request  is  being  filed with the
 Division of Governmental Coordination  for concurrence,  as provid-
 ed  in Section 307 (c)(3) of the Coastal Zone Management Act of
 1972,  as amended [P.L.  94-370? 90 Stat. 1013? 16  U.S.C. 1456
 (c) (3)] , that the project described in the Corps  of Engineers
 Public Notice No.   SEE BELOW , will comply with  the  Alaska Coastal
 Management Program and that the project will be conducted in a
 manner consistent with that program.

 Any person desiring to present views pertain-Ing to  the  project's
 compliance or consistency with the Alaska Coastal Management
 Program may do so by providing his views  in i.Titing to  the
 Division of Governmental Coordination, Office of  Management and
 Budget,  Pouch AW, Juneau, AK 99811, within 3t days  of publication
 of this notice.

 Attachment 2
2-850259, 2-850260 and 2-850261

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                                  APPENDIX  C
                                                            DRAFT
               EVALUATION OF THE DISCHARGE OF DREDG1D AND FILL
           MATERIAL IN ACCORDANCE WITH  SECTION 404(B)(D GUIDELINES
                             SUBPART A - GENERAL

Dredged and fill material should not be discharged into the aquatic
ecosystem unless it can be demonstrated that such a discharge 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,

A permit for the discharge of dredged or fill material from the Corps of
Engineers (Corps), Alaska District, is required under Section 404 of the
Clean Water Act.  The Corps approves discharges at particular sites through
application of the 404(b)(l) guidelines and a public interest review. EPA
reviews the permit application and provides comments to the Corps.   The
Corps, in applying the 404(b)(l) guidelines, must determine the potential
short-term or long-term effects of the proposed discharge on the physical,
chemical, and biological components of the aquatic environment.

                  SUBPART B  - COMPLIANCE WITH THE GUIDELINES

The proposed Diamond Chuitna Coal Project would involve discharge of fill
material into special aquatic habitats for mine development and for
construction of mine site facilities.  The proposed project and alternatives
evaluated for impact analysis are discussed in Chapters two and three of the
final EIS.  There are no project development alternatives which achieve  the
project purpose that do not involve discharge of fill material into waters
of the United States.

In addition to being evaluated under the 404(b)(l)  guidelines,  the  discharge
of fill material will have to be certified as being in compliance with state
water quality and toxic effluent standards pursuant to Section 307  of the
Clean Water Act (40 CFR 219).   No threatened or endangered species,  critical
habitat areas or marine sanctuary would be impacted by the proposed project
as discussed in chapter four of the final EIS.

As determined in Subparts C through G of this evaluation and as  discussed in
chapter five of the final EIS,  the proposed project or any of the action
alternatives, would contribute to adverse impacts on waters of the  United
States including adverse effects on life stages of  organisms dependent on
the aquatic ecosystem, ecosystem diversity,  productivity and stability,  and
recreational, aesthetic, and economic values.

Pertinent information about primary,  secondary and  cumulative impacts of the
proposed project and alternatives related to alterations of:   substrate;
water circulation, fluctuation and salinity; turbidity/suspended
particulates; structure and function of aquatic ecosystems and organisms,  is
contained in chapter five of the final EIS.   In addition,  discussions of
water quality impacts within the mixing zone of the discharge area  is also
found in Chapter five of the final EIS.

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                            SUBPARTS C -THROUGH f
DRAFT
Potential impacts on the physical  and chemical characteristics of the
aquatic ecosystem, biological  characteristics of the aquatic ecosystem,
special aquatic sites and human  use characteristics are found in chapter
five of the final EIS.
                                 SUBPART G

The source and type of discharge material that would be used to develop the
proposed project or any of the  alternatives is described in chapters two and
four of the final IIS.  Gravel  fill that would be used to construct roads
and other facilities would be very unlikely to be contaminated or contain
natural toxic substances;  therefore, testing of gravel fill material would
not be necessary.  The chemical characteristics of mine overburden that
would be excavated and then replaced in the mine pit has been examined in
detail in project baseline studies and summarized in Section 4.3.1.4 of the
final EIS.  Mine overburden would be unlikely to contain toxic materials.
Nevertheless, continued monitoring of overburden chemistry, especially that
portion of the overburden  to be replaced on the ground surface during
reclamation would be conducted  during mine operation.
                                 SUBPART H
Appropriate and practical steps have been identified in Chapters two and six
which would minimize potential adverse impacts of the discharge on the
aquatic ecosystem.   Many of  the mitigative measures which avoid or reduce
project impacts have been incorporated into each action alternative.
Additional mitigative measures will be required as part of the Corps
permit.  With the addition of appropriate mitigation measures, many of which
are discussed in the final EIS, the discharge of dredged or fill material in
association with the development of this project would not cause significant
degradation of the waters of the United States.

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	Appendix D
Proposed Final NPDES Permits

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                       APPENDIX D
              PROPOSED FINAL NPDES  PERMITS
This  appendix contains  the  four  NPDES  permits which  EPA
proposes  to  issue  for  the Diamond  Chuitna Coal  Project.
Written comments received during the public review period for
the draft NPDES  permits  are included  within comment letters
from the Alaska Division  of Governmental Coordination and the
Trustees for  Alaska,  located in Chapter  10.0 of this final
EIS.  The responses to draft EIS comments.  As  a result of
EPA's  review  of the  permit-related  comments,  appropriate
revisions were  made  to  the draft  NPDES  permits.    These
revisions are noted  in  the responses  to comments  and  are
reflected in  the  following proposed  final NPDES  permits.
These proposed final NPDES permits are subject to  final review
and  certification  by the  State  of  Alaska Department  of
Environmental  Conservation pursuant to  Section  401  of  the
Clean Water Act and a  review and determination of consistency
with the  approved Alaska Coastal Management Program by  the
State of Alaska,  Office of Management and  Budget, Division of
Governmental Coordination.

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                                            Permit  No.:  AK-004357-5
                                            Application No.:  AK-004357-5


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


                     AUTHORIZATION TO DISCHARGE UNDER THE

                NATIONAL POLLUTANT  DISCHARGE ELIMINATION SYSTEM


      In compliance with the provisions of the Clean Water Act,
33 U.S.C.  §1251  et seq.. as amended by the Water Quality Act of 1987,
P.L. 100-4,  the  "Act",

                          DIAMOND ALASKA COAL COMPANY
                            (Diamond  Chuitna Mine)

is authorized  to discharge from a facility located near the village of Tyonek,
Alaska,  to receiving waters named Lone Creek and Chuitna River, and unnamed
tributaries  to the Chuitna River, in accordance with discharge points,
effluent limitations, monitoring requirements and other conditions set forth
herein.

      This permit shall become effective

      This permit and the authorization to discharge shall  expire at midnight,
Signed  this       day of
                                          DRAFT
                                 Director, Water Division, Region 10
                                 U.S. Environmental Protection  Agency

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                                                   Page 2 of 20
                                                   Permit No.:   AK-004357-5
                                TABLE OF CONTENTS

 Cover  Sheet—Issuance  and  Expiration  Dates

 I.     Effluent  Limitations  and Monitoring Requirements

       A.   Specific  Limitations and Monitoring  Requirements
       B.   Other Permit  Requirements
       C.   Definitions

 II.    Monitoring, Recording and Reporting Requirements

       A,   Representative Sampling
       B.   Monitoring  Procedures
       C.   Reporting of  Monitoring Results
       D.   Additional Monitoring by the Permittee
       E.   Records Contents
       F,   Retention of  Records
       G.   Twenty-four Hour Notice of Noncompllance Reporting
       H.   Other Noncompllance Reporting
       I.   Inspection and Entry

 III.   Compliance Responsibll1 ties

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

 IV.    General Requirements

       A.   Changes in Discharge of Toxic Substances
       B.   Planned Changes
       C.   Anticipated Noncompliance
       D.   Permit Actions
       E.   Duty to Reapply
       F.   Duty to Provide Information
       G.   Other Information
       H.   Signatory Requirements
       I.   Availability of Reports
       J.   Oil  and Hazardous Substance Liability
       K.   Property Rights
       L.   Severability
       M.   Transfers
       N.   State Laws

Attachment A:  40 CFR 125,  Subpart K,  §125.104(a) and 

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                                                 Page 3 of 20
                                                 Permit No.:  AK-004357-5

I.     EFFLUENT  LIMITATIONS AND MONITORING REQUIREMENTS

      A.    Spec 1f i c Li mltat1ons and Mon1 tor ing Regu1rements.

           During the term of this permit, the permittee is authorized to
           discharge from outfall numbers 001-018, in accordance with the
           limitations and requirements specified below.

           1.   Effluent Limitations During Baseflow Conditions

               a.   Discharges from outfalls 001-018 shall comply with the
                    following limitations and monitoring requirements during
                    baseflow conditions:
      Effluent
      Characteristics
 Effluent Limitations
Avg. Monthly Max. Daily
Monitoring Requirements
Frequency  Sample Type
     Total Iron
     Total Suspended     35.0 mg/1
       Solids (TSS)
     Settleable Solids
       (SS>, ml/1
     Turbidity, NTU
     Receiving Stream
       Turbidity, NTU
       -Upstream of
        Outfall
       -500 feet down-
        stream of outfall
     pH                  Not less
                         standard
                         than 8.5
     Effluent Flow (mgd)
     Receiving Stream
       Flow (cfs)
     Boron
     Nickel
     Manganese
     Ammonia (nitrogen)
     Zinc
              1.0 mg/1
             70.0 mg/1
         than 6.5
         units, nor greater
         standard units.
weekly
weekly

weekly

weekly



weekly

weekly
weekly
                           weekly
                           weekly

                           monthly
                           monthly
                           monthly
                           monthly
                           monthly
grab
grab

grab

grab



grab

grab
grab
           instantaneous
           instantaneous

           grab
           grab
           grab
           grab
           grab
     There shall be no discharge of floating solids,  visible  foam or oil  and
     grease which causes a sheen on the surface  of the  receiving  water.

               b.   Discharges from outfalls 017 and  018  shall  also comply
                    with the following limitations and  monitoring
                    requirements, during baseflow conditions:
     Effluent
     Characteristics
Effluent Limitations
Avg. Monthly Max. Daily
MonJtoring Requ1rements
Frequency  Sample Type
     Total Hydrocarbons*   —         0.015 mg/1     weekly      grab

     *Total Hydrocarbons shall  be measured by Standard  Method  503(6).
                                  P^  ^ ff5""/-'
                                  RAF i

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                                            Page 4 of 20
                                            Permit No.:  AK-004357-5

     2.   Effluent Limitations During Precipitation Events (Alternate
          Limitations)

          a.   Any discharge (or increase in the volume of a discharge)
               from outfalls 001 - 018 caused by precipitation within
               any 24-hour period less than or equal to 5,10 Inches (or
               snowmelt of equivalent depth) shall comply with the
               following limitations and monitoring requirements:
Effluent
Characterlsties
            Effluent Limitations
                Max. Daily
                         N/A
                                           Monitoring Requirements
                                           Frequency  Sample Type
                                     weekly*
Effluent Flow (mgd)
Receiving Stream
  Flow (cfs)             N/A               weekly*
SS                      0.5 ml/1           dally
pH                not less than 6.5        daily
                  standard units, nor greater
                  than 8.5 standard units
TSS               N/A                      weekly*
Oil and Grease    N/A                      weekly*
Total Iron        N/A                      weekly*
                         Instantaneous

                         instantaneous
                         grab
                         grab
                                                      grab
                                                      grab
                                                      grab
C* These parameters shall be measured at least once during a precipitation
event when these alternate limitations apply.]

There shall be no discharge of floating-solids, visible foam or oil and
grease which causes a sheen on the surface of the receiving water.

          b.  Any discharge (or increase in the volume of a discharge)
              from outfalls 001 - 018 caused by precipitation within any
              24-hour period greater than 5.10 Inches (or snowmelt of
              equivalent depth) shall comply with the following
              limitations and monitoring requirements:
Effluent
Characteristics

Effluent Flow (mgd)
Receiving Stream
  Flow (cfs)
pH
              Effluent Limitations
                 Max.  Daily
TSS
SS
Total
Iron
                         N/A

                         N/A
                    not less
                    standard
                    than 8.5
                         N/A
                         N/A
                         N/A
              Monitoring Requirements
              Frequency  Sample Type

              weekly*    instantaneous
              weekly*
than 6.5      dally
units, nor greater
standard units.
              weekly*
              weekly*
              weekly*
                                                instantaneous
                                                grab
grab
grab
grab
[* These parameters shall  be measured at least once during a
precipitation event when these alternate effluent limitations  apply.]
There shall^be no discharge of floating solids
and grease which causes a sheen on the surface
water.
                                          visible  foam  or  oi1
                                         of the  receiving

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                                  Page  5  of 20
                                  Permit  No.:   AK-004357-5

c.    The alternate precipitation  limitations and  monitoring
     requirements in Parts  I.A.2.a.  or  b.  begin when  a
     discharge (or an increase  in the volume of a discharge)
     is caused by precipitation  (or  snowmelt of equivalent
     depth),  and shall  continue at each outfall following
     cessation of the precipitation  event  for the following
     time periods.  After  this  time  period elapses,  the
     baseflow condition (Part I.A.I.) apply unless another
     precipitation event causes a discharge (or an  increase
     discharge) from the sedimentation  ponds.
                             In
          Outfall  Number

                001
                002
                003
                004
                005
                006
                007
                008
                009
                010
                Oil
                012
                013
                014
                015
                016
                017
                018
Time Period(days)

       1
       1
       1
       1
       2
       2
       2
       2
       2
       2
       2
       2
       2
       2
       2
       2
       2
       2
     For  the  purpose of  this  part of the permit, the  term
     "cessation of  the precipitation event" is defined  as when
     the  discharge  flow  rate  decreases to the flow rate
     preceedlng the start of  the precipitation event.
    The  permittee has  the burden of proof to show that
    discharge  (or increase  in discharge) resulted from
    precipitation event.
                         the

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                                            Page 6 of 20
                                            Permit No.:   AK-004357-5

B,   Other Permit Requirements.

     1.   Watershed Monitoring Program

          A monitoring program shall be established In order to define
          relationships between soil type, vegetation, and precipitation
          runoff, and the rate and quality of discharge from settling
          ponds for the four seasons of the year.  The resulting
          watershed hydrographs should provide documentation for
          determining the "time of concentration" of the area
          contributing runoff to the sedimentation pond.  The "time of
          concentration" 1s the time It takes for the last of the runoff
          from the hydraulically most remote point in the drainage area
          to reach the inlet of sedimentation pond.  The program shall
          include provisions for monitoring influent to  the
          sedimentation pond and precipitation.

          The permittee shall  submit details of  this program to EPA and
          the Alaska Department of Environmental  Conservation 
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                                       Page 7 of 20
                                       Permit No.:  AK-004357-5

5.   Best Management Practices (BMP) Plan

     Within one year of the effective date of this permit or three
     months before construction begins (whichever date occurs
     first), the permittee shall submit a BMP plan to EPA for
     review and approval.  This plan shall be developed in
     accordance with 40 CFR 125.104 (see Attachment A), and shall
     also consider the BMP for water management presented 1n the
     EPA "Development Document for Effluent Limitations and
     Standards for the Coal Mining Point Source Category" (EPA
     440/1-82/057, October 1982, pages 362, 367-376).

     The BMP plan, upon approval shall become part of this permit.
     A copy of the BMP plan shall be kept at the facility.

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

     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 waters of the
     United States and the specific objectives and requirements of
     the BMP plan, the permit and/or the BMP program shall be
     subject to modification to incorporate revised BMP
     requirements.

6,   Mixing Zones

     The mixing zones for outfalls 001  to 018 for meeting the
     Alaska Water Quality Standards for turbidity are as follows:

          The downstream  edge of the mixing zone shall  not exceed
          500 feet from the outfal1.

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                                            Page 8 of 20
                                            Permit No.:  AK-004357-5
C.   Definitions.
     1.   "Average monthly discharge limitation" means the highest
          allowable average of "daily discharges" over a calendar month,
          calculated as the sum of all  "daily discharges" measured
          during a calendar month divided by the number of "daily
          discharges" measured during that month.

     2.   "Baseflow Conditions" refers  to the sustained flow of water in
          rivers and streams resulting  primarily from groundwater
          seepage Into the water courses.

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

     4.   "Daily discharge" means the discharge of a pollutant measured
          during a calendar day or any  24-hour  period that reasonably
          represents the calendar day for purposes of sampling.   For
          pollutants with limitations expressed In units  of mass,  the
          "daily discharge" Is calculated as the total  mass of the
          pollutant discharged over the day.  For pollutants with
          limitations expressed in other  units  of measurement,  the
          "dally discharge" is calculated as the average  measurement of
          the pollutant over the day.

     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.   "Maximum dally discharge limitation"  means the  highest
          allowable "daily discharge."

     7.   "Precipitation Event" includes  any period  of  time for  which
          there  has been measurable precipitation,  and  periods of
          snowmelt (occurring  at any time there is  snow on  the ground
          within the watershed and the  temperature  is above OeC).

     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.

     9.    A  "24-hour composite"  sample  shall  mean  a  flow-proportioned
          mixture of not less  than  8  discrete aliquots.   Each aliquot
          shall  be a grab sample of not less  than  100 ml  and  shall be
          collected and  stored in  accordance  with procedures  prescribed
          in  the most recent edition of Standard  Methods  for  the
          Examination of Mater and  Mastewater.

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

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                                                  Page  9 of 20
                                                  Permit No.:   AK-004357-5

II.    MONITORING,  RECORDING AND REPORTING REQUIREMENTS

      A.    Rgpns en tat 1 ve  Samp 1.1ng.   Samples  taken 1n compliance  with  the
           monitoring  requirements established  under Part I shall  be collected
           from the  effluent stream  prior to  discharge  Into the receiving
           waters.   Samples and measurements  shall  be representative of the
           volume  and  nature of the  monitored discharge.

      B.    Monitoring  Procedures.

           1.    Settleable Solids.   Fill  an Imhoff cone  to the one-liter mark
                with a  thoroughly mixed  sample.   Allow  to settle  undisturbed
                for  45  minutes.  Gently  stir  along  the  Inside  surface  of the
                cone with  a stirring rod.  Allow  to settle undisturbed for 15
                minutes  longer.  Record  the volume  of settled  material  In the
                cone as  mil 11 liters  per  liter.  Where a  separation of
                settleable and  floating  material  occurs,  do not include the
                floating material in the reading.

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

      C.    Reporting of  Honitoring Results.   Monitoring  results shall  be
           summarized each  month on  the  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.H.,
           Signatory Requirements, and submitted  to the  Director, Water
           Division and  the  State agency  at the following  addresses:

      original to:    United  States Environmental  Protection Agency (EPA)
                    Region  10
                    1200  Sixth Avenue,  WD-135
                    Seattle, Washington   98101

      copy  to:       Alaska  Department of  Environmental  Conservation (ADEC)
                    Southcentral Region
                    3601  "C" Street, Suite 1350
                    Anchorage, Alaska   99503
                                        te. »•*» ft.

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                                            Page 10 of 20
                                            Permit No.:  AK-004357-5

0.   AdditionalMonitoring 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.

E,   Records Contents.  Records of monitoring Information shall Include:

     1.   The date, exact place, and time of sampling or measurements;

     2.   The IndlvlduaHs) who performed the sampling or measurements;

     3.   The date(s) analyses were performed;

     4.   The 1nd1 vlduaKs) who performed the analyses;

     5.   The analytical techniques or methods used; and

     6.   The results of such analyses.

F.   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 three years from the date
     of the sample, measurement, report or application.  This period may
     be extended by request of the Director or AOEC at any time.   Data
     collected on-slte,  copies of Discharge Monitoring Reports,  and a
     copy of this NPDES  permit must be maintained on-site during the
     duration of activity at  the permitted location.

G.   Twenty-four Hour Notice  of Noncompllance Reporting.

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

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

          b.   Any unanticipated bypass which exceeds  any effluent
               limitation in  the permit (See  Part III,G.»  Bypass of
               T r e a t me n t Facilities.);

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

          d.   Violation of a maximum  daily discharge  limitation for any
               of the pollutants listed in the permit  to  be  reported
               within 24 hours.
                                    -. ?:•*».  JR
                                    " !

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                                            Page 11 of 20
                                            Permit No.:  AK-004357-5

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

          a.   A description of the noncompliance and Its cause;

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

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

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

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

     4.   Reports shall  be submitted to the addresses in Part II.e..
          Re por t i n g of Mon1 tor1n g ResuIts.

H.   Other Noncomp1i ance Report i ng.   Instances  of noncompliance not
     required to be reported within  24 hours shall  be reported at the
     time that monitoring reports for Part  II.C, are submitted.  The
     reports shall  contain the Information  listed in Part II.G.2.

I.   Inspection and Entry.   The  permittee shall  allow the Director,
     ADEC, or an authorized representative  (including an authorized
     contractor acting as a representative  of the Administrator), upon
     the presentation of credentials and other  documents as may be
     required by law,  to:

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

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

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

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

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                                                  Page 12 of 20
                                                  Permit No.:   AK-004357-5
III.   COMPLIANCE RESPONSIBILITIES
           Duty to Comply.   The permittee must comply with  all  conditions  of
           this permit.   Any permit noncompllance  constitutes  a violation  of
           the 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 and  ADEC  of any planned  changes  in
           the permitted facility  or activity  which may  result in
           noncompllance with permit requirements.

           Penalties for Violations of Permit  Conditions.

           1.    Civil  Penalty,   The Act provides, that any person who  violates
                a  permit condition implementing  Sections 301,  302, 306,  307,
                308, 318, or 405 of the Act  shall be  subject to a  civil
                penalty,  not to exceed $25,000 per  day for  each violation.

           2.    Criminal  Penalties:

                a.    Negligent  Violations.   The  Act provides that  any  person
                     who negligently violates  a  permit condition implementing
                     Sections  301,  302,  306, 307, 308, 318, or  405 of  the  Act
                     shall  be  punished by 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  by  both.

                b.    Knowing Violations.   The  Act provides  that any person who
                     knowingly  violates  a permit condition  Implementing
                     Sections  301,  302,  306, 307, 308, 318, or  405 of  the  Act
                     shall  be punished by a fine of not  less than $5,000 nor
                     more than  $50,000 per day of violation, or by
                     imprisonment  for  not more than 3  years, or by both.

                c.    Knowing  Endangerment.  The Act provides that any  person
                     who knowingly  violates a  permit  condition  implementing
                     Sections 301,  302,  306, 307, 308, 318,  or 405 of  the Act,
                     and who knows  at  that time  that  he thereby places another
                     person  In  Imminent  danger of death or  serious bodily
                     Injury, shall,  upon  conviction,  be subject to a fine of
                     not more than  $250,000 or Imprisonment of not more than
                     15 years, or both.   A person which is an organization
                     shall,  upon conviction of violating this subparagraph, be
                     subject to  a fine of not more than $1,000,000.

               d.    False Statements.    The Act provides that any person who
                     knowingly makes any  false material statement,
                     representation, or  certification  in any application,
                     record, report, plan, or other document filed or  required
                     to be maintained  under this Act or who knowingly
                    falsifies,  tampers  with, or renders inaccurate any
                    monitoring  device  or method required to be maintained
                     under this Act, shall upon conviction,  be  punished by a
                     fine of not more  that $10,000,  or by imprisonment for not
                    more than 2 years, or by both.

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                                            Page 13 of 20
                                            Permit No.:  AK-004357-5

     Except as provided in permit conditions in Part III.G..  Bypass of
     Treatment Facilities and PartIII.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 Activity 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.

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

E.   Proper Operation and Maintenance.  The  permittee shall at all times
     properly operate and maintain all facilities and systems of
     treatment and control (and related appurtenances) which  are
     installed or used by the permittee to achieve compliance with the
     conditions of this permit.  Proper operation and maintenance also
     Includes adequate laboratory controls and appropriate quality
     assurance procedures.  This provision requires the operation of
     back-up or auxiliary facilities or similar systems which are
     Installed by a permittee only when the  operation is 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  materials from entering navigable waters.

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                                            Page 14 of 20
                                            Permit No.:  AtC-004357-5
G.   Bypass of Treatment Fac11i 11es:
     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 1s 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.G..
               Twenty-four Hour Notice of NoncompHance Reporting.

    3.     Prohibition of bypass,

          a.   Bypass is prohibited and the Director or ADEC 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 adequate back-up
                    equipment should  have been installed 1n  the  exercise
                    of reasonable  engineering judgment 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 and ADEC  may approve an  anticipated  bypass,
               after considering its  adverse  effects,  if the  Director
               and ADEC determine  that it will  meet  the three conditions
               listed above in paragraph 3.a.  of this  section.

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                                            Page 15 of
                                            Permit No.:
20
  AK-004357-5
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
          noncomptiance was caused by upset, and before an action for
          noncompllance, 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
               cause(s) of the upset;

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

          c.   The permittee submitted notice of the  upset as required
               under Part II.G.,  Twenty-four Hour Notice
               of Noncompllance Reporting;  and

          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 3Q7(a>  of the
     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.

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                                                  Page 16 of 20
                                                  Permit No.:   AK-004357-5
IV.    GENERAL REQUIREMENTS
      A.    Changes In Discharge of Toxic Substances.   Notification  shall  be
           provided to the Director and ADEC as  soon  as  the permittee  knows
           of,  or has reason  to believe:

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

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

                b.    Two hundred micrograms  per  liter (200 ug/1) for acrolein
                     and acrylonitri1e;  five hundred  micrograms  per  liter (500
                     ug/1)  for 2,4-dlnitrophenol and  for 2-methyl-4,
                     6-d1nitrophenol;  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 1n
                     accordance  with 40  CFR  122.21(g><7>;  or

                d.    The level  established by the  Director in  accordance  with
                     40  CFR 122.44(f).

           2.    That any activity  has occurred or  will occur  which would
                result in any  discharge,  on  a non-routine  or  infrequent basis,
                of  a toxic  pollutant which is not  limited  in  the permit,  If
                that discharge  will exceed the highest of  the  following
                "notification  levels":

                a.    Five hundred  micrograms  per liter (500 ug/1);

                b.    One  milligram per liter  (1  mg/1) for  antimony;

                c.    Ten  (10)  times the  maximum concentration  value reported
                     for  that  pollutant  in the permit application in
                     accordance  with 40  CFR  122.21(g)(7); or

                d.    The  level established by the  Director  in  accordance  with
                     40  CFR 122.44(f).

     B,    Planned  Changes.  The permittee shall  give notice  to the Director
           and ADEC as soon as possible  of any planned physical alterations or
           additions  to  the permitted facility.   Notice  is  required only  when:

           1.    The  alteration or  addition to a permitted  facility may meet
               one  of the  criteria for  determining whether a  facility is a
                new source  as determined  in 40 CFR 122.29(b); or

           2.    The  alteration or  addition could significantly change the
                nature or  Increase  the quantity of pollutants discharged.
                This  notification  applies  to  pollutants which are subject
                neither  to  effluent limitations  in the permit, nor to
                notification requirements  under Part  IV.A.I.


                                             D AS

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                                            Page 17 of 20
                                            Permit No.:  AK-004357-5

C.   An11c 1pated Noncomp 11ance.  The permittee shall also give advance
     notice to the Director and ADEC of any planned changes in the
     permitted facility or activity which may result in noncompHance
     with permit requirements.

D.   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
     noncompHance, does not stay any permit condition.

E.   Duty to Reappjy.  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.

F.   Duty to Provide Information.  The permittee shall  furnish to the
     Director and ADEC, within a reasonable time, any Information which
     the Director or ADEC 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 or ADEC,  upon request,  copies of
     records required to be kept by this permit.

G-   OtherInformation.  Nhen 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 or ADEC, it shall promptly submit such facts or
     information.

H.   Signatory Requirements.   All  applications,  reports or information
     submitted to the Director and ADEC 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 or  ADEC shall be  signed by a  person
          described above  or  by a duly  authorized representative  of that
          person.   A  person  is a duly authorized  representative only if:

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

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                                             Page  18  of 20
                                             Permit No,:  AK-004357-5

           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,  position of equivalent
                responsibility,  or an  individual or position having
                overall responsibility  for environmental matters  for the
                company.   (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.H.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.H.2.  must be submitted to  the Director and
           ADEC  prior to  or together with any reports,  information, or
           applications to  be signed by an authorized representative.

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

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

I.   Aval 1abl11ty  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 Director and ADEC.  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.

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                                            Page 19 of 20
                                            Permit No.:  AK-004357-5

L.   Seyerabj1.1 ty.  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 1n
          the agreement mentioned in paragraph 2 above.

N-   State Laws.  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 established
     pursuant to any applicable state law or regulation under authority
     preserved by Section 510 of  the Act.

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                                                                     Page  20  of  20
                                                                     Permit No.:   AK-004357-5
                                 ATTACHMINf   A
1125.194  Bat management practice* pro.
    BMP  pro«ram«  shall be  devel-
oped  In accordance with good  engi-
neering practices and  with the provi-
sions of this subpart.
  (b) 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 pol-
lutants.
  (i)  Each   facility   component  or
system shall be examined for its po-
tential for causing a release of signifi-
cant amounts  of toxic or hazardous
pollutants  to  waters  of the United
States due to  equipment  failure, im-
proper operation, natural phenomena
such as rain or snowfall, etc.
  (il>  Where experience indicates  a
reasonable  potential  for equipment
failure (e.g..  a  tank overflow  or leak-
age), natural condition (e.g.. precipita-
tion), or other  circumstances to result
in significant amounts of toxic or haz-
ardous  pollutants  reaching  surface
waters,  the program should include a
prediction  of the  direction,  rate  of
flow and total quantity of toxic or haz-
ardous pollutants which could be dis-
charged from the facility as a result of
each condition or circumstance;
  (3) Establish specific best manage-
ment practices  to meet the objectives
identified under  paragraph (bX2)  of
this section, addressing  each compo-
nent or system capable of causing a re-
lease of significant amounts of toxic or
hazardous pollutants to the waters of
the United States;
  (4)  The BMP program:  (i)  May  re-
flect requirements for Spill Prevention
Control  and Countermeasure (SPCC)
plans under section 311 of the Act and
40 CFR Part 151. and may incorporate
any part of such plans into the BMP
program by reference;
           EPA  hat  proposed  section
 31KJX1KO regulations (49 PR 39278) which
 require facilities subject to NPDES to devel-
 op and Implement SPCC plain to prevent
 discharge* of reportable quantities of desig-
 nated hazardous substances. While Subpart
 K requires only procedural activities  and
 minor construction, the proposed 40 CFR
 Fart 1S1 (SPCC regulations) are more strin-
 gent and  comprehensive with respect to
 their requirements for spill prevention. In
 developing BMP  programs in  accordance
 with Subpart K, owners or operators should
 also consider the requirement* of proposed
 40 CFR Part 191 which may address many
 of the same areas of the facility covered by
 this Subpart.]

  (11) Shall assure the proper manage-
 ment of solid and hazardous waste in
 accordance  with regulations promul-
 gated under the Solid Waste Disposal
 Act, as amended by the Resource Con-
 servation and  Recovery Act of 1978
 CRCRA) (40 TJ.S.C. 6901 et seq).  Man-
 agement  practices   required  under
 RCRA regulations shall be expressly
 Incorporated into the BMP program;
 and
  (ill)  Shall  address the  following
 points for the ancillary activities  fn
 § 125.102:
  (A) Statement of policy;
  (B) Spill Control Committee;
  (C) Material inventory;
  (D) Material compatibility;
  (E) Employee training:
  (F) Reporting and notification pro-
cedures;
  (O) Visual inspections;
  (H) Preventive maintenance;
  (I) Housekeeping; and
  < J) Security.

[Comment* Additional technical Informa-
tion on BMPs and the elements of a BMP
program is contained in a publication enti-
tled "NPDES Best Management Practices
Guidance  Document."  Copies may be  ob-
tained by  written  request  to Edward  A.
Kramer (EN-338), Office of  Water Enforce-
ment, Environmental  Protection  Agency,
Washington, DC, 20460.1

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                                   Permit No.:  AK-00468S-0
                                   Application No.:  AK-004685-0
                  United States Environmental  Protection Agency
                                    Region 10
                                1200 Sixth Avenue
                            Seattle, Washington 98101
                      AUTHORIZATION TO DISCHARGE UNDER THE

                 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM


      In compliance with the provisions of the Clean Nater Act,
33 U.S.C. §1251 et seq. . as amended by the Water Quality Act of 1987,
P.L. 100-4, the "Act",

                         TIDEWATER SERVICES CORPORATION
                          (Ladd Coal Loading Facility)
                   Diamond  Shamrock Chultna  Coal  Joint Venture

is authorized to discharge from the Ladd coal loading facility located
near the village of Tyonek, Alaska, to receiving waters named Cook Inlet,
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,
Signed this
                  day of
                                                      f*m
                                                      ?» ;j
                                  Director,  Water Division,  Region  10
                                  U.S.  Environmental  Protection  Agency

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                                                   Page 2 of  18
                                                   Permit No.:  AK-004685-0
                                TABLE OF CONTENTS

Cover Sheet—Issuance  and  Expiration Dates

I.    Effluent  Limitations  and Monitoring Requirements

      A.   Specific Limitations and Monitoring Requirements
      B.   Other Permit Requirements
      C.   Definitions

II.   Monitoring, Recording and Reporting Requirements

      A.   Representative Sampling
      B,   Monitoring Procedures
      C.   Reporting of Monitoring Results
      D.   Additional Monitoring by the Permittee
      E.   Records Contents
      F,   Retention of Records
      G.   Twenty-four Hour Notice of Noncompllance Reporting
      H.   Other Noncompliance Reporting
      I.   Inspection and Entry

III.  Compliance Responsibilities

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

IV.   General Requirements

      A.   Changes in Discharge of Toxic Substances
      B.   Planned Changes
      C.   Anticipated Noncompliance
      D.   Permit Actions
      E.   Duty to Reapply
      F.   Duty to Provide Information
      G.   Other Information
      H.   Signatory Requirements
      I.   Availability of Reports
      J.   011  and Hazardous Substance Liability
      K.   Property Rights
      L.   Severability
      M.   Transfers
      N.   State Laws

Attachment A:  40 CFR 125,  Subpart K,  §125.104(a)  and  (b)

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                                               Page 3 of  18
                                               Permit No.:  AK-Q04685-0

   EFFLUENT  LIMITATIONS AND MONITORING  REQUIREMENTS

   A.    Specific  Li'mitations and Monitoring Requirements.

        During  the effective term of this permit, the permittee  is
        authorized to discharge from outfall 001 (sediment pond)  in
        accordance with the following:

        1,   Baseflow Conditions

            Discharges shall comply with the following limitations
            and monitoring requirements during baseflow conditions:

   Effluent           Effluent Limitations       Mon1 toring Requ irement s
   Characteristics   Avg. Monthly Max. Dai1y    Frequency   Sample Type

Total Hydrocarbons*   —          0.015 mg/1    weekly      grab
Total Iron           3.0 mg/1      6.0 mg/1      weekly      grab
Total Suspended      35.0 mg/1     70.0 mg/1      weekly      grab
   Solids (TSS)
Settleable Solids     —           —          weekly      grab
   (SS)
pH                  Not less than 6.0          weekly      grab
                     standard units, nor greater
                    than 9.0 standard units
Effluent Flow (mgd)   —           —           weekly      instantaneous
Receiving Stream     —           —           weekly      instantaneous
   Flow (cfs)

There shall  be no discharge of floating solids, visible foam or oil and
grease which causes  a sheen on the surface  of the  receiving water.

*Total Hydrocarbons  shall  be measured by Standard  Method  503CB).

       2,   Precipitation  Events  (Alternate Limitations)

            a.   Any  discharge  or  increase in  the volume of a discharge
                caused  by  precipitation within  any 24-hour period less
                than or equal  to  5.10 inches  (or snowmelt of equivalent
                depth)  shall  comply with the  following  limitations and
                monitoring requirements:

  Effluent            Effluent Li mi tatigns    Mon i toring Requi rements
  Characteristics       Maximum Daily        Frequency  Sample Type

  Effluent Flow (mgd)      N/A               weekly*     instantaneous
  Receiving  Stream
    Flow (cfs)              N/A               weekly*    instantaneous
  SS                    0.5 ml/1             weekly     grab
  pH                  Not  less  than  6.0      weekly     grab
                      standard  units, nor greater
                      than 9.0  standard units.

  There  shall  be  no  discharge  of  floating solids,  visible  foam or oil  and
  grease which  causes a sheen  on  the  surface  of the receiving  water.

  [* Flow shall  be measured at  least  once during the  period when the
  alternate  limitations  apply.]

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                                            Page 4 of  18
                                            Permit No.:  AK-004685-0
          b.   Any discharge or Increase  in the volume of a discharge
               caused by precipitation within any 24-hour period greater
               than 5.10 Inches (or snowmelt of equivalent depth)  shall
               comply with the following  limitations and monitoring
               requirements:
Effluent
Characteristics

Effluent Flow (mgd)
Receiving Stream
  Flow (cfs)
PH
Effluent Limitations
  Maximum Dai 1y

     N/A
     N/A
Not less than 6.0
standard units, nor
greater than 9.0
standard units.
Monitoring Requirements
Frequency  Sample Type
weekly*

weekly*
weekly
Instantaneous

Instantaneous
grab
There shall be no discharge of floating solids, visible foam or oil and
grease which causes a sheen on the surface of the receiving water.

C* Flow shall be measured at least once during the per-1od when the
alternate limitations apply.]

          c.   The alternate precipitation limitations and monitoring
               requirements In Parts I.A.2.a. or b. begin when a
               discharge (or an increase in the volume of a discharge)
               is caused by precipitation (or snowmelt of equivalent
               depth), and shall  continue two days following cessation
               of the precipitation event.

               For the purpose of this part of the permit, the term
               "cessation of the  precipitation event" is defined as when
               the discharge flow rate decreases to the flow rate
               preceeding the start of the precipitation event.

               The permittee has  the burden of proof to show that the
               discharge (or Increase in discharge) resulted from a
               precipitation event.

B.   Other Permit Requirements.

     1.    Watershed Monitoring Program

          A monitoring program shall  be established in order to define
          relationships between soil  type, vegetation, and precipitation
          runoff, and the rate and quality of discharge from settling
          ponds for the four seasons of the year.   The resulting
          watershed hydrographs should provide documentation for
          determining the "time of concentration"  of the area
          contributing runoff to  the sedimentation pond.  The "time of
          concentration" is the time it takes for  the last of the runoff
          from the hydraullcally  most remote point in the drainage area
          to reach the inlet of sedimentation pond.   The program shall
          include provisions for  monitoring influent to the
          sedimentation pond and  precipitation.

          The permittee shall  submit details of this program to EPA and
          the Alaska Department of Environmental Conservation (ADEC) for
          review and approval  within 90 days of the effective date of
          this permit.           .-•• »• vf%  & f-V

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                                       Page  5 of  18
                                       Permit No.:  AK-004685-0
     Precipitation Monitoring  Program
     The permittee shall  keep a  record of all precipitation events.
     This record shall  Include as  a  minimum dates, time, and
     precipitation amounts  for each  precipitation event.  A copy of
     this record shall  be submitted  with the monthly discharge
     monitoring reports (DMR) see  Part II.C.

3.   Sanitary Haste

     The discharge of sanitary waste from the Ladd Coal Loading
     Facility to any waters of the United States is not authorized.

4.   Use of Chemicals,  Detergents, Solvents or Degreasers

     Hithin six months  of the effective date of this permit, the
     permittee shall  submit to EPA and ADEC for review and approval
     a list of chemicals, detergents, solvents or degreasers that
     are used to wash down equipment or are used in the maintenance
     shops  which may enter the sedimentation ponds through runoff.

5.   Best Management Practices (BMP) Plan

     Within one year of the effective date of this permit or three
     months before construction  begins (whichever date occurs
     first),  the permittee shall submit a BMP plan to EPA for review
     and approval.   This  plan  shall be developed in accordance with
     40 CFR 125.104 (see  Attachment A), and shall  also consider the
     BMP for  water management  presented in the EPA "Development
     Document for Effluent Limitations and Standards for the Coal
     Mining Point Source  Category" (EPA 440/1-82/057,  October 1982,
     pages  362,  367-376).

     The BMP  plan,  upon approval  shall become part of this permit.
     A copy of the  BMP  plan shall be kept at the facility.

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

     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 waters of the
     United States  and  the specific objectives  and requirements of
     the BMP  plan,  the permit and/or the  BMP program shall  be
     subject  to  modification to  incorporate revised BMP requirements.
                DRAFT
DEC     1099

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                                            Page 6 of 18
                                            Permit No.:   AK-004685-0
C.   Definitions.
     1.   "Average monthly discharge limitation" means the highest
          allowable average of "dally discharges" over a calendar month,
          calculated as the sum of all  "dally discharges" measured
          during a calendar month divided by the number of "daily
          discharges" measured during that month.

     2.   "Baseflow Conditions" refers  to the sustained flow of water In
          rivers and streams resulting  primarily from groundwater
          seepage Into the water courses.

     3.   "Bypass" means  the Intentional  diversion of waste streams from
          any portion of  a treatment facility.

     4.   "Daily discharge" means the discharge of a pollutant measured
          during a calendar day or any  24-hour  period that reasonably
          represents the  calendar day for purposes of sampling.   For
          pollutants with limitations expressed in units of mass, the
          "daily discharge" is calculated as the total  mass of the
          pollutant discharged over the day. For pollutants with
          limitations expressed In other  units  of measurement,  the
          "daily discharge" is calculated as the average measurement of
          the pollutant over the day.

     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.   "Maximum daily  discharge limitation"  means the highest
          allowable "daily discharge."

     7.   "Precipitation  Event" includes  any period  of  time for  which
          there  has been  measurable precipitation,  and  periods of
          snowmelt (occurring  at any time there is  snow on  the ground
          within the watershed and the  temperature  is  above 0°C).

     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.

     9.    "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  noncompllance  to the extent  caused  by
          operational  error, improperly designed  treatment  facilities,
          inadequate treatment facilities, lack, of  preventive
          maintenance,  or  careless  or improper  operation.

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                                                  Page 7 of 18
                                                  Permit No.:   AK-004685-0

II.    MONITORING,  RECORDING AND REPORTING REQUIREMENTS

      A.    Representative Sampling.   Samples  taken 1n  compliance  with  the
           monitoring requirements  established  under Part I shall  be  collected
           from the effluent stream prior to  discharge Into the receiving
           waters.   Samples and measurements  shall  be  representative  of the
           volume  and nature of the  monitored discharge.

      B.    Monitoring Procedures.

           1,    Settleable Solids.   Fill  an Imhoff cone  to the  one-liter  mark
                with a thoroughly mixed  sample.   Allow to settle  undisturbed
                for 45 minutes.  Gently  stir  along the inside surface  of  the
                cone with a stirring rod.  Allow  to settle undisturbed for 15
                minutes longer.  Record  the volume of  settled material  in the
                cone as mi 111 liters  per  liter.  Where  a  separation of
                settleable and  floating  material  occurs,  do not include the
                floating material in the  reading.

           2.    Other Parameters.  Monitoring for  other  parameters must be
                conducted according  to test procedures approved under  40  CFR
                Part 136,  unless other test procedures have  been  specified 1n
                this permit.

      C.    Report!ng of Monitoring Results.   Monitoring  results shall  be
           summarized each  month on  the 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  PartIV.H.,
           Signatory Requirements, and submitted  to the Director,  Water
           Division  and  the  State agency at the following  addresses:

      original to:    United  States Environmental Protection Agency (EPA)
                     Region  10
                     1200 Sixth Avenue, WD-135
                     Seattle, Hashington   98101

      copy  to:        Alaska  Department of  Environmental Conservation (ADEC)
                     Southcentral Region
                     3601 "C" Street, Suite 1350
                     Anchorage, Alaska  99503

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                                            Page 8 of 18
                                            Permit No.:  AK-Q04685-0

D.   AdditionalMonitoringby 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.

E.   Records Contents.  Records of monitoring information shall Include:

     1.   The date, exact place, and time of sampling or measurements;

     2.   The IndivlduaHs) who performed the sampling or measurements;

     3,   The date(s) analyses were performed;

     4.   The Indlvidual(s) who performed the analyses;

     5.   The analytical techniques or methods used; and

     6,   The results of such analyses.

F.   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 three years from the date
     of the sample, measurement, report  or application.   This  period may
     be extended by request of the Director or AOEC at any time.   Data
     collected on-s!te,  copies of Discharge Monitoring Reports,  and a
     copy of this NPDES permit must be maintained on-s1te during the
     duration of activity at the permitted location.

G.   Twenty-four Hour Notice  of Noncompllance Reporting.

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

          a.   Any noncompllance which may endanger health or  the
               environment;

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

          c.   Any upset which exceeds any effluent limitation in  the
               permit 
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                                            Page 9 of 18
                                            Permit No.:  AK-004685-0

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

          a.   A description of the noncompliance and Its cause;

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

          c.   The estimated time noncompliance 1s 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 Hater Compliance Section  in Seattle,  Nashington, by phone,
          (206) 442-1213.

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

H.   Other Noncompl1ance Reporting.   Instances  of  noncompliance not
     required to be reported within  24  hours shall  be reported at the
     time that monitoring reports for Part  II.C. are submitted.  The
     reports shall  contain the Information  listed  in Part II.G.2.

I.   Inspection and Entry.  The  permittee shall  allow the Director,
     ADEC, or an authorized  representative  (Including an authorized
     contractor acting as a  representative  of the  Administrator), upon
     the presentation  of credentials and other  documents as  may be
     required by law,  to:

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

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

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

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

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                                                  Page 10 of 18
                                                  Permit No.:   AK-004685-0
III.   COMPLIANCE RESPONSIBILITIES
           Dutyto Comp1y.   The permittee  must comply with  all  conditions  of
           this permit.   Any permit noncompHance  constitutes  a violation  of
           the 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  and  ADEC of any planned  changes  in
           the permitted  facility  or activity  which may  result  in
           noncompHance  with permit requirements.

           Penalties for  Violations of Permit  Conditions.

           1,    Civil Penalty.   The Act provides that any person who  violates
                a  permit  condition Implementing Sections 301, 302, 306,  307,
                308, 318, or 405 of the Act  shall  be  subject to a  civil
                penalty,  not to exceed $25,000 per  day for  each violation.

           2.    Criminal  Penalties:

                a.    Negligent  Violations.   The Act provides that  any person
                     who  negligently violates  a permit condition implementing
                     Sections 301,  302,  306, 307,  308, 318, or  405 of the  Act
                     shall  be punished by  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  by  both.

                b.    Knowing  Violations.   The  Act provides  that any person who
                     knowingly  violates  a  permit condition  implementing
                     Sections 301,  302,  306, 307, 308, 318, or  405 of the  Act
                     shall  be punished  by  a  fine of not  less than  $5,000 nor
                     more than  $50,000 per day of violation, or by
                     Imprisonment  for  not more than 3  years, or by both.

                c.    Knowing  Endangerment.   The Act provides that any person
                     who knowingly  violates  a  permit  condition  implementing
                     Sections 301,  302,  306, 307, 308, 318,  or  405 of the Act,
                     and who  knows  at  that time that  he thereby places another
                     person  i-n  imminent  danger of death or  serious bodily
                     Injury,  shall,  upon conviction,  be subject to a fine of
                     not more than  $250,000 or imprisonment of  not more than
                     15 years,  or  both.  A person which is an organization
                     shall, upon conviction of violating this subparagraph, be
                     subject  to a  fine of not more  than $1,000,000.

                d.    False  Statements.    The Act provides that any person who
                     knowingly  makes any false material statement,
                     representation, or  certification  in any application,
                     record,  report, plan, or other document filed or required
                     to be maintained  under this Act or who knowingly
                    falsifies, tampers with, or renders inaccurate any
                    monitoring device  or method required to be maintained
                     under  this Act, shall  upon conviction,  be  punished by a
                    fine of  not more  that $10,000, or by imprisonment for not
                    more than  2 years, or by both.

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                                            Page 11 of 18
                                            Permit No.:   AK-004685-0

     Except as provided in permit conditions in PartIII.G., Bypass of
     Treatment Facilities and Part III.H., Upset Con dIt1ons, nothing  In
     this permit shall be construed to relieve the permittee of the
     civil or criminal penalties for noncompllance.

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

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

E.   ProperOperation 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 also
     Includes adequate laboratory controls  and  appropriate quality
     assurance procedures.   This provision  requires the  operation of
     back-up or auxiliary facilities  or similar systems  which are
     Installed by a permittee only when the  operation is 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  materials from entering navigable waters.

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                                            Page 12 of 18
                                            Permit No.:   AK-004685-0
G.   Bypass of TreatmentFacilities:
     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 1t 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, 1f
               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.G..
               Twenty-four Hour Notice of Noncompllance Reporting.

    3.     Prohibition of bypass.

          a.   Bypass Is prohibited and the  Director or ADEC 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 adequate back-up
                    equipment should have been  installed  in  the  exercise
                    of  reasonable engineering judgment 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 and ADEC may approve  an  anticipated  bypass,
               after considering its adverse  effects,  if  the  Director
               and ADEC determine that it will  meet  the three conditions
               listed above in paragraph 3.a, of this  section.

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                                            Page 13 of 18
                                            Permit  No.:  AK-004685-0
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
              cause(s)  of  the  upset;

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

          c.   The  permittee submitted notice of  the upset as required
              under  Part II.G., Twenty-four Hour Notice
              of  Noncompliance Reporting; and

          d.   The  permittee complied with any remedial  measures
              required  under Part III.P., 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.

    Toxic Pollutants.   The permittee shall  comply with  effluent
    standards or prohibitions established under Section  307(a) of the
    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.

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                                                  Page 14 of 18
                                                  Permit No.:   AK-004685-0
IV.    GENERAL REQUIREMENTS
      A.    Changes  In Discharge of Toxic Substances.   Notification shall  be
           provided to the Director and ADEC as  soon  as  the permittee knows
           of,  or  has reason  to believe:

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

                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-dinltrophenol;  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  in
                     accordance  with 40  CFR  122.21(g)(7);  or

                d.    The level  established by the  Director In accordance  with
                     40  CFR 122.44(f).

           2.    That  any activity  has occurred or  will occur  which  would
                result  in any  discharge,  on  a non-routine  or  Infrequent basis,
                of  a  toxic  pollutant which is not  limited  in  the permit,  if
                that  discharge  will exceed the highest of  the  following
                "notification  levels":

                a.    F!ve hundred  micrograms per liter (500 ug/1);

                b.   One  milligram per liter (1  mg/1) for  antimony;

                c.   Ten  (10)  times the  maximum concentration  value reported
                    for  that  pollutant  in the permit application  in
                    accordance  with 40  CFR  122.21(g)(7); or

                d.   The  level established by the  Director  in  accordance  with
                    40  CFR 122.44(f),

     B.    PIanned Changes.  The permittee shall  give notice  to the Director
           and ADEC as soon as possible  of any planned physical alterations  or
           additions to  the permitted facility.   Notice  is required only  when:

           1.    The alteration or  addition to a  permitted facility may meet
               one of the  criteria for  determining whether a  facility is a
                new source  as determined  in 40 CFR 122.29(b); or

           2.    The alteration or  addition could  significantly change the
                nature or increase the quantity  of pollutants discharged.
                This notification applies  to pollutants which are subject
                neither  to effluent limitations  in the permit, nor to
                notification requirements under  Part IV.A.I.

                                    *»•«•». t-v  ft "»*Si*w?l
                                    '  "'•  -1    -   •

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                                            Page 15 of 18
                                            Permit No.:  AK-004685-0

C.   Antic 1 paired Noncomp1lance.  The permittee shall also give advance
     notice to the Director and ADEC of any planned changes In the
     permitted facility or activity which may result in noncompllance
     with permit requirements.

D.   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
     noncompllance, does not stay any permit condition.

E.   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.

F.   Dutyto Provide Information.  The permittee shall  furnish to the
     Director and ADEC, within a reasonable time, any Information which
     the Director or ADEC 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 or ADEC,  upon request,  copies of
     records required to be kept by this permit.

G.   Other Information.   Nhen 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 or ADEC,  it shall promptly submit such facts or
     information.

H.   Signatory Requirements.   All  applications,  reports or information
     submitted to the Director and  ADEC 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 or  ADEC shall be  signed  by a  person
          described above  or  by a duly  authorized representative  of that
          person.   A  person  is  a duly  authorized  representative only if:

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

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                                        Page 16 of 18
                                        Permit No.:  AK-004685-0

      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, position of equivalent
           responsibility, or an Individual or position having
           overall responsibility for environmental matters for the
           company.  (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.H.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.H.2. must  be submitted to the Director and
      ADEC prior to or together  with any reports, information, or
      applications to be  signed  by an authorized representative.

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

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

 Aval 1ab1l1ty 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 Director and  ADEC.   As
 required by the Act, permit applications,  permits  and effluent  data
 shall not be considered  confidential.

 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.

 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.

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                                       Page 17 of 18
                                       Permit No.:  AK-004685-0

Severabi11ty.  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.

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 1n paragraph 2 above.

State laws.   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 established
pursuant to any applicable state law or regulation under authority
preserved  by Section 510 of the Act.

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                                                                    Page 18  of  18
                                                                    Permit  No.:   AK-004685-0
                                 ATTACHMENT   A
0125.104  Best
practice* pro*
  (a)  BMP  programs  shall be devel-
oped  In accordance with good  engi-
neering practices and  with the provi-
sions of this subpart.
  (b) 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 pol-
lutants.
  (1)  Each   facility   component  or
system shall be examined for its po-
tential for causing a release of signifi-
cant amounts  of toxic or hazardous
pollutants  to  waters  of  the  United
States due to  equipment  failure, im-
proper operation, natural  phenomena
such as rain or snowfall, etc.
  (11)  Where experience  indicates  a
reasonable  potential  for equipment
failure (e.g.,  a  tank overflow  or leak-
age), natural condition (e.g., precipita-
tion), or other  circumstances to result
in significant amounts  of toxic or haz-
ardous  pollutants  reaching  surface
waters, the program should Include a
prediction of  the  direction,  rate of
flow and total quantity of toxic or haz-
ardous pollutants which could be dis-
charged from the facility as a result of
each condition or circumstance;
  (3) Establish specific best manage-
ment practices  to meet the objectives
identified under paragraph (b)(2) of
this section, addressing each compo-
nent or system  capable of causing a re-
lease of significant amounts of toxic or
hazardous pollutants to the waters of
the United States;
  (4)  The BMP program:  (i)  May re-
flect requirements for Spill Prevention
Control  and Countermeasure  (SPCC)
plans under section 311 of the Act and
40 CFR Part 151, and may Incorporate
any part of such plans into the BMP
program by reference;
 (Comment:  EPA  has  proposed  Motion
 31KJK1KO regulations (43 PR 39276) which
 require faculties subject to NPDES to devel-
 op and Implement SPCC plans to prevent
 discharges of reporUble quantities of desig-
 nated hazardous substances. While Subpart
 K  requires only procedural activities and
 minor  construction, the proposed 40 CFR
 Part 191 (SPCC regulations) are more strin-
 gent and  comprehensive with respect to
 their requirements for spill prevention. In
 developing BMP programs In accordance
 with Subpart K. owners or operators should
 also consider the requirements of proposed
 40 CFR Part 151 which may address many
 of the same areas of the facility covered by
 this Subpart.]

  (ii) Shall  assure the proper manage-
 ment of solid and hazardous waste in
 accordance  with regulations promul-
 gated  under the Solid Waste Disposal
 Act. as amended by  the Resource Con-
 servation and Recovery Act of 1976
 (RCRA) (40 U.S.C.  6901  et seq). Man-
 agement  practices   required  under
 RCRA regulations shall be expressly
 incorporated into the BMP program;
 and
  (ill)  Shall  address  the  following
 points for  the ancillary activities  in
 S 125.102:
  (A) Statement of policy;
  (B) Spill Control Committee;
  (C) Material inventory;
  (D) Material compatibility;
  (E) Employee training:
  (F) Reporting and notification  pro-
cedures;
  (O) Visual Inspections;
  (H) Preventive maintenance;
  (I) Housekeeping; and
  (J) Security.

[Comment* Additional technical Informa-
tion on BMPs and the elements of  a BMP
program Is contained in a publication enti-
tled "NPDES Best Management Practices
Guidance  Document."  Copies may be  ob-
tained  by  written  request  to Edward  A.
Kramer (EN-338). Office of Water Enforce-
ment,  Environmental  Protection  Agency,
Washington. DC, 20460.1

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                                                 Permit No.:  AK-004331-1
                                                 Application No.:  AK-004331-


                 United States Environmental Protection Agency
                                   Region  10
                               1200 Sixth  Avenue
                           Seattle,  Nashington 98101


                     AUTHORIZATION TO DISCHARGE UNDER THE

                NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM


     In compliance with the provisions of the Clean  Hater Act,
33 U.S.C.  §1251  et seq.. as amended by the  Water Quality Act of 1987,
P.L.  100-4,  the  "Act",

                         GRANITE  POINT COAL PORT,  INC.
                 (Diamond Shamrock Chuitna Coal Joint Venture)

Is authorized  to discharge from the port  site facility located southwest
of the village of Tyonek, Alaska,  to receiving  waters named Cook  Inlet,
In accordance  with discharge points, effluent limitations,  monitoring
requirements and other conditions  set forth herein.

     This  permit shall become effective

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


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-004331-1
                                TABLE OF CONTENTS

Cover Sheet—Issuance and  Expiration Dates

I.    Effluent Limitations and Monitoring Requirements

      A.   Specific Limitations and Monitoring Requirements
      B.   Other Permit Requirements
      C.   Definitions

II.   Monitoring, Recording and Reporting Requirements

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

III.  Compliance Responsibilities

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

IV.   General Requirements

      A.   Changes In Discharge of Toxic Substances
      B.   Planned Changes
      C.   Anticipated Noncompliance
      D.   Permit Actions
      E.   Duty to Reapply
      F.   Duty to Provide Information
      G.   Other Information
      H,   Signatory Requirements
      I.   Availability of Reports
      J.   Oil  and Hazardous Substance Liability
      K.   Property Rights
      L.   Severability
      M.   Transfers
      N.   State Laws

Attachment A:  40 CFR 125,  Subpart  K.  §125.104(a)  and  (b)

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                                                  Page 3 of 19
                                                  Permit No.:  AK-004331-1

I.     EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

      A.    Specific  limitations and Monitoring  Requirements.

           1.    During  the effective term of this  permit,  the  permittee 1s
                authorized to discharge  from outfall  001  (sanitary waste)  In
                accordance with the following effluent limitations and
                nranitoring requirements:
      Effluent
      Characteristics

      Flow  (gpd)
      Biochemical Oxygen
        Demand  (6005)
      Total  Suspended
        Solids  (TSS)
      PH
      Fecal Coliform
          Effluent Limitations
          Avg. Monthly Meekly Avg.
                     Monitoring Requirements
                     Frequency Sample Type
           2000
           30 mg/1

           30 mg/1
        45 mg/1

        45 mg/1
             monthly
             monthly

             monthly

             monthly
           Not less than 6.0
           standard units, nor greater
           than 9.0 standard units.
           	          —          monthly
          Instantaneous
          grab

          grab

          grab


          grab
     The monthly average  percent removal of BOOR and TSS  shall not  be  less
     than 85%.  Removal rates and associated calculations  shall be  submitted
     monthly with each Discharge Monitoring Report  (DMR) form.

     There shall be no discharge of floating sol Ids, visible foam or oil  and
     grease which causes  a  sheen on the surface of  the receiving water.
          2.
During the effective term of this permit, the permittee 1s
authorized to discharge from outfall  002 (sediment pond) in
accordance with the following:
               a.   Baseflow Conditions  Discharges
               following  limitations and monitoring
               baseflow conditions:
                                     shall  comply with the
                                     requirements during
     Effluent
     Characteristics

     Total Hydrocarbons*
     Total Iron
     Total Suspended
        Solids (TSS)
     Settleable Solids
        (SS)
     pH
     Effluent Flow (mgd)
     Receiving Stream
        Flow (cfs)
           Eff1uent Li ml tations
           Avg.Monthly Daily Max.
            3.0
           35.0
mg/1
mg/1
 0.15 mg/1
 6.0 mg/1
70.0 mg/1
Mpn.1tor ing
Frequency

weekly
weekly
weekly

weekly
           Not less than 6.0          weekly
           standard units,  nor greater
           than 9.0 standard units
                                      weekly
            —           —           weekly
Requirements
 Sample Type

 grab
 grab
 grab

 grab

 grab
                                  instantaneous
                                  1nstantaneous
     There shall be no discharge of floating solids, visible foam or oil and
     grease which causes a sheen on the surface of the receiving water.

     *Total Hydrocarbons shall be measured using Standard Method 503(8).

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                                            Page 4 of 19 ,
                                            Permit No.:  AK-004331-1

          b.   Precipitation Events (Alternate Limitations)

               (1)  Any discharge or Increase in the  volume of  a
                    discharge caused by precipitation within  any  24-hour
                    period less than or equal to 5.10 Inches  (or
                    snowmelt of equivalent depth)  shall  comply  with  the
                    following limitations and monitoring requirements:
Effluent
Characteristics

Effluent Flow (mgd)
Receiving Stream
  Flow (cfs)
SS
PH
                         Mon rtor1ngRegulrements
                         Frequency    Sample  Type
                         weekly*

                         weekly*
                         dally
                         dally
            instantaneous

            Instantaneous
            grab
            grab
                     Effluent Limitations
                       Maximum Dally

                           N/A

                           N/A
                           0.5 ml/1
                      Not less than 6.0
                      standard units,  nor
                      greater than 9.0
                      standard units.

There shall  be no discharge of floating  solids, visible foam or oil and
grease which causes a sheen on the surface of the receiving water.

[* Flows shall be measured at least once during the period when the
alternate limitations apply.]

                    Any discharge or  Increase in the volume of a
                    discharge caused  by  precipitation within any 24-hour
                    period greater than  5.10 Inches (or snowmelt of
                    equivalent depth)  shall comply with the following
                    limitations  and monitoring requirements:
Effluent
Characteristics

Effluent Flow (mgd)
Receiving Stream
  Flow (cfs)
pH
Effluent Limitations
  Maximum Dai 1y
Monitoring
Frequency

weekly*

weekly*
daily
                                                        Requirements
                                                         Samp]e Type

                                                         Instantaneous

                                                         Instantaneous
                                                         grab
      N/A

      N/A
 Not less than  6.0
 standard units,  nor
 greater than 9.0
 standard units.
There shall  be no discharge  of  floating  solids, visible foam or oil
grease which causes  a sheen  on  the  surface of the receiving water.

[* Flow shall  be measured  at least  once  during the period when the
alternate limitations apply.]
                                              and
                              Dfr*% A ff~*f*
                              RAFT

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                                            Page 5 of 19
                                            Permit No.:  AK-004331-1

               (3)  The alternate precipitation limitations and
                    monitoring requirements in Parts I.A.Z.b.U) or (2)
                    begin when a discharge (or an increase in the volume
                    of a discharge) Is caused by precipitation (or
                    snowmelt of equivalent depth), and shall  continue
                    two days following cessation of the  precipitation
                    event.

                    For the purpose of this part of the  permit, the term
                    "cessation of the precipitation event" is defined as
                    when the discharge flow rate decreases to the flow
                    rate proceeding the start of the precipitation event.

                    The permittee has the burden of proof to show that
                    the discharge (or increase in discharge)  resulted
                    from a precipitation event.

B.    Other Permit Requirements.

     1.    Watershed Monitoring Program

          A monitoring program shall  be established In order  to define
          relationships between soil  type,  vegetation, and precipitation
          runoff, and the  rate and quality  of discharge  from  settling
          ponds for the four seasons  of the year.   The resulting
          watershed hydrographs should provide documentation  for
          determining the  "time of concentration"  of the area
          contributing runoff to the  sedimentation pond.   The "time of
          concentration"  1s the time  it takes  for  the last of the runoff
          from the hydraulically most remote  point in the drainage area
          to reach the Inlet of sedimentation  pond.   The program shall
          include provisions for monitoring influent to  the
          sedimentation pond and precipitation.

          The permittee shall  submit  details  of  this program  to EPA and
          the Alaska Department of Environmental Conservation (ADEC)  for
          review  and approval  within  90 days  of  the  effective date of
          this permit.

     2.    Precipitation Monitoring Program

          The permittee shall  keep a  record of all  precipitation
          events.   This record shall  include  as  a  minimum dates,  time,
          and precipitation amounts for each  precipitation  event.   A
          copy of this  record  shall be submitted with  the monthly
          discharge monitoring reports (DMR)  see Part  II.C.

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                                       Page 6 of 19
                                       Permit No.:  AK-004331-1

3.   Use of Chemicals, Detergents, Solvents or Degreasers

     HI thin six months of the effective date of this permit,the
     permittee shall submit to EPA and AOEC for review and approval
     a list of chemicals, detergents, solvents or degreasers that
     are used to wash down equipment or are used In the maintenance
     shops which may enter the sedimentation ponds  through runoff.

4.   Best Management Practices (BMP) Plan

     Within one year of the effective date of this  permit or three
     months before construction begins (whichever date occurs
     first), the permittee shall  submit a BMP plan  to EPA for
     review and approval.  This plan shall be developed In
     accordance with 40 CFR 125.104 (see Attachment A), and shall
     also consider the BMP for water management presented in the
     EPA "Development Document for Effluent Limitations and
     Standards for the Coal  Mining Point Source Category" (EPA
     440/1-82/057, October 1982,  pages 362, 367-376).

     The BMP plan, upon approval  shall become part  of this permit.
     A copy of the BMP plan shall  be kept at the facility.

     The permittee shall  amend the BMP plan whenever there Is a
     change in facility design, construction,  operation,  or
     maintenance which materially affects the facility's  potential
     for discharge of significant amounts of hazardous or toxic
     pollutants to waters of the  United States.

     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 waters of the
     United States and the specific objectives and  requirements of
     the BMP plan, the permit and/or the BMP program shall  be'
     subject to modification to incorporate revised BMP
     requlrements.
                                 T
                                                              nrn     10

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                                            Page 7 of 19
                                            Permit No.:  AK-004331-1
C.   Definitions.
     1.   "Average monthly discharge limitation" means  the highest
          allowable average of "dally discharges" over  a calendar month,
          calculated as the sum of all  "dally discharges" measured
          during a calendar month divided by the number of "daily
          discharges" measured during that month.

     2.   "Baseflow Conditions" refers  to the sustained flow of water in
          rivers and streams resulting  primarily from groundwater
          seepage into the water courses.

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

     4.   "Daily discharge" means the discharge of a  pollutant  measured
          during a calendar day or any  24-hour  period that reasonably
          represents the calendar day for purposes of sampling.   For
          pollutants with limitations expressed in units  of mass,  the
          "daily discharge" Is calculated as the total  mass of  the
          pollutant discharged over the day.  For pollutants  with
          limitations expressed in other  units  of measurement,  the
          "daily discharge" is calculated as the average  measurement of
          the pollutant over the day.

     5.   A  "Grab" sample 1s a single sample or measurement taken  at a
          specific time or over as short  a period of  time as  is  feasible.

     6.   "Maximum dally discharge limitation"  means  the  highest
          allowable "daily discharge."

     7.   "Precipitation Event" includes  any period of  time for  which
          there  has been measurable precipitation,  and  periods of
          snowmelt (occurring  at any time there is  snow on  the  ground
          within the watershed and the  temperature  is above 0"C).

     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.

     9.   "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 noncompllance  to the extent  caused by
          operational  error,  improperly designed  treatment  facilities,
          inadequate treatment facilities,  lack of  preventive
          maintenance,  or careless  or Improper  operation.

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                                                  Page 8 of 19
                                                  Permit No.:  AK-004331-1

II.    MONITORING,  RECORDING AND REPORTING REQUIREMENTS

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

      B.    Monitoring Procedures.

           1.    Settleable Solids.  Fill  an Imhoff cone to the one-liter mark
                with a thoroughly  mixed sample.   Allow to settle undisturbed
                for 45 minutes.  Gently stir along the inside  surface of the
                cone with a stirring rod.   Allow to settle undisturbed for 15
                minutes  longer.  Record the volume of settled  material  in  the
                cone as  milHliters  per liter.   Where a separation  of
                settleable and  floating material  occurs,  do not Include the
                floating material  In the  reading.

           2.    Other Parameters.  Monitoring for other parameters  must toe
                conducted according  to test procedures approved under 40 CFR
                Part 136,  unless other test procedures have been specified in
                this permit.

      C.    Reporting of  Monitoring Results.   Monitoring results shall  be
           summarized each month on  the Discharge  Monitoring Report (DMR)  form
           
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                                            Page 9 of  19
                                            Permit No.: AK-004331-1

 D,    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,

 E.    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 1nd1v1dual(s)  who performed the analyses;

      5.    The analytical techniques or methods used;  and

      6.    The results of such  analyses.

 F.    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 three  years from the date
     of the sample, measurement, report or application.  This period may
      be extended by request of the Director or ADEC at any time.   Data
      collected on-slte, copies of Discharge Monitoring Reports,  and a
      copy of this NPDES permit must be maintained on-site during the
     duration of activity at the permitted location.

G.    Twenty-four Hour Notice of Noncompllance Reporting.

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

          a.   Any noncompllance which may endanger health or the
               environment;

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

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

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

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                                            Page 10 of 19
                                            Permit No.: AK-004331-1

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

          a.   A description of the noncompliance and its cause;

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

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

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

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

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

H.   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.C. are submitted.   The
     reports shall  contain the Information  listed in Part II.G.2,

I.   Inspection and Entry.   The permittee shall  allow the Director,
     ADEC, or an authorized representative  (including an authorized
     contractor acting as a representative  of the Administrator), upon
     the presentation of credentials and other  documents as may be
     required by law,  to:

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

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

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

     4.   Sample or monitor at reasonable times,  for  the  purpose  of
          assuring  permit compliance or  as otherwise  authorized  by the
          Act,  any  substances  or  parameters  at  any  location.
                                no

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                                                  Page  11  of 19
                                                  Permit  No.:  AK-004331-1
III.   COMPLIANCE RESPONSIBILITIES
      A.    Duty to Comply.   The  permittee  must  comply  with  all  conditions  of
           this permit.   Any permit noncompllance  constitutes  a violation  of
           the  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  and ADEC of  any planned  changes  in
           the  permitted facility  or activity which may  result  in
           noncompllance with permit requirements.

      B.    Penalties for Violations of Perm!tConditions.

           1.    Civil Penalty.   The Act provides that  any person who violates
                a  permit condition implementing Sections 301,  302, 306,  307,
                308, 318, or 405 of the Act  shall  be subject to a  civil
                penalty,  not to  exceed $25,000 per  day for  each violation.

           2.    Criminal  Penalties:

                a.    Negligent Violations.   The Act provides that  any person
                     who negligently violates a permit condition implementing
                     Sections  301,  302,  306, 307,  308, 318, or  405 of the  Act
                     shall be  punished by  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  by  both.

                b.    Knowing Violations.   The Act provides  that any person who
                     knowingly violates  a  permit condition  Implementing
                     Sections  301,  302,  306, 307,  308, 318, or  405 of the  Act
                     shall be punished by  a  fine of not  less than  $5,000 nor
                     more than $50,000 per day of violation, or by
                     imprisonment  for  not more than  3 years, or by both.

                c.    Knowing  Endangerment.   The Act  provides that  any person
                     who knowingly  violates  a permit condition  implementing
                     Sections 301,  302,  306, 307, 308, 318, or  405 of the Act,
                     and who knows  at  that time that he thereby places another
                     person  in imminent  danger of death or  serious bodily
                     injury,  shall,  upon conviction, be subject to a fine of
                     not more than  $250,000 or imprisonment of  not more than
                     15 years, or  both.  A person which is an organization
                     shall,  upon conviction of violating this subparagraph, be
                     subject  to  a  fine of not more  than $1,000,000.

                d.    False Statements.   The Act provides that any person who
                     knowingly makes any false material statement,
                     representation, or  certification In any application,
                     record, report, plan, or other document filed or required
                     to be maintained  under this Act or who knowingly
                     falsifies,  tampers with, or renders inaccurate any
                     monitoring  device or method required to be maintained
                     under this Act, shall upon conviction,  be  punished by a
                     fine of not more  that $10,000, or by Imprisonment for not
                    more than 2 years, or by both.

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                                            Page  12 of 19
                                            Permit No.: AK-Q0433I-1

     Except as provided in permit conditions in Part III.G.. By pass of
     Treatment FacJIJtjes and Par t III.H., Up set Cond1t i on s, 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 Activity not a Defense.  It shall not be  a
     defense for a permittee 1n 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 1n violation of this permit which
     has a reasonable likelihood of adversely affecting human health or
     the environment.

E.   Proper Operation and Maintenance.  The permittee shall  at all times
     properly operate and maintain all facilities and systems of
     treatment and control  (and related appurtenances) which are
     installed or used by the permittee to achieve compliance with the
     conditions of this permit.  Proper operation and maintenance also
     Includes adequate laboratory controls and appropriate quality
     assurance procedures.   This provision requires the operation of
     back-up or auxiliary facilities or similar systems which are
     installed by a permittee only when the operation is  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  materials from entering  navigable  waters.

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                                            Page  13 of  19
                                            Permit No.:  AK-004331-1
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.G..
               Twenty-four Hour Notice of  Noncomplfance Reporting.

    3.     Prohibition of bypass.

          a.    Bypass is prohibited and the  Director  or ADEC 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  adequate back-up
                    equipment  should have  been  installed in the exercise
                    of  reasonable engineering judgment 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  and  ADEC may approve an anticipated bypass,
               after  considering its adverse effects,  if the Director
               and  ADEC  determine that  it will  meet the  three conditions
               listed above  in  paragraph 3.a. of this  section.

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                                            Page 14 of 19
                                            Permit No.:  AK-004331-1
     Upset Conditions.
     1.   Effect of an upset.  An upset constitutes an affirmative
          defense to an action brought for noncompllance 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
          noncompllance was caused by upset,  and before an action for
          noncompllance, 1s 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
               cause(s) of the upset;

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

          c.    The  permittee submitted notice of the upset as required
               under Part II.G., Twenty-four  Hour Notice
               of Noncompliance Reporting; and

          d.    The  permittee complied with any remedial  measures
               required under Part III.P.. 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
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                                                  Page  15 of  19
                                                  Permit No.: AK-004331-1
IV.    GENERAL REQUIREMENTS
      A.    Changes  in  Discharge  of  Toxic  Substances.   Notification  shall  be
           provided  to the  Director and ADEC  as  soon  as  the  permittee  knows
           of,  or  has  reason  to  believe:

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

                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 in
                    accordance  with 40 CFR 122.21(g)(7); or

                d.   The  level established by the Director in accordance  with
                    40 CFR 122.44(f).

           2.    That any  activity has  occurred or will occur which  would
                result In any discharge,  on a non-routine or infrequent basis,
                of a toxic  pollutant which Is not limited  in the permit,  If
                that discharge will  exceed the highest of  the following
                "notification levels":

                a.   Five hundred micrograms  per  liter (500  ug/1);

                b.   One  milligram  per  liter  (1  mg/1)  for antimony;

                c.   Ten  (10) times  the maximum  concentration value reported
                    for  that pollutant in the permit  application in
                    accordance  with 40 CFR 122.21(g)(7); or

                d.   The  level established by the Director in accordance  with
                    40 CFR 122.44(f).

      B.    Planned Changes.   The permittee shall give  notice to  the Director
           and  ADEC  as soon as possible of any planned physical  alterations or
           additions to the permitted  facility.  Notice  is required only  when:

           1.    The  alteration or addition to a  permitted facility  may meet
                one  of the  criteria for determining whether  a facility is a
                new  source  as determined  in 40 CFR 122.29(b); or

           2.    The  alteration or addition could significantly change  the
                nature or increase  the quantity of pollutants discharged.
                This notification applies to  pollutants  which are subject
                neither to  effluent limitations  in the permit, nor  to
                notification  requirements under  Part  IV.A.I.

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                                            Page  16 of 19
                                            Permit No.: AK-004331-1

C.   Anticipated Noncompllance.  The permittee shall also give advance
     notice to the Director and ADEC of any planned changes In the
     permitted facility or activity which may result in noncompllance
     with permit requirements.

D.   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 relssuance, or
     termination, or a notification of planned changes or anticipated
     noncompllance, does not stay any permit condition.

E.   Dutyto 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.

F-   Duty to ProvideInformation.  The permittee shall  furnish to the
     Director and ADEC, within a reasonable time, any information which
     the Director or ADEC 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 or ADEC,  upon request,  copies of
     records required to be kept by this permit.

G.   Other Informat1 on.  When the permittee becomes aware  that It failed
     to submit any relevant facts in a permit application, or submitted
     incorrect information 1n a permit application or  any  report to the
     Director or ADEC, it shall  promptly submit such  facts or
     information.

H.   Signatory Requirements.   All  applications,  reports or information
     submitted to the Director and  ADEC 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 or  ADEC shall  be  signed  by a  person
          described above or  by  a duly  authorized  representative  of  that
          person.   A  person  is  a  duly  authorized  representative only if:

          a.    The  authorization  1s made in writing by a person
               described  above  and  submitted  to the Director and  ADEC,
               and

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                                             Page  17  of  19
                                             Permit No.:  AK-004331-1

           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,  position of equivalent
                responsibility,  or an  individual or position having
                overall responsibility  for environmental  matters  for the
                company.   (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.H.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.H.2.  must be submitted to  the Director and
           ADEC  prior to  or  together with any reports, information, or
           applications to be signed by an authorized  representative.

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

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

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

J-   011  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.

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                                            Page 18 of 19
                                            Permit No.: AK-004331-1

L.   Severabl1ity.  The provisions of this permit are severable, and 1f
     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.

N.   State Laws.   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 established
     pursuant to any applicable state law or regulation  under authority
     preserved by Section 510 of the Act.

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                                                                           Page  19  of  19
                                                                           Permit No.:   AK-004331-1
                                 ATTACHMENT  A
§ 125.104  Beat manarement practice* pro-
   gram.
  (a)  BMP  program* shall be  devel-
oped  in  accordance with  good  engi-
neering practices and with the  provi-
sions of this subpart.
  (b) 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 pol-
lutants.
  (I)   Each   facility  component  or
system shall be examined for its po-
tential for causing a release of signifi-
cant amounts  of toxic  or hazardous
pollutants to  waters  of the United
States due to  equipment failure, im-
proper 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 leak-
age), natural condition (e.g., precipita-
tion), or  other  circumstances to result
in significant amounts of toxic or haz-
ardous  pollutants  reaching  surface
waters, the  program should include a
prediction of  the direction,  rate of
flow and total quantity of toxic or haz-
ardous pollutants which could be dis-
charged from the facility as a result of
each condition or circumstance;
  (3)  Establish specific  best manage-
ment  practices to meet the objectives
identified under  paragraph (b)(2) of
this section, addressing  each compo-
nent or system  capable of causing a re-
lease of significant amounts of toxic or
hazardous pollutants to the waters of
the United States;
  (4)  The BMP program:  (1)  May re-
flect requirements for Spill Prevention
Control  and Countermeasure (SPCC)
plans under section 311 of  the Act and
40 CFR Part 151, and may incorporate
any part of such plans Into the BMP
program by reference;
(Comment* EPA  has  proposed  section
31KJXIMC) refutations (43 PR 39270) which
require facilities subject to NPDES to devel-
op and Implement SPCC plan* to prevent
discharges of reportable quantities of desig-
nated hazardous substances. While Subpart
K requires only procedural activities and
minor construction, the proposed 40 CFR
Part 151 (SPCC regulations) an more strin-
gent and  comprehensive with respect  to
their requirements for spill prevention.  In
developing  BMP  programs in  accordance
with Subpart K. owners or operators should
also consider the requirements of proposed
40 CFR Part 191 which may address many
of the sane areas of the facility covered  by
this Subpart)

  (ii) Shall assure the proper manage-
ment of solid and hazardous waste  in
accordance with regulations promul-
gated under the Solid Waste Disposal
Act, as amended by the Resource Con-
servation and Recovery Act of 1978
(RCRA) (40 U.S.C. 6901 et setfi.  Man-
agement   practices   required   under
RCRA regulations shall be expressly
incorporated into the BMP program;
and
  (ill)  Shall  address  the  following
points for the ancillary activities  in
§ 125.102:
  (A) Statement of policy;
  (B) Spill Control Committee;
  (C) Material inventory;
  (D) Material compatibility;
  (E) Employee training:
  (F) Reporting and  notification pro-
cedures;
  (G) Visual inspections;
  (H) Preventive maintenance;
  (I) Housekeeping; and
  (J) Security.

C Comment.'  Additional  technical informa-
tion on BMPs and the elements of a BMP
program is contained In a publication enti-
tled "NPDES Best Management Practices
Guidance Document."  Copies may be ob-
tained by  written  request to Edward  A.
Kramer (EN-338), Office of Water Enforce-
ment, Environmental  Protection  Agency,
Washington, DC, 20460.)

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                                                 Permit No.:  AK-004356-7
                                                 Application No.:  AK-004356-7


                  United  States  Environmental  Protection  Agency
                                    Region  10
                                1200 Sixth  Avenue
                            Seattle,  Hashington 98101


                      AUTHORIZATION TO DISCHARGE UNDER THE

                 NATIONAL POLLUTANT DISCHARGE  ELIMINATION  SYSTEM


      In compliance with  the provisions of the Clean Water Act,
33 U.S.C. §1251 et seq..  as amended by the Hater Quality Act of 1987,
P.L. 100-4, the "Act",

                           TIDEWATER SERVICES  COMPANY
                              (Housing Fac11Ities)
                   Diamond  Shamrock Chuitna Coal  Joint Venture

1s authorized to discharge from a facility located  near  the village of Tyonek,
Alaska,  to receiving waters named the tributaries of the  Chuitna River and the
Chuitna  River,  in accordance with discharge points,  effluent limitations,
monitoring requirements and other conditions  set forth  herein.

      This permit shall become effective

      This permit and the authorization to discharge shall expire at midnight,
Signed this       day of
                                  Director,  Water Division,  Region 10
                                  U.S.  Environmental  Protection Agency

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                                                  Page 2  of 17
                                                  Permit  No.:   AK-004356-7

                                TABLE OF CONTENTS

 Cover  Sheet—Issuance  and  Expiration  Dates

 I.     Effluent  Limitations  and  Monitoring Requirements

       A.   Specific  Limitations and Monitoring  Requirements for  Outfall  001
       B.   Specific  Limitations and Monitoring  Requirements for  Outfalls 002
           and  003
       C.   Best Management  Practices  (BMP) Plan
       D.   Definitions

 II.    Monitoring, Recording and Reporting Requirements

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

 III.   Compliance Responsibilities

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

 IV.    General Requirements

       A.   Changes in Discharge of Toxic Substances
       B.   Planned Changes
       C.   Anticipated Noncompliance
       D.   Permit Actions
       E.   Duty to Reapply
       F.   Duty to Provide Information
      G.   Other Information
       H.   Signatory Requirements
       I.   Availability of Reports
       J.   Oil  and Hazardous Substance Liability
      K.   Property Rights
       L.   Severability
      M.   Transfers
       N.   State Laws

Attachment A:  40 CFR 125, Subpart K,  §125.104(a) and (b)

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                                              Page  3  of  17
                                              Permit  No.:   AK-004356-7
   EFFLUENT  LIMITATIONS  AND  MONITORING  REQUIREMENTS

   A.    Specific  Limitations and  MonitoringRequirements  for  Outfall  001.

        During  the  effective term of  this  permit,  the  permittee  Is
        authorized  to discharge from  outfall  001  (sanitary  waste)  In
        accordance  with  the  following effluent  limitations  and monitoring
        requirements:
 Effluent
 Characteristics

 Biochemical Oxygen
   Demand  (8005)

 Total Suspended
   Solids  (TSS)

 PH
Flow, gpd
 Effluent  Limitations
              Monitoring Requirements
Avg. Monthly Weekly Avq.
30 mg/1
30 mg/1
Not less
45 mg/1
45 mg/1
than 6.0
Frequency Sample Type
monthly
monthly
monthly
grab
grab
grab
  standard  units, nor
  greater than 9.0
  standard  units.

  50,000
Fecal Coliform, #/100ml  —
                monthly

                monthly
              instantaneous

              grab
The average monthly percent removal of 6005 and TSS shall not be  less
than 85%.  Removal rates and associated calculations shall be submitted
monthly with each Discharge Monitoring Report (DMR) form.

There shall be no discharge of floating solids or visible foam or oil and
grease which causes a sheen on the surface of the receiving water.

 B.   Specific Limitations and Monitoring Requirements for Outfalls 002
      and 003.

      During the effective term of this permit, the permittee is
      authorized to discharge from outfalls 002 and 003 (sediment ponds)
      In accordance with the following effluent limitations and monitoring
      requi rements:
EFFLUENT
CHARACTERISTIC

TSS

Settleable Solids
  (SS>

PH
Flow, mgd
EFFLUENT LIMITATION
Avg. Monthly Max. Dai 1y
              MONITORING REQUIREMENTS
              Frequency  Sample Type
20.0 mg/1
30.0 mg/1

 0.2 ml/1
Not less than 6.0
standard units, nor
greater than 9.0
standard units.
weekly

weekly


weekly
                           weekly
grab

grab


grab




instantaneous
There shall  be no discharge of floating solids or visible foam or oil and
grease which causes a sheen on the surface of the receiving water.

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                                           Page 4 of 17
                                           Permit No.:   AK-004356-7
C.   Best Management Practices (BMP) Plan
     Within one year of the effective date of this permit or three
     months before construction begins (whichever date occurs
     first), the permittee shall  submit a BMP plan to EPA for review
     and approval.  This plan shall  be developed 1n accordance with
     40 CFR 125.104 (see Attachment  A), and shall also consider the
     BMP for water management presented In the EPA "Development
     Document for Effluent Limitations and Standards for the Coal
     Mining Point Source Category" (EPA 440/1-82/057, October 1982,
     pages 362, 367-376).

     The BMP plan, upon approval  shall become part of this permit.
     A copy of the BMP plan shall  be kept at the facility.

     The permittee shall  amend the BMP plan whenever there 1s a
     change In facility design,  construction, operation, or
     maintenance which materially  affects the facility's potential
     for discharge of significant  amounts of hazardous or toxic
     pollutants to waters of the United States.

     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 waters of the
     United States and the specific  objectives and requlremants of
     the BMP plan, the permit and/or the BMP program shall  be
     subject to modification to Incorporate revised BMP requirements.
                                                             DEC    J989

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                                          Page 5 of 17
                                          Permit No.:   AK-004356-7
D.   Definitions.
     1.    "Average  monthly discharge limitation" means the highest
          allowable average of "daily discharges" over a calendar
          month,  calculated as the sum of all "daily discharges"
          measured  during a calendar month divided by the number
          of "daily discharges" measured during that month.

     2.    "Bypass"  means the Intentional diversion of waste  streams
          from  any  portion of a treatment facility.

     3.    "Dally  discharge" means the discharge of a pollutant
          measured  during a calendar day or any 24-hour period that
          reasonably represents the calendar day for purposes  of
          sampling.  For pollutants with limitations expressed 1n
          units of  mass, the "dally discharge" is calculated as  the
          total mass of the pollutant discharged over the day.   For
          pollutants with limitations expressed in other units of
          measurement, the "daily discharge" is calculated as  the
          average measurement of the pollutant over  the day.

     4.    A  "Grab"  sample is a single sample or measurement  taken
          at a  specific time or over as  short a period of time as
          1s feasible.

     5.    "Maximum  dally discharge limitation" means the highest
          allowable "dally discharge."

     6.    "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.

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

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                                                 Page 6 of 17
                                                 Permit No.:   AK-004356-7

II,   MONITORING,  RECORDING AND REPORTING REQUIREMENTS

      A.    Representat1ve Samp1ing.   Samples taken in compliance with the
           monitoring requirements established under Part I  shall  be collected
           from the effluent stream prior to discharge Into  the receiving
           waters.   Samples and measurements shall be representative of the
           volume  and nature of the  monitored discharge.

      B.    Moni tori ng Procedures.

           1.    Settleable Solids.   Fill  an  Imhoff cone to the one-liter mark
                with a thoroughly  mixed  sample.   Allow to settle undisturbed
                for 45 minutes. Gently  stir along the inside surface of the
                cone with a stirring rod.  Allow to settle undisturbed for 15
                minutes  longer. Record  the  volume of settled material In the
                cone as  ml 111 liters  per  liter.   Nhere a separation  of
                settleable and floating  material  occurs,  do  not include the
                floating material  in the  reading.

           2.    Other Parameters.  Monitoring for  other parameters  must be
                conducted according  to test  procedures approved under 40 CFR
                Part 136,  unless other test  procedures have  been specified In
                this permit.

      C.    Reporting of  Monitoring Results.   Monitoring results shall  be
           summarized each  month on  the  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.H.,
           Signatory Requirements, and submitted  to the Director, Nater
           Division  and  the State  agency  at  the  following addresses:

      original  to:    United States Environmental  Protection Agency  (EPA)
                     Region 10
                     1200 Sixth Avenue,  WD-135
                     Seattle,  Nashington   98101

      copy  to:        Alaska Department of  Environmental Conservation  (ADEC)
                     Southcentral  Region
                     3601  "C"  Street, Suite  1350
                     Anchorage, Alaska  99503

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                                            Page  7 of  17
                                            Permit No.:  AK-004356-7

 D.    Additlonal 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  1n the DNR.   Such
      increased frequency shall also  be indicated.

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

      1.    The date, exact place, and time of sampling or measurements;

      2.    The individual
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                                           Page 8 of 17
                                           Permit No.:  AK-004356-7

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

          a.   A description of the noncomplfance and Its cause;

          b.   The period of noncompllance, Including exact dates and
               times;

          c.   The estimated time noncompllance 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 Nater Compliance Section in Seattle, Washington, by phone,
          (206) 442-1213.

     4.   Reports shall  be submitted to the addresses In Part II.e..
          Reporting of Monitoring Results.

H.   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.C. are submitted.  The
     reports shall  contain the information listed in Part II.G.2.

I.   Inspection and Entry.  The permittee shall allow the Director,
     ADEC, or an authorized  representative (Including an authorized
     contractor acting as a  representative of the Administrator), upon
     the presentation of credentials and other documents as may be
     required by law, to:

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

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

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

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

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                                                 Page  9  of  17
                                                 Permit  No.:  AK-004356-7
III.   COMPLIANCE RESPONSIBILITIES
           Duty to Comply.   The  permittee  must  comply  with  all  conditions  of
           this permit.   Any permit  noncompllance  constitutes a violation  of
           the  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  and ADEC of  any planned  changes  in
           the  permitted facility  or activity which  may  result  1n
           noncompllance with permit requirements.

           Penalties for Violations  of Permit Conditions.

           1.    Civil Penalty.   The  Act provides that  any person who violates
                a  permit condition implementing Sections 301, 302, 306,  307,
                308,  318, or  405 of  the Act  shall be subject to a  civil
                penalty,  not  to  exceed $25,000 per day for  each  violation.

           2.    Criminal  Penalties:

                a.    Negligent Violations.   The Act  provides that  any person
                     who negligently violates a permit condition implementing
                     Sections 301, 302,  306, 307, 308, 318, or  405 of the  Act
                     shall be punished  by  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  by  both.

                b.    Knowing  Violations.   The Act provides  that any person who
                     knowingly violates  a  permit condition  implementing
                     Sections 301, 302,  306, 307, 308, 318, or  405 of the  Act
                     shall be punished  by  a  fine of not  less than $5,000 nor
                     more than $50,000  per day of violation, or by
                     imprisonment  for  not more than 3 years, or by both.

                c.    Knowing  Endangerment.   The Act provides that any person
                     who knowingly violates a permit condition  implementing
                     Sections 301, 302,  306, 307, 308, 318, or 405 of the  Act,
                     and who knows at  that time that he thereby places another
                     person in imminent  danger of death or  serious bodily
                     injury,  shall,  upon conviction,  be subject to a fine  of
                     not more than $250,000 or imprisonment of not more than
                     15 years, or  both,  A person which is an organization
                     shall, upon conviction of violating this subparagraph, be
                     subject to  a  fine of not more than $1,000,000.

                d.    False Statements.    The Act provides that any person who
                     knowingly makes  any false material statement,
                     representation,  or  certification in any application,
                     record, report,  plan, or other document filed or required
                     to be maintained under this Act  or who knowingly
                    falsifies,  tampers with, or renders inaccurate any
                    monitoring  device or method required to be  maintained
                    under this Act,  shall upon conviction,  be punished by a
                    fine of not more that $10,000,  or by imprisonment for not
                    more than 2 years, or by both.

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                                           Pagt 10 of 17
                                           Permit No.:  AK-004356-7

     Except as provided in permit conditions 1n 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 Activity not a Defense.  It shall not be a
     defense for a permittee in an enforcement action that it would have
     been necessary to halt or reduce the permitted activity in order to
     maintain compliance with the conditions of this permit.

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

E.   Proper Operation and Maintenance.  The permittee shall at all times
     properly operate and maintain all facilities and systems of
     treatment and control  (and related appurtenances) which are
     Installed or used by the permittee to achieve compliance with the
     conditions of this permit.  Proper operation and maintenance also
     includes adequate laboratory controls and appropriate quality
     assurance procedures.   This provision requires the operation of
     back-up or auxiliary facilities or similar systems which are
     Installed by a permittee only when the operation Is 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  materials from entering navigable waters.

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                                       Page 11  of 17
                                       Permit No.:   AK-004356-7
 Bypass of Treatment Fac1 Titles:
 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.G..
           Twenty-four Hour Notice of Noncompliance Reporting.

3.     Prohibition of bypass.

      a.   Bypass Is prohibited and the Director or ADEC 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 adequate back-up
                equipment should  have been  installed  In  the  exercise
                of reasonable engineering judgment  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 and ADEC  may approve  an  anticipated  bypass,
           after considering its  adverse  effects,  if  the  Director
           and  ADEC determine that it will  meet  the three  conditions
           listed above in paragraph 3.a. of this  section.

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                                           Page 12 of
                                           Permit No.:
17
  AK-004356-7
     Upset Conditions.
     1.   Effect of an upset.  An upset constitutes an affirmative
          defense to an action brought for noncompllance 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
          noncompllance was caused by upset, and before an action for
          noncompllance, 1s 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
               cause(s) of the upset;

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

          c.   The permittee submitted notice of the upset as required
               under Part II.G.. Twenty-four Hour Notice
               of Noncompllance Reporting;  and

          d.   The permittee complied with  any remedial  measures
               required under Part III.P..  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
     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.

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                                                 Page  13 of 17
                                                 Permit  No.:  AK-004356-7
IV.    GENERAL REQUIREMENTS
      A.    ChangesIn  Dischargeof  Toxic  Substances.   Notification  shall  be
           provided  to the  Director and ADEC as  soon  as  the  permittee  knows
           of,  or has  reason  to  believe:

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

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

                b.   Two  hundred micrograms  per  liter (200 ug/1) for acrolein
                    and  acrylonitr1le; five hundred  micrograms per liter (500
                    ug/1)  for 2,4-dlnitrophenol and  for 2-tnethyl-4,
                    6-dlnltrophenol;  and one milligram  per  liter (1 mg/1) for
                    antimony;

                c.   Five (5)  times  the maximum concentration value reported
                    for  that  pollutant 1n the permit application in
                    accordance with 40 CFR  122.21(g)(7>; or

                d.   The  level established by the Director in accordance with
                    40 CFR 122.44(f).

           2.    That any  activity has occurred or will occur which would
                result  in any  discharge,  on  a non-routine or Infrequent basis,
                of a toxic pollutant which is not limited in the permit,  if
                that discharge will  exceed the highest of the following
                "notification  levels":

                a.   Five hundred micrograms per liter (500 ug/1);

                b.   One milligram per liter (1  mg/1)  for antimony;

                c.   Ten  (10)  times  the maximum concentration value reported
                    for  that  pollutant in the permit application in
                    accordance with 40 CFR  12Z.21(g)<7); or

                d.   The  level established by the Director in accordance with
                    40 CFR 122.44(f),

     B.    Planned Changes.   The permittee shall  give notice to the  Director
           and ADEC as  soon as possible of any planned physical  alterations  or
           additions to the permitted facility.   Notice  is required  only when:

           1.   The  alteration or addition to a  permitted facility may meet
               one  of  the criteria  for determining whether a facility is a
               new source as determined  in 40 CFR  122.29(b); or

           2.   The  alteration or addition could  significantly change  the
               nature  or increase  the quantity  of  pollutants discharged.
               This notification applies  to pollutants which are  subject
               neither to effluent  limitations  in  the permit,  nor to
               notification requirements  under  Part IV.A.I.

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                                           Page  14 of  17
                                           Permit No.:  AK-004356-7

C.   An11c1 pated Noncomp11 ance.  The permittee shall also give advance
     notice to the Director and ADEC of any planned changes in the
     permitted facility or activity which may result in noncompliance
     with permit requirements.

D.   PermitActions.  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 relssuance, or
     termination, or a notification of planned changes or anticipated
     noncompliance, does not stay any permit condition.

E.   Duty toReappjy.  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.

F.   Duty to Provide Information.  The permittee shall  furnish to the
     Director and ADEC, within a reasonable time, any information which
     the Director or ADEC 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 or ADEC, upon request, copies of
     records required to be kept by this permit.

G.   Other Information.  When the permittee becomes aware that it failed
     to submit any relevant facts 1n a permit application, or submitted
     incorrect information in a permit application or any report to the
     Director or ADEC,  1t shall promptly submit such facts or
     information.

H.   Signatory Requirements.   All  applications,  reports or information
     submitted to the Director and ADEC 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 or ADEC shall  be signed by a  person
          described above  or  by a duly authorized representative  of that
          person.   A person  is a duly authorized  representative  only if:

          a.    The authorization 1s made in writing  by  a  person
               described  above and  submitted  to  the  Director  and  ADEC,
               and
                                  3 "A .

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                                       Page 15 of 17
                                       Permit No.:  AK-004356-7

      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, position of equivalent
           responsibility, or an individual or position having
           overall responsibility for environmental  matters for the
           company.  (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,H.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.H.2. must be submitted to the  Director and
      ADEC prior to or  together with any reports, information, or
      applications to be  signed by an authorized representative.

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

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

 Avai1ab111ty 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  Director and  ADEC.   As
 required by  the Act, permit applications,  permits and effluent  data
 shall not be considered  confidential.

 Oil  andHazardous 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.

 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.

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                                           Page 16 of 17
                                           Permit No.:  AK-004356-7

L.   Severabllity.  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
          1n 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.

N-   State Laws.   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 established
     pursuant to any applicable state law or regulation under authority
     preserved by Section 510 of the  Act.
                                       if.
                                        *

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                                                                      Page  17  of  17
                                                                      Permit No.:   AK-004356-7
                                 ATTACHMENT  A
1125.104  Bart
  (a)  BMP  program* shall be devel-
oped  In accordance with  good engi-
neering practices and with the provi-
sions of tola subpart
  (b) 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 pol-
lutants.
  <1)  Each   facility  component  or
system shall be examined for its po-
tential for causing a release of signifi-
cant amounts of toxic or hazardous
pollutants  to waters of the United
States due to equipment  failure, im-
proper operation, natural  phenomena
such as rain or snowfall, etc.
  (U)  Where experience  Indicates  a
reasonable  potential for  equipment
failure (e.g., a tank overflow  or leak-
age), natural condition (e.g., precipita-
tion), or other circumstances to result
in significant amounts of toxic or haz-
ardous  pollutants  reaching  surface.
waters,  the  program should include a
prediction  of the  direction,  rate  of
flow and total quantity of toxic or haz-
ardous pollutants which could be dis-
charged from the facility as a result of
each condition or circumstance:
  (3) Establish specific best manage-
ment practices to meet the objectives
identified under  paragraph (bX2)  of
this section, addressing  each compo-
nent or system capable of causing a re-
lease of significant amounts of toxic or
hazardous pollutants to  the waters of
the United States;
  (4)  The BMP  program:  (1)  May  re-
flect requirements for Spill Prevention
Control  and Countermeasure (SPCC)
plans under section 311 of the Act and
40 CPR Part 151, and may incorporate
any part of such plans into the BMP
program by reference:
 (Comment: EPA  hat  proposed  section
 3UCJX1XO regulation! (43 PR 38376) whk*
 require facilities subject to NPDES to devel-
 op and implement SPCC plans to prevent
 discharge* of reportable quantities of desig-
 nated hazardous substances. While Subpart
 K require* only procedural activities and
 minor construction, the proposed 40 CPU
 Part 111 (SPCC regulation*) are more strin-
 gent and  comprehensive with  respect  to
 their requirement* for spill prevention.  In
 developing BMP  programs In  accordance
 with Subpart EC, owners or operators should
 also  consider the requirement* of proposed
 40 CPR Part 1SI which may address many
 of the same areas of the facility covered  by
 this Subpart.]

  (ii) Shall assure the proper manage-
 ment of solid and hazardous waste  in
 accordance  with regulations promul-
 gated under the Solid Waste Disposal
 Act, as amended by the Resource Con-
 servation and Recovery Act of 1976
 (RCRA) (40 U.S.C. 6901 et sett).  Man-
 agement  practices   required   under
 RCRA regulations shall be expressly
 incorporated into the BMP program:
 and
  (ill)  Shall  address the  following
 points for the ancillary activities  in
 1125.102:
  (A) Statement of policy;
  (B) Spill Control Committee:
  (C) Material inventory;
  (O) Material compatibility;
  (E) Employee training:
  (P) Reporting and  notification pro-
cedures;
  (O) Visual inspections;
  (H) Preventive maintenance;
  (I) Housekeeping; and
  (J) Security.

 {Comment: Additional  technical informa-
tion on BMPs and the elements of a BMP
programis contained in a publication enti-
tled  " NPDES Best Management Practices
Guidance Document."  Copies may be ob-
tained by  written  request  to Edward  A.
Kramer (EN-336), Office of Water Enforce-
ment, Environmental  Protection  Agency,
Washington, DC. 20460.1

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                      	Appendix E
Air Quality Emissions Calculations

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                                  APPENDIX E
                             AIR QUALITY EMISSIONS
                               TABLE OF CONTENTS

                                                                          Page

1.0  INTRODUCTION	 E-l

2.0  CONSTRUCTION-RELATED AND TEMPORARY EMISSIONS 	 E-l

     2.1  Construction Land Clearing Fugitive Dust Emissions 	 E-l
     2.2  Construction Land Clearing Dozer Tailpipe Emissions 	 E-2
     2.3  Construction Slash Burning Emissions	 E-2
     2.4  Temporary Overland Truck Coal Haul Fugitive Dust Emissions 	 E-3
     2.5  Temporary Truck Coal Haul Exhaust Emissions	 E-3

3.0  MINE AREA EMISSIONS 	 E-4

     3.1  Land Clearing/Reclamation 	 E-4
     3.2  Slash Burning Emissions	 E-4
     3.3  Overburden Removal - Truck Shovel 	 E-4
     3.4  Overburden Removal - Dragline 	 E-5
     3.5  Overburden Hauling	 E-6
     3.6  Overburden Dumping	.,	 E-6
     3.7  Coal Removal	 E-7
     3.8  Coal Hauling 	 E-7
     3.9  Coal Dumping 	 E-8
     3.10 Coal Primary Crushing 	 E-8
     3.11 Wind Erosion - Mine Area	 E-9
     3.12 Haul Road Maintenance/Graders 	 E-9
     3.13 Dozer Tailpipe Emissions 	 E-10
     3.14 Grader Tailpipe Emissions 	 E-10
     3.15 Haul Truck Tailpipe Emissions	 E-ll
     3.16 Other Mine Area Sources 	 E-12

4.0  MINE SERVICE AREA EMISSIONS 	 E-12

     4.1  Secondary Coal  Crushing	 E-12
     4.2  Coal Screening 	 E-13
     4.3  Coal Handling At Mine Services Area	 E-13
     4.4  Coal Stockpile	 E-14
     4.5  Wind Erosion - Mine Service Facilities Area 	 E-14

5.0  PORT FACILITY EMISSIONS 	 E-15

     5.1  Coal Handling at Port Facility	 E-15
     5.2  Coal Stockpile at Port Facility	 E-16
     5.3  Wind Erosion - Port Facility	 E-16
     5.4  Coal Ship Emissions 	 E-16
     5.5  Fuel Delivery and Storage Emissions 	 E-17
     5.6  Fuel and Supply Ship Emissions 	 E-18

6,0  HOUSING FACILITY EMISSIONS	 E-18

     6.1  Incinerator Emissions 	 E-18

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7.0  GENERAL PROJECT AREA EMISSIONS	,	  E-19

     7.1  Overland Conveyor Emissions 	  E-19
     7.2  Miscellaneous Vehicle Traffic Fugitive Dust	  E-20
     7.3  Miscellaneous Vehicle Tailpipe Emissions 	  E-21
     7.4  Other Project Sources 	  E-21

8.0  SECONDARY POWER GENERATION EMISSIONS	  E-22
9.0  LEVEL 1 VISIBILITY SCREENING ANALYSIS 	  E-22
10.0 REFERENCES	  E-23

ATTACHMENT A - State of Alaska Department of Environmental  Conservation

ATTACHMENT B - (Excerpt from: California Air Resources Board, 1983.
                    Draft Report to the California Legislature on Air
                    Pollutant Emissions from Marine Vessels).

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                        APPENDIX i
                   AIR QUALITY EMISSIONS
1.0  INTRODUCTION

     This appendix  contains  calculations of significant air
emissions   associated   with  the   project.     It  includes
construction and  temporary  (overland truck haul) emissions,
and   short-term   and   annual   average   production-phase
emissions.

     Production   phase  emissions,   where   feasible,   are
assigned to one of the four functional areas of the project;
the mine  area,  the service area, the  port facility,  or the
housing  facility.   Emissions  which occur  between  the four
functional  areas,  such  as  overland conveyor  emissions and
miscellaneous vehicle emissions, are listed separately.

     Production-phase emissions are calculated for both pro-
duction year 3  and  full  production  emissions.  Pull produc-
tion   corresponds   to   the   fourth  year   of  production.
Emissions estimates for both years were fairly close because
though year 3 would have half the coal production of year 4,
a significantly  higher  amount of overburden  would  be moved
in year  3.   Therefore,  emissions for  both years were esti-
mated and modeled.  Where production emissions show only one
annual  rate,  emissions would  be approximately  the  same at
both production levels.

     Emission  factors,  except where noted,  are calculated
from   State   of   Alaska   Department   of   Environmental
Conservation  emission  factor  equations  for  surface  mines
(Attachment  A).   Original  sources  for  the Attachment  A
equations are also indicated below where appropriate.

2.0  CONSTRUCTION-RELATED AND TEMPORARY EMISSIONS

     Construction-related   emissions   include   the   land
clearing  and  slash burning  emissions  which  would  occur
during the  first  three years of the project,  prior  to coal
production.  Temporary emissions include the emissions from
the overland coal haul  by truck to the port site.  This will
occur only  during the first  two years  of  coal  production,
while  the  conveyor is  being  constructed.    These  overland
truck haul  emissions  are  of concern because  the emissions
will be  significantly higher  than  the  emissions from the
conveyor.

2.1  Construction Land Clearing^Fugitive Dust Emissions

     Emission Factor =  5.7  a1*2/*!1*3 Ib/hr              (1)
     Source:  U.S. EPA 1985, Section 8.24
                            E-l

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         where s = silt content of overburden = 31%
               M = moisture content of overburden =45%

               EF = 5.7(31)l*2/(45)1*3
                  =2.49 Ib/hr

     Emissions:
          Annual
               PM = (2.49 lb/hr)<44,548 hr/yr)*
                  =55.5 ton/yr

2.2  Construction Land Clearing Dozer Tailpipe Emissions

     Emission Factors

         NOX:  4.166 Ib/hr
         S02:  0.348 Ib/hr
         CO:   1.794 Ib/hr
         VOC:  0.192 Ib/hr
         PM:   0.165 Ib/hr

     Source:  U.S. EPA 1985, Table II-7.1

     Emissions:

         Annual

                                    hr/yr>a

     Emissions of the other pollutants are calculated in the
same manner.

2.3  ConstructionSlash Burning_Emi8sions

     Emission Factors:

         NOX:  64 Ib/acre
         S02!  0 Ib/acre
         CO:   2235 Ib/acre
         HC:   384 Ib/acre
         PM:   272 Ib/acre

     ADEC Emission Factor.  Source: U.S. EPA 1985,
Section 11.1.

     Emissions:
         Annual
            PM -  (272  Ib/acre)(150 acres/year)(ton/2000 lb)
               =20.4 ton/yr

     Emissions  of  the   other   pollutants  are  calculated
likewise using the emission factors given above.
a Letter from TBC to Dan Barlow (Diamond Alaska Coal Co.),
  March 17, 1988
                            E-2

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2.4  Temporary Overland Truck Coal Haul Fugitive
         Pus t _Emission s

     ADEC Emission Factor.  Source: U.S. EPA 1985,
Section 8.24.

     Emission Factor - 0.0067w3«4L°-2                  (2)

         where w = number of wheels = 6
               L = road surface silt loading » 40.8 g/m^

               EF - (0.0067)(6)3-4(40.8)°*2
                  - 6.22 Ib/VMT

     Control:  Emissions would  be 85i controlled  through  a
               program of chemical  dust  supressant applica-
               tion and watering.

     Emissions:
         Annual
             PM = (6.22 lb/VMT)(99 trips/day)(22 mi/trip)
                  (338 day/yr)(1-0.85 control)(ton/2000 Ib)
                = 343 ton/yr

2.5  Temporary Truck goal Haul  Exhaust Emissions

     Assume 1000 hp engines  and a vehicle speed of 30 mph.

     Emission Factors:

         NOX:   8.15 g/hphr
         S02:   0.887 g/hphr
         CO:    2.28 g/hphr
         HC:    0.37 g/hphr
         PM:    0.502 g/hphr

     Source:  U.S.  EPA 1985, Table II-7.1

     Emissions:
         Annual
         NOX = (8.15 g/hphr)(1000 hp)(hr/30 mi)(99 trips/
               day)(22 mi/trip)(338 day/yr)(lb/454 g)
               (ton/2000 Ib)
             = 220.3 ton/yr

     Emissions of the other  pollutants are calculated in the
     same manner  using  the emission  factors given  above.
     All HC emissions are assumed to be VOCS.
                            E-3

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3.0  MINI AREA EMISSIONS

     Emissions  in  the mine  area would  include  those asso-
ciated  with  land  clearing  and  slash  burning,  overburden
removal , coal removal , overburden replacement ,  and reclama-
tion activities.

3.1  Land Clearing/Reclamation

     This includes  reclamation and land clearing emissions
from bulldozer work.  Emissions are the  same as those calcu-
lated for construction (Section 2.1).

     Emissions:
     Annual
     2.49 Ib/hr x 44,548 hr x ton      =  55.5 ton/yr
                     yr       2,OQ01b
     PM = 55.5 ton/yr

     Hourly
     PM = 55.5 ton x 2,000 Ib x    yr    x 1 day - 13.7 Ib/hr
            yr         ton      338 days    24hr

3 .2  S lash Bur ni ng Emi ss ions

     Emissions  are   the   same   as   those   calculated  for
construction  (Section 2.3).   Slash burning would not occur
simultaneously with most of the other activities and acreage
involved in  a single burn  session is unknown.   Therefore,
hourly slash burn emissions are not quantified.

     Annual PM * 20.4 ton/yr

3.3  Overburden  Removal - Truck Shovel

     Emission Factor » 0. 0018k ( s/5 ) (u/5)  (d/5)   Ib/ton   (3)
                                /5
                                U-
ADEC Emission Factor.  Source:  U.'S. EPA 1985,
    Section 11.2.3.3.

    where k = particle size factor = 0.73
          s = silt content of overburden = 31%
          u = annual average wind speed « 5.6 mph
          d — drop distance into trucks =» 5 feet
          M = moisture content of overburden = 45%
          Y ~ batch size of shovels =22.3
          EF » (0.0018) (0.73) (31/5) (5. f/5) (5/5)
                    (45/2)2 (22.3/6)0-33

             * 1.17 x 10~5 Ib/ton
                       B-4

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     Emissions:
         Annual, production year 3
             PM = (1.17 x ID"5 Ib/ton)(17.481 x 106 ton/yr)
                  (ton/2000 Ib)
                = 0.1 ton/yr

         Annual, full production
             PM * (1.17 x 10-5 ib/ton)(17.186 x 10^ ton/yr)
                  (ton/2000 Ib)
                =0.1 ton/yr

         Hourly
             PM = (2.49 Ib/hr Mil dozers)(13.3 hr/day)
                  (day/24 hr)(2000 Ib/ton)
                =0.02 Ib/hr

     Note that overburden movement and coal movement consti-
tute  the entire  material  movement   scenario  at the  mine.
There are no additional catagories of material (such as top-
soil) to be handled.
3.4  OverburdenRemoval - Drafline

     Emission factor * (0.04)(0.75)(365-n)/365           (4)

     ADEC Emission Factor.  Source:  U.S. EPA 1978.

         where n = number of wet days per year =100

               IF - 0.02178 Ib/yd3

     Emissions:
         Annual, production year 3
             PM = (0.02178 Ib/yd3)(15.151 x 106 yd3/yr)
                  (ton/2000 Ib)
                - 165.0 ton/yr

         Hourly, production year 3
             PM = (165.0 ton/yr)(yr/365 day)(day/24 hr)
                  (2000 Ib/ton)
                =37.7 Ib/hr

         Annual, full production
             PM = (0.02178 Ib/yd3)(20.327 x 106 yd3/yr)
                  (ton/2000 Ib)
                = 221.4 ton/yr

         Hourly, full production
             PM = (221.4 ton/yr)(yr/365 day)(day/24 hr)
                  (2000 Ib/ton)
                =50.6 Ib/hr
                            E-5

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3 . 5  Overburden Hauling

     Emission Factor = 6.22 Ib/VMT (see Section 2.4)

     Control:  851 control with application of chemicals.

     Emissions:
         Annual , production year 3
             PM = (6.22 lb/VMT)(483,645 VMT/yr ) ( 1-0 .85
                  control) (ton/2000 Ib)
                * 225.6 ton/yr

         Annual, full production
             PM = (6.22 lb/VMT)(134,837 VMT/yr )( 1-0.85
                  control ) ( ton/2000 Ib)
                =62.9 ton/yr

         Hourly, production year 3
             PM - (225.6 ton/yr Hyr/365 day) (day/24 hr)
                  (2000 Ib/ton)
                =51.5 Ib/hr

         Hourly, full production
             PM - (62.9 ton/yr )(hr/36 5 day) (day/ 2 4 hr)
                  (2000 Ib/ton)
                =14.4 Ib/hr

3.6  Overburden Dumping

     Emission Factor - See Section 3.3.

         where k = 0.73, s = 31%,  u = 5.6 mph, M  = 45%
               d = drop distance to ground = 6 feet
               Y = batch size of trucks =96.9
               EF = (0.0018) (0.73) (31/5) (5. 6/5) (6/5)
                         (45/2)2 (96.9/6)0-33

                  = 8.64 x ID'6 Ib/ton

     Emissions:
         Annual ,  production year 3
             PM = (8.64 x 10~6 Ib/ton) (30.679 x  106 ton/yr)
                  (ton/2000 Ib)
                =0.1 ton/yr

         Annual,  full production
             PM = (8.64 x 10~5 Ib/ton) (30.161 x  106 ton/yr)
                  (ton/2000 Ib)
                =0.1 ton/yr

         Hourly
             PM - (0.1 ton/yr) (yr/365 day) (day/24  hr)
                  (2000 Ib/ton)
                = 2.3 x 10-2 ib/hr
                            E-6

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3.7  Coal_Removal

     Emission Factor = 0.003 x 0.70 Ib/ton
                     - 2.1 x ID'3 Ib/ton

     ADEC Emission  Factor.   Source:   U.S. EPA 1978.   Note
that  this  emission  factor  is  also  used by  the State  of
Wyoming Division of Air Quality.

     Emissions:
         Annual, production year 3
             PM = (2.1 x 10-3 Ib/ton)(6 x 106 ton/yr)
                  (ton/2000 Ib)
                =6.3 ton/yr

         Annual, full production
             PM = (2.1 x 10-3 ib/ton)(12 x 106 ton/yr)
                  (ton/2000 Ib)
                =12.6 ton/yr

         Hourly, production year 3
             PM = (6.3 ton/yr)(yr/365 day)(day/24  hr)
                  (2000 Ib/ton)
                =1.4 Ib/hr

         Hourly, fully production
             PM = (12.6 ton/yrMyr/365 day)(day/24 hr)
                  (2000 Ib/ton)
                =2.9 Ib/hr

3-8  Coal Hauling

     Emission Factor =6.22 Ib/VMT (see Section 2.4)

     Control:  85% with application of chemicals.
     Emissions:
         Annual, production year 3
             PM = (6.22 lb/VMT)(93,529 VMT/yr5(1-0.85
                  control)(ton/2000 Ib)
                =43.6 ton/yr

         Annual, full production
             PM = (6.22 lb/VMT)(187,059 VMT/yr)(1-0.85
                  control)(ton/2000 Ib)
                * 87.3 ton/yr

         Hourly, production year 3
             PM = (43.6 ton/yr)(yr/365 day)(day/24 hr)
                  (2000 Ib/ton)
                =10.0 Ib/hr

         Hourly, full production
             PM = (87.3 ton/yr(yr/365 day)(day/24  hr)
                  (2000 Ib/ton)
                =19.9 Ib/hr

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3.9  Coal Pugging

     Emission Factor » (See Section 3.3)

         where k * 0.73, u = 5.6 mph
               s * silt content of coal =6.2%
               d = drop distance into hopper = 6 feet
               M = moisture content of coal = 28%
               Y = batch size of trucks =96.9 yd3

               EP = ( 0 . 0018 ) ( 0 1 . 73 ) ( 6 . 2/5 ) ( 5 . 6/5 ) { 6/5 )
                                2 (96.9/6)0.33
                  - 4.46 x 10~6 Ib/ton

     Emissions:
         Annual, production year 3
             PM • C4.46 x 10"6 lb/ton)(6 x 106 ton/yr)
                  (ton/2000 Ib)
                =0.01 ton/yr

         Annual, full production
             PM = (4.46 x 10-6 ib/ton5(12 x 10* ton/yr)
                  (ton/2000 Ib)
                =0.03 ton/yr

         Hourly, production year 3
             PM » (0.01 ton/yr Hyr/365 day) (day/24 hr)
                  (2000 Ib/ton)
                - 2.3 x 10-3 Ib/hr

         Hourly, full production
             PM = (0.03 ton/yr Hyr/365 day) (day/24 hr)
                  (2000 Ib/ton)
                = 6.8 x 10-3 Ib/hr

3.10 Coal Primary Crushing

     Emission Factor =0.02 Ib/ton

     ADEC Emission Factor.  Source:  U.S. EPA 1985,
Section 8.23

     Control:  99% with baghouse.

     Emissions:
         Annual , production year 3
             PM = (0.02 Ib/ton) (6 x 106 ton/yr) (1-0.99
                  control) (ton/2000 Ib)
                = 0.6 ton/yr

         Annual, full production
             PM = (0.02 Ib/ton) (12 x 106 ton/yr) < 1-0 .99
                  control) (ton/2000 Ib)
                =1.2 ton/yr
                            1-8

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                  (2000 Ib/ton)
                =0.1 Ib/hr

         Hourly, full production
             PM = (1.2 ton/yr)(yr/365day)(day/24 hr)(2000
                  Ib/ton)
                =0.3 Ib/hr

3.11 Wind Erosion- MineArea

     Emission Factor » alCKL'V ton/acre-yr

     ADEC Emission Factor.  Source:  U.S. EPA 1978.

         where a = suspended fraction = 0.025
               I = soil erodibility = 47 ton/acre-yr
               C = Climatic factor =0.1
               K = Roughness factor =0.7
               L'= Unsheltered field width factor =0.7
               V'= Vegetation Factor =1.0

     Emission Factor = (0.025)(47)(0.1)(0.7)(0.7(1.)
                     = 0.576 ton/acre-yr

     Disturbed    area   »    mined    area-reclaimed    area
                    = 746 acres - 85 acres
                    = 661 acres (year 6)

     Emissions:
         Annual, production year 3
             PM = (0.0576 ton/acre-yr)(661 acres)
                =38.0 ton/yr

         Annual, full production
             PM = (0.0576 ton/acre-yr)(1054 acres - 430
                   acres)
                =35.9 ton/yr

         Hourly, production year 3
             PM * (3.8 ton/yr)(yr/365 day)(day/24 hr)
                  (2000 Ib/ton)
                =8.7 Ib/hr

         Hourly, full production
             PM = (35.9 ton/yr)(yr/365 day)(day/24 hr)
                  (2000 Ib/ton)
                =8.2 Ib/hr
3.12 Haul RoadMaintenance/Graders

     Emission factor = 0.04s2-5 Ib/VMT

     Source:   U.S.  EPA 1985,  Section 8.24
                            E-9

-------
         where s = grader speed » 4 mph

     EF - CO.04)(4)2-5
        =1.28 Ib/VMT

     Control:  50 percent with watering

     Emissions:
         Annual
             PM - (1.28 lb/VMT)(2 graders)(18 hr/day)
                  (4 mi/hr) x (338 day/yr)(ton/2000
                  lb)(l-0.50)
                * 15.6 ton/yr

         Hourly
             PM   =   (1.28   lb/VMT>(2   graders)(4   mi/hr)
                  (1-0.50)
                =5.1 Ib/hr

3.13 Dozer^Tailgipe Ernissions

     Emissions  are   the  same  as   those   calculated  for
construction (Section 2.2).

         Hourly
             NOX - (4.166 lb/hr)(44,548 hr/yr)(yr/338 days)
                   (day/24 hr)
                 =22.9 Ib/hr

     Emissions of the other pollutants are calculated in the
same manner.

3.14 Grader	TaiIpipe Emissigns

     Emission Factors:

         NOX:  0.713 Ib/hr
         S02:  0.086 Ib/hr
         CO:   0.151 Ib/hr
         VOC:  0.040 Ib/hr
         PMj   0.061 Ib/hr

     Source:  U.S. EPA 1985, Table II-7.1

     Emissions:
         Annual
             NOX = (0.713 Ib/hr)(2 graders)(18  hr/day)
                   (338 day/yr)(ton/2000 Ib)
                 =4.3 ton/yr

     Annual emissions of the other pollutants are calculated
in the same manner.
                            E-10

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Grader Tailpipe    NOX    S02     CO      VOC     PM

Annual Emissions   4.3    0.5     0.9     0.2     0.4
  (tons/yr)

         Hourly
             NOX = (0.713 lb/hr)(2 graders)
                 - 1.4 Ib/hr

3.15 Haul Truck Tailpipe Emissions

     Emission factors:  See Section 2.5.

     Emissions:
         Annual, production year 3
            NOX - (8.15 g/hphr)(1000 hp)(hr/30 mi)(93,529
                  VMT/yr)(lb/454 g)(ton/2000 Ib)
                = 28.0 ton/yr

         Annual, full production
            NOX - (8.15 g/hphrHlQQO hp)(hr/30 mi) (187,059
                  VMT/yr)91b/454 g)(ton/2000 Ib)
                =56.0 ton/yr

         Hourly, production year 3
            NOX = (28.0 ton/yr)(yr/365 day)(day/24  hr)(2000
                  Ib/ton)
               =6.4 Ib/hr

         Hourly, full production
            NOX = (56.0 ton/yr)(yr/365 day)(day/24  hr)(2000
                  Ib/ton)
                =12.8 Ib/hr
     Emission of the other  pollutants  are calculated in the
same manner with the emission  factors  listed  above.   All HC
emissions are assumed to be ₯OCs.

     Haul Trucks:   (Overburden)

     Emissions:
          Annual,  production year 3
          NOX - (8.15 g/hphr) (1000 hp) (hr/30 mi)
                (483,645 VMT/yr) (lb/454 g) (ton/2000 Ib)
              = 144.8 ton/yr

          Annual,  full production
          N0x = (8.15 g/hphr)(1000 hp)(hr/30 mi)
                (134,837 VMT/yr)(lb/454 g)(ton/2000 Ib)
              =  40.3 ton/yr

          Hourly,  production year 3
          NOX = (144.8 ton/yr)(yr/365 day)(day/24 hr)
                (2000 Ib/ton)
              =33.1 Ib/hr
                            B-ll

-------
          Hourly, full production
          N°x - (40.3 ton/yr)(yr/365 day)(day/24 hr)
                (2000 Ib/ton)
              =9.2 Ib/hr

     Note:  Vehicle  miles  travelled for coal and overburden
are  found  in  fable  4  of  "Response  to  Comments  by  ADEC
Regarding  the  Diamond  Chuitna Project  Air  Quality  Impact
Analysis", April 20, 1987.
3.16 Other Mine Area Sources

     Other potential  sources  of emissions in  the  mine area
are the permanent landfill and secondary blasting.   Blasting
will not be required for removal of the coal or the overbur-
den.   Blasting  would  only be  required occasionally  when
large boulders are encountered.  Activities at the permanent
landfill would also be  intermittent.   Because the emissions
from  these  sources would  occur intermittently  and  because
they are not  expected to  be substantial,  they are  not quan-
tified.
4.0  MINE SERVICE AREA EMISSIONS

     Emissions in the mine  service  area include those asso-
ciated with coal handling, processing, and storage.

4.1  Secondary Coal Crushing

     Emission Factor =0.06 Ib/ton

     Source: PEDCo 1976.   This emission  factor  is somewhat
             higher  than   the  ADEC   emission   factor   of
             0.05 Ib/ton for secondary crushing, as given in
             AP-42 Section  8.23.   However,  the 0.06 Ib/ton
             reflects the emissions as modeled.

     Control: 99% with baghouse.
     Emissions:
         Annual, production year 3
             PM = (0.06 Ib/ton)(6 x 106 ton/yr)(1-0.99
                  control)(ton/2000 Ib)
                =1.8 ton/yr

         Annual, full production
             PM - (0.06 Ib/ton)(12 x 10^ ton/yr)(1-0.99
                  control)(day/24 hr)(ton/2000 Ib)
                = 3.6 ton/yr

         Hourly, production year 3
             PM = (1.8 ton/yrHyr/365 day)(day/24 hr)(2000
                            E-12

-------
         Ib/ton)
       =0.4 Ib/hr

Hourly, full production
    PM = (3.6 ton/yr) (yr/365 day) (day/24 hr)(2000
         Ib/ton)
         0.8 Ib/hr
                =
4.2  Coal Screening

     Emission Factor = 0.10 Ib/ton  (PEDCo 1976)

     Control: 99% with baghouse.

     Emissions;
         Annual, production year 3
             PM - (0.10 Ib/ton) (6 x 106 ton/yr )( 1-0 .99
                  control) (day/2 4 hrX ton/2000 Ib)
                = 3.0 ton/yr

         Annual , full production
             PM - (0.10 Ib/ton) (12 x 106 ton/yr) (1-0. 9 9
                  control) (day/24 hr)  (ton/2000 Ib)
                * 6 . 0 ton/yr

         Hourly, production year 3
             PM » (3.6 ton/yrO (yr/365  day) (day/24 hr)(2000
                  Ib/ton)
                =0.7 Ib/hr

4.3  Coal Handling At Mine Services Area

     There  are  two main  coal transfer  points in the  mine
services  area;  the transfer/weight stations  and  the  surge
pile.  A control factor of 90% is assumed for  enclosure.

     Emission Factor = 0.0018k(s/5) (u/5) (d/10)
                                     '
         Source:  U.S. EPA 1985, Section 8.24

         where k = particle size multiplier =0.77
               s = silt content of coal =6.2%
               u = annual average wind speed = 5.6 mph
               d = drop distance for the conveyor system
                   10 feet
               M = moisture content of the coal = 28%

              EF =(0.0018)(0.77)(6.2/5)(5.6/5)(10/10)/(28/2)2
                 = 1.0 x 10~5 Ib/ton

     Emissions:
         Annual, production year 3
             PM = (1.0 x 10-5 Ib/ton)(6 x 106 ton/yr)(1-0.90
                  control) x (ton/2000 lb)(2 transfers)
                = 0.006 ton/yr
                            B-13

-------
         Annual, full production
             PM = (1.0 x 10-5 lb/ton)(12 x 1Q6 ton/yr)
                  (1-0.90 control) x (ton/2000 lb)(2 trans-
                  fers)
                - 0.012 ton/yr

         Hourly, production year 3
             PM = (0.006 ton/yr)(yr/365 day)(day/24 hr)
                  (2000 Ib/ton)
                - 0.00 Ib/hr

         Hourly, full production
             PM = (0.012 ton/yr)(yr/365 day)(day/24 hr)(2000
                  Ib/ton)
                - 0.00 Ib/hr

     The mine services area coal handling emissions analysis
above was  based  on  a preliminary  simplified  description of
the  coal  handling  system.   A  more detailed  analysis,  too
lengthy to include,  revealed  that  the  emissions would be
less than  those  presented here.   The major  assumptions of
this detailed analysis were:  99% control with a baghouse on
splitter  hopper, secondary crusher,  and  associated  drop
points? 90% control  with enclosure for the transfer stations
and  surge  pile  and 20% of  coal volume  circulated  through
surge pile.

4.4  Coal Stockpile

     Emission Factor = 1.6 u Ib/acre-hr

     ADEC Emission Factor.  Sources  U.S. EPA 1985,
Section 8.24.

         where u = wind speed =2.5 m/s

               SF -  (1.6X2.5)
                  =4.0 Ib/acre-hr

     Controls 50% with watering.

     Emissions:
         Annual
             PM - (4.0 lb/acre/hr)(2.35 acre)(8760 hr/yr)
                  (ton/2000 Ib) (1-0.50 control)
                = 20.5 ton/yr

         Hourly
             PM » (4.0 Ib/acre/hr)(2.35 acre)(8760 hr/yr)
                  (1-0.50 control)

                =4.7 Ib/hr


4.5  Wind Erosion -  Mine Service Facilities Area
                            E-14

-------
     Emission Factor = 0.0576 ton/acre-yr (see Section 3.11)

     Emissions:
         Annual
            PM = (0.0576 ton/acre-yr)(173 acres)
               = 10.0 ton/yr

         Hourly
            PM = (10.0 ton/yr)(yr/365 day)(day/24 hr)
                  (2000 Ib/ton)
               =2.3 Ib/hr

5.0  PORT FACILITY EMISSIONS

     Emissions at the port facility would be associated with
coal  handling  and   storage,   and  coal  and  supply  ship
emissions.

5.1  Coal Handling atPort Facility

     Eight main  coal transfer  points  at the  port facility
were  calculated,  including  the  transfer station,  the coal
stacker, stockpile retrieval, and the shiploader.

     Emission Factor = 1.0 x 10~5 ib/ton (see Section 4.3)

     Control: 90% with enclosure.

     Emissions:
         Annual, production year 3
            PM - (1.0 x 10~5 Ib/ton)(6 x 106 ton/yr)(1-0.90
                  control) (ton/2000 Ib) x 8 transfers
               = 0.024 ton/yr

         Annual, full production
            PM - (1.0 x ID'5 Ib/ton)(12 x 106 ton/yr)(1-0.90
                  control) (ton/2000 Ib) x 8 transfers
               * 0.048 ton/yr

         Hourly, production year 3
            PM = (0.024 ton/yr)(yr/365 day)(day/24 hr)(2000
                  Ib/ton)
               - 0.005 Ib/hr

         Hourly, full production
            PM »  (0.048  ton/yr)(yr/365  day)(day/24 hr)(2000
                  Ib/ton)
               =0.01 Ib/hr

     The  port  facility   coal  handling  emissions  analysis
above was based on  a preliminary,  simplified description of
the  coal  handling  system.   A  more detailed  analysis,  too
lengthy to  include,  revealed  that  the  emissions  would  be
less than  those  presented here.   The major  assumptions  of
the detailed analysis were:   99% control with a baghouse on
                            E-15

-------
transfer stations  12  and #3;  90% control with enclosure for
transfer station  #1,  the stackers,  the shiploader, and con-
veyor drop points; 5% of coal volume to bypass silo.

5.2  Coal Stockpile at Port Facility

     Emission Factor * 4.0 Ib/acre-hr  (see Section 4.4)

     Control:  50% with watersprays and compaction.

     Emissions:
         Annual
            PM = (4.0 lb/acre/hr)(24.9 acres)(1-0.50
                  control)(8760 hr/yr) (ton/2000 Ib)
               = 218.1 ton/yr

         Hourly
            PM - (218.1 ton/yr)(yr/365 day)(day/24 hr)(2000
                  Ib/ton)
               =49.8 Ib/hr

5.3  Wind Erosion - Port Facility

     Emission Factor = 0.0576 ton/acre-yr (see Section 3.10)

     Emissions:
         Annual
            PM = 0.0576 ton/acre-yr)(206 acres)
               =11.9 ton/yr

         Hourly
            PM - (11.9 ton/yr)(yr/365 day)(day/24 hr)(2000
                  Ib/ton)
               =2.7 Ib/hr

5.4  Coa1 Ship Emissions

     Emissions of the ships while "hoteling" at port, during
loading.  The ships are  assumed  to  be steamships burning 3%
sulfur fuel.  Also, the ships are assumed to be of the maxi-
mum size, which is approximately 100,000 tons capacity.

     Fuel use during  hoteling was assumed to  be 12% of the
full  power  fuel  use  of  0.58 Ib fuel  per  ship horsepower
hour,  for  a  21,000 hp  vessel (GARB  1983.    See Attachment
B) .   Emission factors are  based on AP-42  emission factors
for steamship while hoteling (U.S. EPA 1985, Table II-3.2).

     Emission Factors:

         NOX (as N02)                    8.0 Ib/hr
         SOa (3% sulfur oil)          103.8 Ib/hr
         CO                             1.1 Ib/hr
         VOC                            0.1 Ib/hr
         PM                             3.5 Ib/hr
                            E-16

-------
     Emissions:
         Annual
            NOX - (8.0 lb/hr)(3760 hr/yr)(ton/2000 Ib)
                = 15.0 ton/yr

         Hourly
           NOX =8.0 Ib/hr

5.5  Fuel Delivery and Storage Emissions

     Most  of  the project's  power  needs  would be  supplied
through  the  use of electricity.   Diesel fuel  and  gasoline
would  be required  only for  the vehicles  and other  minor
uses.    Hydrocarbon  emissions  from  gasoline  and  diesel
storage tanks at the port site and mine site were calculated
according  to  the  methodology  in  AP-42  Section 4.3.2  for
fixed roof storage  tanks (U.S. EPA  1985).   The hydrocarbon
emissions  consist  of vapors  from  breathing  loss  (LB)  and
working loss (LW).

     The  following  parameters were  common  to  all  calcula-
tions:

     Pa = 14.7 psia, Ts = 40°F,  T =^41°Fr  Fp = 1.33, Kc »
     lf Kn -1.0, H = 0.5 h =10 ft, Mv= 130 for diesel and
     66 for gasoline, P = 0.0031 psia for diesel and 3.4
     psia for gasoline.

     Port site, diesel tanks
     2 x 10^ gallons diesel stored in two tanks.  For each
     tank, D = 92 ft, H » 0.5 h - 10 ft.  Also; C - 1.0, V -
     2 x 106, N = 3.0.

     LB = 0.64 ton/yr
     Lw = 0.03 ton/yr
     Lt = Lb + Lw
         =0.67 ton/yr

     Port site, gasoline tank
     D = 50 ft, H = 10 ft,  C - 1, V = 315,000 gal, N = 3.0
     LB = 7.90 ton/yr
     Lw = 2.54 ton/yr
     Lt » Lb + Lw
         = 10.44 ton/yr

     Mine site, diesel tank
     D - 40 ft, H = 10 ft,  C - 1, V = 164,000 gal, N = 36.6
     LB = 0.08 ton/yr
     Lw = 0.03 ton/yr
     Lt = Lb + Lw
         =0.11 ton/yr

     Mine site, gasoline tank
     D - 14 ft, H = 10 ft,  C - 0.7,  V = 23,600 gal,  N = 36.4
     LB = 0.61 ton/yr
                            E-17

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     Lw = 2.32 ton/yr
     Lt - Lb 4- Lw
         =2.93 ton/yr

Thus, total  VOC emissions  from  full storage are  11.1 tons
per year at  the port  site and 3.0 tons per year at the mine
site.

5 .6  Fug 1 _ and	Suggly_	Shi p	Emi s s ions

     There is currently no information available on fuel and
supply ship schedules and sizes for the project.  These ship
emissions, therefore,  have not  been quantified.   The main
pollutant of concern from the vessels would be SO2-

SO2 emissions  from  the coal  ships  (Section  5.4)  were quan-
tified based on fairly conservative assumptions of 3% sulfur
fuel  and maximum  vessel  size.    The  modeled  impacts  from
these ships  were  far below the PSD  SC>2  increments (see EIS
Table 5-21).  Therefore,  emissions from the fuel and supply
ships  are not  expected  to  have  any significant  adverse
impact on air quality.

6.0  HOUSING FACILITY EMISSIONS

     Two potential sources of emissions at the housing faci-
lity would  be the incinerator  and the airport.   The inci-
nerator  would  burn  only  general  camp  refuse  (household
waste) to  reduce  the volume  of  material to  be landfilled.
The airport  would  be used to transport workers  to and from
the site.  Approximately two 50 person flights per day would
be required.  The planes  would  be emitting  for  only a short
period of time before  they reached a level  where the pollu-
tants  would  be  rapidly  dispersed.    Therefore,  airport
emissions are not quantified.  Incinerator emission calcula-
tions follow.   Note  that the steam boiler at  the housing
facility will be electrically powered.

6.1  Inc i aerator Emi ss i ons

     For a worst-case analysis,  a  peak  load of  1000 Ib/hr
and operation 12 hours per day is assumed.

     Emission Factors:

         NOX:  3 Ib/ton
         HC:    3 Ib/ton
         CO:   10  Ib/ton
         S02:  2.5 Ib/ton
         PM:   7 Ib/ton

     Source:  U.S.   EPA   1985,  Table 2.3-1.     Industrial-
             commercial multiple-chamber incinerator
             assumed.
                            E-18

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     Annual emissions:
         NOX  =  3  Ib N0x/ton x 0.5 ton/hr  x  12  hr/day x 365
               day/yr x ton/2000 Ib
              = 3.3 ton/yr

     Hourly
         NOX  = (3 lb/tonM0.5 ton/hr)
              =1.5 Ib/hr

     Emissions  of   the   other   pollutants  are  calculated
likewise using the emission factors listed above.

            Emiss long       NOX    HC    CO     S02    PM
Peak emissions (Ib/hr)      1.5    1.5    5     1.25   3.5
Annual emissions (ton/yr)   3.3    3.3   11.0   2.7    7.7

7.0  GENERAL PSOJECT AREA EMISSIONS

     General project  emissions include all  emissions which
could not be assigned to either the mine area, service area,
port  facility, or  housing  area.    This  includes  conveyor
emissions and miscellaneous vehicle emissions.

7 . 1  Overland Conveyor Emiss ions

     Conveyor  emissions  are  typically  quantified  based on
the  number of  transfer  points,  rather  than  the  conveyor
length, as  the majority of  emissions result  from  the coal
drop  at  the  transfer  points.   The  overland conveyor  is
somewhat unusual due to its length (approximately 11 miles).
A concerted effort was made to locate an emission factor for
the conveyor itself, rather than one related to the transfer
points.   This  included  a  literature search  and  contacting
conveyor manufacturers.   No emission factors  based on con-
veyor length were  found.   Therefore, for lack of  a better
factor, therefore, emissions  were  calculated via  an erosion
type calculation for  coal  stockpiles.  The exposed area was
taken to  be the area of  the  exposed coal on the conveyor
belt.  The wind speed was  taken to  be the speed of the con-
veyor  belt.    The  conveyor  belt  would  be   sheltered  from
crosswinds since  it is  hooded over  the  top  and  one side.
This hood would also help capture dust arising from conveyor
movement .

     The overland conveyor emissions as quantified below are
in  addition  to the  conveyor transfer  emissions  quantified
elsewhere.  The shorter  conveyors  at the mine/mine services
area and  at the  port site are typical  of  the conveyors for
which the transfer  point emission factors were developed. It
would therefore be inappropriate to include a quantification
of "wind erosion" emissions for those conveyors.

     Emission Factor:  1.6c Ib/acre-hr
                            E-19

-------
     Source:  0.S. EPA 1985, Section 8.24.

         where c = the speed of conveyor belt • 5.08 in/sec

     Emission Factor » (1.6)(5.08)
                     =8.13 Ib/acre-hr

     Control:  90% for conveyor belt hood

     Emissions:
         Annual, production year 3
            PM = (8.13 Ib/acre-hr)(2 ft wide)(55,800 ft
                  long)(acre/43,560 ft2) x (1-0.90
                  control)(169 day/yr)(ton/2000 Ib)
               =4.2 ton/yr

         Annual, full production
            PM = (8.13 Ib/acre-hr)(2 ft wide)(55,800 ft
                  long) (acre/43,560 ft2)(i-o.90 control)
                  (338 day/hr)(ton/2000 Ib)
               =8.4 ton/yr

         Hourly
            PM - (8.13 Ib/acre-hr)(2 ft wide)(55,800 ft
                  long)(acre/43,560 ft)x (1-0.90 control)
               - 2.1 Ib/hr

7.2  Miscellaneous Vehicle Traffic Fugitive Dust

     Emission Factor - 5.9k(s/12)(S/30)(W/3)0.7(w/4)0.5
     Ib/VMT

     Source:  U.S. EPA 1985, Section 11.2

         where k = particle size multiplier =0,8
               s = silt content of road material = 8%
               S = vehicle speed = 30 mph
               W = vehicle weight * 2 tons
               w = number of wheels = 4

               EF - 5.9(0.8){8/12)(30/30)(2/3)°'7(4/4)°'5
                  =2.37 Ib/VMT

     Control: 85% control with chemical application.

     Emissions:
         Annual
              PM = (2.37 Ib/VMT)(51,000 VMT/yr)(1-0.85
                    control)(ton/2000)
                 =9.1 ton/yr
         Hourly
              PM = (9.1 ton/yr)(yr/365 day)(day/24 hr)
                    (2000 Ib/ton)
                 =2.1 Ib/hr
                            E-20

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7.3  Miscellaneous Vehicle Tailgipe Emissions

     Emission Factors:
         NOX:
         S02:
         CO:
         VOC:
         PM:

     Source:
               1.19 g/mi
               0.8 g/mi
               13.29 g/mi
               1.55 g/mi
               0.2 g/mi
              NOX, CO, and TOG are EMFAC7PC emission factors
              for medium  duty trucks, 50% gasoline  and 50%
              diesel.  PM estimated from truck emission fac-
              tors   (GARB  1986).     S02  estimated   from
              Tables II-7.1 and II-7.2 (USEPA 1985).

     Emissions:
         Annual
            NOX = (1.19 g/mi)(51,000 VMT/yr)(lb/454 g)
                  (ton/2000 Ib)
                = 0.067 ton/yr

         Hourly
            NOX » (0.067 ton/yr}(yr/365 day)(day/24 hr)
                  (2000 Ib/ton)
                = 0.004 Ib/hr

     Annual and hourly emissions of the other pollutants are
calculated likewise, using the above emission factors.
                    NO,
                           S02
CO
VOC
PM
Annual Emissions   0.067  0.045   0.746
(tons/yr)
                                          0.087   0.011
Hourly Emissions   0.004  0.003   0.050   0.006   0.001
(Ib/hr)

7.4  Other ProjectSources

     Other  project  components  which  would  be  potential
sources  of  air  emissions  include  the  sewage  treatment
plants,  water  treatment  plants,  heliport,  temporary  land-
fills, and emergency generators.   The  temporary  landfills
would only be used for construction materials.  The heliport
would  primarily  be used  during construction.   These  minor
sources  of construction  emissions are not quantified.   The
water treatment plants and  sewage treatment  plants would be
very  minor  sources  of   hydrocarbons  and   possibly   par-
ticulates.   The  emergency  generator  sizes  and fuel  types
have  not  been  specified  yet.    Therefore,   emissions  from
these sources are not quantified.
                            E-21

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8.0  SECONDARY POWER GENERATION EMISSIONS

     Power  generation  emissions  are  based  on  projected
emissions from a  proposed  Chugach Electric project to bring
a turbine on  line as a baseline  unit  rather  than  a back-up
unit.

9.0  LEVEL 1 VISIBILITY SCREENING ANALYSIS

     (See EPA 1980 for a discussion of variables and visibi-
lity analyses).

     x » distance to nearest Class I area
       * 137 km to Tuxedni National Wildlife Refuge and
         Wilderness Area
     Qpart * particulate mass emission rate
           = (885.2 ton/yr)(yr/338 day)(2000 Mt/2200 ton)
           =2.38 Mt/day
     QNOX  - (186.5 ton/yr)(yr/338 day)(2000 Mt/2200 ton)
           = 0.502 Mt/day
     QS02  = (216.5 ton/yr)(yr/338 day)(2000 Mt/2200 ton)
           - 0.582 Mt/day

     x is greater than 100 km, therefore, Sz = 100  m
     p = 2.0 x 108/S2 x
       = 2.0 x 108/(100 m)(137 km) = 1.46 x 104
     rvo = 170 km (highest visibility area)

     Taerosol = (1.06 x 10~5)(170 km)(2.38 + 1.31 (0.582)
              - 5.66 x 10-3

     Tpart = 10(10-75(p)(Qpart)
           = 10(10-7)(1.46 x 1Q4)(2.38)
           - 0.0347
     TNOX  = 1.7(10~7)(p)(QNOX)
           - 1.7  (10-7)(1.46 x 104)(0.502)
           - 1.25 x 10-3

     Cl - [1.25 x 10-3/CQ.0347 + 1.25 x 1Q-3)][1 -  exp
          (-0.0347 - 1.25 x 10-3)]
          [exp(-0.78(137/170)]
        = 6.55 x  10-4
     C2 » [1 - (1/(C1 + 1)) exp(- Tpart - TN02)1[exp(-1.56
           x/rvo)]
        = [1 - (1/(1 + 6.55 x 10-4) exp(-0.0347 - 1.25 x
          10-3)3
          [exp(-l.56(137/170)1
        «" 0.0102
     C3 - 0.368 [1 - exp(-Taerosol)]
        = 0.36811 - exp(-5.66 x 10~3)]
        - 2.07 x  10-3

     Since Cl, C2, and C3 are all  well below  0.10,  there
will be no impact of the project  on visibility in  any Class
I area.
                            E-22

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10.0 REFERENCES

California  Air  Resources Board (CARS).  1983.   Draft report
     to   the California   legislature   on  air   pollutant
     emissions from marine vessels.  Volume I. June, 1983.
     _.  1986.   Methodology to calculate emission factors for
     on-road  motor  vehicles,    California  Air  Resources
     Board.  November, 1986.
PIDCo.  1976.   "Evaluation  of  fugitive  dust  from mining,
     Task 1  report,  Identification  of  Fugitive Dust Sources
     Associated With Mining", Prepared for U.S. EPA, April.

TRC  Environmental   Consultants.  1986.     Diamond  Chuitna
     project  air  quality  impact   anslysis.    December 11,
     1986.
            1987a.
Responses  to comments  by  the  Alaska
     Department of  Environmental  Conservation regarding the
     Diamond  Chuitna  Project  Air Quality  Impact  Analysis.
     April 20, 1987.

	.  1987b.   Additional  responses  to comments  by the
     Alaska   Department   of   Environmental   Conservation
     regarding  the  Diamond  Chuitna  project  air  quality
     impact analysis.

USEPA.  1978.    "Survey  of fugitive  dust from  coal  mines,"
     by PEDCo Environmental, Inc., February.

	. 1980.  Workbook for estimating visibility impairment.
     EPA-450/4-80-031.  Nov., 1980.

	. 1985.  Compilation of Air Pollutant Emission Factors.
     Document AP-42.  4th Ed. Volume I: stationary point and
     area  sources  and  Volume II: mobile  sources.   United
     States  Environmental  Protection  Agency.    September,
     1985.
                            E-23

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                                      ATTACHMENT A

                                     STATE OF ALASKA
                        DEPARTMENT OF ENVIRONMENTAL CONSERVATION

                        FUGITIVE EMISSION FACTORS. SURFACE MINES
SOURCE

Overburden Removal
  -  Truck/Shovel
  -  Scraper, Dozers
  -  Dragline

Overburden Drilling

Overburden Blasting

Overburden Hauling
Overburden Dumping
  (batch drop)

Product Drilling

Product Blasting

Product Removal

Product Hauling



Reclamation

Haulroad Repair/
  Construction

Mind Erosion

- stripped area

- overburden stockpiles

- wash stockpiles

- product stockpiles

- tailings ponds
           EMISSION FACTOR
       .OOlBk («/5)(u/5)(d/5)
     32(365-N)/365
.04x0.75(365-N)/365
         SOlbs/blast x 0.75

         .0067*3.4 10.2 or

5.9k(B/12)(S/3Q)(H/3)0.7(w/»)0.5(365-N)
                                  365

           0.017k
      coals 35 Ibs/blast x 0.75

      coal? .003 x 0.70

      0.0067 *3.4 |_0.2 or

5.9k(s/12)(S/30)W3)0.7(w/4)0.5(365-N)
                                  365
           k 4.8 sO.6

           32(365-N)/365
      alCKL'V

      .0756 sf(365-N)/235

      .0756 sf(365-N)/235

      coal; 1.6u

      alCKL'V1
                                        UNITS
                                        Ib/ton
                                              Ibs/hr
                                              lba/yd3
                                       Ib/VMT
                                        Ib/ton
                                        Iba/ton

                                        Ib/VMT


                                        Ib/acre

                                        Ibs/hr
                                      tons/acre/yr

                                       Ib/day/acre

                                       Ib/day/acre

                                       lbs/acre/hr

                                      tons/acre/yr
                                   1 of 3

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SOURCE

Product Preparation

conveyors/transfer points/
  truck dump

stackers - raw
         - surge
         - fines

C ruaing  - primary
         - secondary
         - tertiary

Screening

Graders/compacting
  on stockpiles

Load Out/Tipple

Additional Sources

Slash Burning

Miscellaneous Road Traffic
Ship Traffic

Fuel Storage

Incineration

Power Generation
                                      ATTACWENT A
                                       (continued)
     EMISSION FACTOR
0.017 x 0.75 (coal)
.0018k (s/5Ku/5)(H/10)
           (M/2)2
EPA-AP-42



EPA-AP-42

32(365-N)/365
     272

     5.97
      M4

EPA-AP-42

EPA-AP-42

BACT or EPA-AP-42

BACT or EPA-AP-42
  f: % time - windspeeds >12 mph
  Ns Nr. days - precip. >0.01 inch/year - table
  Ms (surface) moisture content - %
  L: Surface silt loading (g/ra2)
  k: Particle size mulitplier - table
  Ss Silt content (3) - table
  LI: Average wind speed (M/S)
H;d: Drop distance (feet)
  Ys Batch size (yd3)
  w: Mean number of wheels
  W: Mean vehicle weight (tons)
UNITS



Ib/ton


Ib/ton
Ibs/hr
Ibs/acre

Ib/VMT
                                   2 of 3

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                                      ATTACHMENT A
                                       (continued)
  Ai Fraction Mind erosion losses becoming suspended  )
  I: Surface erodability                              )
  C: Climatic factor                                  )  Tables AP-42
  K: Surface roughness factor       ) ,
 Us Unsheltered field width factor )  Use 1.0
 V: Vegetation cover factor        )

Surface soil type              A            I (tons/acre/yr)

Rocky, gravelly              0.025                 38
Sandy                        0.010                134
Fine                         0.041                 52
Clay loam                    0.025                 47
                                  3  Of 3

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                                             B
  (EXCERPT FROM:  CALIFORNIA AIR RESOURCES BOARD,  1983.   DRAFT REPORT TO
  THE CALIFORNIA LEGISLATURE ON AIR POLLUTANT EMISSIONS FROM MARINE
  VESSELS).
          3.   Factors Affecting Fuel Consumption
     For a given fuel sulfur content, emissions of sulfur dioxide  are  directly
 related to a vessel's fuel consumption rate.   The fuel  consumption  rate  in
 turn depends on the size (shaft horsepower or  SHP)  and  the  type (diesel,  steam
 turbine, gas turbine) of the powerplant used to drive a vessel and  on  the
 amount of power used to perform various operations.  A  14,000 deadweight  ton
 (OrtT)  general freighter would consume  fuel  at  a rate of about 60  tons  per day
 while  a 70,000 OWT tanker would consume about  110 tons  per  day of fuel at
 cruising speed.   Those  vessels are  of  a size that  typically visit California
 Coastal Waters.   Marine diesel engines  burn 0.28  to 0.44 pound of fuel per SHP
 hour and marine  steam engines  burn  0.51  to 0.65 pound per SHP hour,-  •
               a.    Ship  Powerplant  Size
     The power required  of  a  ship's  powerplant  is a function of the size of the
 ship and  the  speed  at which  the  ship is  intended to operate.  Tankers and bulk
 carriers  are  designed to carry large loads, and a high  speed is not essential
 to their operation.  Maximum cruising speeds for these types of vessels are
                                   Q /
 generally in  the range of  16 knots.—-   Modern  passenger and container-
carrying ships, on the other hand, operate at  speeds of  20 to 25 knots.—
Container vessels carry cargoes that have high  worth to  weight  ratios,  are
perishable, or for other reasons must be delivered rapidly.   Thus  for  the same
tonnage of cargo carrying capacity,  bulk carriers and  tankers  have smaller
powerplants than container ships, general cargo carriers,  and other
                                  1 of 6

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                    ATTACHMENT B (continued)




 specialized types of dry cargo vessels.  Military vessels usually have at



 least three to four times the total shaft horsepower of commercial vessels of"


                 11 /                                                         '"*1
 equivalent size.—'



     Power requirements for commercial  vessels typically range from about-^fOgf



 SHP for a 12,000 OWT vessel  to about 45,000 SHP for an  LNG carrier.*  Typical



 horsepower requirements for tankers are shown in Table  VH-4.   As the table



 shows,  the maximum power requirement for a tanker is approximately 65,000



 SHP.   However,  tankers larger than  about 280,000 OWT do not visit California



 Coastal "Waters.   Typical  maximum power requirements for other  types  of ships



 are shown in  Table V1I-5.  As Table VII-5  shows,  container ships  can have much



 larger powerplants than either tankers  or  bulk  carriers.



     Table VII-6  shows  the  average shaft  horsepower  for  ships which visited



 various California ports  in  1976 and 1979.   In  developing  emissions



 inventories, the  staff  took  into account the differences  in powerplant  sizes



 of  vessels that operate in California Coastal Waters.



    Shoreside facilities for  whicn  sulfur dioxide emission controls  are



 required  are comparable in size to marine vessel boilers and engines,  and many



 are smaller than  typical marine vessel power plants.  Industrial ooilers  and



process heaters in the  South Coast Air Basin have heat  input capabilities as


                            127
small as 25 million Btus/hr;-—  steam generators used in oil production



operations in Kern County have heat  input capacities of  20 to 60 mi 11 ion



Btus/hour.—To control sulfur dioxide emissions in the South Coast Air



Basin, boilers and heaters that b-jrn oil are required to burn low sulfur fuel



oil and most steam generators in Kern County are equipped with stack  gas
*   However,  a small commercial  fishing  vessel  can  have  a  power  rating  of  100

    to 200 SHP.
                              2  of 6

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                         ATTACHMENT  B  (continued)
                               TABLE VII-4
                          POWERPLANT REQUIREMENTS
                      FOR TANKERS, BY DEADWEIGHT TON
 Sources:
Displacement
D.W.T.
10,000
15,000
25,000
50,000
100,000
200,000
300,000
500,000
550,000
Air Pollution Impact
Power
SHP
6,000
10,000
12,000
20,000
25,000
30,000
40,000
60,000
65,000











of Maritime Shipping Operations in the Port
          ofHouston, Texas A & M  University,  November 5,  1973.

          The Tanker Register, H.  Clarkson & Company Limited, London,
          England,  19817
                               TABLE VI1-5
                     MAXIMUM POWERPLANT REQUIREMENTS
                      FOR COMMERCIAL MAKINE VESSELS
Type of
Vessel
Bulk Carrier
Oi 1 Tanker
Container Ship
Maximum Power
SHP
40,000
65,000
80,000
Sources:   Air PollutlonImpact of MaritimeShipping OperationsinthePort
          ofHouston,  Texas A & M University, November 5,  1973.

          The Tanker Register, H. Clarkson & Company Limited,  London,
          England,  1981.

          Kerr Steamship  Company, Inc.  January 21,  1981,  response to ARB
          staff October 22,  1980, questionnaire on  marine  vessel  traffic,
          bunkering, and  fuel  systems.
                                3  of 6

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                       ATTACHMENT B (continued)

 52.   it.  Commander James Oliver, U. S. Coast Guard, San Francisco,
      California:  Personal communication to Air Resources Board Staff,
      December 10,  1982.

 REFERENCES FOR CHAPTER VIII

 1.    Responses to  Air Resources Board staff questionnaire,  "Marine Petroleum
      Terminals,"  July 22, 1980.

 c.    Shipboard Guide to  Pollution-Free Operations.   United  States Department
      of  Commerce,  December 1976.

 3.    Responses to  Air Resources Board staff questionnaire,  "Marine Vessel
      Emissions Task  Force; Information Request  -  Housekeeping  Operations,"
      June  10,  1982.

 4.    Annual  Petroleum Rev Jew.   California  Energy  Commission, April  1982.

 5.    Responses to  Air Resources Board staff questionnaire,  "Black Oil  Tanker
      Equipment and Operations,"  January 21,  1981.

 6.    Responses to  Air Resources Board staff questionnaire,  "Marine  Transfer  ot
      Petroleum and Petroleum Products,"  July 22,  1980.

 7.    Roy L.  Nersesian, Ships and Shipping.   (Tulsa,  Oklahoma:   PennWell
      Publishing  Company^1981).

8.    Alex Marks, ElIements  of Oi1-Tanker Transportation.   (Tulsa,  Oklahoma:
      PennWell  Publishing Company, 1982).

9.    J. F. Mackenzie  and C. T.  Rau, "Gaseous Hydrocarbon  Emissions  During  the
      Loading of Marine Vessels,"  TheAnnual Meeting  of  the Air  Pollution
      Control Association,  Portland, Oregon, June 27-July1, 1976.

10.  Responses to  Air Resources  Board  staff questionnaire, "Lightering,"   Ju1 -
      15, 1980.

11.  Hydrocarbon Emissionsfrom  CrudeTankers.  Exxon Corporation, October 2,
      1978.

12.  Consolidated 8-31 Marine Emission Study Final Report.  8-31 Technical
     Advisory Committee,  December 1978.

13.  Hydrocarbon Emissions During Marine Loading of Crude Oil,  Ventura _Cou,''.l/•
     California!Western Oil  and Gas  Association, August 1977.~~

14.  Compilation of Air Pollutant Emission Factors.  AP-42,  Supplement No. .«.
     U.S.  Environmental Protection Agency,  July 1979.

15.  W. C.  Kelly, L.  R. Reckner and  G. D.  Maines,  Inventory of  Emissions from
     Marine Operations within  the California CoastalMaters.(San Bernardino.
     California:Scott Environmental  Technology,  Inc.for the  California An
     Resources Board, June 26,  1981).
                               4 of 6

-------
                          ATTACHMENT B (continued)

  16.  Considerationof Model Rule for the Control of Sulfur Oxides and Organic
      Gas £m1ssIons from Marlne Vessel Operat ions.(Sacramento, California:
      California Air Resources Board, October 1978).

  17.  Atmospheric Hydrocarbon Emissions from Marlne Vessel Transfer
      Operations.  Pub1icat ion 2514A (Wash i ng ton, D.C.:  American Petro1eum
      Institute,  September 1981).

  18.  QuarterlyFuel and Energy Summary, First Quarter 1979, Second Quarter
      1979,  Third Quarter 1979, Fourth Quarter 1979.  California Energy
      Commission, 1979.

  19.  Personal  communication from Margaret Felts, California Energy Commission,
      to Air Resources Board staff,  January 10,  1983.

 20.  Personal  communication from William Collett, Omnipure Inc., to Air
      Resources Board  staff,  December 20, 1982.

 21.  United States  Code of Federal  Regulations,  Title 33,  §157.132 and
      §157.166, 1982.

 22.  McGill,  Inc.  (Tulsa,  Oklahoma:   Promotional  Brochure).

 23.  Vapor-Disposal Uni ts:   Three Models to  Match Any Appjicat ion.  Bulletin
      3 9C  (Ph(Tade1phi ia, Term sy1v an i a:   Nat i onal  Ai rOi1  Burner Company,  Inc.).

 24.  Air  Pollution  Control Manual -  Vapor .Recovery Equipment  for Hydrocarbons
      and  Conden sab1e  Gases.   (Pompton PIains, New Jersey:   E dw ar d s  E n gi neer i ng
      Corp.}.

 25.   Personal  communication  from R.  G.  Pongetti,  Celanese  Chemical  Company,  to
      Air  Resources  Board Staff,  July 2,  1979.

 26.   James  Karas, Bay  Area Air Quality Management  District, at  the Marine
      Vessel Emissions  Task Force Meeting,  July  14,  1982.

 27.   Vapor  Balance  LineScreening Study  - Control  of  HydrocarbonEmissvons
      from Offshore  Sant a Ynez  Crude  Load ing^  Exxon Research  and Engi neering
      Company,  December 9,  1977.

 28.   C. E.  Burklin, V. 0. Collins, and M. I. Owen, Background  Information on
      Hydrocarbon Emissions fromMarine Terminal Operations.   (Research
      Triang1e  Park,North Caro1ina:Prepared by Radian Corporation, Austin,
      Texas,  for  the U.S. Environmental Protection Agency, November, 1976).

29.   "Nelson Cost Indexes", Oi1 and  Gas Journal, April 2, 1979.

30.  -"Nelson Cost Indexes", Oil and  Gas Journal, September 6, 1982.

31.  Control of Hydrocarbon Emissions from Statignary Sources in the
     Caj i forni a South  Coast Air fiasi n~.   (Tus t in, Ca 11 f orni a:  prepared by  KVB,
     Inc.for the California Air Resources Board, June 1978).
                                   5 of 6

-------
                          ATTACHMENT B (concluded)

 32.  Exxon Corporation's response to Air Resources Board staff questionnaire
      "Marine Vessel Traffic, Bunkering, and Fuel Systems," October 22, 1980.'

 33.  Robert H. Perry, Cecil H. Chilton, and Sidney D. Kirkpatrick, Editors
      Chemical Engineer's Handbook - Fourthi Edition.  (New York, N.Y.:    "'
      McGraw-Hill Book Company, Inc., 1963).

 34.  Air Quality ManagementPlan, 1982 Revision.  South Coast Air Quality
      Management 0istrict arid Southern California Association of Governments,
      August 1982.

 35.  Annual EnergyProduction and Consumption 1980.  California Energy
      Commission,  1980.

 36.  C.  F.  Day,  et  al.   "The Development and Operation of an Inert Gas System
      for Oil  Tankers,"   Transact i ons of the Roy a1 Inst1 tut i on of Nava1
      Architects.  Volume 114,London, England, 1972.

 37.  R.  Swanek,  Evaluation  of liquidCargo TankOverpressure.  (Washington,
      D.C.:   U.S.  Coast  Guard,  September 1978).

 38.  Inert  FlueGasSystem  Operating Instructions.   B.  P.  Tanker Co,  Limited,
      July 1971.

 39.  Shell  Inert  Gas Qperat i ng  Instructions.   Shell  International  Petroleum
      Company  Limited,Decemb'er3,1975.

 40.   Lt.  Commander  James Oliver,  U.S.  Coast  Guard,  at  the  Marine Vessel
      Emissions Task  Force Meeting,  June  9,  1982.

 41.   Santa  Barbara  County Air Pollution  Control  District Rule 327.

 REFERENCE FOR CHAPTER IX

 1.    Mortada  International,  Marine Bunker  Fuels  Analysis and  Forecast  of  Price
      Availabi1ity.   (Springfield,  Virginia:   Prepared  for  the Maritime
      Administration, U.S. Department of  Commerce, October  1978).


REFERENCES  FOR CHAPTER X

 1.    Bonner and Moore Associates,  Inc.,  The  1985  Cali forn i a Oi1  Scenar i o
      Study.   (Houston,  Texas:  Prepared for  the  Ad Hoc Group  of California
      Industry and Government Representatives, March 20, 1980).

2.   A Statistical Analysis of the World's Merchant Fleet.  (Washington,
      0.C.:Maritime Administration, U.S. Department of Commerce,  December 31,
      1979).

3.   Revel Shinnar and Ofer Dressier, "The Self-Accelerating  Effects of
      Inflation",  Chemical Engineerjjg Progress.   December  1982.
                                6 of 6

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	Appendix F
Procedures for Wetlands Protection -
              Statement of Findings

-------
                         ENVIRONMENTAL PROTECTION AGENCY
                        PROCEDURES ON WETLANDS PROTECTION

     Executive Order 11990 entitled "Protection of Wetlands," dated May 24,
 1977, requires federal agencies to take action to avoid adversely impacting
 wetlands wherever possible, to minimize wetlands destruction, and to preserve
 the values of wetlands.  Procedures have been established (40 CFR Part 6,
 Appendix A, Section 6) for review of proposed EPA actions to determine whether
 such actions will affect wetlands, and if so, then to conduct a wetlands
 assessment, act to minimize potential harm to wetlands, evaluate alternative
 actions, and to prepare a Statement of Findings.  The Statement of Findings
 outlines the basis for the decision, alternatives considered, actions to
 minimize harm to wetlands, and overall wetland effects.  These procedures,
 including the appropriate public notice requirements, may be incorporated  into
 the EIS process where an EIS is required.  Because the proposed Diamond
 Chuitna coal project will be located in and affect wetlands, the above
 procedures have been incorporated into this EIS.  The Statement of Findings is
 included below.

 STATEMENT OF FINDINGS

     The proposed EPA action is Issuance of NPDES permits, authorizing
 discharges of wastewater associated with the coal mine operations, housing
 area, and (alternative) port sites at Ladd and Granite Point.  The applicant
 wishes to retain two transportation corridor/port site options
 (southern/Granite Point and northern/Ladd).  Two alternatives Incorporating
 these options are therefore identified in this FEIS as the applicant's
 Proposed Project.  The applicant's proposal entails ultimate development of
 only one of these transportation corridors.  The haul road and conveyor would
 both be constructed within the same corridor leading to the associated port
 site (either Ladd or Granite Point).  The preferred agency alternative, as
 discussed in this FEIS, Incorporates the eastern corridor and port site at
 Ladd.  However, NPDES permits are not required for the transportation
 corridor, so EPA does not have direct permitting authority affecting selection
of either the (preferred) eastern or (proposed) northern corridor to the Ladd
 port.

     By far the greatest project-related wetland losses would occur at the
 actual  mine site.  Smaller wetland losses would occur within the alternative
 transportation corridor/port sites.   This Statement of Findings addresses  the
 three EIS action alternatives, all of which incorporate the same mine site
 location.  Additional supporting information is provided in the FEIS as noted.

 Reasons, Proposed Project Must Be Located In Wetlands Including Consideration
of Alternatives

     The process by which the various Diamond Chuitna project component
options were evaluated and alternatives selected Is described in Chapter 3 of
 this FEIS.   Optional  mine site and mine service area component locations were
not evaluated in the EIS.  The mine site is located on state coal lease land

-------
 in  the Beluga/Chultna region of Alaska where geological  studies  have  shown
 coal reserves  to exist.   Economically recoverable coal reserves  exist at  the
 proposed mine  site, where  the coal  seams are relatively  shallow  and thick,
 resulting  In a minimum necessary amount of overburden excavation and  surface
 disturbance.   Surrounding  Beluga/Chuitna coal reserves are generally  deeper
 and/or in  thinner seams.   Optional  mine service area component locations  were
 not addressed  due to logistical constraints and the necessity for the service
 area to be located in direct proximity to the mine.

     Optional  locations for the non-mine project components (coal
 transportation corridors,  port site, overburden stockpile, and housing
 area/airstrip) were evaluated in the EIS (see Chapter 3 of this  FEIS).  These
 options, when  combined with the mine site/service area components, were used
 to formulate the alternatives evaluated 1n detail In the EIS.  The optional
 port site  locations were constrained by relative distance from the mine,  and
 technical, economic, and environmental considerations.  The general
 transportation corridor alignments were constrained by the location of the
 mine service area and the  respective optional port sites to which they
 connect.

     Wetlands occur throughout the Beluga region, both within and outside the
 area affected by the project alternatives.   Wetland losses would occur under
 all of the alternatives addressed in the EIS.  No other alternatives are
 available which would impact fewer wetlands while allowing the project to
 proceed.

 ProjectEffects on Natural and Beneficial  Values of Wetlands

     The functional  values of the wetlands  1n the project area are discussed
 in Section 4.3.2.3 of this FEIS.   Wetland Impacts are discussed in Section
 5.3.1.4 (and in other sections referenced)  of this FEIS.   The acreages of
wetlands Impacted,  by project component,  are shown on Table 5-2 of this FEIS.
 By far the largest proportion of wetlands (1,353 acres)  would be directly
 impacted by the mine site component.  The amount of wetlands directly Impacted
 by the alternative transportation corridors/port sites would be approximately
 31, under the eastern/ladd alternative,  51, under the northern/Ladd
alternative,  and 141,  under the southern/Granite Point alternative,  of the
 total  direct wetland losses resulting from  the  entire project.

     The wetlands in the project  area are not alone  high  value habitat,  but
 the habitat diversity and forest  edge associated with the interspersed
wetlands and uplands contributes  significantly  to the overall  moderate to high
habitat value of the area.  Wetland-related plant and animal  productivity
would  be directly impacted as mining progresses  southwesterly,  while
reclamation will  follow the mining in stages.   The acidic,  muskeg-type
wetlands which are widely dispersed  throughout  the area  are not highly
productive and the net primary productivity of  replacement communities could
be as  high or higher than the communities  that  now exist.  Therefore adverse
 impacts to primary wetland productivity  would not be  significant  on  a

-------
 regional  scale.   Food webs would be  interrupted  In  the  Immediate vicinity  of
 pre-tnlning  wetland  areas but  such  interruption would probably not  be
 significant on a  regional basis because of  the isolated nature of  most  area
 wetlands  and  the  large extent of similar wetlands outside  the project area.

     Significant  impacts to local  hydrologic regimes could occur as a result
 of  the direct loss  of wetlands at  the mine  site.  Netlands in the  project  area
 store large quantities of water and  play an important role in surface water  -
 ground water  interactions.  Removal  of the  deep organic layers underlying  the
 muskeg on the sides of the stream  valleys could disrupt post-mining shallow
 groundwater baseflows to area streams.  Soil porosity and deeper groundwater
 recharge  rates could increase as a result of removal of water-retaining
 organic deposits.   An extensive sediment pond system will be constructed which
 may, during the period they are In operation, enhance groundwater  recharge and
 moderate flood peaks in the Chultna  drainage.

     The removal of wetlands could alter the quality of surface water runoff
 from the reclaimed  mine area.  Wetlands tend to remove suspended sediment  from
 inflowing waters therefore postreclamation runoff would likely contain more
 sediment than at present.  The acidity of postreclamation runoff should be
 reduced due to the  net loss of peat  deposits.  The planned sediment pond
 system will  control the flow of sediment Into streams during the period of
 mining,  as  reclamation proceeds.  Planned undisturbed vegetative buffers
 between the mined area and surrounding streams will  also reduce sediment in
 the runoff.


 Actions  Taken to Minimize Potential Harm to Netlands

     The project reclamation plan,  as required by the State Surface Coal
 Mining Permit, includes a plan for  the restoration of wetlands in the mining
 area.  This  plan provides for the enhancement of wetlands development through
 creation of two to five acre peat-filled depressions throughout the reclaimed
 mine area, and the rehabilitation of certain sediment control  ponds.  The
 permit also requires construction of a minimum of four 1/2 acre coho salmon
 rearing  ponds.  These requirements  are subject to further review and possible
 revisions as necessary with the goal  of achieving the desired  restoration of
 wetland  functions.  The wetland restoration measures would reduce net wetland
 losses expected  as a result of the  project.   Postreclamation  wildlife habitat
 value could  be less than  pre-mlnlng conditions due to reductions in habitat
 diversity now contributed by the interspersed wetland/upland  areas; however,
 this diversity is expected to re-establish  over the  long-term.

     An  extensive sediment pond system is  planned, which is expected to reduce
 the hydrologic and water  quality impacts  associated  with the  direct loss of
wetlands  during  the period of mining, as  reclamation proceeds.

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     Measures will  also be undertaken to minimize the adverse effects of
non-mine project components on wetlands.  Project roadways and facilities have
been designed to avoid wetland areas.  The specific transportation corridor
alignments are routed around wetlands wherever feasible Instead of traveling
the shortest distance through wetlands.   Drainage and sediment control
measures,  Including construction of runoff diversions and collection ditches,
Installation of culverts,  revegetatlon of roadcuts, and site-specific sediment
control  measures will  be undertaken for project facilities and roads.  In
areas where the roadway crosses bogs or muskegs, a construction technique will
be used  which will  effectively "float" the road over the undisturbed
underlying vegetation mat.

-------