Ocean Discharge Criteria Evaluation for Oil and Gas
Geotechnical Surveys and Related Activities in Federal
Waters of the Beaufort and Chukchi Seas, Alaska
(NPDES Permit No.: AKG-28-4300)
United States
Environmental Protection
kl Agency
REVISED August 2014
Prepared by:
U.S. Environmental Protection Agency
Region 10, Office of Water and Watersheds
Seattle, Washington
Assisted by:
Tetra Tech, Inc.
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Executive Summary
The U.S. Environmental Protection Agency (EPA), Region 10, is issuing a National Pollutant Discharge
Elimination System (NPDES) general permit for effluent discharges associated with oil and gas
geotechnical surveys and related activities in federal waters of the Beaufort and Chukchi Seas (see Error!
Reference source not found.). The Geotechnical General Permit (Geotechnical GP) will authorize
twelve types of discharges from facilities engaged in oil and gas geotechnical surveys to evaluate the
subsurface characteristics of the seafloor and related activities in federal waters of the Chukchi and
Beaufort Seas for a permit term of five years (2014-2019).
Geotechnical surveys include drilling of borings into the subsurface to collect soil borings to assess
geologic stability for potential placement of oil and gas installations. These installations include
production and drilling platforms, ice islands, anchor structures for floating exploration drilling vessels,
and potential buried pipeline corridors. Geotechnical surveys result in a disturbance of the seafloor and
may produce discharges consisting of soil, rock and cuttings materials, in addition to facility-specific
waste streams authorized under this general permit.
Geotechnical "related activities" also result in a disturbance of the seafloor and produce similar
discharges. Such related activities may include feasibility testing of mudline cellar construction
equipment or other equipment that disturbs the seafloor, and testing and evaluation of trenching
technologies.
Section 403(c) of the Clean Water Act (CWA) requires that NPDES permits for discharges into marine
waters of the territorial seas, the contiguous zone and the oceans comply with EPA's Ocean Discharge
Criteria. Because the area of coverage of the Geotechnical GP is within federal waters of the Beaufort and
Chukchi Seas, the scope of this Ocean Discharge Criteria Evaluation extends seaward from the outer
boundary of the territorial seas (Error! Reference source not found.). The purpose of this Ocean
Discharge Criteria Evaluation (ODCE) is to evaluate the discharges under the Geotechnical GP (Permit
No. AKG-28-4300) and assess their potential to cause unreasonable degradation of the marine
environment.
The Geotechnical GP does not authorize discharges associated with any activities requiring either of the
following: (1) an Exploration Plan submitted to the Bureau of Ocean Energy Management (BOEM) for
approval pursuant to Title 30 of the Code of Federal Regulations (CFR) 550 Subpart B; or (2) an
Application for Permit to Drill submitted to the Bureau of Safety and Environmental Enforcement
(BSEE) pursuant to 30 CFR 250 Subpart D. Furthermore, the Geotechnical GP does not authorize
discharges associated with geotechnical surveys or related activities conducted at depths greater than 499
feet below the seafloor.
Geotechnical surveys and related activities, as defined, are considered ancillary activities subject to
BOEM's regulations at 30 CFR § 550.207. A permit is not required from BOEM for ancillary activities
(30 CFR § 550.105); however, to the extent these activities are performed ""on-lease." they must be
conducted in accordance with BOEM and the Bureau of Safety and Environmental Enforcement (BSEE)
regulations at 30 CFR Parts 551 and 251.
The State of Alaska Department of Environmental Conservation (DEC) is developing a permit for similar
discharges to state waters of the Beaufort and Chukchi Seas under its Alaska Pollutant Discharge
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
i
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Elimination System (APDES) program authority. DEC's permit also includes an ODCE for discharges
authorized by that permit.
The discharges from oil and gas geotechnical surveys and related activities authorized under the
Geotechnical GP are similar in nature to those discharges associated with exploration drilling activities,
but at much lower volumes. Whereas an exploration well is drilled into geologic formations (to depths
approximately 10,000 feet or greater below the seafloor) to evaluate the presence of hydrocarbon
accumulation, geotechnical surveys include collection of borings at depths ranging from approximately
50 feet to 499 feet below the seafloor to assess the seafloor and subsurface characteristics. Operators
intend to conduct geotechnical surveying at certain locations within their lease prospects and the area
between these prospects and shore, to:
a) delineate potential corridors for buried in-field flow lines and pipelines connecting different
prospects,
b) evaluate subsurface suitability for potential placement of ice-islands, jack-up rigs, production and
drilling platforms, and anchor structures for floating exploration drilling vessels, and
c) delineate corridors for a potential buried export pipeline between the lease prospects and shore.
The scope of the "related activities" (i.e., estimated discharge volumes, frequency, and duration analyzed
in the Fact Sheet and ODCE), is based in part on discharges associated with mudline cellar construction
as reported by Shell in 2012 at its Burger A and Sivulliq N/G leases in the Chukchi and Beaufort Sea,
respectively. For purposes of the ODCE, EPA assumes four equipment feasibility testing activities would
occur each year (two per sea), for a period of 7-10 days per event, totaling 20 events during the 5-year
permit term. Each activity would result in a seafloor disturbance of approximately half of a typical
mudline cellar dimension. The typical mudline cellar dimension is 20 feet wide and 40 feet deep;
therefore, EPA's assumption is that equipment testing would disturb an area that is approximately 10 feet
by 20 feet, generating a total of approximately 235,000 gallons of cuttings materials to be discharged
during the 5-year permit term. EPA also assumes drilling fluids would not be used for geotechnical
related activities.
Table ES-1 below summarizes the types of geotechnical surveys that could occur in any given year by
different operators. Geotechnical surveying activities are short in duration and, depending on targeted
depth, range between 1 to 3 days to complete one borehole. Borehole diameters can be as small as 4
inches to a maximum of 12 inches.
The depths of boreholes, borehole diameter, and numbers of boreholes differ depending on the specific
survey or activity goals. The shallow pipeline borings will generally be drilled to depths less than or equal
to 50 feet below the seafloor surface. The deeper pipeline assessment soil borings would be collected at
depths typically between 200 to 300 feet below the seafloor surface. EPA defines the shallow boreholes
as those drilled to depths of less than or equal to 50 feet (< 50 feet), and deep boreholes as those drilled to
depths of greater than 50 feet and less than or equal to 499 feet (> 50 feet and < 499 feet).
For purposes of this evaluation and based on information provided by the Alaska Oil and Gas Association
of projected geotechnical surveying activities in the Beaufort and Chukchi Seas, EPA estimates that
geotechnical surveys in any given year and performed by multiple operators would include approximately
100 boreholes drilled in federal waters (AOGA 2013). This number is derived by adding the upper range
numbers and assuming half of the state/federal boreholes would be drilled in federal waters. Using this
ii
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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approach, the projected 2015 activities total 103 boreholes, while the 2016-2020 activities consist of a
total of 86 boreholes per year. For simplicity, EPA estimates 100 boreholes per year.
Table ES-1. Geotechnical survey activity summaries
2015 2014 Activity
Program
Type
Technology
Depth of
Borehole
(feet
below
seafloor
surface)
Water
Depth
(meters)
Borehole
Diameter
(inches)
No. of
Holes
Season/Timing
of Activity
Location
(Sea)
State or
Federal
Waters
Duration
per
Borehole
Pipeline
Rotary DP
<50
20-45
9
20-24
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Platform
Rotary DP
>50 and
<499
40-45
9
3-8
Open Water
Chukchi/
Beaufort
Federal
Up to 3
days
Other
Rotary on Ice
>50 and
<499
<5 to <10
6.5
50a
Winter
Chukchi/
Beaufort
State/F e
deral
Up to 1
day
Pipeline
Rotary/CPT
<50
>20
4-12
40
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Jack Up
Drill Unit
Rotary/CPT
>50 and
<499
<20
4-12
12 a
Open Water
Chukchi/
Beaufort
State/F e
deral
Up to 1
day
a Half of these boreholes are assumed to occur in federal waters.
2016 2015 Activity
Program
Type
Technology
Depth of
Borehole
(feet
below
seafloor
surface)
Water
Depth
(meters)
Borehole
Diameter
(inches)
No. of
Holes
Season/Timing
of Activity
Location
State or
Fed
Waters
Duration
per
Borehole
Pipeline
Rotary DP
<50
20-45
9
20-24
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Platform
Rotary DP
>50 and
<499
40-45
9
3-6
Open Water
Chukchi/
Beaufort
Federal
Up to 3
days
Pipeline
Rotary DP
<200
40-45
9
Up to
10
Open Water
Chukchi/
Beaufort
Federal
1-2 days
Pipeline
Rotary/CPT
>50
>20
4-12
40
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Jackup
Drill Unit
Rotary/CPT
>50 and
<499
<20
4-12
12 a
Open Water
Chukchi/
Beaufort
State/F e
deral
Up to 1
day
a Half of these boreholes are assumed to occur in federal waters.
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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2017 2016 Activity
Program
Type
Technology
Depth of
Borehole
(feet
below
seafloor
surface)
Water
Depth
(meters)
Borehole
Diameter
(inches)
No. of
Holes
Season/Timing
of Activity
Location
State or
Fed
Waters
Duration
per
Borehole
Pipeline
Rotary DP
<50
20-45
9
20-24
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Platform
Rotary DP
>50 and
<499
40-45
9
3-6
Open Water
Chukchi/
Beaufort
Federal
Up to 3
days
Pipeline
Rotary DP
<200
40-45
9
Up to
10
Open Water
Chukchi/
Beaufort
Federal
1-2 days
Pipeline
Rotary/CPT
>50
>20
4-12
40
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Jackup
Drill Unit
Rotary/CPT
>50 and
<499
<20
4-12
12 a
Open Water
Chukchi/
Beaufort
State/F e
deral
Up to 1
day
a Half of these boreholes are assumed to occur in federal waters.
2018 201-7 Activity
Program
Type
Technology
Depth of
Borehole
(feet
below
seafloor
surface)
Water
Depth
(meters)
Borehole
Diameter
(inches)
No. of
Holes
Season/Timing
of Activity
Location
State or
Fed
Waters
Duration
per
Borehole
Pipeline
Rotary DP
<50
20-45
9
20-24
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Platform
Rotary DP
>50 and
<499
40-45
9
3-6
Open Water
Chukchi/
Beaufort
Federal
Up to 3
days
Pipeline
Rotary DP
<200
40-45
9
Up to
10
Open Water
Chukchi/
Beaufort
Federal
1-2 days
Pipeline
Rotary/CPT
>50
>20
4-12
40
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Jackup
Drill Unit
Rotary/CPT
>50 and
<499
<20
4-12
12 a
Open Water
Chukchi/
Beaufort
State/F e
deral
Up to 1
day
a Half of these boreholes are assumed to occur in federal waters.
2019 2018 Activity
Program
Type
Technology
Depth of
Borehole
(feet
below
seafloor
surface)
Water
Depth
(meters)
Borehole
Diameter
(inches)
No. of
Holes
Season/Timing
of Activity
Location
State or
Fed
Waters
Duration
per
Borehole
Pipeline
Rotary DP
<50
20-45
9
20-24
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Platform
Rotary DP
>50 and
<499
40-45
9
3-6
Open Water
Chukchi/
Beaufort
Federal
Up to 3
days
Pipeline
Rotary DP
<200
40-45
9
Up to
10
Open Water
Chukchi/
Beaufort
Federal
1-2 days
Pipeline
Rotary/CPT
>50
>20
4-12
40
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Jackup
Drill Unit
Rotary/CPT
>50 and
<499
<20
4-12
12 a
Open Water
Chukchi/
Beaufort
State/F e
deral
Up to 1
day
a Half of these boreholes are assumed to occur in federal waters.
iv ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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2020 2019 Activity
Depth of
Borehole
(feet
below
Water
Borehole
State or
Duration
Program
Type
Technology
seafloor
surface)
Depth
(meters)
Diameter
(inches)
No. of
Holes
Season/Timing
of Activity
Location
Fed
Waters
per
Borehole
Pipeline
Rotary DP
<50
20-45
9
20-24
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Platform
Rotary DP
>50 and
<499
40-45
9
3-6
Open Water
Chukchi/
Beaufort
Federal
Up to 3
days
Pipeline
Rotary DP
<200
40-45
9
Up to 10
Open Water
Chukchi/
Beaufort
Federal
1-2 days
Pipeline
Rotary/CPT
>50
>20
4-12
40
Open Water
Chukchi/
Beaufort
Federal
Up to 1
day
Jackup
Drill Unit
Rotary/CPT
>50 and
<499
<20
4-12
12 a
Open Water
Chukchi/
Beaufort
State/
Federal
Up to 1
day
a Half of these boreholes are assumed to occur in federal waters.
While the majority of geotechnical surveys and related activities in federal waters would occur during the
open water periods (i.e., July-October), it is possible that the activity could occur during the winter
months when landfast ice is present, particularly in the Beaufort Sea. Geotechnical surveys and related
activities conducted during the open water periods will be performed using drilling systems and/or
equipment located on stationary vessels, sucli a< floating, moored, jack-up and/or lift barges. The
geotechnical surveys would utilize rotary drilling type systems, including conventional and newer seabed-
based technology, from the deck of a vessel that is secured by either dynamic positioning or an anchoring
system. During the winter months, geotechnical drilling units and support equipment would be staged on
the ice surface. In these instances, the activities would be conducted on-ice and equipment and personnel
transported to the site locations via truck.
In general, the shallow pipeline boreholes will rely on the use of seawater and not water-based drilling
fluids; however, the use of drilling fluids may be necessary based on the nature of subsurface conditions.
Related activities would only occur during the open water period and do not require water-based drilling
fluids.
The Geotechnical GP will authorize the following waste streams to be discharged:
• Discharge 001 - Water-based Drilling Fluids and Drill Cuttings
• Discharge 002 - Deck Drainage
• Discharge 003 - Sanitary Wastes
• Discharge 004 - Domestic Wastes
• Discharge 005 - Desalination Unit Wastes
• Discharge 006 - Bilge Water
• Discharge 007 - Boiler Blowdown
• Discharge 008 - Fire Control System Test Water
• Discharge 009 - Non-Contact Cooling Water
• Discharge 010 - Uncontaminated Ballast Water
• Discharge 011 - Drill Cuttings (not associated with Drilling Fluids)
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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• Discharge 012 - Cement Slurry
EPA derived discharge volume estimates on a per shallow- and deep-borehole basis using information
submitted in Shell's 2013 NPDES permit application for geotechnical surveying activities. The per-
borehole discharge volumes were extrapolated and presented using the estimate of 100 boreholes in
federal waters per year (Table ES-2).
Table ES-2. Estimated discharge volumes associated with geotechnical surveys per borehole and
per year
Discharge
Estimated Discharge
Volume1 per Shallow2
Geotechnical Borehole
Estimated Discharge
Volumes per Deep3
Geotechnical
Boreholes
Estimated Discharge
Volumes per Year4
< 50 feet
> 50 and < 499 feet
100 boreholes
U.S. Liquid Gallons
Water-based drilling fluids and drill
cuttings (001)5
7,000s
21,000s
1,232,000s
Deck drainage (002)
2,000
6,000
352,000
Sanitary wastes (003)
2,473
7,418
435,186
Domestic wastes (004)
21,000
63,000
3,696,000
Desalination unit wastes (005)
109,631
328,892
19,294,977
Bilge water (006)
3,170
9,510
557,927
Boiler blowdown (007)
N/A
--
--
Fire control system test water (008)
2,000
6,000
352,000
Non-contact cooling water (009)
2,726,234
8,178,703
479,817,254
Uncontaminated ballast water (010)
504
1,512
88,704
Drill cuttings (not associated with
drilling fluids) (Oil)7
N/A8
--
--
Cement slurry (012)
1
3
114
1 Source: Shell's NPDES Permit Application Form 2C (April 3, 2013) andL. Davis (personal communication, August 7, 2013).
2 Shallow boreholes: Depth < 50 feet
3 Deep boreholes: Depth >50 feet and < 499 feet
4 Source: AOGA 2013
5 Discharged at the seafloor and may include mud pit cleanup materials. To provide a conservative estimate, EPA assumes all
100 boreholes would utilize water-based drilling fluids. Also, approximately 4,800 gallons of drilling fluids is estimated to be
discharged from the mud pit per year. This discharge volume is in addition to the Discharge 001 estimated volume presented in
the table above.
0 Conservative estimates that include entrained seawater and do not account for soil boring sample removal.
7 Discharge 011 includes the cuttings materials generated from geotechnical related activities. For purposes of the ODCE, EPA
estimates that approximately 235,000 gallons of cuttings materials would be discharged from equipment feasibility testing
activities during the 5-year permit term.
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ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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8 Discharge Oil may also include cuttings from shallow boreholes. While the majority of shallow boreholes may not use water-
based drilling fluids, to provide a conservative estimate, EPA assumes drilling fluids would be used and the volumes are
captured above under Discharge 001.
This ODCE evaluates the waste streams authorized to be discharged by the Geotechnical GP. EPA's
Ocean Discharge Criteria (Title 40 of the Code of Federal Regulations (CFR) Part 125, Subpart M) set
forth specific determinations that must be made before permit issuance to ensure that there is no
unreasonable degradation of the marine environment. Unreasonable degradation of the marine
environment is defined (40 CFR 125.121 [e]) as follows:
• Significant adverse changes in ecosystem diversity, productivity, and stability of the biological
community within the area of discharge and surrounding biological communities;
• Threat to human health through direct exposure to pollutants or through consumption of exposed
aquatic organisms; or
• Loss of aesthetic, recreational, scientific, or economic values, which are unreasonable in relation to
the benefit derived from the discharge.
This ODCE is based on 10 criteria (40 CFR 125.122):
• Quantities, composition, and potential for bioaccumulation or persistence of the pollutants to be
discharged;
• Potential transport of such pollutants by biological, physical, or chemical processes;
• Composition and vulnerability of the biological communities which may be exposed to such
pollutants, including the presence of unique species or communities of species, the presence of
species identified as endangered or threatened pursuant to the Endangered Species Act, or the
presence of those species critical to the structure or function of the ecosystem, such as those
important for the food chain;
• Importance of the receiving water area to the surrounding biological community, including the
presence of spawning sites, nursery/forage areas, migratory pathways, or areas necessary for other
functions or critical stages in the life cycle of an organism;
• Existence of special aquatic sites including, but not limited to, marine sanctuaries and refuges,
parks, national and historic monuments, national seashores, wilderness areas, and coral reefs;
• Potential impacts on human health through direct and indirect pathways;
• Existing or potential recreational and commercial fishing, including finfishing and shellfishing;
• Any applicable requirements of an approved Coastal Zone Management Plan;
• Other factors relating to the effects of the discharge as may be appropriate; and
• Marine water quality criteria developed pursuant to CWA section 304(a)( 1).
If the Regional Administrator determines that the discharge will not cause unreasonable degradation of
the marine environment, an NPDES permit may be issued. If the Regional Administrator determines that
the discharge will cause unreasonable degradation of the marine environment, an NPDES permit may not
be issued.
If the Regional Administrator has insufficient information to determine, prior to permit issuance, that
there will be no unreasonable degradation of the marine environment, an NPDES permit may not be
issued unless the Regional Administrator, on the basis of best available information, determines that:
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit vii
Revised - August 2014
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(1) such discharge will not cause irreparable harm to the marine environment during the period in which
monitoring will take place; (2) there are no reasonable alternatives to the on-site disposal of these
materials; and (3) the discharge will be in compliance with certain specified permit conditions (40 CFR
125.122). "Irreparable harm" is defined as "significant undesirable effects occurring after the date of
permit issuance which will not be reversed after cessation or modification of the discharge" (40 CFR
125.122[a]).
A summary of the evaluation conducted for each of the 10 criteria is presented below.
Criterion 1. The quantities, composition, and potential for bioaccumulation or persistence of the
pollutants to be discharged.
The discharges from geotechnical surveys and related activities to federal waters are not expected to
cause an unreasonable degradation of the marine environment because the pollutants associated with
those discharges are not bioaccumulative or persistent. The Geotechnical GP will authorize only the
discharge of water-based drilling fluids, which if used, would most likely occur for deeper boreholes.
Recent studies show that metals associated with water-based drilling fluids are not readily absorbed by
living organisms (Neff 2010). Effects on benthic and zooplankton communities are expected to be limited
to physical smothering in the vicinity of the discharge (Section 3.4.2 discusses the nature and extent of
deposition).
The Geotechnical GP applies limits on the concentrations of mercury and cadmium in stock barite, and
places suspended particulate phase toxicity limits on the discharges of water-based drilling fluids. These
limits are established by the national Effluent Limitation Guidelines (ELGs) for the oil and gas extraction
point source category (40 CFR Part 435) and are applied by EPA for the Geotechnical GP to ensure
unreasonable degradation does not occur. EPA also requires baseline site characterization at each
geotechnical surveys and related activities, or submission of existing, representative baseline data and
post-activity environmental monitoring at locations that use water-based drilling fluids. This data will
establish the areas of potential impact and will be evaluated by EPA to ensure unreasonable degradation
does not occur during the 5-year permit term. The data will also be used in future agency decision-
making.
Criterion 2. The potential transport of such pollutants by biological, physical, or chemical processes.
Pollutant transfer can occur through biological, physical, or chemical processes. While some degree of
physical transfer is expected from geotechnical surveys and related activities in the Beaufort and Chukchi
Seas, the effects would be limited by the short duration of activity (i.e., 1 to 3 days to drill one
geotechnical borehole depending on the diameter and depths of the holes and 7 to 10 days for
geotechnical-related activities) and the quantity and composition of discharges. Due to the short duration
of geotechnical borehole drilling and related activities the relatively small volumes of drilling fluids (if
used) and cuttings generated when compared to exploration well drilling, the expected areas of deposition
and thickness, and the distances between geotechnical surveys and related activities, benthic habitat
effects are likely to occur in a limited area and the extent and duration of effects are expected to be short
term.
Drilling fluid and cuttings deposition will not result in significant accumulations on the seafloor (see
Section 3.4.2). Table ES-3 below summarizes the amount of water-based drilling fluids and drill cuttings
discharged for each borehole, based on the diameter and depths of each borehole. The estimates include a
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ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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conservative assumption that water-based drilling fluids would be used to collect all boreholes during the
open water season.
Table ES-3. Summary of water-based drilling fluids and drill cuttings produced per borehole, by
depth (AOGA, 2013)
Cuttings and Drilling Fluids Discharged1 per Borehole by Depth
Depth: 50 feet
Depth: 200 feet
Depth 499 feet
Drill
Season
Borehole
Diameter2
Cuttings
Drilling
Fluids3
Total
Cuttings
Drilling
Fluids
Total
Cuttings
Drilling
Fluids
Total
Open
Water
7 inches
11 ft3
22 ft3
33 ft3
48 ft3
89 ft3
137 ft3
124 ft3
223 ft3
347 ft3
8 inches
15 ft3
22 ft3
37 ft3
64 ft3
89 ft3
154 ft3
165 ft3
223 ft3
388 ft3
9 inches
20 ft3
23 ft3
43 ft3
85 ft3
89 ft3
174 ft3
213 ft3
223 ft3
437 ft3
On-Ice
8 inches
15 ft3
4
15 ft3
65 ft3
65 ft3
166 ft3
-
166 ft3
1 Conversion: 1 cubic foot (ft3) = 7.480 U.S. gallons.
2 Borehole diameters range between 4 and 12 inches. This table reflects estimated volumes for an average size diameter
borehole.
3 Drilling fluids are not expected to be used for boreholes drilled at 50 feet or less below the seafloor surface; however, the
volumes are included here to provide estimates sufficient to cover all possible scenarios.
4 Water-based drilling fluids are not expected to be used for this activity.
Drilling fluids and drill cuttings are not directly discharged at the sea surface, or within the water column.
They are pushed out of the borehole to the seafloor surface by the pressure of the boring activity and
drilling fluids in the well bore. Additionally, the Geotechnical GP requires that the discharge of any mud
pit materials occur at the seafloor.
Chemical transport of drilling fluids is not well described in the literature. Any occurrence would most
likely result from oxidative/reductive reactions in sediments that change the speciation and sorption-
desorption processes that change the physical distribution of pollutants.
Criterion 3. The composition and vulnerability of the biological communities which may be exposed to
such pollutants, including the presence of unique species or communities of species, the presence of
species identified as endangered or threatened pursuant to the Endangered Species Act (ESA), or the
presence of those species critical to the structure or function of the ecosystem, such as those important for
the food chain.
Within the nearshore shallower areas, there is some potential for authorized discharges to produce either
acute or chronic effects on biological communities through exposure in the water column or in the benthic
environment due to relatively low dilution and the potential presence of sensitive biological communities.
For purposes of the ODCE, nearshore shallow areas are defined as the portion of the shelf between the
coast and the approximately 20-meter isobath. This definition is consistent with that used in the
Department of Interior-sponsored studies in the Beaufort Sea.
Marine organisms in shallow areas could also be exposed to sources of contaminants, including trace
metals; however, the extent of exposure is short term (a matter of days) due to the relatively short
duration of activity, the anticipated discharge volumes, the expected rapid dilution and deposition of
discharged materials, and the required treatment and effluent limitations placed by the permit. The limits,
restrictions, and requirements in the Geotechnical GP will minimize contaminant exposure to the
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biological communities and species that exist in the area. Additionally, the Geotechnical CP's Area of
Coverage is within federal waters, generally located 3nm miles from shore, which are in deeper waters.
Eight threatened and endangered species occur within the Area of Coverage: two avian species
(spectacled eider, and Steller's eider), three cetacean species (bowhead, fin, and humpback whales), two
pinnipeds (bearded seal and ringed seal), and one carnivore (polar bear). The Pacific walrus is a candidate
species, subject to annual review by the U.S. Fish and Wildlife Service (USFWS). These species live or
spend a portion of their lives in the Area of Coverage. The potential effects on those species include
temporary behavioral changes resulting from geotechnical surveys and related activities, and potential
exposure to contaminants in the discharges. On the basis of the transient use of the area by those species,
the short duration of activities at any one location (1 to 3 days for geotechnical boreholes; 7 to 10 days for
related activities), and the limited areal extent of potential impacts, the risks to the biological communities
through exposure are expected to be minimal.
EPA has completed a Biological Evaluation (BE) on the effects of authorized discharges on endangered,
threatened, proposed and candidate species. The BE concluded that the discharges "may affect, but are
not likely to adversely affect" ESA listed, candidate, and proposed species, or their designated critical
habitat areas. EPA has requested concurrence on these determinations from t The USFWS and the
National Marine Fisheries Service (NMFS) have concurred with EPA's determinations of effect.
Criterion 4. The importance of the receiving water area to the surrounding biological community,
including the presence of spawning sites, nursery/forage areas, migratory pathways, or areas necessary for
other functions or critical stages in the life cycle of an organism.
The Area of Coverage provides foraging habitat for a number of species, including marine mammals and
birds. Bowhead whale migrations occur through the southern portions of the area with whales following
open water leads generally in the shear zone as they move from the Chukchi Sea to the Beaufort Sea.
Polar bear dens are found near shorefast ice and pack ice. Ringed seals are polar bear's primary food
source, and areas near ice edges, leads, or polynyas where ocean depth is minimal are the most productive
hunting grounds (USFWS 2009). Polar bears are more likely to be encountered during activities
conducted in shallow, nearshore locations in the Beaufort Sea. Fish and other whale species use the Area
of Coverage for feeding, spawning, and migration. The limited duration of the discharges authorized
under the Geotechnical GP would not degrade the receiving waters or sensitive habitat.
The Geotechnical GP contains seasonal and area restrictions on the discharges, including prohibitions on
discharges onto stable ice, to the Spring Lead System within 3-25 mile deferral area in the Chukchi Sea
before July 1. and water-based drilling fluids and drill cuttings (Discharge 001) during spring and fall
bowhead whale hunting activities in the Chukchi and Beaufort Sea. The permit also requires
environmental monitoring for two phases to ensure protection of the receiving water environment and
regional biological communities. Phase I baseline site characterization is required for all locations of
geotechnical surveys and related activities, or submission of existing, representative baseline data; and
Phase II post-activity monitoring is required if water-based drilling fluids are used.
Criterion 5. The existence of special aquatic sites including, but not limited to, marine sanctuaries and
refuges, parks, national and historic monuments, national seashores, wilderness areas, and coral reefs.
No marine sanctuaries or other special aquatic sites, as defined by 40 CFR 125.122, are in or adjacent to
the Geotechnical GP Area of Coverage. The nearest special aquatic site—the Alaska Maritime National
Wildlife Refuge (Chukchi Unit)—is approximately 60 miles to the southeast of the Chukchi Sea. The
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refuge provides habitat to a number of arctic seabird species and encompasses shoreline areas from south
of Cape Thompson (located approximately 26 miles to the southeast of Point Hope) to Cape Lisburne.
The National Historic Preservation Act (NHPA) requires federal agencies to ensure that any agency-
funded and permitted actions do not adversely affect historic properties that are included in the National
Register of Historic Places or that meet the criteria for the National Register. The Geotechnical GP
requires a baseline site characterization at each location, or submission of existing, representative baseline
data. Information gathered from the baseline site characterization or otherwise submitted will assist EPA
with meeting the NHPA Section 106 requirements and ensure potential historic properties are not affected
by the permit.
Criterion 6. The potential impacts on human health through direct and indirect pathways.
Human health within the communities on the North Slope, Northwest Arctic, and St. Lawrence Island
communities is directly related to the subsistence activities in and along the Chukchi and Beaufort Seas.
In addition to providing a food source, subsistence activities serve important cultural and social functions
for Alaska Natives. Individuals in the communities have expressed concerns related to contaminant
exposure through consumption of subsistence foods and other environmental pathways. Concerns have
also been expressed over animals swimming through discharge plumes that may contain chemicals.
Current levels of contamination in subsistence food sources are low (NMFS 2013). EPA recognizes that
even the perception of contamination could produce an adverse effect by causing hunters to avoid
harvesting particular species or from particular areas. Reduction of subsistence harvest or consumption of
subsistence resources because of a lack of confidence in the foods could produce an effect on human
health. Because discharges could influence subsistence harvest activities, the Geotechnical GP prohibits
the discharge water-based drilling fluids and drill cuttings associated with drilling fluids during spring
and fall bowhead hunting activities in the Chukchi and Beaufort Sea, respectively. As discussed further
below, the permit also: (1) prohibits discharges into the Spring Lead System within the 3-25 mile deferral
area in the Chukchi Sea prior to July 1; (2) limits the concentrations of pollutants to be discharged; (3)
requires collection of environmental data or submission of existing, representative data in monitoring to
collect and monitor the discharge area before conducting (for all locations) and after completion of
geotechnical surveys and/or related activities and £4) requires additional monitoring after completion of
geotechnical surveys and related activities when drilling fluids are used. These requirements ensure direct
and indirect human health impacts would not occur.
Criterion 7. Existing or potential recreational and commercial fishing, including finfishing and
shellfishing.
In 2009, the North Pacific Fishery Management Council developed a Fishery Management Plan (FMP)
for fish resources in the Arctic Management Area. The geographic extent of the Arctic Management Area
is all marine waters in the U.S. Exclusive Economic Zone of the Chukchi and Beaufort Seas from 3
nautical miles offshore the coast of Alaska or its baseline to 200 nautical miles offshore, north of Bering
Strait and westward to the U.S./Russia maritime boundary line and eastward to the U.S./Canada maritime
boundary. The plan establishes a framework for sustainably managing Arctic marine resources. It
prohibits commercial fishing in the Arctic waters of the region until sufficient information is available to
support sustainable fisheries management (74 FR 56734, November 3, 2009). The FMPs applicable to
salmon and Pacific halibut fisheries likewise prohibit the harvest of those species in the Arctic
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Management Area. The Council's Arctic FMP is created under authority of the U.S. Magnuson-Stevens
Fishery Conservation and Management Act (MSFCMA) and includes the following:
• All Federal waters of the U.S. Arctic will be closed to commercial fishing for any species of finfish,
mollusks, crustaceans, and all other forms of marine animal and plant life; however, harvest of
marine mammals and birds is not regulated by the Arctic FMP.
• The Arctic FMP will not regulate subsistence or recreational fishing or State of Alaska-managed
fisheries in the Arctic.
Subsistence fishing occurs throughout the coastal region of the Arctic Management Area by residents of
villages during open water seasons. Some activities occur to a limited extent in the area during winter,
generally using gill nets threaded through hole in the ice or by jigging. In summer, rod and reel, gill net,
and jigging are techniques used to capture fish. Species harvested for subsistence purposes include Pacific
herring, Dolly Varden char, whitefishes, Arctic and saffron cod, and scu'pins (NPFMC 2009).
There are few recreational fisheries in the Arctic Management Area. Most recreational catch in the Arctic
likely would occur in state waters located almost exclusively in inland lakes and streams, or along the
coast or in river delta waters. These activities would fall under the classification of sport, subsistence, or
personal use fisheries, and are regulated by state law (NPFMC 2009).
Based on the limited duration of the discharges authorized and the limits and requirements established in
the Geotechnical GP, it is not expected that the discharges would affect fishing success or the quality of
the fish harvested.
Criterion 8. Any applicable requirements of an approved Coastal Zone Management Plan.
As of July 1, 2011, there is no longer an approved Coastal Zone Management Act (CZMA) program in
the State of Alaska, per AS 44.66.030, because the Alaska State Legislature did not pass legislation
required to extend the program. Consequently, federal agencies are no longer required to provide the State
of Alaska with CZMA consistency determinations.
Criterion 9. Such other factors relating to the effects of the discharge as may be appropriate.
EPA has determined that the discharges authorized by the Geotechnical GP will not have
disproportionately high and adverse human health or environmental effects with respect to the discharge
of pollutants on minority or low-income populations living on the North Slope, Northwest Arctic and St.
Lawrence Island, particularly the coastal communities. In making this determination, EPA considered the
potential effects of the discharges on the communities, including subsistence areas, and the marine
environment. EPA's evaluation and determinations are discussed in more detail in Section 6.9.
Criterion 10. Marine water quality criteria developed pursuant to CWA section 304(a)(1).
EPA's national recommended water quality criteria for the protection of aquatic life and human health in
surface water for the applicable pollutants of concern are presented below in Table ES-4. These criteria
are published pursuant to Section 304(a) of the CWA and provide guidance for states and tribes to use in
adopting water quality standards.
Compliance with federal water quality criteria is evaluated under this criterion. Parameters of concern for
impacts on water quality in discharges from geotechnical surveys and related activities include oil and
grease, metals, chlorine, pH, temperature and total suspended solids (TSS).
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Table ES-4. National recommended water quality criteria for applicable pollutants of concern
Saltwater Aquatic Life
Human Health Consumption
CMC2 (Acute)
CCC3 (Chronic)
(Organisms Only)
Pollutant1
fig/L
fig/L
fig/L
Cadmium5
40
8.8
4
Chlorine
13
7.5
—
Mercury5
1.8
0.94
—
Methylmercury5
1.8
0.94
0.3
Oil and Grease
Narrative6
--
pH
--
6.5-8.5
--
TSS
Narrative7
--
Temperature
Species Dependent8
-
1 Source: http://water.epa.gov/scitecli/swguidaiice/standards/criteria/cinTent/iiidex.cfm
2 Criterion maximum concentration
3 Criterion continuous concentration
4 EPA has not calculated criteria for contaminants with blanks
5 A priority pollutant, defined by EPA as a set of regulated pollutants for which the agency has developed analytical test
methods. The current list of 126 priority pollutants can be found in Appendix A to 40 CFR Part 423.
0 For aquatic life: (a) 0.01 of the lowest continuous flow 96-hour LC50 to several important freshwater and marine species, each
having demonstrated high susceptibility to oils and petrochemicals; (b) levels of oils or petrochemicals in the sediment which
cause deleterious effects to the biota; (3) surface waters shall be virtually free from floating nonpetroleum oils of vegetable or
animal origin, as well as petroleum-derived oils (USEPA 1986).
7 The depth of light penetration not be reduced by more than 10 percent (USEPA 1986).
8 (a) The maximum acceptable increase in the weekly average temperature resulting from artificial sources is 1°C (1,8°F) during
all seasons of the year, providing the summer maxima are not exceeded; and (b) daily temperature cycles characteristic of the
water body segment should not be altered in either amplitude or frequency (USEPA 1986).
The Geotechnical GP contains a prohibition on discharge if the waste streams contain free oil, as
determined by visual observation and/or the static sheen test. To control the levels of metal constituents in
the discharge, the permit limits the concentrations of indicator metals, such as mercury and cadmium in
stock barite, established by the national Effluent Limitation Guidelines. The permit requires deck
drainage (Discharge 002), bilge water (Discharge 006), and ballast water, if contaminated, (Discharge
010) to be treated through an oil-water separator prior to discharge to control oil and grease. The permit
also requires pH monitoring for Discharges 001, 002, 004, 005, 006, 007, 008, and 010 as well as limiting
pH for the discharges of sanitary wastes (Discharge 003) and noncontact cooling water (Discharge 009) if
chemicals are added to the system.
Finally, the Geotechnical GP contains a daily maximum limitation of 1 milligram per liter of chlorine for
sanitary waste water (Discharge 003) and effluent limitations for TSS that are based on secondary
treatment standards based on best professional judgment.
Because the effluent limitations and requirements contained in the permit comply with federal water
quality criteria, EPA concludes that the discharges will not cause an unreasonable degradation of the
marine environment.
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CONTENTS
1. INTRODUCTION 1-1
1.1. Purpose 1-1
1.2. Scope of Analysis 1-3
1.2.1. Geotechnical GP Area of Coverage 1-3
1.2.2. Nature and Type of Activity 1-3
1.2.3. Authorized Discharges 1-5
1.3. Overview of Document 1-5
2. OIL AND GAS GEOTECHNICAL SURVEYING AND RELATED ACTIVITIES 2-1
2.1. Description of the Activities 2-1
2.2. Comparison of Geotechnical Surveys to Exploration Activities 2-3
3. AUTHORIZED DISCHARGES, ESTIMATED QUANTITIES, AND MODELED
BEHAVIOR 3-1
3.1. Authorized Discharges 3-1
3.2. Summary of Permit Changes 3-1
3.3. Description of the Discharges 3-2
3.3.1. Water-Based Drilling Fluids and Drill Cuttings (Discharge 001) 3-2
3.4. Other Discharges 3-4
3.4.1. Deck Drainage (Discharge 002) 3-4
3.4.2. Sanitary and Domestic Waste (Discharge 003 and 004) 3-4
3.4.3. Desalination Unit Waste (Discharge 005) 3-5
3.4.4. Bilge Water (Discharge 006) 3-5
3.4.5. Boiler Blowdown (Discharge 007) 3-5
3.4.6. Fire Control System Test Water (Discharge 008) 3-5
3.4.7. Non-Contact Cooling Water (Discharge 009) 3-5
3.4.8. Uncontaminated Ballast Water (Discharge 010) 3-5
3.4.9. Drill Cuttings (not associated with Drilling Fluids) (Discharge 011) 3-6
3.4.10. Excess Cement Slurry (Discharge 012) 3-6
3.5. Estimated Discharge Quantities 3-6
3.6. Predictive Modeling of Discharges 3-8
3.6.1. Dilution of Suspended Drilling Fluid and Drill Cuttings 3-8
3.6.2. Thickness and Extent of Drilling Fluids and Drill Cuttings 3-9
3.6.3. Dilution of Miscellaneous Discharges 3-10
4. DESCRIPTION OF THE EXISTING PHYSICAL ENVIRONMENT 4-1
4.1. Climate and Meteorology 4-1
4.1.1. Air Temperature 4-1
4.1.2. Precipitation 4-1
4.1.3. Winds 4-1
4.2. Oceanography 4-2
4.2.1. Bathymetric Features and Water Depths 4-2
4.2.2. Circulation and Currents 4-2
4.2.3. Tides 4-4
4.2.4. Stratification, Salinity, and Temperature 4-4
4.3. Ice 4-5
4.3.1. Landfast Ice Zone 4-6
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4.3.2. Stamukhi Ice Zone 4-6
4.3.3. Pack Ice 4-6
4.3.4. Spring Lead System 4-7
4.4. Sediment Transport 4-16
4.5. Water and Sediment Quality 4-16
4.5.1. Turbidity and Total Suspended Solids 4-16
4.5.2. Metals..'. 4-16
4.6. Ocean Acidification 4-19
5. DESCRIPTION OF THE EXISTING BIOLOGICAL ENVIRONMENT 5-1
5.1. Plankton 5-1
5.2. Macroalgae and Microalgae 5-2
5.3. Benthic Invertebrates 5-3
5.4. Fish 5-4
5.5. Marine Mammals 5-6
5.6. Coastal and Marine Birds 5-12
5.7. Threatened and Endangered Species 5-19
5.8. Essential Fish Habitat 5-21
5.9. Subsistence Activities and Environmental Justice Considerations 5-21
5.9.1. Importance of Subsistence 5-23
5.9.2. Subsistence Participation and Diet 5-24
5.10. Climate Change and Effects on Subsistence 5-27
6. DETERMINATION OF UNREASONABLE DEGRADATION 6-1
6.1. CRITERION 1 6-1
6.1.1. Seafloor Sedimentation 6-2
6.1.2. Benthic Communities 6-3
6.1.3. Trace Metals 6-3
6.1.4. Persistence 6-4
6.1.5. Bioaccumulation 6-6
6.1.6. Control and Treatment 6-6
6.2. CRITERION 2 6-7
6.2.1. Biological Transport 6-7
6.2.2. Physical Transport 6-8
6.2.3. Chemical Transport 6-9
6.2.4. Metals 6-9
6.2.5. Organics 6-10
6.3. CRITERION 3 6-11
6.3.1. Water Column Effects 6-11
6.3.2. Benthic Habitat Effects 6-11
6.3.3. Threatened and Endangered Species 6-12
6.4. CRITERION 4 6-12
6.5. CRITERION 5 6-17
6.6. CRITERION 6 6-17
6.7. CRITERION 7 6-18
6.8. CRITERION 8 6-19
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6.9. CRITERION 9 6-19
6.9.1. Environmental lustice 6-19
6.9.2. Combined Effects with Exploration Discharges 6-21
6.10. CRITERION 10 6-24
6.10.1. Oil and Grease 6-25
6.10.2. pH 6-25
6.10.3. Metals 6-25
6.10.4. Chlorine 6-26
6.10.5. TSS 6-26
6.10.6. Temperature 6-26
6.11. Determinations and Conclusions 6-27
7. BIBLIOGRAPHY 7-1
8. GLOSSARY 8-1
FIGURES
Figure 1-1. Area of coverage for oil and gas geotechnical surveys and related activities in federal
waters of the Beaufort and Chukchi Seas 1-2
Figure 4- 1. Major water mass flows in the Chukchi and Beaufort Seas 4-3
Figure 4- 2. Spring Leads for March 1994 in the Area of Coverage for the Oil and Gas NPDES
General Permit for Geotechnical Surveys and Related Activities in Federal Waters of
the Beaufort and Chukchi Seas 4-8
Figure 4- 3. Spring Leads for April 1994 in the Area of Coverage for the Oil and Gas NPDES
General Permit for Geotechnical Surveys and Related Activities in Federal Waters of
the Beaufort and Chukchi Seas 4-9
Figure 4- 4. Spring Leads for May 1994 in the Area of Coverage for the Oil and Gas NPDES
General Permit for Geotechnical Surveys and Related Activities in Federal Waters of
the Beaufort and Chukchi Seas 4-10
Figure 4- 5. Spring Leads for lune 1994 in the Area of Coverage for the Oil and Gas NPDES
General Permit for Geotechnical Surveys and Related Activities in Federal Waters of
the Beaufort and Chukchi Seas 4-11
Figure 4- 6. Spring Leads for March 2009 in the Area of Coverage for the Oil and Gas NPDES
General Permit for Geotechnical Surveys and Related Activities in Federal Waters of
the Beaufort and Chukchi Seas 4-12
Figure 4- 7. Spring Leads for April 2009 in the Area of Coverage for the Oil and Gas NPDES
General Permit for Geotechnical Surveys and Related Activities in Federal Waters of
the Beaufort and Chukchi Seas 4-12
Figure 4- 8. Spring Leads for May 2009 in the Area of Coverage for the Oil and Gas NPDES
General Permit for Geotechnical Surveys and Related Activities in Federal Waters of
the Beaufort and Chukchi Seas 4-13
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Figure 4- 9. Spring Leads for June 2009 in the Area of Coverage for the Oil and Gas NPDES
General Permit for Geotechnical Surveys and Related Activities in Federal Waters of
the Beaufort and Chukchi Seas 4-14
Figure 5- 1. Chukchi Sea Spring Lead System Seasonally Restricted Area (see Permit Part
II A.6.) ' 5-14
Figure 6- 1. Seasonal bowhead whale migration routes in the Chukchi Sea 6-14
Figure 6- 2. Seasonal bowhead whale migration routes in the Beaufort Sea 6-15
Figure 6- 3. Designated critical habitat areas in the Chukchi Sea 6-16
TABLES
Table 3-1. Typical metals concentrations in barite used in drilling fluids 3-3
Table 3-2. Estimated discharge volumes of waste streams associated with geotechnical activities
per borehole and per year 3-6
Table 3-3. Predicted dilution for drilling fluids discharges from geotechnical surveys 3-8
Table 3-4. Predicted dilution for combined drilling fluids and cuttings discharges from
geotechnical investigations 3-9
Table 3-5. Deposition thickness for combined drilling fluids and drill cuttings discharges from
geotechnical surveys 3-10
Table 3-6. Predicted dilution for miscellaneous discharges 3-12
Table 4-1. Concentrations of metals collected in Beaufort Sea sediments 4-18
Table 4-2. Concentrations of metals (mean ± SD) in sediment samples from Burger A 4-18
Table 4-3. Concentrations of dissolved metals (mean ± SD) for water samples 4-19
Table 5-1. Common fishes in the Chukchi and Beaufort Seas 5-4
Table 5-2. Shorebirds in the Beaufort and Chukchi Seas 5-15
Table 5-3. Raptors in the Beaufort and Chukchi Seas 5-16
Table 5-4. Seabirds in the Beaufort and Chukchi Seas 5-17
Table 5-5. Waterfowl in the Beaufort and Chukchi Seas 5-18
Table 5-6. Summary of Endangered Species Act-listed, proposed, and candidate species occurring
in the Area of Coverage 5-19
Table 5-7. EFH species potentially present in the Area of Coverage 5-21
Table 5-8. Percent total subsistence harvest by species 5-25
Table 6-1. Concentrations of metals in Beaufort Sea amphipods (in ppm) 6-6
Table 6-2. Deposition thickness for combined drilling fluids and cuttings discharges from
geotechnical surveys 6-8
Table 6-3. Summary of water-based drilling fluids and drill cuttings produced per borehole, by
depth (AOGA 2013) ' 6-11
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Table 6-4. Estimated discharge volumes of waste streams associated with geotechnical surveys
per borehole and per year compared with discharges associated with a single
exploration well in the Chukchi Sea 6-22
Table 6-5. Marine water quality criteria developed pursuant to CWA section 304(a)(1) 6-24
Table 6-6. Federal water quality criteria for metals 6-25
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ABBREVIATIONS AND ACRONYMS
ACC
Alaska Coastal Current
AKMAP
Alaska Monitoring and Assessment Program
As
Arsenic
BMP
Best Management Practices
BOEM
Bureau of Ocean Energy Management
BOD
Biochemical Oxygen Demand
BSEE
Bureau of Safety and Environmental Enforcement
Cd
Cadmium
CFR
Code of Federal Regulations
CPT
Cone Penetrometer Tests
CZMA
Coastal Zone Management Act
CWA
Clean Water Act
DP
Dynamic Positioning
EFH
Essential Fish Habitat
EJ
Environmental Justice
ELG
effluent limitation guidelines
EPA
U.S. Environmental Protection Agency
ESA
Endangered Species Act
FMP
fisheries management plan
FR
Federal Register
GP
General Permit
Hg
Mercury
JPC
Jumbo Piston Corer
LC50
lethal concentration to 50% test organisms
MLLW
mean lower low water
MMS
Minerals Management Service
MSD
Marine Sanitation Device
NHPA
National Historic Preservation Act
NMFS
National Marine Fisheries Service
NOI
Notice of Intent
NPDES
National Pollutant Discharge Elimination System
OCS
Outer Continental Shelf
ODCE
Ocean Discharge Criteria Evaluation
Pb
Lead
RSD
Relative Standard Deviation
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SLS Spring Lead System
SPP suspended particulate phase
TSS total suspended solids
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UNITS
Mg/g
micrograms per gram
l-ig/L
micrograms per liter
°C
degrees Celsius
°F
degrees Fahrenheit
bbl
barrels
bbl/day
barrels per day
cm
centimeters
cm/s
centimeters per second
ft
feet
ft/sec
feet per second
g
grams
gal
gallons
gal/day
gallons per day
h
hour
in
inches
kg
kilograms
km
kilometers
L
liters
m
meters
mg/kg
milligram per kilogram
mg/L
milligrams per liter
mi
miles
mm
millimeter
m/s
meters per second
nmi
nautical miles
ppm
part per million
ppt
part per thousand
Sv
Sverdrups
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1. INTRODUCTION
1.1. Purpose
The U.S. Environmental Protection Agency (EPA) is issuing a National Pollutant Discharge Elimination
System (NPDES) general permit for wastewater discharges associated with oil and gas geotechnical
surveys and related activities in federal waters of the Beaufort and Chukchi Seas (Geotechnical GP,
AKG-28-4300) off northern Alaska (Error! Reference source not found.). Section 403(c) of the Clean
Water Act (CWA) requires that NPDES permits for discharges into the territorial seas, the contiguous
zone, and the oceans, comply with EPA's Ocean Discharge Criteria. As the Geotechnical GP applies to
discharges to federal waters, the geographic scope of the Ocean Discharge Criteria Evaluation (ODCE)
extends seaward from the outer boundary of the territorial seas. The purpose of ODCE is to assess the
discharges authorized under the Geotechnical GP and evaluate the potential for unreasonable degradation
of the marine environment.
EPA's Ocean Discharge Criteria (Title 40 of the Code of Federal Regulations [CFR] Part 125, Subpart
M) set forth factors the Regional Administrator must consider when determining whether discharges to
the Outer Continental Shelf (OCS) will cause unreasonable degradation of the marine environment.
Unreasonable degradation is defined as follows (40 CFR 125.121(e)):
• Significant adverse changes in ecosystem diversity, productivity, and stability of the biological
community within the area of discharge and surrounding biological communities;
• Threat to human health through direct exposure to pollutants or through consumption of exposed
aquatic organisms; or
• Loss of aesthetic, recreational, scientific, or economic values that are unreasonable in relation to the
benefit derived from the discharge.
EPA regulations set out 10 criteria to consider when conducting an ODCE (40 CFR 125.122):
1. Quantities, composition, and potential for bioaccumulation or persistence of the pollutants to be
discharged.
2. Potential transport of such pollutants by biological, physical, or chemical processes.
3. Composition and vulnerability of the biological communities which may be exposed to such
pollutants, including the presence of unique species or communities of species, the presence of
species identified as endangered or threatened pursuant to the Endangered Species Act, or the
presence of those species critical to the structure or function of the ecosystem, such as those
important for the food chain.
4. Importance of the receiving water area to the surrounding biological community, including the
presence of spawning sites, nursery/forage areas, migratory pathways, or areas necessary for
other functions or critical stages in the life cycle of an organism.
5. Existence of special aquatic sites including, but not limited to, marine sanctuaries and refuges,
parks, national and historic monuments, national seashores, wilderness areas, and coral reefs.
6. Potential impacts on human health through direct and indirect pathways.
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Chukchi Seas
7. Existing or potential recreational and commercial fishing, including finfishing and shelltishing.
8. Any applicable requirements of an approved Coastal Zone Management Plan.
9. Other factors relating to the effects of the discharge as may be appropriate.
10. Marine water quality criteria developed pursuant to CWA section 304(a)(1).
On the basis of the analysis in this ODCE, the Regional Administrator will determine whether the general
permit may be issued. The Regional Administrator can make one of three findings:
1. The discharges will not cause unreasonable degradation of the marine environment and issue the
permit.
2. The discharges will cause unreasonable degradation of the marine environment, and deny the
permit.
3. There is insufficient information to determine, before permit issuance, that there will be no
unreasonable degradation of the marine environment, and issue the permit if, on the basis of
available information, that:
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• Such discharge will not cause irreparable harm1 to the marine environment during the period in
which monitoring will take place.
• There are no reasonable alternatives to the on-site disposal of these materials.
• The discharge will be in compliance with additional permit conditions set out under (40 CFR
125.123(d)).
1.2. Scope of Analysis
This document evaluates the impacts of waste water discharges associated with the Geotechnical GP for
geotechnical surveys and related activities in federal waters of the Beaufort and Chukchi Seas. Oil and
gas exploration, development and production activities, and their associated discharges, are not authorized
by the Geotechnical GP and are not evaluated in this document. Sections 2.2 and 6.9.2 discuss the
differences between exploration and geotechnical surveys and related activities and compare the
estimated volumes discharged associated with both types of activities.
This document relies extensively on information provided in the Final, Supplemental, and Draft
Environmental Impact Statements for BOEM Multiple Lease Sales 193, 209, 212, 217 and 221 (MMS
2007, 2008; BOEMRE 2010) and the Environmental Assessment for Sale 202 (MMS 2006); the Effects
of Oil and Gas Activities in the Arctic Ocean Draft and Supplemental Draft Environmental Impact
Statement (NMFS 201 la, 2013), and the ODCEs for EPA's Beaufort and Chukchi Exploration NPDES
General Permits (USEPA 2012b). The information presented here is a synthesis of those documents.
1.2.1. Geotechnical GP Area of Coverage
The Area of Coverage authorized by the Geotechnical GP includes federal waters of the Beaufort and
Chukchi Seas located seaward from the outer boundary of the territorial seas to the U.S./Russian border to
the west and extending eastward to the U.S./Canadian border. The Area of Coverage includes the lease
sale planning areas managed by the Bureau of Ocean Energy Management (BOEM) located in the OCS,
as well as those from the planning area boundary to the outer boundary of the territorial seas, where
geotechnical surveys and related activities could occur within federal waters.
1.2.2. Nature and Type of Activity
Geotechnical surveying is conducted to evaluate the seafloor and subsurface characteristics to:
• Delineate potential corridors for buried in-field flow lines and pipelines connecting different
prospects.
• Evaluate subsurface suitability for potential placement of ice-islands, jack-up rigs, production and
drilling platforms, and anchor structures for floating exploration drilling vessels.
• Delineate corridors for a potential buried export pipeline between the lease prospects and shore.
Drilling boreholes to varying depths and removing core samples are the primary activities conducted
during geotechnical surveying. Geotechnical related activities include feasibility testing of mudline cellar
construction equipment, testing and evaluation of trenching technologies, or other equipment that disturbs
the seafloor.
1 Irreparable harm is defined as significant undesirable effects occurring after the date of permit issuance which will
not be reversed after cessation or modification of the discharge [40 CFR 125.121(a)],
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The Geotechnical GP does not authorize discharges associated with any activities requiring either of the
following: (1) an Exploration Plan submitted to the Bureau of Ocean Energy Management (BOEM) for
approval pursuant to 30 CFR 550 Subpart B; or (2) an Application for Permit to Drill submitted to the
Bureau of Safety and Environmental Enforcement (BSEE) pursuant to 30 CFR 250 Subpart D.
Furthermore, t The Geotechnical GP does not authorize discharges associated with geotechnical activities
conducted at depths greater than 499 feet below the seafloor. The Geotechnical GP also does not
authorize discharges to state waters landward from the outer boundary of the territorial seas.
Ice is present much of the year in both the Chukchi and Beaufort Seas. While the majority of geotechnical
surveying activities would occur during the open water periods (i.e., July to October), it is possible that
within nearshore locations, the geotechnical surveys could occur during the winter months when landfast
ice is present. Related activities are expected to occur only during the open water season.
During the open water season, geotechnical surveys and related activities will be conducted using vessels,
such as floating, moored, jack-up and/or lift barges. The vessels may remain stationary relative to the
seafloor by means of a dynamic-positioning (DP) system, such as single-beam sonar and ultra-short
baseline acoustic positioning, which automatically controls and coordinates vessel movements using bow
and/or stern thrusters as well as the primary propeller(s). Vessels may also be anchored to the seafloor.
Winter geotechnical surveys during landfast ice periods will not require a vessel for the drilling activities;
the geotechnical equipment would be staged on the ice surface. Geotechnical surveys and related
activities generally do not require any chase/support vessels. The actual timing of geotechnical surveys
and related activities is strongly influenced by ice and weather conditions.
Geotechnical surveys are generally short in duration and, depending on targeted depth, range between 1 to
3 days to complete one borehole. The typical diameter of the boreholes ranges from 4 to 12 inches. For
purposes of this evaluation, and based on available information, EPA estimates that geotechnical
surveying in federal waters of the Beaufort and Chukchi Seas in any given year and performed by
multiple operators could consist of drilling approximately 100 boreholes. The depths of the boreholes,
borehole diameter, and numbers of boreholes differ depending on specific geotechnical program goals
(e.g., shallow pipeline, deep assessment, or deep platform assessment). The shallow pipeline borings will
generally be drilled no deeper than 50 feet below the seafloor. The deeper pipeline assessment soil
borings would be conducted at depths less than 499 feet and would be more typically range between 200
to 300 feet below the seafloor.
Of the estimated 100 boreholes that may be drilled per year in federal waters of both the Beaufort and
Chukchi Seas, approximately 1/3 of the boreholes would be shallow holes (< 50 feet below seafloor
surface), and the remaining boreholes would be collected at deeper depths (> 50 feet and < 499 feet below
the seafloor surface).
It is anticipated that geotechnical surveys would be conducted on a 24 hour per day schedule. Shallow
boreholes can be completed during one day. Deeper boreholes would require 2-3 days per hole to
complete. While it is not likely that a completed borehole will be plugged after samples have been
collected, if the substrate conditions warrant the borehole to be plugged to maintain sub-seafloor stability,
a heavy cement-bentonite slurry would be used.
Geotechnical related activities are estimated by EPA to occur at a frequency of two events per sea per
year, for a combined total of 20 events during the 5-year term of the permit (2014-2019). Each activity
would take approximately 7-10 days to complete.
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The Geotechnical GP will authorize discharges from geotechnical surveys and related activities and
associated discharges from geotechnical facilities for a permit term of five years, as discussed below.
1.2.3. Authorized Discharges
The Geotechnical GP covers facilities that discharge effluent associated with oil and gas geotechnical
surveys and related activities in federal waters of the Beaufort and Chukchi Seas. Authorized discharges
consist of the following:
• Discharge 001 - Water-Based Drilling Fluids and Drill Cuttings
• Discharge 002 - Deck Drainage
• Discharge 003 - Sanitary Wastes
• Discharge 004 - Domestic Wastes
• Discharge 005 - Desalination Unit Wastes
• Discharge 006 - Bilge Water
• Discharge 007 - Boiler Blowdown
• Discharge 008 - Fire Control System Test Water
• Discharge 009 - Non-Contact Cooling Water
• Discharge 010 - Uncontaminated Ballast Water
• Discharge 011 - Drill Cuttings (not associated with Drilling Fluids)
• Discharge 012 - Cement Slurry
EPA has applied the Effluent Limitation Guidelines (ELGs) for the Offshore Category of the Oil and Gas
Extraction Point Source Category, found at 40 CFR 435, Subpart A, to the water-based drilling fluids and
drill cuttings discharge (Discharge 001), and to other discharges as appropriate, based on Best
Professional Judgment (40 CFR 122.44). ELGs are technology-based national standards for controlling
conventional and toxic pollutants, based on the performance of treatment and control technologies.
1.3. Overview of Document
This ODCE provides an evaluation of the types of geotechnical surveys and related activities discharges,
estimated discharge volumes, and potential effects from discharges authorized under the Geotechnical GP
on receiving water quality, biological communities, and human receptors. Section 2 provides a general
description of the anticipated geotechnical surveys and related activities. Section 3 discusses the types and
estimated quantities of discharges, and describes the potential dispersion of the discharged materials.
Section 4 summarizes the physical environments in the Chukchi and Beaufort Seas. Section 5 summarizes
the aquatic communities and important species, including threatened and endangered species, and the
potential biological and ecological effects from discharges associated with geotechnical surveys and
related activities on those species. Section 6 addresses the ten ocean discharge criteria and evaluates
whether the Geotechnical GP will cause unreasonable degradation of the marine environment.
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2. OIL AND GAS GEOTECHNICAL SURVEYING AND RELATED
ACTIVITIES
2.1. Description of the Activities
Geotechnical surveys and related activities will include collection of soil borings to assess the seafloor
and subsurface conditions for potential installations of development and production platforms, ice islands,
anchor structures for floating exploration drilling vessels, and for buried oil delivery pipeline systems.
Examples of related activities include feasibility testing of mudline cellar construction equipment and
other equipment that disturbs the seafloor.
Geotechnical boring operations are generally short in duration and, depending on depths ranging from 50
feet to 499 feet below the seafloor surface, can be completed within 1 to 3 days per borehole.
Uncertainties associated with subsurface and/or weather conditions can reduce or extend this time. It is
anticipated that geotechnical drilling will be conducted on a 24 hour per day schedule. For purposes of
this evaluation, EPA estimates that approximately 100 geoteclimcal boreholes would be completed each
year in federal waters during the 5-year permit term. EPA assume^ that approximately 1/3 of the
boreholes would be shallow holes (< 50 feet), and 2/3 of the boreholes would be collected at deeper
depths (>50 feet and < 499 feet).
Spacing between borehole locations will vary. Initial pipeline spacing could range from boreholes 5 to 10
kilometers (16,500 to 32,800 feet) apart; however, as the pipeline route is refined overtime, the spacing
would need to be closer and could range from 0.5 to 1 kilometers (1,640 to 3,281 feet) apart. Other
geotechnical surveys may require spacing of approximately 500 feet between boreholes and up to % to 'A
mile (1,320 to 2,640 feet) between holes. In the case of evaluating jack up rig spud cans (cylindrically
shaped steel shoes with pointed ends, similar to a cleat, that are driven into the ocean floor to add stability
to the rig during operations), borings are typically spaced 3-5 meters (10 to 16.4 feet) apart. Depending
upon the stratigraphy, borings might be drilled in all 3 jack up rig spud can locations. The actual spacing
of these borings would then be dependent upon the jack up rig selected. However, spud cans are usually
on the order of 30-40 meters (98.4 to 131.2 feet) apart.
Geotechnical related activities could occur twice per year per sea, consisting of a total of 10 events per
sea, or 20 times over the 5-year term of the permit. A reasonable assumption of the scope of the
equipment feasibility testing activities may include seafloor disturbance of half the size and scale of the
mudline cellars completed by Shell in 2012 at the Burger and Sivulliq prospects, as feasibility testing of
equipment are not expected to result in construction of the entire mudline cellar. The feasibility testing
activities are expected to be completed approximately 7-10 days per event. Shell's mudline cellars are 20
feet wide and 40 feet deep.
Geotechnical surveys and related activities in the OCS must be conducted in accordance with BOEM and
BSEE regulations. Per BOEM regulations at 30 CFR 550.07 these types of geotechnical surveying
activities are considered ancillary activities. While a permit is not required from BOEM for ancillary
activities (30 CFR 550.105), prior to authorizing the activities, BOEM requires notification by the
operator at least 30 days in advance of planned surveys (30 CFR 550.208).
Water-based drilling fluids may be used to drill geotechnical boreholes, especially the deeper holes below
50 feet. The primary purpose of drilling fluids include: (1) providing a lubricant during the drilling
process; (2) helping to promote borehole stability; (3) helping to remove cuttings and debris from the hole
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so core samples can more easily be retrieved to the vessel; and (4) preventing the loss or damage of
equipment in the borehole.
It is anticipated that seawater will be used as the primary lubricant, particularly for the shallow holes.
However, hole sweeps, i.e., removal of cuttings from the borehole, may require the use of additives, such
as a salt water gel (i.e., Attapulgite Clay, Sepiolite, guargum or polymers) as a viscosifying agent. Deeper
holes may require the use of barite to increase the weight of the drilling fluid to increase fef hole stability.
The general make-up of water-based drilling fluids includes 6.4% salt water gel, 1.3% barite, and 92.3%
seawater.
Drilling fluids are mixed onboard the vessel in a "mud pit," either a round or square open-top container,
which has an approximate holding capacity of 800 to 1,600 gallons. A mud pit is fitted with a mud
agitator to keep the solids (drilling additives) from settling to the bottom of the container. Operators
intend to pre-mix large batches of drilling fluids in the mud pit, and depending on the sizes of the pit,
multiple batches may be mixed during a season and using the a single batch of fluids could be used to
drill multiple geotechnical boreholes. If solids become a problem in the mud pit during the season, then
the system will be "cleaned" by flushing the container with seawater, agitating, and discharging the
mixture at the seafloor. Any excess drilling fluids that remain in the mud pit after completion of the last
geotechnical borehole of the season will be discharged at the seafloor.
There are three primary technologies used to conduct geotechnical surveys:
• Seabed-Based Drilling System
• Jumbo Piston Corer Sampling System
• Conventional Wet-Rotary Drilling Technology
Seabed-based drilling systems are operated remotely from an A-frame onboard the facility. The seabed-
based drilling system is placed on the seafloor, and conducts cased-hole drilling to recover core samples
(each core is approximately 3m in length). The system has enough casings to drill to 100 feet below the
seafloor at one time, obtaining undisturbed core samples up to that depth. The system can also drill
upwards of 300 feet below the seafloor; however, there are no additional casings available for use beyond
100 feet. Seabed-based drilling systems do not require the use of drilling fluids as the borehole is cased
from the seafloor mudline to the bottom of the hole. The casing is removed upon completion of the
borehole. Due to the continuous core sampling ability, the amount of cuttings deposited at the seafloor is
much less compared to the conventional rotary drilling technology (discussed below). This technology
can conduct cone penetrometer tests (CPT). Tests performed using a CPT provide in situ data on site
stratigraphy (i.e., subsurface soil and rock layers), homogeneity of subsurface stratigraphy and pore-water
pressure; this data helps corroborate information obtained from laboratory analysis of the collected soil
boring samples.
The jumbo piston corer (JPC) has been used in Arctic conditions for borehole assessments upwards of 60
to 100 feet below the seafloor. The JPC is not a drilling technology, but rather a core sampling system,
which consists of a continuous coring tool that is lowered to the seafloor on a heavy lift winch operated
from an A-frame. The coring tool has a trigger device that is activated once the JPC nears the seafloor,
allowing the JPC to freefall from a set distance, driving the corer into the seafloor in one continuous
motion. Some JPC sampling systems utilize a weighted corehead (4,000-5,000 pounds), to retrieve soil
samples from greater depths. With either method, the JPC retrieves an undisturbed continuous core
sample between 60-100 feet in length (L. Davis, Shell, personal communication (9/25/2013) and Woods
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Hole Oceanographic Institution Seafloor Laboratory Sampling Website (accessed 9/25/2013)). Since the
JPC coring system does not conduct any drilling operations, it does not require the use of drilling fluids
and will not result in the discharge of cuttings at the seafloor. CPT soundings are generally conducted at a
site adjacent to the borehole location.
The conventional wet-rotary drilling technology is the primary system proposed for use in the Beaufort
and Chukchi Seas. The conventional techniques are generally performed from a variety of vessel types
with standard drill pipe and a top-drive drilling rig. These activities are generally performed from the
deck of a vessel positioned on location by either dynamic positioning utilizing satellite technology, or
with older vessels, a 4-point anchor spread (Shell 2014). The conventional wet-rotary drilling technology
has the ability to drill up to 499 feet below the seafloor. It generally requires the use of seawater (without
additives) or drilling fluids as a lubricant. The use of drilling fluids is dependent on the desired depth of
the borehole and the subsurface sediment characteristics. All drilling fluids and drill cuttings are
discharged at the seafloor.
Stationary vessels are used to conduct geotechnical surveying activities during the open water periods.
During the winter months, the drilling equipment and other supporting equipment would be staged on the
ice surface.
2.2. Comparison of Geotechnical Surveys to Exploration Activities
There are numerous differences between geotechnical surveys and related activities and exploration
drilling, including associated discharges associated with each activity. Some key differences include:
• Goals of the activities
• Sizes of the holes, drilling depths below the seafloor surface, and duration of the activities
• Types of equipment used
• Discharge location of drilling fluids and drill cuttings (Discharge 001)
• Discharge volumes
The primary goal under an exploration drilling program is to drill exploration wells to determine the
nature of potential hydrocarbon reservoirs. These wells include multiple casings and are drilled into
geologic formations that are typically 10,000 feet or more below the seafloor surface and can take
approximately 30 to 45 days to complete, depending on targeted depths and type of drill rig used.
Whereas, the focus of geotechnical surveying and related activity is to evaluate the characteristics of the
subsurface conditions and the feasibility of equipment for use in Arctic conditions, respectively. A
detailed description of these activities is provided above in Section 2.1.
The initial exploration well drilling process typically requires a large-diameter pipe, typically 36 inches,
called the conductor casing, that is hammered, jetted, or placed on the seafloor, depending on the
composition of the substrate (USEPA 1993). As the drill hole deepens, drilling is stopped periodically to
add sections of cylindrical steel casing through which the drill string operates. The casing keeps the walls
from collapsing and binding the drill string. To keep each string of casing in place, cement is pumped
down through the new string of casing, forced out of the open hole and back up the annular space outside
the casing, between it and the open hole, filling the voids. Once the cement is set outside the casing, the
drilling process can continue. The addition of casing can be continued until final well depth is reached.
Geotechnical surveys, on the other hand, do not involve multiple casings; rather, a coring tool is used to
collect and remove the soil cores.
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During exploration drilling, drilling fluids are pumped down through the drill pipe and ejected from the
drill bit into the well. The drilling fluids lift cuttings off the bottom of the well away from the drill bit, and
circulate the cuttings back to the surface through the annular space between the outside of the pipe and the
borehole. The cuttings and fluid are sent through a series of shaker tables and separators to remove the
fluid from the cuttings. The cuttings are then disposed through an outfall or disposal caisson, depending
on the type of exploratory drilling rig or unit.
The drilling fluid is returned to the mud pit for recycling. As drilling proceeds, these components
accumulate and eventually the fluid becomes too viscous for further use. When this happens, a portion of
the drilling fluid is discharged (to the water column), and water and additives, such as barite (barium
sulfate), are added to the remaining drilling fluid to bring concentrations back to proper levels, to
counteract reservoir pressures and prevent water from seeping into the well from the surrounding rock
formation (Neff 2008; USEPA 2000).
Unlike exploration drilling, seawater will be used as the primary lubricant to drill the shallow
geotechnical boreholes. In certain instances and for deeper boreholes, a salt water gel may be used to
assist with the displacement of cuttings from the borehole. Deeper holes may also require the use of barite
to increase the weight of the drilling fluid for hole stability. The drilling fluids and drill cuttings
associated with geotechnical surveys are pushed out of the borehole to the seafloor surface and discharged
at the seafloor.
As discussed in Sections 3.1 and 3.2, the discharges from oil and gas geotechnical surveys and related
activities authorized under the Geotechnical GP are similar in nature to those discharges associated with
exploration drilling activities. However, the expected discharge volumes from geotechnical surveys and
related activities are significantly less.
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3. AUTHORIZED DISCHARGES, ESTIMATED QUANTITIES, AND
MODELED BEHAVIOR
3.1. Authorized Discharges
Geotechnical surveys and related activities generate a number of waste streams that are discharged into
federal waters of the Chukchi and Beaufort Seas. Geotechnical surveys result in a disturbance of the
seafloor and may produce discharges consisting of soil, rock and cuttings materials, in addition to facility-
specific waste streams associated with stationary vessels. Related activities also result in a disturbance of
the seafloor and produce similar discharges.
The Geotechnical GP authorizes discharges of 12 waste streams listed in Section 1.2.3, subject to specific
requirements, and includes the general provisions:
• No discharge to the Spring Lead System within the 3-25 mile lease deferral area in the Chukchi Sea
prior to July 1.
• No discharge of water-based drilling fluids and drill cuttings (Discharge 001) during bowhead
hunting activities in the Chukchi and Beaufort Seas in the spring and fall, respectively.
• All mud pit discharges must occur at the seafloor.
• No discharge of any waste stream onto stable ice.
• No discharge of any waste stream if an oil sheen is detected either through visual observation or a
static sheen test.
• Chemicals added to any discharge must not exceed the maximum concentrations specified in the
EPA product registration labeling or the manufacturer's recommended concentration. An inventory
of all chemicals used must be kept and reported, including product names, registration number,
constituents, total quantities used, rates of use, where in the process they are used, and calculated
maximum concentrations in any discharged waste stream.
• Toxicity characterization must be conducted for the following waste streams if chemicals are added:
deck drainage (002); desalination unit wastes (005); bilge water (006); boiler blowdown (007); fire
control system test water (008); and non-contact cooling water (009). Effluent toxicity
characterization must be conducted weekly, or once per discharge event, as applicable.
• Report the volumes of each waste streams discharged.
3.2. Summary of Permit Changes
EPA has made several changes to the requirements of the Geotechnical GP from the draft version, as
discussed in this ODCE and the Fact Sheet that accompanies the Geotechnical GP re-proposal. The
changes include the following:
• Adding a seasonal prohibition to restrict all discharges within the 3-25 mile deferral area in the
Chukchi Sea 0:
• Clarifying Environmental Monitoring Program (EMP) requirements;
• Clarifying drilling fluid testing requirements for Drilling Fluids and Drill Cuttings (Discharge
001),
• Revising sampling frequencies for total residual chlorine and fecal coliform associated with
Sanitary Wastewater (Discharge 003); and
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• Clarifying Notice of Intent (NOI) submission requirements.
The seasonal prohibition to restrict all discharges within the 3-25 mile deferral area in the Chukchi Sea
corresponds with other federal regulatory requirements, such as the Bureau of Ocean Energy
Management's (BOEM) decision to defer the 3-25 mile area in the Chukchi Sea from leasing. The July 1
date is based on many factors, including the fact that offshore activities are traditionally conducted during
the open water (ice-free) season, which typically begins on or after July 1. and corresponds with NMFS'
estimate of completion of the spring bowhead migration (NMFS 2011) and its standard restriction under
the Marine Mammal Protection Act (MMPA) prohibiting vessel entry into the Chukchi Sea through the
Bering Strait prior to July 1 (NMFS 2012).
3.3. Description of the Discharges
3.3.1. Water-Based Drilling Fluids and Drill Cuttings (Discharge 001)
The Geotechnical GP authorizes the discharge of water-based drilling fluids and drill cuttings, including
the discharge of residual drilling fluids from the mud pit cleanup operations, which typically occurs once
per season, to the seafloor. Drilling fluids are not returned to the sea surface; they exit the borehole at the
seafloor at the top of the borehole with the cuttings.
Drilling fluids and drill cuttings discharges are subject to the following effluent limitations:
• Suspended particulate phase acute toxicity testing of drilling fluids (once per season batch).
• No discharge upon failure of the static sheen test (daily once per batch).
• No discharge of drilling fluids or drill cuttings generated using drilling fluids that contain diesel oil.
• Mercury and cadmium concentrations in stock barite are limited at 1 milligrams per kilogram
(mg/kg) and 3 mg/kg, respectively.
• Each batch of The drilling fluid systems must be analyzed for metals of concern if barite is used.
As discussed in the Fact Sheet for the permit re-proposal. EPA has removed the "once per batch'1 testing
requirements for suspended particulate phase toxicity and mercury and cadmium. The testing frequency
has been replaced with once per season, and sampling may be performed pre-season. If a new drilling
fluids formulation or lot/supply of stock barite is used during the season, then additional testing is
required.
Additionally, the Geotechnical GP requires environmental monitoring for two phases: Phase I site
characterization for all locations of geotechnical surveys and related activities, or submission of existing,
representative baseline data; and Phase II post-activity monitoring if water-based drilling fluids are used.
As discussed above, seawater will be used as the primary lubricant to collect the shallow geotechnical
boreholes. In certain instances, a salt water gel may be used to assist with the displacement of cuttings
from the borehole, called "borehole sweeps." Deeper holes may require the addition of barite to increase
the weight of the drilling fluid for hole stability. The general make-up of water-based drilling fluids for
geotechnical surveying is 92.3% seawater, 6.4% salt water gel, and 1.3% barite.
Examples of salt water gel, or visosifier agents include Attapulgite Clay, Sepiolite, guargum, or other
natural polymers. Attapulgite is a naturally occurring hydrated magnesium aluminum silicate clay
mineral. Guar gum is extracted from the Guar seed. The most important property of Guar Gum is its
ability to hydrate rapidly in cold water to attain uniform and very high viscosity. It is widely used in the
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oil and gas industry for controlling fluid and water loss and lubricating and cooling of drill bits
(http://npguar.com/en/guar_gum.php). Both attapulgite and Guar Gum are listed under the Oslo/Paris
Convention (for the Protection of the Marine Environment of the North-East Atlantic) (OSPAR) List of
Substances Used and Discharged Offshore which are Considered to Pose Little or No Risk to the
Environment (PLONOR) (AOGA 2013).
Barite is a chemically inert mineral that is heavy and soft, and is the principal weighting agent in water-
based drilling fluids. Barite is composed of over 90 percent barium sulfate, which is virtually insoluble in
seawater, and is used in geotechnical activities to increase borehole stability. Quartz, chert, silicates, other
minerals, and trace levels of metals can also be present in barite. Barite is a concern because it is known
to contain trace contaminants of several toxic heavy metals such as mercury, cadmium, arsenic,
chromium, copper, lead, nickel, and zinc (USEPA 2000).
Table 3-1 presents the metals concentrations generally found in barite that were the basis for the cadmium
and mercury limitations in the Oil and Gas Offshore Subcategory of the effluent limitation guidelines.
Table 3-1. Typical metals concentrations in barite used in drilling fluids
Metal
Barite concentrations
(mg/kg)
Aluminum
9,069.9
Antimony
5.7
Arsenic
7.1
Barium
359,747.0
Beryllium
0.7
Cadmium
1.1
Chromium
240.0
Copper
18.7
Iron
15,344.3
Lead
35.1
Mercury
0.1
Nickel
13.5
Selenium
1.1
Silver
0.7
Thallium
1.2
Tin
14.6
Titanium
87.5
Zinc
200.5
Source: USEPA (1993) 821-R-93-003 (Offshore ELG Development Document); Table XI-6
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
3-3
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Drilling fluids will be mixed as a batch and used to drill multiple geotechnical boreholes. The
composition of drilling fluids may be adjusted from one borehole to the next. Given the relatively shallow
depths of the geotechnical boreholes as compared to exploration drilling, it is expected that one batch of
drilling fluids would be used during the season; however, it is possible that multiple batches may be used
for one hole. The Geotechnical GP requires testing for suspended particulate phase toxicity and mercury
and cadmium in stock barite no less than once per season, with additional testing required if the drilling
fluids formulation or lot/supply of stock barite changes during the course of a drill season.
3.4. Other Discharges
In addition to water-based drilling fluids and drill cuttings (Discharge 001). the Geotechnical GP
authorizes 11 other waste streams for discharge. For purposes of the ODCE, the discussion of sanitary and
domestic wastewater is combined. Discharges 002, 003, 004, 005, 006, 007, 008, 009, and 010 are also
referred collectively as "miscellaneous discharges" in the ODCE. Discharge 011 includes cuttings
materials that are not associated with drilling fluids, i.e. where no drilling chemicals or additives are
added. The Geotechnical GP includes specific effluent limitations, monitoring and reporting requirements
for each of the waste streams.
3.4.1. Deck Drainage (Discharge 002)
Deck drainage refers to any wastewater generated from deck washing, spillage, rainwater, and runoff
from curbs, gutters, and drains, including drip pans and wash areas. Such drainage could include
pollutants such as detergents used in deck and equipment washing, oil, grease, and drilling fluids spilled
during normal operations.
When water from rainfall or from equipment cleaning comes in contact with oil-coated surfaces, the water
becomes contaminated and must be treated prior to discharge. The Geotechnical GP requires separate area
drains for washdown and rainfall that may be contaminated with oil and grease from those area drains that
would not be contaminated so the waste streams are not comingled. The permit also requires all deck
drainage contaminated with oil and grease to be treated through an oil-water separator prior to discharge,
monitoring for pH, and effluent toxicity characterization if chemicals are used in the system.
3.4.2. Sanitary and Domestic Waste (Discharge 003 and 004)
Sanitary waste (Discharge 003) is human body waste discharged from toilets and urinals and treated with
a marine sanitation device (MSD). The discharge is subject to secondary treatment and consists of
chlorinated effluent. Domestic waste (Discharge 004) refers to gray water from sinks, showers, laundries,
safety showers, eyewash stations, and galleys. Gray water can include kitchen solids, detergents,
cleansers, oil and grease. The Geotechnical GP prohibits the discharge of floating solids, garbage, debris,
sludge, deposits, foam, scum, or other residues of any kind. In cases where sanitary and domestic wastes
are mixed prior to discharge, the most stringent discharge limitations for both discharges must apply to
the mixed waste stream.
The volume of sanitary and domestic wastes varies widely with time, occupancy, facility characteristics
and operational situation. Pollutants of concern in sanitary waste controlled by the Geotechnical GP
include biochemical oxygen demand, pH, total suspended solids (TSS), fecal coliform bacteria, and total
residual chlorine.
3-4
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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3.4.3. Desalination Unit Waste (Discharge 005)
Desalination unit waste is residual high-concentration brine, associated with the process of creating
freshwater from seawater. The concentrate is similar to sea water in chemical composition; however,
anion and cation concentrations are higher. The Geotechnical GP requires pH monitoring and effluent
toxicity characterization if chemicals are added.
3.4.4. Bilge Water (Discharge 006)
Bilge water is seawater that collects in the lower internal parts of a vessel hull. It could become
contaminated with oil and grease and with solids, such as rust, when it collects at low points in the bilges.
The Geotechnical GP requires treatment of all bilge water through an oil-water separator before
discharge, monitoring for pH, and effluent toxicity characterization if chemicals are added. Additionally,
the permit includes a best management practices (BMP) provision requiring the operator to ensure that
intake and exchange activities minimize the risk of introducing non-indigenous/invasive species to both
the Chukchi and Beaufort Seas.
3.4.5. Boiler Blowdown (Discharge 007)
Boiler blowdown is the discharge of water and minerals drained from boiler drums to minimize solids
buildup in the boiler. The Geotechnical GP requires monitoring for pH and effluent toxicity
characterization if chemicals are added.
3.4.6. Fire Control System Test Water (Discharge 008)
Fire control system test water is seawater that is released while training personnel in fire protection, and
the testing and maintaining of fire protection equipment. Similar to the other miscellaneous discharges
discussed above, the Geotechnical GP requires monitoring for pH and effluent toxicity characterization if
chemicals are added.
3.4.7. Non-Contact Cooling Water (Discharge 009)
Non-contact cooling water is seawater that is used for non-contact, once-through cooling of various
pieces of equipment on the vessel. Non-contact cooling water consists of one of the highest volumes of
the discharges authorized under the Geotechnical GP. The volume of non-contact cooling water depends
on the configuration of heat exchange systems. Some systems use smaller volumes of water that are
heated to a greater extent, resulting in a higher temperature differential between waste water and receiving
water. Other systems use larger volumes of water to cool equipment, resulting in a smaller difference
between the temperatures of waste water and receiving water. Depending on the heat exchanger materials
and the system's design, biocides or oxidizing agents might be needed to control biofouling on condenser
tubes and intake and discharge conduits.
The Geotechnical GP requires monitoring for pH, temperature, and effluent toxicity characterization if
chemicals are added. In addition, the permit establishes a pH limit of 6.5-8.5 standard units if chemicals
are added, and includes a BMP provision requiring the operator to ensure that cooling water intake
structures are selected and operated to minimize impingement and entrainment of fish and shellfish.
3.4.8. Uncontaminated Ballast Water (Discharge 010)
Ballast water is seawater added or removed to maintain the proper ballast floater level and vessel draft.
The Geotechnical GP requires all ballast water contaminated with oil and grease to be treated through an
oil-water separator before discharge. The permit also requires monitoring for pH.
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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3.4.9. Drill Cuttings (not associated with Drilling Fluids) (Discharge 011)
Drill cuttings are small rock particles, varying in size from fine silt to gravel, deposited onto the seafloor
surface as a result of boring activities. This waste stream is includes cuttings not associated drilling fluids.
Cuttings materials are either pushed out of the borehole or flushed out by the use of seawater. This
discharge is generally associated with shallow boreholes and the geotechnical related activities that may
include feasibility testing and evaluation of oil and gas technologies, such as mudline cellar construction
or trenching that would disturb the seafloor surface.
3.4.10. Excess Cement Slurry (Discharge 012)
Most geotechnical boreholes will not be plugged, however, in rare cases the substrate conditions may
warrant the holes to be plugged to ensure sub-seafloor stability. If needed, a heavy bentonite slurry would
be used.
3.5. Estimated Discharge Quantities
The estimated scope of geotechnical surveys in the Beaufort and Chukchi Seas in any given year
performed by multiple operators within federal waters is approximately 100 boreholes. Discharge
estimates for geotechnical surveys and related activities were derived by EPA using available information
and best professional judgment. The tables below provide an estimate of potential volumes that could be
discharged for each waste stream during the 5-year term of the Geotechnical GP. Table 3-2 provides
estimated discharge volumes of waste streams, by depth and per year, associated with geotechnical
surveying activities to be conducted in federal waters of the Beaufort and Chukchi Seas. All boreholes are
assumed to require the use of water-based drilling fluids and drill cuttings, though in reality, most shallow
boreholes may only utilize seawater.
Table 3-2. Estimated discharge volumes of waste streams associated with geotechnical activities per
borehole and per year
Discharge
Estimated Discharge
Volume1 per Shallow2
Geotechnical
Borehole
Estimated Discharge
Volumes per Deep3
Geotechnical
Boreholes
Estimated Discharge
Volumes per Year4
< 50 feet
> 50 and < 499 feet
100 boreholes
U.S. Liquid Gallons
Water-based drilling fluids and drill
cuttings (001)5
7,000s
21,0006
1,232,000s
Deck drainage (002)
2,000
6,000
352,000
Sanitary wastes (003)
2,473
7,418
435,186
Domestic wastes (004)
21,000
63,000
3,696,000
Desalination unit wastes (005)
109,631
328,892
19,294,977
Bilge water (006)
3,170
9,510
557,927
Boiler blowdown (007)
N/A
--
--
Fire control system test water (008)
2,000
6,000
352,000
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ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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Non-contact cooling water (009)
2,726,234
8,178,703
479,817,254
Uncontaminated ballast water (010)
504
1,512
88,704
Drill cuttings (not associated with
drilling fluids) (Oil)7
N/A8
--
--
Cement slurry (012)
1
3
114
1 Source: Shell's NPDES Permit Application Form 2C (April 3, 2013) andL. Davis (personal communication, August 7, 2013).
2 Shallow boreholes: Depth < 50 feet
3 Deep boreholes: Depth >50 feet and < 499 feet
4 Source: AOGA 2013
5 Discharged at the seafloor and may include mud pit cleanup materials. To provide a conservative estimate, EPA assumes all
100 boreholes would utilize water-based drilling fluids. Also, approximately 4,800 gallons of drilling fluids is estimated to be
discharged from the mud pit per year. This discharge volume is in addition to the Discharge 001 estimated volume presented in
the table above.
0 Conservative estimates that include entrained seawater and do not account for soil boring sample removal.
7 Discharge 011 includes the cuttings materials generated from geotechnical related activities. For purposes of the ODCE, EPA
estimates that approximately 235,000 gallons of cuttings materials would be discharged from equipment feasibility testing
activities during the 5-year permit term.
8 Discharge 011 may also include cuttings from shallow boreholes. While the majority of shallow boreholes may not use water-
based drilling fluids, to provide a conservative estimate, EPA assumes drilling fluids would be used and the volumes are
captured above under Discharge 001.
As discussed in Section 3.1.1, above, mud pit cleanup would be discharged as a batch at the end of a
geotechnical surveying season. Estimated discharge volumes have not been provided by industry;
therefore, for purposes of this ODCE evaluation, EPA assumes that the mud pit capacities are either 800
or 1,600 gallons. If four different companies operate each season and all use drilling fluids to collect a
total of 100 boreholes, then approximately 4,800 gallons of mud pit materials (seawater and additives)
would be discharged per year at the seafloor under Discharge 001 (USEPA 2013).
The discharges of cuttings materials associated with geotechnical related activities would occur under
Discharge 011. EPA assumes that those activities would occur two times per year per sea (i.e., four
geotechnical related activities would occur each year), consisting of a total of 20 events over the five year
term of the permit. The duration of geotechnical related activities would consist of approximately 7-10
days per event. Furthermore, EPA assumes each equipment feasibility test would disturb an area half the
dimensions of a typical mudline cellar, resulting in a seafloor disturbance of approximately 10 feet wide
by 20 feet deep. Therefore, one feasibility testing activity would result in an approximate discharge
volume of 11,750 gallons for a total volume of 235,000 gallons of cuttings discharged during the 5-year
term of the permit. These assumptions are based in part on discharges associated with mudline cellar
construction reported by Shell for its Burger A and Sivulliq N/G leases in the Chukchi and Beaufort Sea,
respectively, and on best professional judgment.
Discharge 011 may also include cuttings from shallow boreholes. While the majority of shallow
boreholes may not use water-based drilling fluids, to provide a conservative estimate, EPA assumes
drilling fluids would be used and the volumes are captured under Discharge 001.
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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3.6. Predictive Modeling of Discharges
3.6.1. Dilution of Suspended Drilling Fluid and Drill Cuttings
EPA applied a two-dimensional advection diffusion equation to predict dilution of drilling fluids and drill
cuttings. The first analysis isolated the drilling fluids discharge, and included scenarios for the range of
expected discharge rates (172 to 556 gallons per day (gal/day)) and current speeds (0.02 to 0.4 meters per
second (m/s). Dilution was estimated at three distances from the location of the borehole on the surface of
the seafloor (1, 10, and 100 meters). Across all scenarios, the predicted dilution ranges from a low of 6.5
(1 meter distance, 556 gal/day discharge, and 0.02 m/s current) to a high of 4188 (100 meter distance, 172
gal/day discharge, and 0.4 m/s current). Because the analysis is based on simple lateral spreading, the
predicted dilution at 100 meters is 10 times the dilution at 1 meter (i.e., proportional to the square root of
the radius) for a given current speed and discharge rate. At a fixed distance of 100 meters, across all
current speeds and discharge rates, the dilution ranges from 65 to 4188. The results for dilution of drilling
fluids discharges are shown in Table 3-3.
Table 3-3. Predicted dilution for drilling fluids discharges from geotechnical surveys
Case ID
Current
Speed
(m/s)
Discharge
Rate
(gal/day)
Discharge
Rate
(cm/s)
Dilution
Factor
at 1 meter
Dilution
Factor at
10 meters
Dilution
Factor at
100 meters
101
0.02
172
7.57 E-6
20.9
66.2
209.4
102
0.02
333
14.65 E-6
10.8
34.2
108.2
103
0.02
556
24.46 E-6
6.5
20.5
64.8
104
0.10
172
7.57 E-6
104.7
331.1
1047.0
105
0.10
333
14.65 E-6
54.1
171.1
541.1
106
0.10
556
24.46 E-6
32.4
102.5
324.1
107
0.30
172
7.57 E-6
314.1
993.4
3141.0
108
0.30
333
14.65 E-6
162.3
513.3
1623.0
109
0.30
556
24.46 E-6
97.2
307.4
972.2
110
0.40
172
7.57 E-6
418.8
1325.0
4188.0
111
0.40
333
14.65 E-6
216.4
684.4
2164.0
112
0.40
556
24.46 E-6
129.6
409.9
1296.0
The same analytical approach was used for the combined discharge of drilling fluids and drill cuttings.
The results are linearly proportional to the discharge rate, and the total discharge is assumed to be
comprised of nearly equal parts cuttings and drilling fluids. The expected total discharge rate ranges from
322 to 1093 gal/day. The predicted dilution ranges from a low of 3.3 (1 meter distance, 1093 gal/day
discharge, and 0.02 m/s current) to a high of 2238 (100 meters distance, 322 gal/day discharge, and
0.4m/s current). At 100 meters, across all scenarios, the dilution ranges from 33 to 2238. The results are
presented below in Table 3-4.
3-8
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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Table 3-4. Predicted dilution for combined drilling fluids and cuttings discharges from geotechnical
investigations
Case ID
Current
Speed
(m/s)
Discharge
Rate
(gal/day)
Discharge
Rate
(cm/s)
Dilution
Factor at
1 m
Dilution
Factor at
10 meters
Dilution
Factor at
100 meters
101
0.02
322
14.17 E-6
11.2
35.4
111.9
102
0.02
651
28.64 E-6
5.5
17.5
55.3
103
0.02
1093
48.08 E-6
3.3
10.4
33.0
104
0.10
322
14.17 E-6
55.9
176.9
559.4
105
0.10
651
28.64 E-6
27.7
87.5
276.8
106
0.10
1093
48.08 E-6
16.5
52.1
164.9
107
0.30
322
14.17 E-6
167.8
530.7
1678.0
108
0.30
651
28.64 E-6
83.0
262.6
830.3
109
0.30
1093
48.08 E-6
49.5
156.4
494.6
110
0.40
322
14.17 E-6
223.8
707.6
2238.0
111
0.40
651
28.64 E-6
110.7
350.1
1107.0
112
0.40
1093
48.08 E-6
65.9
208.5
659.5
3.6.2. Thickness and Extent of Drilling Fluids and Drill Cuttings
EPA estimated the thickness of deposition of drilling fluids and drill cuttings based on the advection
diffusion equation. The same range of ambient currents and discharge rates were used as in the dilution
analysis (see Section 3.4.1, above). Similar to the dilution analysis, the predicted thickness of deposition
at 100 meters is 10 times the thickness at 1 meter (i.e., proportional to the square root of the radius) for a
given current speed and discharge rate. Across all scenarios, the predicted thickness ranges from a high of
30 millimeters (1 meter distance, 1093 gal/day discharge, and 0.02 m/s current) to a low of 0.04
millimeters (100 meters distance, 322 gal/day discharge, and 0.4 m/s current). At 100 meters, across all
current speeds and discharge rates, the thickness of deposition for the combined discharge of drilling
fluids and drill cuttings ranges from 0.04 to 3 millimeters (mm).
For detailed information about the model and simulation results, see Results from Geotechnical Surveying
and Related Activities Modeling Scenarios Technical Memorandum, (Modeling Technical Memorandum)
dated November 12, 2013 (Hamrick 2013).
The results of the combined deposition of drilling fluids and drill cuttings are shown below in Table 3-5.
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
3-9
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Table 3-5. Deposition thickness for combined drilling fluids and drill cuttings discharges from
geotechnical surveys
Case ID
Current
Speed
(m/s)
Discharge
Rate
(gal/day)
Discharge
Rate
(cm/s)
Thickness at
lm
(mm)
Thickness
at 10 m
(mm)
Thickness
at 100 m
(mm)
101
0.02
322
14.17 E-6
8.94
2.83
0.89
102
0.02
651
28.64 E-6
18.07
5.71
1.81
103
0.02
1093
48.08 E-6
30.33
9.59
3.03
104
0.10
322
14.17 E-6
1.79
0.57
0.18
105
0.10
651
28.64 E-6
3.61
1.14
0.36
106
0.10
1093
48.08 E-6
6.06
1.92
0.61
107
0.30
322
14.17 E-6
0.60
0.19
0.06
108
0.30
651
28.64 E-6
1.20
0.38
0.12
109
0.30
1093
48.08 E-6
2.02
0.64
0.20
110
0.40
322
14.17 E-6
0.45
0.14
0.04
111
0.40
651
28.64 E-6
0.90
0.29
0.09
112
0.40
1093
48.08 E-6
1.52
0.48
0.15
3.6.3. Dilution of Miscellaneous Discharges
EPA has also conducted an analysis to estimate the dilution of the aqueous phase of discharges from
geotechnical activity under the permit (Tetra Tech 2013). Similar to the model used for dilution of drilling
fluids and drill cuttings discharges, the two-dimensional advection diffusion equation was used to predict
dilution for miscellaneous discharges, such as deck drainage, desalination unit wastes, and non-contact
cooling water.
The analysis of miscellaneous discharges covered a larger number of scenarios than the drilling fluids and
drill cuttings discharges. Because drilling fluids and drill cuttings are always to be discharged at the
seafloor and are not positively buoyant, the range of scenarios for drilling fluids and drill cuttings
discharge is narrower than the range of miscellaneous discharges, which can be discharged at a wider
range of depths. In addition, there is a wide range of discharge rates for the miscellaneous discharges.
The analysis included a range of discharge rates (50 to 62,500 bbl/day), discharge depths (2 to 50 meters),
and current speeds (0.02 to 0.4 m/s). The range of depths analyzed was wider than the depth of discharge
expected under the permit (20 to 50 meters). Dilution was estimated at three distances from the location
of the outfall (10, 100, and 1000 meters). Across all scenarios and a minimum depth of 20 meters, the
predicted dilution factor ranges from a low of 12 (case 145: 20 meters depth, 10 meters distance, 62,500
bbl/day discharge, and 0.02 m/s current) to a high over 12 million (case 196: 50 meters depth, 1000
meters distance, 50 bbl/day discharge, and 0.4 m/s current). Again, because the analysis is based on
3-10
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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simple lateral spreading, the predicted dilution is proportional to the square root of the radius) for a given
scenario.
For the worst case scenario (case 145), the dilution factor ranges from 12 at a distance of 10 meters to 123
at a distance of 1000 meters. For this case, if the ambient concentration of a pollutant of concern is zero,
then the concentration of that pollutant at a distance of 10 meters will be 1/12th or 8 percent of the
discharge concentration. If the pollutant is present in the ambient water, the concentration at a given
distance from the outfall will be function of the dilution, discharge concentration, and ambient
concentration.
This dilution analysis does not include buoyancy-based mixing due to salinity and/or temperature
differentials between the discharge and ambient waters. Since buoyancy processes increase dilution, this
analysis provides conservative estimates of dilution.
The results for all scenarios miscellaneous discharges are shown in Table 3-6.
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
3-11
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Table 3-6. Predicted dilution for miscellaneous discharges
Case ID
Effective
Water
Depth
(meters)
Current
Speed
(rn/s)
Discharge
Rate
(bbl/day)
Discharge
Rate
(cm/s)
Dilution
Factor
at 10 meters
Dilution
Factor at
100 meters
Dilution
Factor at
1000 meters
101
2
0.02
50
0.00009
487
1541
4874
102
2
0.02
250
0.00046
97
308
975
103
2
0.02
1250
0.00230
20
62
195
104
2
0.02
2500
0.00460
10
31
97
105
2
0.02
62500
0.11500
0
1
4
106
2
0.10
50
0.00009
2437
7706
24370
107
2
0.10
250
0.00046
487
1541
4874
108
2
0.10
1250
0.00230
97
308
975
109
2
0.10
2500
0.00460
49
154
487
110
2
0.10
62500
0.11500
2
6
20
111
2
0.30
50
0.00009
7311
23120
73110
112
2
0.30
250
0.00046
1462
4624
14620
113
2
0.30
1250
0.00230
292
925
2924
114
2
0.30
2500
0.00460
146
462
1462
115
2
0.30
62500
0.11500
6
19
58
116
2
0.40
50
0.00009
9748
30830
97480
117
2
0.40
250
0.00046
1950
6165
19500
118
2
0.40
1250
0.00230
390
1233
3899
119
2
0.40
2500
0.00460
195
617
1950
120
2
0.40
62500
0.11500
8
25
78
121
5
0.02
50
0.00009
1927
6092
19270
122
5
0.02
250
0.00046
385
1218
3853
123
5
0.02
1250
0.00230
77
244
771
124
5
0.02
2500
0.00460
39
122
385
125
5
0.02
62500
0.11500
2
5
15
3-12
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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Table 3-6. Miscellaneous discharge cases (continued)
Case ID
Effective
Water
Depth
(meters)
Current
Speed
(rn/s)
Discharge
Rate
(bbl/day)
Discharge
Rate
(cm/s)
Dilution at
10 meters
Dilution at
100 meters
Dilution at
1000 meters
126
5
0.10
50
0.00009
9633
30460
96330
127
5
0.10
250
0.00046
1927
6092
19270
128
5
0.10
1250
0.00230
385
1218
3853
129
5
0.10
2500
0.00460
193
609
1927
130
5
0.10
62500
0.11500
8
24
77
131
5
0.30
50
0.00009
28900
91390
289000
132
5
0.30
250
0.00046
5780
18280
57800
133
5
0.30
1250
0.00230
1156
3655
11560
134
5
0.30
2500
0.00460
578
1828
5780
135
5
0.30
62500
0.11500
23
73
231
136
5
0.40
50
0.00009
38530
121800
385300
137
5
0.40
250
0.00046
7706
24370
77060
138
5
0.40
1250
0.00230
1541
4874
15410
139
5
0.40
2500
0.00460
771
2437
7706
140
5
0.40
62500
0.11500
31
97
308
141
20
0.02
50
0.00009
15410
48740
154100
142
20
0.02
250
0.00046
3083
9748
30830
143
20
0.02
1250
0.00230
617
1950
6165
144
20
0.02
2500
0.00460
308
975
3083
145
20
0.02
62500
0.11500
12
39
123
146
20
0.10
50
0.00009
77060
243700
770600
147
20
0.10
250
0.00046
15410
48740
154100
148
20
0.10
1250
0.00230
3083
9748
30830
149
20
0.10
2500
0.00460
1541
4874
15410
150
20
0.10
62500
0.11500
62
195
617
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit 3-13
Revised - August 2014
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Table 3-6. Miscellaneous discharge cases (continued)
Case ID
Effective
Water
Depth
(meters)
Current
Speed
(rn/s)
Discharge
Rate
(bbl/day)
Discharge
Rate
(cm/s)
Dilution at
10 meters
Dilution at
100 meters
Dilution at
1000 meters
151
20
0.30
50
0.00009
231200
731100
2312000
152
20
0.30
250
0.00046
46240
146200
462400
153
20
0.30
1250
0.00230
9248
29240
92480
154
20
0.30
2500
0.00460
4624
14620
46240
155
20
0.30
62500
0.11500
185
585
1850
156
20
0.40
50
0.00009
308300
974800
3083000
157
20
0.40
250
0.00046
61650
195000
616500
158
20
0.40
1250
0.00230
12330
38990
123300
159
20
0.40
2500
0.00460
6165
19500
61650
160
20
0.40
62500
0.11500
247
780
2466
161
40
0.02
50
0.00009
43590
137900
435900
162
40
0.02
250
0.00046
8719
27570
87190
163
40
0.02
1250
0.00230
1744
5514
17440
164
40
0.02
2500
0.00460
872
2757
8719
165
40
0.02
62500
0.11500
35
110
349
166
40
0.10
50
0.00009
218000
689300
2180000
167
40
0.10
250
0.00046
43590
137900
435900
168
40
0.10
1250
0.00230
8719
27570
87190
169
40
0.10
2500
0.00460
4359
13790
43590
170
40
0.10
62500
0.11500
174
551
1744
171
40
0.30
50
0.00009
653900
2068000
6539000
172
40
0.30
250
0.00046
130800
413600
1308000
173
40
0.30
1250
0.00230
26160
82710
261600
174
40
0.30
2500
0.00460
13080
41360
130800
175
40
0.30
62500
0.11500
523
1654
5231
3-14 ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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Table 3-6. Miscellaneous discharge cases (continued)
Case ID
Effective
Water
Depth
(meters)
Current
Speed
(rn/s)
Discharge
Rate
(bbl/day)
Discharge
Rate
(cm/s)
Dilution at
10 meters
Dilution at
100 meters
Dilution at
1000 meters
176
40
0.40
50
0.00009
871900
2757000
8719000
177
40
0.40
250
0.00046
174400
551400
1744000
178
40
0.40
1250
0.00230
34870
110300
348700
179
40
0.40
2500
0.00460
17440
55140
174400
180
40
0.40
62500
0.11500
698
2206
6975
181
50
0.02
50
0.00009
60920
192700
609200
182
50
0.02
250
0.00046
12180
38530
121800
183
50
0.02
1250
0.00230
2437
7706
24370
184
50
0.02
2500
0.00460
1218
3853
12180
185
50
0.02
62500
0.11500
49
154
487
186
50
0.10
50
0.00009
304600
963300
3046000
187
50
0.10
250
0.00046
60920
192700
609200
188
50
0.10
1250
0.00230
12180
38530
121800
189
50
0.10
2500
0.00460
6092
19270
60920
190
50
0.10
62500
0.11500
244
771
2437
191
50
0.30
50
0.00009
913900
2890000
9139000
192
50
0.30
250
0.00046
182800
578000
1828000
193
50
0.30
1250
0.00230
36550
115600
365500
194
50
0.30
2500
0.00460
18280
57800
182800
195
50
0.30
62500
0.11500
731
2312
7311
196
50
0.40
50
0.00009
1218000
3853000
12180000
197
50
0.40
250
0.00046
243700
770600
2437000
198
50
0.40
1250
0.00230
48740
154100
487400
199
50
0.40
2500
0.00460
24370
77060
243700
200
50
0.40
62500
0.11500
975
3083
9748
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit 3-15
Revised - August 2014
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4. DESCRIPTION OF THE EXISTING PHYSICAL ENVIRONMENT
4.1. Climate and Meteorology
The Area of Coverage is in the Arctic Climate Zone and is characterized by cold temperatures, nearly
constant wind, and low precipitation. Important meteorological conditions that could affect the
Geotechnical GP discharges include air temperature, rain and snowfall, and wind speed and direction.
Air temperature controls the ice formation and break-up and whether ice would need to be managed as
part of Geotechnical GP activities. Precipitation determines the quantity and concentration of pollutants
discharged from deck drainage and wind speed and direction influence coastal oceanographic conditions.
The following sections describe the physical setting of the Area of Coverage of the Geotechnical GP.
4.1.1. Air Temperature
Subfreezing temperatures prevail for most of the year throughout both the Chukchi and Beaufort Seas. An
extreme low temperature of -62 "F has been recorded at Prudhoe Bay. Prolonged periods of high winds,
during winter, lead to extreme ice pressures and dangerous wind-chill conditions. There is brief summer
season usually lasting from June to August, with temperatures generally above the freezing point with
precipitation usually falling in the form of rain (MMS 2008).
The Arctic Climate Impact Assessment (ACIA 2005) summarizes spatial and temporal temperature trends
in the Arctic according to observations from the Global Historical Climatology Network database
(Peterson and Vose 1997 cited in MMS 2008) and the Climate Research Unit database (Jones and
Moberg 2003 cited in MMS 2008). Both time series for stations north of latitude 60°N show a statistically
significant warming trend of 0.16 °F per decade for the period of 1900 to 2003 (ACIA 2005 cited in
MMS 2008). In general, temperatures increased from 1900 to the mid-1940s, decreased until about the
mid-1960s, and then increased again to the present. When temperature trends are broken down by season,
the largest changes occurred in winter and spring. The greater amount of warming in the Arctic compared
to that for the globe as a whole is consistent with climate model projections (IPCC 2007 cited in MMS
2008). As discussed in Section 6.2, temperature would not have a substantial effect on the behavior of the
discharges, and therefore changes in temperature are not expected to affect the discharges.
4.1.2. Precipitation
There is great seasonal variation in precipitation in the Beaufort-Chukchi Sea region. Rainfall is usually
light during the short summer months; however, heavier rainstorms occasionally occur. These heavier
rainstorms typically occur during July and August (Alaska Annual Temperature Summary (WRCC 2011
cited in NMFS 2013)).
Along the Beaufort Sea coast, total annual precipitation ranges from four to six inches, while the average
annual snowfall ranges from approximately 30 to 42 inches. The Chukchi Sea coast receives more annual
precipitation and average annual snowfall. Annual precipitation ranges from four to 11 inches while
average snowfall ranges from approximately 40 to 53 inches per year (Alaska Annual Temperature
Summary (WRCC 2011 cited in NMFS 2013)).
4.1.3. Winds
Surface winds exhibit seasonally complicated flow regimes in the Chukchi and Beaufort Seas and have
considerable directional variation along the coast and offshore. Along the Beaufort Sea coast, onshore
winds are predominantly from the east, east-northeast, and northeast, while offshore winds most
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit 4-1
Revised - August 2014
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commonly come from the west, west-southwest, and southwest. Winter winds along the Chukchi Sea
coast exhibit a strong northerly prevalence; however, wind directions can vary from northwest in the
western part of the sea to northeast in the eastern part. During the summer, the Chukchi Sea experiences
winds that alternate between the north and south (Alaska Prevailing Wind Direction (WRCC 2011 cited
in NMFS 2013)).
4.2. Oceanography
Oceanographic considerations include tides, wind, freshwater overflow and inputs, ice movement,
stratification, and current regime. The following is a brief review of the oceanographic and
meteorological conditions within the Area of Coverage.
4.2.1. Bathymetric Features and Water Depths
The Chukchi and Beaufort Seas are parts of the Arctic Ocean and both are linked, atmospherically and
oceanographically, to the Pacific Ocean. Affecting regional meteorological conditions is the atmospheric
connection to the Aleutian Low. The oceanographic connection is the Bering Strait that draws relatively
warm nutrient-rich water into the Arctic Ocean from the Bering Sea (Weingartner and Danielson 2010
cited in NMFS 2013).
While the Chukchi Sea is an overall shallow sea with a mean depth of 131 to 164 feet (40-50 meters), the
continental shelf of the Beaufort Sea depth gradually increases from approximately 121 feet (36.9 meters)
to a maximum depth of around 12,467 feet (3,800 meters) along the shelf break and continental shelf
(Weingartner 2008, Greenberg et al. 1981, cited in NMFS 2013).
Several major bathymetric features exist in both seas including three major sea valleys, the Herald and
Barrow Canyons near the western and eastern edges of the Chukchi Sea and the Barrow Canyon, just
northwest of Barrow. Additionally, two large shoals, the Hanna and Herald define the western and eastern
edges of the Chukchi Sea. Those topographic features exert a steering effect on the oceanographic
circulation patterns in the area (MMS 2008). Barrow Canyon is just northwest of Barrow and serves to
drain water from the Chukchi Sea and bring upwelled water from the basin to the shelf. They are narrow
(less than 250 meters), have low elevations (less than 2 meters) and, particular to the Arctic, they are short
(Stutz, Trembainis and Pilkey 1999 cited in MMS 2008). The shoals rise 5-10 meters (16-33 feet) above
the surrounding seafloor and are found in water depths of 10-20 meters (33-65 feet) (MMS 2008).
Barrier islands provide two main benefits: they protect the coastlines from severe storm damage; and they
harbor several habitats that are refuges for wildlife. The salt marsh ecosystems of the islands and the coast
help to purify runoff from mainland streams and rivers. Continental shelves vary in width from almost
zero up to the 930 mi-wide Siberian shelf in the Arctic Ocean and average 78 kilometers (48 miles) in
width. The continental slope in the Beaufort Sea has water depths varying from 60 to 1,500 meters (197 to
4,921 feet). The shelf varies in width between Barrow and Canada and generally is a narrow shelf
averaging about 80.5 kilometers (50 miles).
4.2.2. Circulation and Currents
Current velocity and turbulence can vary markedly with location/site characteristics and can affect the
movement and concentration of suspended matter, and the entrainment, resuspension, and advection of
sedimented matter. The direction of the current determines the predominant location of the discharge
plume while current velocity influences the extent of area affected. Velocity and boundary conditions also
affect mixing because turbulence increases with current speed and proximity to the seafloor.
4-2
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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The Chukchi Sea is fed by Pacific Ocean and Arctic Ocean waters. Pacific waters enter the Chukchi Sea
through the Bering Strait in the south. Arctic waters enter the Chukchi Sea through Long Strait and in
episodic up-shelf transfers from the Arctic Ocean proper (e.g., via Barrow Canyon). The circulation and
modification of waters in the Chukchi Sea influence the input to the Arctic Ocean from the Pacific.
Although the volume of water from the Pacific through the Bering Strait is relatively small (-0.8
Sverdrups [Sv] northward in the annual mean [Sv is a unit of volume transport equal to 1,000,000 cubic
meters per second [264,172,100 gallons per second]), it contributes seawater of high heat and freshwater
content, low density, and high nutrients to the Chukchi Sea and the Arctic Ocean (MMS 2008).
Circulation in the Beaufort Sea can be divided into waters shallower than 40 meters and in offshore
waters deeper than 40 m. Offshore waters are primarily influenced by the large-scale Arctic circulation
known as the Beaufort Gyre, which is driven by large atmospheric pressure fields. In the Beaufort Gyre,
water moves to the west in a clockwise motion at a mean rate of 5—10 centimeters per second (cm/s). The
southern portion of the Beaufort Gyre is found in the offshore region of the proposed Beaufort Sea sales
area. The Beaufort Gyre expands and contracts, depending on the state of the Arctic Oscillation (Steele et
al. 2004 as cited in MMS 2008). Below the surface flow of the Beaufort Gyre, the mean flow of the
Atlantic layer (centered at 500 meters) is counterclockwise in the Canada Basin. Below the polar mixed
layer, currents appear to be driven primarily by ocean circulation rather than the winds (Aagaard et al.
1998 cited in MMS 2008). Figure 4- 1. illustrates the major water mass flows in the Chukchi and
Beaufort Seas.
Source: IA1S (2010)
Figure 4-1. Major water mass flows in the Chukchi and Beaufort Seas.
The Alaska Coastal Current (ACC) is a narrow, fast-moving current flowing northeasterly at
approximately 0.16 feet per second (ft/sec) along the Alaska coastline. North of Cape Lisburne, the ACC
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
4-3
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parallels the 66-foot isobath until it reaches the Barrow Sea Valley at Wainwright. It then follows parallel
with the valley from Wainwright to Point Barrow where it turns and flows southeasterly parallel to the
coastline. The ACC flow is variable, and directional reversals can persist for several weeks because of
changes in wind direction. During northeasterly flow, clockwise eddies can separate the nearshore
circulation from the ACC between Cape Lisburne and Icy Cape (MMS 1990).
The currents in the ACC are strongly influenced by the bathymetry and wind. Current speeds of 0.66 to
1.0 ft/sec are characteristic of the eastern Chukchi Sea. Bottom temperature gradients and currents are
greatest in the vicinity of Icy Cape and Point Franklin (Weingartner and Okkonen 2001 in MMS 1991).
Current velocities of 1.67 to 2.85 ft/sec have been reported south of Icy Cape (MMS 1990).
MMS (1990) reports that during open-water periods, ACC waters are driven by the wind. Northeasterly
winds promote upwelling that brings cooler bottom water into the nearshore area. Southwesterly winds
establish a warm coastal jet in the nearshore region, which displaces the cooler bottom water. Easterly
winds shift the ACC offshore, centering it approximately 12.4 miles from the coast. Westerly winds shift
the ACC closer to the coast. Traditional knowledge confirms the movement of tides along with wind
direction but also indicates that tides can move opposite the wind direction. One observer offshore
Omalik Lagoon reported that the currents 5 to 10 miles out move to the north with a south wind and to the
south with a northeast wind (SRB&A 2011). Traditional knowledge participants stated that in the
summer, currents move from north to south or south to north but can change direction rapidly, and their
direction can depend on the distance from shore (SRB&A 2011). The mean surface current direction year-
round is to the west and parallels the bathymetry. The tidal action coupled with the easterly nearshore
circulation results in the gradual removal of warm, brackish water from nearshore and replaces it with
colder, more saline water. Alternatively, tidal action coupled with westerly nearshore circulation causes
accumulation of warm, brackish water along the coast. Other controls on nearshore circulation include
river discharge, ice melt, bathymetry, and the configuration of the coastline.
In the landfast ice zone of the nearshore Beaufort, Weingartner et al. (2009) determined that during the
open water season, mid-depth currents are at least 20 cm/s, whereas during the landfast ice season, they
generally are less than 10 cm/s. Tidal currents are less than 3 cm/s and most likely have a negligible
dynamical effect on the currents and circulation (MMS 2008). During ice covered periods, landfast ice in
the nearshore areas protects the water from the effects of the winds. Therefore, the circulation pattern is
influenced by storms and brine drainage (MMS 2008).
4.2.3. Tides
Tidal ranges for the Beaufort and Chukchi Seas are small, ranging from <0.3 meter (1 feet) to <0.7 meter
(2 feet). The Beaufort Sea tides propagate from west to east along the coast. Tidal currents are largest on
the western side of the Chukchi Sea and near Wrangel Island, ranging up to 5 cm/s (0.1 knots/s). While
tides may not seem to exert an important influence on the oceanography of the seas, they likely play an
important role in seas ice dynamics and movement (Woodgate et al. 2005).
4.2.4. Stratification, Salinity, and Temperature
Nearshore waters are strongly influenced by inputs of fresh water from rivers, particularly in the Beaufort
Sea. In nearshore areas, a two-layered stratified system is formed with fresher water from riverine input
overlying more saline oceanic water. The surface layer generally shows a marked decrease in salinity in
the vicinity of major rivers. In the winter, the lack of freshwater input into coastal waters results in weak
4-4
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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stratification. Freshwater input also causes a marked temperature division between nearshore and offshore
waters.
In the Beaufort area, the MacKenzie River flows all year long, contributing the largest amount of
freshwater per year. Coastal water temperature typically ranges from 41 to 50 °F and has salinities that
are generally less than 31.5 parts per thousand (ppt) (Lewbel and Gallaway 1984 in MMS 2003). Offshore
waters are colder and more saline than the coastal waters. Water temperatures are near 32 °F and have
salinities of 32.2 to 33 ppt (Lewbel and Gallaway 1984 cited in MMS 2003).
During the spring (May to July) warm water (above 32 °F) appears in the Chukchi Sea because of the
gradual increase of solar radiation and warm water advected through the eastern Bering Strait (NMFS
2013). During the summer (July to August), the deep waters are generally still cold, ranging from 32 to
37 °F, depending on location, however, temperatures can reach above 48 °F. During the fall (September
to October), the surface water temperatures stay cool ranging from 36 to 43 °F. The Chukchi Sea surface
temperatures fall below 32 °F during the winter (November to April).
4.3. Ice
Sea ice, formed by the freezing of sea water, is a dominant feature of the Arctic environment. It is frozen
seawater that floats on the ocean surface; it forms and melts with the polar seasons. Annual formation and
decay of sea ice greatly influence the oceanographic dynamics of the Chukchi and Beaufort Seas
regulating heat, moisture, and salinity. Sea ice insulates the relatively warm ocean water from the cold
polar atmosphere, except where cracks or leads (areas of open water between large pieces of ice) in the
ice allow exchange of heat and water vapor from ocean to atmosphere in winter. Sea ice impacts virtually
all of the physical, biological, and cultural aspects of life of the region. In general, sea ice reaches its
maximum extent in March and minimum extent in September.
In the Chukchi Sea, sea ice generally begins forming in late September or early October, with full ice
coverage by mid-November or early December (MMS 2008). However, traditional knowledge
information indicates that freeze ups are happening later, starting in October, and while hunters have used
the ice starting in October in the past, they now have to wait until December (SRB&A 2011). Ice begins
melting in early May in the southern part of Chukchi Sea, and early to mid-June in the northern region.
Maximum open water occurs in September (MMS 2008); however, in the Arctic, some sea ice persists
year after year.
In the Beaufort Sea, sea ice generally begins forming in late September or early October, with full ice
coverage by mid-November or early December. Ice begins melting in early May in the southern part of
Beaufort Sea, and early to mid-June in the northern region. Maximum open water occurs in September
(MMS 2008).
The analysis of long-term data sets indicates substantial reductions in both the extent (area of ocean
covered by ice) and thickness of the Arctic sea-ice cover during the past 20 to 40 years during summer
and more recently during winter. Simulations conducted for the trajectory of Arctic sea ice indicate
decreasing September ice trends that are typically four times larger than observed trends, and predict near
ice-free September conditions by 2040 (Holland et al. 2006). Factors causing reductions in winter sea ice
can be different from those in summer.
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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4-5
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4.3.1. Landfast Ice Zone
Landfast ice, or fast ice, which is attached to the shore, is relatively immobile and extends to variable
distances off shore: generally 8- to 15-meter isobaths, but it can extend beyond the 20-meter (65.6-foot)
isobath. It is usually reformed yearly, although it can contain floes of multiyear pack ice. About mid-May,
the near-shore ice begins to melt; by July, the pack ice retreats northward. Much of the fast ice melts
within the 10-meter isobath during the summer, but it is very dependent upon the wind direction which
controls the ice floes. Traditional knowledge workshop participants during development of the Beaufort
and Chukchi Exploration NPDES General Permits indicated that breakup varies from year to year,
generally occurring in June or July. Freeze up typically occurs in October, although open water might be
present in certain areas all winter long (SRB&A 2011). Landfast ice is characterized by a gradual advance
from the coast in early winter and a rapid retreat in the spring (Mahoney et al. 2007 cited in MMS 2008).
The advance is not a continuous advance but involves the forming, breakup, and reforming of the landfast
ice.
The two types of landfast ice are bottomfast and floating. Bottomfast ice is frozen to the bottom out to a
depth of about 2 m; in areas deeper than 2 m, landfast ice floats. Movement of ice in the landfast zone
(called ice shoves, or ivu by the Inupiaq) is intermittent and can occur at any time but is more common
during freeze up and breakup. Onshore winds are highly correlated with ice shoves (MMS 2008).
Landfast ice moves in two general ways: (1) pile-ups and rideups and (2) breakouts. Onshore movement
of the ice generates pileups and rideups, which can extend up to 20 meters inland (MMS 2008). Landfast
ice can also move because of breakouts, where landfast ice breaks and drifts with pack ice.
The Beaufort Sea has much more extensive landfast ice cover than the Chukchi Sea. Differences in
geographic setting and bathymetry between the Chukchi and Beaufort Seas lead to marked differences in
the character of sea ice in these two regions. Due to its more southerly location and connection to the
Pacific Ocean, the Chukchi Sea experiences a longer open water season than the Beaufort. In addition,
due to the combination of a thinner ice pack and a coastline that offers the opportunity for open water
creation under almost any drift direction, sea ice in the Chukchi Sea is more mobile and changeable than
sea ice in the Beaufort. This is also reflected in the greater extent of landfast sea ice in the Beaufort Sea
(Pew 2013).
4.3.2. Stamukhi Ice Zone
Seaward of the landfast-ice zone is the stamukhi, or shear, ice zone. In this zone, large pressure ridges and
rubble fields occur between stationary landfast ice and mobile pack ice when winds drive the pack ice
into the landfast ice (MMS 2008). Pressure ridges in the Beaufort reach depths of 18-25 meters and act as
sea anchors for landfast ice.
4.3.3. Pack Ice
Pack ice is seaward of the stamukhi ice zone and includes first-year ice, multiyear un-deformed and
deformed ice, and ice islands. First-year ice forms in fractures, leads, and polynyas (large areas of open
water) and varies in thickness from inches to more than 3 feet. Traditional knowledge indicates that in
recent years, ice has been less stable, there is less multiyear ice, pack ice is smaller, and large icebergs are
rarely seen (SRB&A 2011). The Chukchi open-water system appears to be the result of the general
westward motion seen in the Beaufort Gyre and is strongly influenced by the wind direction. Historically,
first-year floes off the Chukchi Sea coast had a thickness of about 4 to 5 feet, and multiyear floes were 10
to 16.4 feet thick. Sea ice that is thicker than 16.4 feet is common in Arctic Ocean pack ice and is
generally believed to consist of pressure ridges and rubble fields (Eicken et al. 2006 cited in MMS 2008).
4-6
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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Increased ridging generally occurs from east to west and in the vicinity of shoals and large necks of land
(MMS 2008).
Ice islands are icebergs that have broken off from an ice shelf with a thickness of 100 to 164.0 feet and
range from tens of thousands of square feet to nearly 200 square miles. Movement of floating ice is
controlled by atmospheric systems and oceanographic circulation. During winter, movement is small and
occurs with strong winds that last for several days. The long-term direction of ice movement is from east
to west in response to the Beaufort Gyre; however, weather systems can cause short-term variations. A
system of seven recurring leads and polynyas develop in the Chukchi Sea. The Chukchi Sea has some of
the largest areal fractions of leads along the northern coast of Alaska and Canada, because of the wind-
driven polynyas that form along the coast from Point Hope to Barrow (MMS 2008). A general
observation made by participants in traditional knowledge workshops was that the pack ice breaks up
more quickly and that once the ice goes out, it does not return (SRB&A 2011).
4.3.4. Spring Lead System
Arctic leads are long, narrow channels in the pack ice that can be hundreds of meters wide and kilometers
long (Tschudi et al. 2002). Spring leads and polynyas provide important habitat for several seal species,
polar bears, and migrating bowhead and beluga whales. Inupiat hunters rely on the spring leads and areas
of open-water for spring hunting of bowheads from April to June (Norton and Graves 2004 as cited in
NMFS 2012).
The development of leads is highly dependent on the passage of individual weather systems. Lead
patterns appear to be marginally linked to the prevailing atmospheric circulation regime. Eicken et al.
(2006) evaluated the lead distribution patterns and landfast ice extent along the northern Alaska and
northwest Canadian coast between 1993 and 2004. Based on their results and on datasets published in
previous studies, thev found that major lead patterns and landfast ice patterns are repeated and that thev
appear to conform to consistent seasonal and spatial patterns of variability. These patterns are controlled
to a large extent by a combination of topographic (or bathvmetric) constraints, atmospheric forcing and
large-scale ice dynamics (Eicken et al. 2006). Highest lead fractions and largest sizes are observed in the
eastern Chukchi Sea and off the Mackenzie Delta, with fewer and smaller leads present in the central
Beaufort Sea. This is a result of the prevailing easterly wind directions, forcing ice offshore and creating
recurring flaw leads and polynyas along the landfast ice edge (Eiken et al. 2006).
Figures 4-2 through 4-5 and 4-6 through 4-9 depict the locations of spring leads during March. April.
May and June of the years 1994 and 2009. respectively, using data from the MMS PCS STUDY 2005-
068 (Eicken et al.. 2006) and from additional data provided directly by Dr. Haio Eicken at the University
of Alaska. Fairbanks. In addition to the locations of the spring leads, the figures show the Beaufort and
Chukchi sea lease areas, the Chukchi Sea deferral area, polar bear and Steller's eider critical habitat areas.
and Environmental Sensitivity Index (ESI) areas for humpback and bowhead whales, i.e.. areas that have
been identified as at risk if an oil spill occurs nearby. Figures of the spring lead system for additional
years are included in the administrative record for the Geotechnical GP. The recent data provided by Dr.
Eicken have not vet been published and should be considered preliminary.
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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Legend
• Populated Places
Federal'Slar* Maritime Boundary (3-Mites Oftowrej
¦ «¦ Chukchi Sea Detenal Boundary
|i™1 Cov#rag«Awa
M Spring Leads (March 1994)
Hanna Stioal SHA
Polar B«#r Critical HaWtW
Spoctac led EKJor Critical Habitai
Bowhoad & Humpback Whala* (ESI data from NOAA>
Cbyfcctw Soa Aciivo Fodoral Loaws
B-eautert Sea Available Slate L«a»>
Beaufcrt Sea Ac too State Leases (As of DecembGf f, 2009)
Oil and Gas Basins
il Protraellon Diagram Outlines
I
^ — I
V
I
* Wainwright
•Atqasuk
Prudhoe Bay
Stefans'son Sound
Boulder Patch
- r Kaktovik
fe' Point Hope
m
Location of Spring Leads in Relation to Area of Coverage for Oil
and Gas Geotechmcal Surveying and Related Activities in Federal
waters of the Arctic Ocean, EPA Permit Number AKG-28-4300
March 1994
A-{^'
Figure 4- 2. Spring Leads for March 1994 in the Area of Coverage for the Oil and Gas NPDES General Permit for Geotechnical
Surveys and Related Activities in Federal Waters of the Beaufort and Chukchi Seas
4-8
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
Revised - August 2014
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Location of Spnng Leads in Relation to Area of Coverage for Oil
and Gas Geotechnical Surveying and Related Activities in Federal
waters of the Arctic Ocean. EPA Permit Number AKG-28-4300
0 65 T30 260 t
April 1994 , ,, T" "Q-
Legend
• Populated Places
Federal'State Manbme Boundary (3-Mites Offshore)
— — Chukclil Sea Oeferral Boundary
LT"I Coverage Area
B Spring Leacs (April 1994)
Hanna Shoal SHA
Polar Bear Crilical Habitat
Spectacled Eider GrtficsJ Habitat
BovitiMd & Humpback Whales (ESI data from NOAA)
Figure 4- 3. Spring Leads for April 1994 in the Area of Coverage for the Oil and Gas NPDES General Permit for Geotechnical
Surveys and Related Activities in Federal Waters of the Beaufort and Chukchi Seas
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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4-9
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iWainwright
'Atqasuk
Kaktovik
Nuiqsut#
Stefansson Sound
Boulder Patch
{ > Point Lay
¦Ledyard Bay
Point Hope
Location of Spring Leads in Relation to Area of Coverage for Oil
and Gas Geotechnical Surveying and Related Activities in Federal
waters of the Arctic Ocean, EPA Permit Number AKG-28-4300
Figure 4- 4. Spring Leads for May 1994 in the Area of Coverage for the Oil and Gas NPDES General Permit for Geotechnical
Surveys and Related Activities in Federal Waters of the Beaufort and Chukchi Seas
4-10
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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iWainwright
'Atqasuk
Ntuqsut#
Kaktovilkr
Prudhoe Bay
Stefensson Sound
Boulder Patch
Point Lay
¦Ledyard Bay
Point Hope
Legend
• Populated Places
—— - Federal'Slaie Maritime Boundary (3-Mile & Offshore)
«¦ ¦ ChukeM Sea Oafaral Boundary
I™ Coverage Area
B Spring Leads (Juno 1994)
Hanna Shoel SHA
. _ Polar Bear Critical Kabrtai
Speciacled Etder Critical Habitai
Bowlvoad & Humpback Whale* (E5I data from NOAA>
~u
Chwkchi Sea Active Federal Loasos
> -
Beaufort Scs Available SUIe L«a»s
Beau tort Sea Active State Leases (At of December 1. 2009) f
Oil and Gas Basins
Offtetal Protraction Diagram Outlines i
¦IV s.- -
•v-r i
¦ -'¦¦¦ . • - '-WJ.-tr. '
' V I
-i; A • - *
" w «. •
Location of Spring Leads in Relation to Area of Coverage for Oil o 65 tm 260 i
and Gas Geotechnical Surveying and Related Activities in Federal June 1994 *-(Vi
waters of the Arctic Ocean, EPA Permit Number AKG-28-4300 " " 50 V
Figure 4- 5. Spring Leads for June 1994 in the Area of Coverage for the Oil and Gas NPDES General Permit for Geotechnical
Surveys and Related Activities in Federal Waters of the Beaufort and Chukchi Seas
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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'Atqasuk
Nuiqsut •
Kaktovil
Prudhoe Bay
Stefansson Sound
Boulder Patch
Point Lay
¦Ledyard Bay
Lisburne
Point Hope
Legend
• Populated Places
¦¦ ¦ Chukchi Sea Deferral Boundary
Federal/State Maritime Boundary (3-Miles Offshore)
| Coverage Area
71 Spring Leads (March 2009)
Hanna Shoal SHA
Polar Bear Critical Habitat
Spectacled Eider Critical Habitat
Bowhead & Humpback Whales (ESI data from NOAA)
Chukchi Sea Active Federal Leases
Beaufort Sea Available State Leases
K Beaufort Sea Active State Leases (As of December 1, 2009)
Location of Spring Leads in Relation to Area of Coverage for Oil
and Gas Geotechnical Surveying and Related Activities in Federal
Waters of the Arctic Ocean, EPA Permit Number AKG-28-4300
March 2009
Figure 4- 6. Spring Leads for March 2009 in the Area of Coverage for the Oil and Gas NPDES General Permit for Geotechnical
Surveys and Related Activities in Federal Waters of the Beaufort and Chukchi Seas
Figure 4- 7. Spring Leads for April 2009 in the Area of Coverage for the Oil and Gas NPDES General Permit for Geotechnical
Surveys and Related Activities in Federal Waters of the Beaufort and Chukchi Seas
4-12
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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in a Shoal
'Wainwright
'Atqasuk
Nuiqsut*
Prudhoe Bay
Stefansson Sound
Boulder Patch
Point Lay
¦Ledyard Bay
J1 Cape Lisburne
^Point Hope
Legend
• Populated Places
™ ¦ Chukchi Sea Deferral Boundary
Federal/State Maritime Boundary (3-Miles Offshore)
I Coverage Area
Spring Leads (May 2009)
Hanna Shoal SHA
Polar Bear Critical Habitat
Spectacled Eider Critical Habitat
Bowhead S Humpback Whales (ESI data from NOAA)
Chukchi Sea Active Federal Leases
Beaufort Sea Available State Leases
H Beaufort Sea Active State Leases (As of December 1, 2009)
Oil and Gas Basins
Official Protraction Diagram Outlines
1
•••'•• 'iV-
May 2009
Location of Spring Leads in Relation to Area of Coverage for Oil
and Gas Geotechnical Surveying and Related Activities in Federal
Waters of the Arctic Ocean, EPA Permit Number AKG-28-4300
Figure 4- 8. Spring Leads for May 2009 in the Area of Coverage for the Oil and Gas NPDES General Permit for Geotechnical
Surveys and Related Activities in Federal Waters of the Beaufort and Chukchi Seas
ODCE for Oil and Gas Geotechnical Surveys and Related Activities NPDES General Permit
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Spectacled Eider Critical Habitat
Bowhead & Humpback Whales (ESI data from NOAA)
Chukchi Sea Active Federal Leases
Beaufort Sea Available State Leases
Beaufort Sea Active State Leases (As of December 1. 2009)
Oil and Gas Basins
Official Protraction Diagram Outlines
BarrbW?
Wain wright
'Atqasuk
Nuiqsut#
Kaktovil
Prudhoe Bay
Stefansson Sound
Boulder Patch
Point Lay
¦Ledyard Bay
Cape Lisburne
Point Hope
Location of Spring Leads in Relation to Area of Coverage for Oil
and Gas Geotechnical Surveying and Related Activities in Federal
Waters of the Arctic Ocean, EPA Permit Number AKG-28-4300
June 2009
Figure 4- 9. Spring Leads for June 2009 in the Area of Coverage for the Oil and Gas NPDES General Permit for Geotechnical
Surveys and Related Activities in Federal Waters of the Beaufort and Chukchi Seas
In the 1970s. Shapiro and Bums (1975 as cited in Braliam et al. 1980) found that in March or April, the
pack ice reaches its maximum extent in the Bering Sea. Ice breakup begins as temperatures rise and wind
direction shifts from northeast to south or southwest, pushing the ice northward. In the northwestern
Bering Sea, between the Chukchi Peninsula and St. Lawrence Island, strong currents further help to break
up the ice and form an open-water corridor. North of the Bering Strait, a shear or flaw zone forms parallel
to the Alaskan coast causing numerous small leads to develop along and near this zone. An intermittent
lead system forms from the Bering Strait through outer Kotzebue Sound to Point Hope and on to Point
Barrow. This lead svstem usually consists of a single, major nearsliore lead that ties between landfast ice
and the pack ice (Braham et al. 1980).
Hie differences in bathymetry and hydrography between the Chukchi and Beaufort seas lead to marked
differences in the character of sea ice in these two regions. Due to its more southerly location and the
inflow of heat through Bering Strait, the Chukchi Sea experiences a longer open water season than the
Beaufort Sea. In addition, the combination of a thinner ice pack and a coastline that offers the opportunity
for open water creation under almost any drift direction, sea ice in the Chukchi Sea is more mobile and
changeable than sea ice in the Beaufort Sea. This is reflected in the more varied lead patterns in the
Chukchi Sea and in the greater extent of landfast sea ice in the Beaufort Sea. The Chukchi Sea and to
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lesser extent the Beaufort Sea are characterized by recurring coastal lead patterns that are particularly
prominent in the months of March through May (Mahonev et al. 2012).
Sea ice in the Chukchi Sea is generally newly grown each year (Mahonev 2012). In the Chukchi Sea,
there is a net northward flow, which enters through Bering Strait and branches into different
bathvmetricallv constrained currents (Wcingartncr et al.. 2005 as cited in Mahonev et al. 2012). The heat
flux associated with this northward flow enhances the early loss of ice in the Chukchi Sea (Woodgate et
al. 2010 as cited in Mahonev et al. 2012). The area of the Chukchi Sea that is most consistently open is
off the northwest coast of Alaska, where the pack ice is frequently driven away from the shore, leaving
behind wide areas of thin ice or open water. The most prominent coastal polvnvas and flaw leads form
along the eastern Chukchi Coast between Point Hope and Point Barrow, as well as to the north and west
of Wrangel Island, with less distinct flaw leads appearing off the northern coast of Chukotka (Mahonev et
al. 2012).
The Beaufort Sea retains a significant perennial (or multivear) ice cover (Mahonev 2012). Circulation in
the Beaufort Sea is dominated by the anticvclonic (clockwise) motion of the Beaufort Gyre, which
transports some of the oldest and thickest ice in the Arctic from the region north of the Canadian
Archipelago into the Beaufort Sea. This motion is driven by atmospheric circulation around a persistent
region of high pressure (the Beaufort High). The strength of the Beaufort Gyre can vary from year to year
and the ice motion can sometimes reverse for periods of a few days. However, in winter the average drift
is approximately parallel to the coastline (Mahonev et al. 2012). The deformation and lead patterns in the
Beaufort Sea are mainly determined by the interaction of the pack ice with the coast or landfast ice edge
along the North Slope. The predominant pack ice drift direction is to the west, and the infrequent shift to
the east or north are generally of small magnitude (Mahonev et al. 2012). Persistent leads and polvnvas
along the Beaufort coast are observed along the Mackenzie Delta. Herschell and Barter Island (Mahonev
etal. 2012).
The spring lead system and spring-migration corridor through the Beaufort Sea extends farther offshore
than through the Chukchi Sea (NMFS 2013). Offshore activities, such as geotechnical surveys and related
activities, are unlikely to occur within the Beaufort Sea spring lead system during the bowhead migration
because the ice at this time of year would be too thick for vessels to get to the location to conduct the
activities (NMFS 2008).
Hanna and Herald Shoals and Herald Island play an important role as sources of open water or leads and
points of origin for more extended lead systems. Thev are the only offshore features that are consistently
associated with open water and thin ice (Mahonev et al. 2012).
The combination of prevalent open water and an almost exclusively first year ice pack makes the sea ice
in the Chukchi Sea more mobile than that in the Beaufort Sea. As a result, winter lead patterns in the
Chukchi Sea are characterized by numerous intersecting openings that change rapidly, whereas the
Beaufort Sea generally has fewer, more isolated leads (Mahonev 2012).
Mahonev et al. (2012) performed an analysis of all sufficiently cloud-free Advanced Very High
Resolution Radiometer (AVHRR) imagery from November-June for the period 1993-2010 to evaluate the
location, concentration and recurring patterns of leads and openings in the sea ice in the Chukchi and
Beaufort seas. This work expanded on a project that thev performed under the MMS PCS STUDY 2005-
068 project. Under this most recent project, thev were able to demonstrate a clear regional contrast in the
distribution and seasonality of lead patterns in the Beaufort and Chukchi seas (Mahonev et al. 2012). In
the Beaufort Sea, thev observed a recurring lead pattern termed the "Barrow Arch/1 and found that most
of the other lead patterns were confined to a relatively narrow zone between the margins of the pack ice
and the coast (Mahonev et al. 2012). In the Chukchi Sea, thev observed more dynamic ice conditions
compared to the Beaufort Sea. Thev found that the Chukchi coastal polvnvas and flaw leads are
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widespread and represent the most persistent lead pattern in the entire region. This includes lead systems
forming off Wrangel Island, which are often linked to the same weather patterns responsible for open
water off the Chukchi coast (Mahoncv et al. 2012).
Unlike the MMS PCS STUDY 2005-068. which found little change in landfast ice extent since the
1970s, the researchers in this study observed a possible reduction in landfast ice extent since 2006.
Analysis of additional data covering more recent years would be required to confirm these findings, but
thev point toward changes in the coastal ice regime of the Beaufort Sea that are unprecedented during the
satellite record (Mahoncv et al. 2012).
Mahonev et al. (2012) found that the Arctic Sea ice cover has undergone significant changes in the past
two decades. These changes include a reduction in summer ice extent (with four consecutive record
minima attained between 2001 and 2005) as well as substantial thinning of the ice pack (Eicken et al. e
2006). Beginning in the 2006 season, compared to previous years with very few leads outside of the
Barrow Arch and the Mackenzie flaw zone, thev observed that the number density and extent of leads in
this region appeared to have increased substantially, mostly as a result of the changing composition of the
Beaufort ice pack. Mahonev et al. (2012) noted that thev will need to evaluate this area further to assess
whether these changes are reversible. Recent climate modeling studies predict that the Arctic could be
free or nearly free of sea ice in summer within the next few decades (Mahonev 2012). With more open
water and a great influx of shortwave radiation, the changing ice regime is likely to have substantial, but
poorly understood to date, ecological impacts (Mahonev et al. 2012).
4.4. Sediment Transport
Sediment transport and distribution in the Chukchi and Beaufort Seas is controlled by several factors,
including storms, ice gouging, entrainment in sea ice, wave action, currents, and bioturbation. The bulk of
sediment on the Alaskan continental shelf is transported northwards with the prevailing current. Sediment
transport in response to severe storms is an important means of sediment transport in the Area of
Coverage. Storm transport of sediment is particularly effective in the fall months when storms are
associated with fresh ice, which enhances erosion and often entraps sediments in new ice. In the spring,
the breakup and melting of this sediment-laden ice can result in sediment being transported far distances
from the point of entrapment.
4.5. Water and Sediment Quality
4.5.1. Turbidity and Total Suspended Solids
Turbidity is caused by suspended matter or other impurities that interfere with the clarity of the water. It
is an optical property that is closely related to the concentration of total suspended solids in the water.
Natural turbidity is caused by particles from riverine discharge, coastal erosion, and resuspension of
seafloor sediment, particularly during summer storms (NMFS 2013). Turbidity levels are generally higher
during the summer open-water period relative to the winter ice-covered period. Under relatively calm
conditions, turbidity levels are likely to be less than 3 Nephelometric Turbidity Units (NTU) and may be
in excess of 80 NTU during high wind conditions. Nearshore waters generally have high concentrations
of suspended material during spring and early summer due to runoff from rivers. The highest levels of
suspended particles are found during breakup (NMFS 2013).
4.5.2. Metals
In the marine environment, metals are found in the dissolved, solid, and colloidal phases. The distribution
of metals amounts among the three phases depends upon the chemical properties of the metal, the
4-16
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properties of other constituents of the seawater, and physical parameters. Current EPA water quality
criteria for metals in marine waters are based on dissolved-phase metal concentrations because they most
accurately reflect the bioavailable fraction, and hence the potential toxicity of a metal (NMFS 2013).
Although EPA has established water quality criteria for water, there are no comparable national criteria or
standards for chemical concentrations in sediment.
The main inputs of naturally-occurring metals to the Arctic Ocean are derived from terrestrial runoff,
riverine inputs, and advection of water into the Arctic Ocean via the Bering Strait inflow and the Atlantic
water inflow (NMFS 2013). Naturally occurring concentrations of metals are generally higher in the
Chukchi Sea relative to those in the Beaufort Sea. Metals from the Bering Sea may be deposited in the
Chukchi Sea sediments are Bering Sea water flows over the relatively shallow Chukchi Sea shelf (NMFS
2013).
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Table 4-1 below summarizes sediment metals data collected between 1984 and 2008 in the Beaufort Sea
by BOEM (formerly MMS) and oil industry monitoring programs. Most samples were collected some
distance in both time and space, from exploratory drilling activities, so the concentrations can be
considered to represent the natural background. Concentration ranges are mg/kg dry weight (parts per
million (ppm)) (Neff 2010).
4-18
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Table 4-1. Concentrations of metals collected in Beaufort Sea sediments
Years
Arsenic
Barium
Cadmium
Chromium
Copper
Mercury
Nickel
Lead
Vanadium
Zinc
1984-1986
-
128-704
0.06-0.27
22-89
7.6-30
-
-
5.7-19
37-142
37-123
1993
10-43
-
0.06-0.43
77-110
11-63
0.04-0.15
21-75
11-26
-
65-160
1997-1999
7-16
116-569
0.11-0.27
13-63
7-27
0.008-0.02
7-34
6-15
24-117
18-96
1999-200 la
1.0-23
142-863
0.03-0.75
13-104
3.6-46
0.003-0.11
-
2.8-22
27-173
15-136
1999-20023
4.2-28
155-753
0.03-0.82
13-104
3.6-50
0.003-0.20
6.0-48
3.2-22
27-173
15-157
2001-2002
15-31
525-631
0.14-0.20
91-188
31-37
0.05-0.10c
45-52
16-26
147-211
114-146
2003
6.9-20
329-649
0.08-0.45
56-84
16-55
0.005-0.09
26-54
11-29
87-136
48-111
2004-2006
4.7-25
142-863
0.03-0.77
15-100
3.9-46
0.003-0.11
6.9-46
4.3-20
87-156
64-108
2008
9.5-22
456-714
0.16-0.31
59-96
15-27
0.03-0.08
-
9.9-18
87-156
64-108
2008b
10-21
585-18,300
0.15-0.24
73-135
21-53
0.04-0.06
-
14-49
113-131
64-108
a Brown et al. (2010) summarizes data for 1999 to 2002 MMS ANIMIDA Program; Trefry et al. (2003) summarizes data for
1999 to 2001 for the same program.
b Surface sediment samples collected near the Hammerhead exploratory drilling site in Camden Bay in 2008.
c Concentration of methylmercury ranged from 0.00001 to 0.00013 ppm.
More than 300 sediment samples from the northeastern Chukchi Sea have been collected and analyzed for
19 metals. This data set includes 69 samples from the Burger Study Area and 259 samples located outside
the Burger Study Area. Table 4-2 summarizes concentrations of metals in sediment and water samples in
the 2012 Burger A drill site area. The concentrations of 19 metals in 18 sediment samples collected from
the Burger A drill site during 2012 had an average relative standard deviation (RSD) of approximately 7%
(Shell 2013).
Table 4-2. Concentrations of metals (mean ± SD) in sediment samples from Burger A
Total
Parameter
Ag
Al
As
Ba
Be
Cd
Cr
Cu
Fe
Hg
(n = 18)
(Mg/g)
(%)
(fig/g)
(fig/g)
(fig/g)
(fig/g)
(fig/g)
(fig/g)
(fig/g)
(ng/g)
Mean
0.14
6.09
13.0
625
1.4
0.19
85
17.0
3.5
39
SD1
0.02
0.17
3.3
14
0.1
0.02
3
1.3
0.2
3
RSD2
14
2.8
25
2.2
7.1
10
3.5
7.7
5.7
7.7
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MeHg
Mn
Ni
Pb
Sb
Se
Sn
T1
V3
Zn
Parameter
(ng/g)
(Mg/g)
(fig/g)
(Hg/g)
(Hg/g)
(Hg/g)
(Hg/g)
(Hg/g)
(Hg/g)
(Hg/g)
Mean
0.115
329
29
12.6
0.70
0.93
2.0
0.44
130
92
SD
0.015
27
1.3
0.6
0.03
0.04
0.2
0.02
8
5
RSD1
13
5.2
4.6
4.7
3.6
4.8
10
4.7
5.9
5.5
1 SD = standard deviation
2 RSD = (SD/mean) x 100%
3 V = vanadium
Table 4-3 summarizes the concentrations of dissolved metals from 6 samples from the Burger Study Area
and 88 samples from the northeastern Chukchi Sea during 2010.
Table 4-3. Concentrations of dissolved metals (mean ± SD) for water samples
Parameter
As
Ba
Cd
Cr
Cu
Total
Hg
Ni
Pb
Sb
Se
T1
Zn
TSS
Burger Study Area (2010; n = 88)
Mean
1.16
7.7
0.046
0.13
0.24
0.0005
0.32
0.004
0.13
0.034
0.009
0.33
0.59
SD
0.04
1.2
0.024
0.07
0.04
0.0003
0.08
0.002
0.01
0.002
0.001
0.06
0.52
RSD
3
16
52
54
17
60
25
50
8
6
11
18
--
Northeastern Chukchi Sea (2010; n = 88)
Mean
1.15
8.2
0.046
0.10
0.27
0.0005
0.32
0.006
0.12
0.034
0.010
0.45
0.80
SD
0.12
2.0
0.021
0.02
0.10
0.0003
0.08
0.002
0.01
0.006
0.002
0.26
0.88
RSD
10
24
46
20
37
60
25
33
8
18
20
58
--
4.6. Ocean Acidification
Over the last few decades, the absorption of atmospheric carbon dioxide (CO2) by the ocean has resulted
in an increase in the acidity of the ocean waters. The greatest degree of ocean acidification worldwide is
predicted to occur in the Arctic Ocean. This amplified scenario in the Arctic is due to the effects of
increased freshwater input from melting snow and ice and from increased CO2 uptake by the sea as a
result of ice retreat (NMFS 2013). Experimental evidence suggests that if current trends in CO2 continue,
key marine organisms, such as corals and some plankton, will have trouble maintaining their external
calcium carbonate skeletons (Orr et al. 2005).
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5. DESCRIPTION OF THE EXISTING BIOLOGICAL ENVIRONMENT
This section provides an overview of the biological communities found in the Chukchi and Beaufort Seas.
The general groups of aquatic organisms that inhabit the Area of Coverage include pelagic (living in the
water column), epontic (living on the underside of or in the sea ice), or benthic (living on or in the bottom
sediments) plants and animals. A multi-disciplinary environmental studies program was initiated in 2008
with support from ConocoPhillips, Shell Exploration and Production Company, and Statoil USA E&P.
The program continues to provide ecological baseline conditions within three study areas in the Chukchi
Sea. Additionally, the State of Alaska through the Alaska Monitoring and Assessment Program
(AKMAP) has been conducting water quality and the ecological status of waters of the northeastern
Chukchi Sea from Pt. Hope to Barrow in waters 10-50 meters in depth within the Beaufort/Chukchi
coastal-shelf ecosystem. AKMAP partnered with the University of Alaska Fairbanks, School of Fisheries
and Ocean Sciences and NOAA's National Status and Trends Bioeffvcts Program for the 2010-2011
sampling. A final report is due in 2014.
BOEM has also conducted extensive biological studies in tlu Beaufort and Chukchi Seas, including
benthic ecology, fisheries, marine birds, and marine ecological monitoring. Information and reports can
be found on BOEM's website at: http: //www .boem. gov/Environmental - Stewardshi i a Environmental-
Studics/Alaska/Biological/indcx.aspx.
The categories of the offshore biological environment discussed are:
• Plankton
• Attached macro- and microalgae
• Benthic invertebrates
• Fishes (demersal and pelagic)
• Marine mammals
• Coastal and marine birds
• Threatened and endangered species
• Essential fish habitat (EFH)
Each of those biological resources is described in terms of seasonal distribution and abundance, growth
and production, environmental factors that influence the resource's importance in the ecosystem, and
habitats. Additional discussions of these resources are found in the Biological Evaluation for the
Geotechnical GP (USEPA 2013) and the BEs and EFH Assessments for the Beaufort and Chukchi
Exploration NPDES General Permits (Tetra Tech 2012a,b,c&d).
5.1. Plankton
Plankton can be divided into two major classes: phytoplankton and zooplankton. Plankton are the primary
food base for other groups of marine organisms found in the Chukchi and Beaufort Seas. The distribution,
abundance, and seasonal variation of these organisms are strongly influenced by the physical
environment. The distribution, abundance, and seasonal variation of these organisms are strongly
influenced by the physical environment. The highest concentrations of phytoplankton in the Beaufort Sea
were observed near Barrow (Dunton et al. 2003). The coast near Kaktovik was identified as another
productive area with upwelling of nutrient-rich water from offshore areas. The combination of regular
upwelling from deep offshore waters in such areas and increased light intensity allow for increased
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productivity (Dunton et al. 2003). For a full discussion of distribution and abundance of plankton, see the
Beaufort Sea BE (Tetra Tech 2012a).
Ongoing research has found that a combination of winds and tides leads to the formation of
oceanographic fronts between water masses in the Beaufort Sea (Ashjian et al. 2007; Moore et al. 2008
cited in MMS 2008). The fronts concentrate the abundant zooplankton in the coastal water off the Elson
Lagoon making it easier for predators to feed on the zooplankton (MMS 2008). No areas or habitats of
extraordinary importance have been identified.
Surveys of the planktonic communities over the Klondike, Burger and Statoil survey areas in the Chukchi
Sea were completed during August 2011 and again as part of a broad scale effort in September/October in
2011. Chlorophyll and nutrient concentrations suggest that August sampling had occurred post-
phytoplankton bloom in all study areas, with some elevated concentrations maintained in the winter-water
cold pools over Shell's Burger and Statoil's lease prospects. The surveys found a total of 77 taxonomic
categories of zooplankton, including 10 meroplanktonic larval categories during the 2011 field season.
The greatest taxonomic diversity was observed within the copepods (25 species, plus juvenile categories),
followed by the cnidarians (13 species), with most species typical for the region and are seeded from the
Bering Sea. A notable exception to previous years occurred in 2011 with the transport of the Arctic basin
copepod species Calctnus hyperborens into the study area during a period of sustained upwelling in
Barrow Canyon. In 2011, Klondike zooplankton could generally be separated from the Burger and Statoil
prospects based on community structure, with temporal evolution of the community structure apparent at
each location. Differences in ice-melt timing, water temperatures, transport of water masses, nutrients and
chlorophyll-a are believed to influence the large inter-annual difference observed in the plankton
communities over the past 4 years (Hopcroft et al. 2013).
The currents moving north through the Bering Strait exert a strong influence on Chukchi Sea primary and
secondary productivity because of the transport of nutrients, detritus, phytoplankton, zooplankton, and
larval forms of invertebrates and fishes from the Bering Sea to the Chukchi Sea. Seasonal ice regimes also
influence the spatial and temporal variation of primary and secondary productivity. Productivity in the
Chukchi Sea decreases from nearshore to offshore waters and is considerably less than the productivity
observed at comparable depths in the Bering Strait.
The growth rates of planktonic organisms are relatively rapid, and the generation lengths are relatively
short. Plankton production is limited primarily by temperature, available nutrients (particularly nitrogen),
and light. The most productive area of Arctic Alaskan waters is the coastal zone. Plankton production is
usually limited to the photic zone, or the depth to which sunlight penetrates the water. Seasonal variation
in nutrient concentration can also affect primary production. Plankton production gradually increases after
ice break-up, when light becomes available and declines after September when light availability limits
photosynthesis. Peak primary production varies by as much as two to three times from year to year and
depends on the relative amount of summer ice cover (Homer 1984).
5.2. Macroalgae and Microalgae
Macroalgae are large, photosynthesizing aquatic plants. Macroalgae populations occur naturally, but an
increase in their biomass (especially if it is associated with a decrease in seagrass) might also be an
indication of deteriorating water quality. Macroalgal biomass is most commonly limited by dissolved
inorganic nitrogen, but it can also be limited if high light attenuation prevents adequate light from
reaching the bottom.
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Attached macroalgae occur in state waters along nearshore and offshore barrier island areas in the
Beaufort Sea containing suitable rocky substrate for attachment. In Arctic Alaskan waters, the distribution
of kelp is limited by three main factors: ice gouging, sunlight, and hard substrate. Ice gouging restricts the
growth of kelp to protected areas, such as behind barrier islands and shoals. Sunlight restricts the growth
of kelp to the depth range where a sufficient amount penetrates to the seafloor, or water shallower than
about 11 meters (36 feet). Hard substrates, which are necessary for kelp holdfasts, restrict kelp to areas
with low sedimentation rates (Dunton et al. 1982; MMS 1990).
Alaska's Beaufort Sea shelf is typically characterized by silty sands and mud with an absence of
macroalgal beds and associated organisms (Barnes and Reimnitz 1974). A diverse kelp community occurs
in the Boulder Patch near Prudhoe Bay in Stefansson Sound. Algae in the Boulder Patch contribute to the
important food web supporting many epibenthic and benthic organisms in the area. Differences in
biomass between surrounding sediment areas and the Boulder Patch demonstrate the importance of this
biologically unique area (Konar 2006; Dunton and Schonberg 2000, Dunton et al. 2005).
A study conducted in the Beaufort Sea, found that kelp grows fastest in late winter and early spring
because of higher concentrations of inorganic nitrogen in the watt column. The presence of macroalgae
is considered rare in the Beaufort Sea. Kelp make up between 50 and 55 percent of the available carbon in
the Stefansson Sound kelp community; phytoplankton make up between 23 and 42 percent (Dunton
1982). Macroalgae presence is considered rare in the Chukchi Sea, but all potential kelp habitats have not
yet been surveyed.
Microalgae are distinguished from phytoplankton in that they are attached rather than free-floating. The
distribution of microalgal communities has been noted as patchy on both large and small scales (MMS
1991), and no important critical habitats or areas have been identified. During the spring and summer
months, large biomasses of photosynthetic ice algae develop on the lower sections of sea ice. Ice algae
contribute organic matter to the water column and are an important part of the Arctic marine food web,
contributing an average of 57 percent to total Arctic marine primary production (Gosselin 1997).
5.3. Benthic Invertebrates
Benthic invertebrates are organisms that live on the bottom of a water body (or in the sediment). The
distribution, abundance, and seasonal variation of benthic species in Arctic Alaskan waters are strongly
correlated with physical factors (e.g., substrate composition, water temperature, depth, dissolved oxygen
concentrations, pH, salinity, sediment carbon/nitrogen ratios, and hydrography). Larger invertebrate
communities are found in nearshore lagoons (ADNR 2009). The abundance, diversity, biomass, and
species composition of benthic invertebrates can be used as indicators of changing environmental
conditions. The biomass of benthic invertebrates declines if communities are affected by prolonged
periods of poor water quality especially when anoxia and hypoxia are common.
Benthic communities can change in response to the following:
• Nutrient enrichment leading to eutrophication.
• Bioaccumulation of toxins to lethal levels in mollusks (shellfish), crustaceans, polychaetes and
echinoderms can cause the loss of herbivorous and predatory species.
• Lethal and sub-lethal effects of heavy metals and other toxicants derived from oil and gas activities.
• Dislodged epifauna and infauna from trawling and dredging, which could result in the collection
and mortality of a substantial invertebrate bycatch.
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• Physical smothering of habitat due to deposition of drilling fluids and cuttings materials discharged
on the ocean floor.
Benthic invertebrates are important modifiers of the seafloor. Burrowing and tube-building by deposit-
feeding benthic invertebrates (bioturbators) help to mix the sediment and enhance decomposition of
organic matter. Nitrification and denitrification are also enhanced because a range of oxygenated and
anoxic micro-habitats are created. Loss of nitrification and denitrification (and increased ammonium
efflux from sediment) in coastal systems are important causes of hysteresis, which can cause a shift from
clear water to a turbid state. The loss of benthic suspension-feeding macroinvertebrates can further
enhance turbidity levels because such organisms filter suspended particles including planktonic algae, and
they enhance sedimentation rates through biodeposition (i.e., voiding of their wastes and unwanted food).
Changes in the macrofauna (and macroflora) causes changes in nutrient storage pools and the flux of
nutrients between these species and microfauna (and microflora). Benthic macrofauna are important
constituents of fish diets and, thus, are an important link for trar i erring energy and nutrients between
trophic levels and driving pelagic fish and crustacean production It is for those reasons and others, that
benthic invertebrates are extremely important indicators of environmental change.
5.4. Fish
The physical environment, mainly temperature and salinity, of the Arctic waters exerts a strong influence
on the temporal and spatial distribution and abundance of fish (MMS 1990, 1991). The Chukchi Sea is
characterized by sub-arctic climate, especially during the open-water season in the later spring and
summer. The Chukchi Sea is an important transition zone between the fish communities of the Beaufort
and Bering Seas (MMS 1991); the fauna is primarily Arctic with continual input of southern species
through the Bering Strait (Craig 1984). Marine fish in the Chukchi Sea are generally smaller than those in
areas farther south, and densities are much lower (Frost and Lowry 1983). The lower diversity, density,
and size of fish in the region have been attributed to low temperatures, low productivity, and lack of
nearshore winter habitat because of ice formation (MMS 1987b). Table 5-1 lists common fish in the Area
of Coverage.
Fish biologists on the Russian-American Long-term Census of the Arctic expedition noted the following
qualitative conclusions: (1) the Chukchi benthic community is highly diverse and patchy; and (2) both
fish abundance and diversity seem lower in the Chukchi Sea than in the Bering Sea (MMS 2008). The
largest catches occurred to the south and were usually at least one order of magnitude higher than those in
the north. Pacific salmon (chinook, coho, pink, sockeye, and chum), Arctic cod, saffron cod, and snow
crab are addressed in detail in the EFH for the Chukchi Exploration NPDES General Permit (Tetra Tech
2012b).
Table 5-1. Common fishes in the Beaufort and Chukchi Seas
Freshwater
Anadromous
Marine
Common name
Scientific name
Common name
Scientific name
Common name
Scientific name
Arctic blackfish
Dallia pectoralis
Arctic cisco*
Coregonus
autumnalis
Arctic flounder
Liopsetta glacialis
Arctic char
Salvelimis alpimis
Arctic lamprey*
Lampetra japonica
Starry founder
Platichthvs stellatus
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Burbot
Lota lota
Bering cisco*
Coregonus
laurettae
Arctic cod
Boreogadus saida
Arctic grayling
Thymallus arcticus
Broad
whitefish*
Coregonus nasus
Saffron cod
Eleginus gracilis
Lake chub
Couesius plumbeus
Dolly Varden
char*
Salvelimis malma
Snailfish
Li par us sp.
Lake trout
Salvelimis
namaycush
Humpback
whitefish*
Coregonus
pidschian
Pacific sand lance
Ammodytes
hexapterus
Longnose
sucker
Catostomus
catostomus
Least cisco*
Coregonus
sardinella
Pacific Herring
Clupa harengus
Ninespine
stickleback
Pungitius pungitius
Slender eelblenny
Lurnpenus fabricil
Stout eelblenny
Lumpenus medius
Round
whitefish
Prosopium
cylindraceum
Eelpout
Lvcodes spp.
Sheefish
Stenodus leucichthys
Arctic sculpin
Myoxocephalus
scorpiodes
Slimy sculpin
Cottus cognatus
Rainbow smelt
Osmerus mordax
dentex
Whitespotted
greenling
Hexagrammus
stelleri
Trout-perch
Percopsis
omiscomaycus
Capelin
Mallotus villosus
Fourhorn sculpin
Myoxocephalus
quadricornis
Arctic staghorn
sculpin
Gymnocanthus
tricuspis
Arctic hookear
Artediellus scaber
Bering wolffish
Anarchichas
orientalis
* The species has populations that can be freshwater only or anadromous (USFWS 2008)
During the open-water season, the nearshore zone of the Beaufort Sea area is dominated by a band of
relatively warm, brackish water that extends across the entire Alaskan coast. The summer distribution and
abundance of coastal fishes (marine and anadromous species) are strongly affected by this band of
brackish water. The band typically extends 1.6 to 9.7 kilometers (1 to 6 miles) offshore and contains more
abundant food resources than waters farther offshore. The areas of greatest species diversity within the
nearshore zone are the river deltas. Fish distribution and abundance in the Beaufort Sea vary by species
and are determined primarily by nutritional and spawning needs. Anadromous fish in the Beaufort Sea
spend most of their lives in fresh water and do not travel far into deep ocean waters. In comparison, many
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marine fish species are pelagic, spending their entire life in deeper ocean waters. The more common
anadromous fish species in the Beaufort Sea are Dolly Varden char, whitefish, cisco and salmon.
Freshwater species would be found almost exclusively in nearshore freshwater environments surrounding
river deltas and bays (Moulton et al. 1985 as cited in MMS 2008). Juvenile fish prefer the warmer,
shallow-water habitats that become available during the open-water period (MMS 2008). Anadromous
fish typically leave the rivers and enter the nearshore waters during spring break-up in June. As the ice
cover melts and recedes, the fish will migrate along the coast (ADNR 1999). Migration back to rivers
varies by species, but most anadromous fish return to fresh water, where they spawn by mid-September
(ADNR 1999). Salmon are anadromous but unlike cisco, whitefish, and Dolly Varden char, they rarely
return to the ocean after spawning, rather they spawn once and die. Salmon are uncommon along coastal
waters (Craig 1984; Augerot 2005 cited in MMS 2008).
A lack of overwintering habitat is the primary factor limiting Arctic fish populations (DNR 1999).
Spawning in the Arctic environment can take place only where there is an ample supply of oxygenated
water during winter. Because of that and because few potential spawning sites meet that requirement,
spawning often takes place in or near the same area where fishes overwinter (MMS 2008). Most marine
species spawn in shallow coastal areas during the winter.
Conservative estimates by the U.S. Department of Interior report that at least 17 species of marine fishes,
13 species of freshwater fishes, 5 species of anadromous fishes, and 7 fish species that can have both
freshwater (only) and anadromous populations can be found in the waters of the Beaufort Sea (Wiswar
1992; Wiswar et al. 1995; Wiswar and Fruge 2006; Scanlon 2009; MMS 2008). Together, the Beaufort
and Chukchi Seas support a large and dynamic Arctic ecosystem that includes as many as 98 fish species
representing 23 families (Mecklenburg et al. 2002; MMS 2006:Tables III.B-1 cited in MMS 2008).
5.5. Marine Mammals
Common (at least seasonally) marine mammals in the Area of Coverage are spotted, ringed, and bearded
seals (ice seals); bowhead, beluga, killer, and gray whales; polar bears; and walruses. At least six other
species of marine mammals (minke whales, fin whales, humpback whales, harbor porpoise, narwhal, and
ribbon seals) are found occasionally or rarely in the Area of Coverage. Those species of marine mammals
that are protected by the Endangered Species Act are discussed further in the BE for the Geotechnical GP
(USEPA 2013).
Ringed Seal. Ringed seals (Phoca hispidct) are circumpolar in distribution (Angliss and Outlaw 2008).
They are found in all seas of the Arctic Ocean including the northern Bering, Chukchi, and Beaufort Seas
(ADF&G 1994). Ringed seals live on or near the ice year-round; therefore, the seasonal ice cycle has an
important effect on their distribution and abundance (MMS 2008). In winter, highest densities of ringed
seals occur in the stable landfast ice. Ringed seals appear to prefer ice-covered waters and remain in
contact with ice for most of the year (Allen and Angliss 2010). Ringed seals live on and under extensive,
largely unbroken, landfast ice (Frost et al. 2002), and they are generally found over water depths of about
10 to 20 meters (33 to 66 feet) (Moulton et al. 2002). Traditional knowledge workshop participants during
development of the Beaufort and Chuckhi Exploration NPDES General Permits identified general areas
where seals were reported to congregate included along the pack ice, in merging currents, in bays,
lagoons, and river deltas (SRB&A 2011).
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The spring lead systems in the Beaufort and Chukchi Seas are also important to ringed seals since these
areas allow them to forage for fishes and comfortably rest on an icy platform if needed. Several
Environmental Resource Areas have been identified in the Alaska Outer Continental Shelf Final
Supplemental Environmental Impact Statement for Oil and Gas Lease Sale 193 in the Chukchi Sea,
Alaska (BOEMRE 2011) for the ringed seal:
• Herald Shoal polvnva area (January-December)
• Hanna Shoal polvnva area (January-December)
• Southern portion of Chukchi spring lead system (April-June)
• Middle portion of Chukchi spring lead system (April-June)
• Northern portion of Chukchi spring lead system (April-June)
Spotted Seal. The Alaska stock of spotted seal (Phoca largha) is the only recognized stock in U.S.
waters. Spotted seals are found in large numbers along the Bering, Chukchi, and Beaufort Sea coasts; they
are common in bays, estuaries, and river mouths and are particularly concentrated along the Chukchi Sea
coast from Kasegaluk Lagoon to the mouth of the Kuk River and Peard Bay (MMS 1991).
From September to mid-October, spotted seals that summered in the Beaufort Sea migrate to the Bering
Sea and spend the winter and spring periods offshore north of the 200-meter (656-foot) isobath along the
ice front, where pupping, breeding, and molting occur (Lowry et al. 2000). Spotted seal is usually a
summer visitor and they are usually in the lagoons around the barrier islands or around bays like
Admiralty Bay, and Smith Bay. Traditional knowledge workshop participants identified Dease Inlet as
important feeding area because of the abundance of fish (SRB&A 2011).
Bearded Seal. The majority of the bearded seal (Erignathus barbatus) population in Alaska is found in
the Bering and Chukchi Seas with seasonal migrations into the Beaufort Sea. The species usually prefers
areas of less-stable or broken sea ice, where breakup occurs early in the year (Burns 1967). They are
found in nearshore areas of the central and western Beaufort Sea during summer (MMS 2008). Important
feeding grounds for bearded seal include areas along ice edges, in the currents between the barrier islands
and near river mouths, and in shallow areas with abundant clam beds. Traditional knowledge workshop
participants reported that bearded seals are commonly seen everywhere along the coast near Point Lay but
are generally abundant near Kasegaluk Lagoon where smelt and herring are present in high numbers
(SRB&A 2011). Additionally, participants reported it is common to see hundreds of bearded seal pups on
the spit between Naokuk Pass and the southern end Kasegaluk Lagoon, where the current is not as strong
(SRB&A 2011). Participants also indicated that bearded seals are not confined to ice areas. Bearded seals
like the feel of moving water, especially during molting (SRB&A 2011).
Walrus. The Pacific walrus (Odobenus rosmarus divergens) is most commonly found in relatively
shallow water areas, close to ice or land. The majority of the walrus population occurs west of Barrow
(Chukchi Sea), although a few walrus can move east throughout the Alaskan portion of the Beaufort Sea
to Canadian waters during the open-water season (Fay 1982). Traditional knowledge workshop
participants identified that while it is relatively rare to see walruses in the Beaufort Sea, Nuiqsut residents
have spotted them near Cross Island, Thetis Island, the area outside the Nigliq Channel of the Colville
River. Respondents typically spotted walrus hauled out on Cross Island or feeding near Cross Island when
sea ice was far from shore (SRB&A 2011).
Pacific walrus are benthic feeders, foraging in the sediments of the seafloor. Such feeding behavior results
in disturbance of wide areas of the seafloor (Nelson et al. 1994). During their fall migration south,
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walruses (primarily females) haul out on the barrier islands along the entire length of the Kasegaluk
Lagoon to Icy Cape, and Cape Lisburne, recently in very large numbers (SRB&A 2011).
Bowhead Whale. The group of bowhead whales (Balaena mvsticetus) that inhabit the Bering-Chukchi-
Beaufort Seas is important to the viability of the species as a whole and is a species of very high
importance for subsistence and to the culture of Alaskan Native peoples of the northern Bering Sea, the
Chukchi Sea, and the Beaufort Sea. Within or near areas where proposed actions could occur, geographic
areas of importance to this stock of bowhead whale include the spring lead system in both the Beaufort
and Chukchi Seas (MMS 2006). The best estimate of the abundance of the Western Arctic bowhead
whale stock is 10.545 with a minimum population estimate of 9.472. Overall, the stock appears to be
healthy and increasing in population (Allen and Angliss 2011 as cited in BOEM 2012).
Bowheads are extremely long lived, slow growing, slow to mature, and currently have high survival rates.
Thev are also unique in their ecology and their obligate use of lead systems to travel to summering
grounds. This dependence on spring leads, described further below, combined with calving and feeding
that occurs during the spring northward migration, further heightens their vulnerability to disturbance and
oil spills in some areas (MMS 2006).
Each spring (mid-March through mid-June, approximately), the bowhead western Arctic stock travel
through breaks in the sea ice, migrating from their winter grounds in the Bering Sea to their summer
grounds in the Canadian Beaufort Sea (Braham et al. 1980). These breaks in the ice, or leads, form when
winds blow the moving pack ice away from landfast ice, creating a flaw zone of open water and broken
ice generally parallel to the shore (Carroll and Smithhisler 1980). Bowhead whales depend on the lead
system as a migratory pathway between wintering and summering grounds (MMS 2006). In spring, ice
obstructs feeding opportunities; therefore, bowhead migratory movements are generally predictable and
consistent between the Bering Strait and Amundsen Gulf along the lead system (Quakenbush et al. 2010
as cited in BOEM 2012). The lead system is apparently an obligate pathway for this population.
Whales are seen in Barrow in early- to mid-April. The early pulse is dominated by juveniles. The size/age
composition of the whales entering the Beaufort Sea gradually switches so that by mid-May to June, large
whales and cow/calf pairs are seen. Most of the herd is believed to have migrated past Barrow in late
May. After passing Barrow, whales travel through spring leads through heavy pack ice, generally in a
northeasterly direction, eventually heading east toward the southeastern Beaufort Sea, reaching the
Canadian Beaufort by July (MMS 2006).
As the whales approach Point Barrow, the nearshore lead narrows and the movement of most whales is
correspondingly constricted. Northeast of Point Barrow the shear zone and extensive lead system in the
northern Beaufort Sea permit the whales to travel to the vicinity of Banks Island and the Amundsen Gulf
region during May and early June. Restriction of ice near Point Barrow and development of offshore
leads northeast of the Point provide the migration pathway, a result of converging water masses from the
Chukchi and Beaufort Seas and shifting winds, generally from the east and northeast. It is probably
advantageous for whales to use these recurring leads, as opposed to those in the southern Beaufort Sea
where there is less ice movement and where the availability of open water is less predictable (Carroll and
Smithhisler 1980).
During a five-year period (2006-2010). researchers from the Alaska Department of Fish and Game
worked with Native whalers from Alaska and marine mammal hunters from Canada to attach 46 satellite
transmitters to bowhead whales to document the migratory routes that connect their summering and
wintering areas (ADF&G 2010). After passing Point Barrow in spring, bowhead whales migrated through
ice that was quantified as 100 percent cover by satellite images. Once past Point Barrow, all tagged
whales traveled northeast before turning east and traveling 100-200 km offshore of the Beaufort Sea coast.
All whales staved between 71 and 72°N latitude. All tagged whales traveled relatively directly to the
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Amundsen Gulf polvnva. arriving there by May 26. 2006 and by May 3. 2008. Amundsen Gulf is used by
bowhead whales from May until mid-September (ADF&G 2010).
Based on duration of migration for seven individual whales, migration between the Bering Sea and the
Canadian Beaufort required an average of 19 days (range of 17-24 days) (ADF&G 2010). During the
spring migration, tagged whales generally did not stop between the Bering Strait and Amundsen Gulf
suggesting limited feeding opportunities or obstructions caused by ice. The spring migratory corridor
between the Bering Strait and Amundsen Gulf is consistent between years (ADF&G 2010). In some
years, parts of the spring lead system in the Chukchi Sea west, northwest, and southwest of Barrow are
used as feeding areas over extended periods of time during the spring migration, but this use is
inconsistent (MMS 2007). However, several researchers have reported that the region west of Point
Barrow seems to be of particular importance for feeding in some years but the whales may feed
opportunistically at other locations in the lead system where oceanographic conditions produce locally
abundant food (Caroll et al. 1987 as cited in MMS 2006. Moore and Reeves 1993. Moore 2000. Moore et
al. 2000a as cited in Mocklin et al. 2012).
Bowheads are filter feeders. Thev apparently feed through the water column, including bottom feeding
(BOEM 2012) as well as surface skim feeding (MMS 2006). Food items most commonly found in
stomachs include euphausiids. copepods. mvsids. and amphipods. Lowrv. Sheffield and George et al.
(2004 as cited in MMS 2006) concluded that feeding near Barrow during the spring migration is a
relatively common event; however, the amount of food in the stomachs tends to be lower in spring than in
autumn (MMS 2006). There is extensive evidence of epibenthic feeding, which indicates that these
whales could be exposed to hydrocarbons entrained in the sediment following an oil spill (Mocklin et al.
2012).
Researchers investigated the olfactory anatomy of bowhead whales and found that these whales have a
cribriform plate and small, but histologically complex olfactory bulb. The olfactory bulb makes up
approximately 0.13 percent of brain weight, unlike odontocetes where this structure is absent. The relative
size of the olfactory bulb in apes (0.06 percent) and humans (0.008 percent) is much smaller than in
bowheads. The researchers also determined that 51 percent of olfactory receptor genes were intact, unlike
odontocetes. where this number is less than 25 percent. This suggests that bowheads have a sense of
smell, and the researchers speculate that the whales may use this to find aggregations of krill on which
thev feed (ADF&G 2010).
Except for land-fast ice, the presence of sea ice does not appear to limit the movements of whales in the
spring in the Beaufort Sea (Ouakenbush et al. 2010 as cited in BOEM 2012). However, sea ice does limit
light penetration and wind-driven upwelling. which influences prey availability and thus whale
movements (Ouakenbush et al. 2010 as cited in BOEM 2012).
When whales encounter a partially closed lead interposed with polvnvas. thev adjust their diving and
surfacing sequences to the size and location of the open water. Whales encountering a small polvnva
would surface and blow as many times as space allowed while traveling at normal speed; then thev would
dive at the far edge of the polvnva. If another polvnva was close, the whales would surface there, take a
few more breaths, and continue on. In this way, thev were able to move steadily through flaw zones that
were mostly covered with ice (Carroll and Smithhisler 1980).
Occasionally. Carroll and Smithhisler (1980) observed a lead closed so tightly that the whales' progress
was hindered, and the polvnvas were too far apart to be reached in a single dive. Some whales proceeded
though the lead appeared closed, but fewer did so than when the lead was open. It appeared that the
whales dove, searched, and, if thev did not find another polvnva. returned to mill in the available polvnva.
thus keeping the surface water from freezing. Bowheads can break new ice as thick as 22 cm. Sea ice is
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more flexible than freshwater ice, and bowheads and white whales (Delyhinayterns lencas) have been
sighted pushing up young ice, forming hummocks to breathe.
The rate of whale travel speed ranges from 1 to 11 km/hour during spring migration. Nearly all the whales
traveled northeastwardly. Fewer than 1 percent traveled in the opposite direction. When thev traveled
southwest, it was usually because of closed leads stopping their progress to the northeast (Carroll and
Smithhisler 1980). Of 2.406 bowheads that were observed over 4 years in the 1970s. 1.815 (75.4 percent)
were traveling singly; 470 (19.5 percent) were in pairs; 105 (4.4 percent) were in groups of three, and 16
(0.7 percent) traveled in groups of four animals (Carroll and Smithhisler 1980).
Calves of-the-vear have been seen migrating with their mothers during April. May, and June, indicating
that at least some calves were born shortly before or during the spring migration (Braham et al. 1980).
Most calving occurs in the Chukchi Sea during the spring migration from March through June from
winter breeding areas in the northern Bering Sea (BOEM 2012). Females give birth to a single calf every
3 to 4 years (MMS 2008b as cited in BOEM 2012). Small calves generally stay close to their mothers'
sides and are difficult to see particularly if thev are on the offshore side of the mother. On two occasions.
very small calves were seen riding their mothers' backs, apparently grasping the mothers with their
flippers (Carroll and Smithhisler 1980).
In the fall, bowheads were presumed to return along a similar general route from the Canadian Beaufort
Sea where thev spend much of the summer (Allen and Angliss 2011 as cited in BOEM 2012). The return
route is closer to shore across the Beaufort Sea, to the Bering Sea to overwinter in polvnvas and along
edges of the pack ice (Braham et al. 1980; Moore and Reeves 1993 as cited in BOEM 2012). The first
whales to begin the fall migration are typically the larger ones, which establish the migration route in the
Beaufort Sea. Migration through the eastern Alaskan portion of the Beaufort Sea continues through
September and into October (Huntington and Ouakenbush 2009 as cited in BOEM 2012).
Beluga Whale. Two stocks of beluga whales (Delphinapterus leiicas) inhabit the Alaskan Chukchi Sea:
the Eastern Chukchi Stock and the Beaufort Stock. Summer breeding concentrations can be found at
Kasegaluk Lagoon. The summer Beaufort Sea stock breeds during the summer mostly in the Mackenzie
Delta (Hazard 1988) and spends the early fall along the edge of the Beaufort Sea pack ice before they too
migrate through the Chukchi to Bering Sea wintering grounds (Allen and Angliss 2010). During the late
summer and early fall, both stocks can be found as far north as latitude 80°N in waters deeper than 200
meters (656 feet) (Suydam et al. 2005). Between 2,000 and 3,000 beluga whales annually feed, calve, and
molt in Kasegaluk Lagoon and Peard Bay (Seaman et al. 1985; Suydam et al. 2001; MMS 2003).
Traditional knowledge workshop participants confirmed that Omalik Lagoon is an important feeding,
calving, molting, and resting habitat.
Beluga feeding areas are closer to shore and concentrated in bays and mouths of rivers. Local hunters
report that beluga regularly use an area near Cape Beaufort. They indicated that the area experienced a
landslide in which a significant portion of a shoreline cliff slid into the sea resulting in a shallow rocky
area used by many fish (SRB&A 2011). Traditional knowledge workshop participants identified that
feeding areas for beluga are generally closer to shore than feeding areas for bowhead whales and that they
tend to concentrate in bays, mouths of rivers, Elson Lagoon, and near reefs (SRB&A 2011). Beluga
whales of the Beaufort Sea and eastern Chukchi Sea stocks winter in the Bering Sea and summer in the
Beaufort and Chukchi Seas, migrating around western and northern Alaska along the spring lead system
in April and May (Richard et al. 2001; Angliss and Outlaw 2005) as cited in BOEMRE 2011). Both
bowheads and belugas are associated with the spring lead and polvnva system in the Chukchi Sea in the
months of March through June (BOEMRE 2011). Beluga use the spring lead system in their northward
migration in the spring through the Chukchi Sea and also use the Kasegaluk Lagoon along the Chukchi
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coast (BOEMRE 2011). Beluga whales also would be vulnerable to oil contact during the spring
migration throughout the spring lead system (MMS 2007).
Gray Whale. The gray whale (Eschrichtius robustus) migrates into the Chukchi and Beaufort Seas during
spring to feed throughout the late spring, summer, and early fall. They migrate out of the Chukchi and
Beaufort Seas with freeze up and migrate south out of the Bering Sea during November to December
(Rice and Wolman 1971). The Eastern North Pacific Stock of the gray whale winter and breed in Mexican
lagoons and summer in the shallow-watered Bering and Chukchi Seas. Small numbers of gray whales
have been observed in the Beaufort Sea east of Point Barrow. Most migrating whales occur within 15
kilometers (9.3 miles) of land (Green et al. 1995) but have been observed up to 200 kilometers (124.3
miles) offshore (Bonnell and Dailey 1993). Traditional knowledge workshop participants noted seeing
gray whales in Camden Bay by Collinson Point and stated that the entire area near Kaktovik is an
important whale habitat area for several species of whales (SRB&A 2011).
In the Chukchi Sea, whales congregate between Cape Lisburne and Point Barrow (Moore et al. 2000b).
Gray whales migrate into the northern Bering and Chukchi Seas starting in late April through the summer
open-water months and feed there until October to November (MMS 2003). Most migrating whales occur
within 15 kilometers (9.3 miles) of land (Green et al. 1995) but have been observed up to 200 kilometers
(124.3 miles) offshore (Bonnell and Dailey 1993). Concentrations of feeding gray whales are found off
Wainwright. Traditional knowledge workshop participants along the Chukchi Sea coast noted that gray
whales are often observed feeding outside Five-Mile Pass (SRB&A2011). Traditional knowledge
workshop participants along the Beaufort Sea coast noted seeing gray whales in Camden Bay by
Collinson Point and stated that the entire area near Kaktovik is an important whale habitat area for several
species of whales (SRB&A 2011).
Fin Whale. Fin whales (Balaenoptera phvsctlus) might occur seasonally in southwestern Chukchi Sea.
Their known current summer feeding habitat includes the southern portion, especially the southwestern
portion, of the Chukchi Sea along the Alaskan coast. Fin whales feed primarily on euphausiids. or "krill".
but also consume substantial quantities of fish. In the North Pacific overall, fin whales preferred
euphausiids (mainly Euvhausia vacificct. Thvsctnoessa lonsipes. T. svinifera. and T. inermis) and large
copepods (mainly Calamis cristus). followed by schooling fish such as herring, walleve pollock
(Theragra chalcogramma), and capelin (NMFS 201 lb). Fish, especially capelin. walleve pollock, and
herring, were the main prey documented in the stomachs from harvested whales taken north of 58° N.
latitude in the Bering Sea. Fin whales appear to make long distance movements quickly to track prey
aggregations and can switch their diet from krill to fish as thev migrate northward (NMFS 201 lb).
Fin whales are rarely observed in the eastern half of the Chukchi Sea. Three fin whales (including a cow-
calf) were observed together in the southern Chukchi Sea, directly north of the Bering Strait, in July 1981
(Ljungblad et al. 1982 as cited in NMFS 201 lb). In 1979-1987. no other fin whale sightings were
reported during aerial surveys of endangered whales in summer (July) and autumn (August. September,
and October) in the Northern Bering Sea (north of Saint Lawrence Island). Chukchi Sea (north of 66° N.
latitude), and east of the International Date Line and the Alaskan Beaufort Sea (157° 01' W. east to 140°
W. longitude) and offshore to 72° N. latitude (Ljungblad 1988 as cited in NMFS 201 lb). Fin whales were
not observed during annual aerial surveys of the Beaufort Sea, conducted in September and October from
1982-2004 (e.g.. Treacv 2002; Moore et al. 2000b as cited in NMFS 201 lb). Fin whales were also not
observed during a 2003 summer research cruise in the Chukchi and Beaufort seas (Bengston and
Cameron 2003 as cited in NMFS 201 lb). With the resurgence of oil and gas activities in the Chukchi Sea
and related monitoring and research, there have been a few fin whale sightings in the eastern half of the
Chukchi Sea (NMFS 201 lb).
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Fin whales are not expected to routinely occur in the Beaufort and Chukchi seas. Continued arctic
warming could result in changes in oceanographic conditions favorable to the distribution and abundance
of fin whale prey species; and extend their distribution into waters of the Chukchi Sea, and possibly
Beaufort Sea (NMFS 201 lb).
Polar Bear. Polar bears (Ursus maritimus) are widely distributed throughout the Arctic where the sea is
ice-covered for large portions of the year. Sea ice provides a platform for hunting and feeding, for seeking
mates and breeding, for denning, and for long-distance movement. Ringed seals are polar bear's primary
food source, and areas near ice edges, leads, or polynyas where ocean depth is minimal are the most
productive hunting grounds. While polar bears primarily hunt seals for food, they may occasionally
consume other marine mammals, including via scavenging on their carcasses (USFWS 2009).
This behavior was also discussed during the Traditional knowledge workshops, where participants
indicated that whale carcasses provide easy feeding opportunities and attract polar bears, making Cross
Island, Barter Island, and Point Barrow (areas where butchered whale carcasses are deposited) prime
feeding grounds. Additionally, respondents indicated that polar bears follow bearded seals in the fall and
are seen near the barrier islands (SRB&A 2011). Traditional knowledge workshop participants reported
that during the winter, polar bear dens are found in both offshore and onshore environments. Participants
commented that on land, polar bears will den along rivers and in areas with larger snow drifts. They also
stated that polar bears will den offshore when there is adequate ice and pressure ridges in which they can
make their den (SB&RA 2011).
Two polar bear stocks are thought to exist in Alaska, the Southern Beaufort Sea and the Chukchi/Bering
Seas. Polar bears typically occur at low densities throughout their circumpolar range. Population
estimates have wide confidence intervals and a reliable estimate does not currently exist (USFWS 2009).
5.6. Coastal and Marine Birds
Migratory birds are a significant component of the marine ecosystem of the Chukchi and Beaufort Seas.
Both areas include important foraging, nesting, and rearing areas for several million birds. Descriptions of
coastal and marine bird distribution are discussed in detail in the Chukchi and Beaufort BE (Tetra Tech
2012a). Most species in the Chukchi and Beaufort Seas are migratory and present in the Arctic only
seasonally, from May through early November. Some species appear only during migration; others nest,
molt, feed, and accumulate critical fat reserves needed for migration while in the area (MMS 1987a). The
main categories of species include waterfowl (e.g., duck, goose, swan), seabirds (e.g., loon, gull, tern),
shorebirds (e.g., sandpiper, plover, crane), and raptors (e.g., hawks, eagles, falcons). Complete lists of all
bird species in those groups are presented in Table 5-2 through Table 5-5.
Aerial surveys in the Chukchi and Beaufort Seas have documented that birds are widespread in
substantial numbers in both nearshore and offshore waters (MMS 2008) and it is likely that this
approximate distribution prevails along most of or the entire Beaufort coastline and into the northern
Chukchi Sea during the open-water season. Traditional knowledge workshop participants noted that birds
follow open ice leads during spring migration (SRB&A 2011). The Sagavanirktok, Kuparuk, Ikpikpuk,
and Colville Rivers that empty into the Beaufort Sea have been identified as important nesting and
breeding areas for waterfowl (MMS 1996). Traditional knowledge workshop participants confirmed the
Colville River Delta, the mouth of the Kalikpik River, Fish Creek, Teshekpuk Lake, and the barrier
islands as important feeding grounds and nesting areas for birds (SRB&A 2011).
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The highest pelagic bird density is near Barrow, which contains high amounts of plankton that are a food
source for birds and other organisms. Traditional knowledge workshop participants confirmed that
Barrow is in the migratory path of several bird species, particularly eiders and brants, and that brants,
long-tailed ducks, and Canada geese molt at the various points found along the Beaufort Sea coast,
including Beechy Point and the area east of Oliktok Point (SRB&A 2011). Most shorebirds and other
waterfowl concentrate in snow-free coastal or inland areas until nest sites are available (MMS 1982).
Most birds are along barrier islands or in lagoons rather than seaward from lagoons or along mainland
shores (Flint et al. 2000 as cited in MMS 2003). Shorebirds are numerically dominant in most coastal
plain bird communities occurring across northern Alaska (including the Arctic National Wildlife Refuge)
and Canada (including Kendall Island Bird Sanctuary).
Five types of habitat particularly capable of supporting a variety of marine and coastal avifauna are the
barrier islands, coastal lagoons, coastal salt marshes, river deltas, and offshore areas. The coastal waters
are primary habitat for nesting, molting, feeding, and resting activities of migratory marine birds. Major
concentrations of birds occur nearshore [in waters shallower than 20 meters (66 feet)] and in coastal areas
along the Chukchi and Beaufort Seas. Nearshore areas also provide important nesting habitat for loons,
waterfowl, and shorebirds and include foraging habitat for seabirds nesting. This was confirmed by
traditional knowledge workshop participants (SRB&A 2011).
The highest nesting densities generally occur in areas of mixed wet and dry habitats, whereas birds often
move to wetter areas for broodrearing. Islands in river deltas and barrier islands provide the principal
nesting habitat for several waterfowl and marine bird species in the Area of Coverage. Shorebirds prefer
wet-tundra habitats or well-drained, gravelly areas for nesting, whereas loons use lakes, and geese prefer
deeper ponds or wet tundra near lakes. Lagoons formed by barrier islands, bays, and river deltas provide
important broodrearing and staging habitat for waterfowl, particularly molting oldsquaws (ADF&G 2008
cited in ADNR 2009).
Important feeding and staging grounds for shorebirds and waterfowl include Kasegaluk Lagoon, the
mouth of the Kuk River, Peard Bay, and salt marshes along the mainland coast. Those habitats are critical
to waterfowl that regularly pass through or near the Beaufort and Chukchi Seas during migration.
Traditional knowledge workshop participants reported that Kasegaluk Lagoon, the barrier islands, spits
surrounding the lagoon, and inland areas near Point Lay are all important habitat areas for waterfowl
species. The smelt in Kasegaluk Lagoon provide food for nesting waterfowl (SRB&A 2011).
The Ledvard Bay area, located between Cape Lisburne and the village of Point Lav within the deferral
area 0. is part of the spring lead system that appears to be a stopover point for a substantial proportion of
all seaducks moving to breeding areas on the Arctic Coastal Plain or western Canada. Similarly, this same
area appears important to many of these same birds once thev leave breeding grounds and molt or stage
prior to migrating to wintering areas (MMS 2007).
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Oil and Gas Geotechnical Surveying and Related Activities In Federal Waters
of the Chukchi Sea • Spring Lead System Seasonal Restrictions
EPA Permit Number AKG-28-43QQ
+ oEPA,,""nl"
i GIS Team
Figure 5-1. Chukchi Sea Spring Lead System Seasonally Restricted Area (see Permit Part H.A.6.).
Spectacled eiders (Somateria fischcn) make use of the spring lead system when thev migrate north from
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the wintering area into the Chukchi Sea in May and June (BOEMRE 2011). After breeding, male eiders
fly to nearshore marine waters in late June where thev undergo a complete molt of their flight feathers. In
Arctic Alaska, the primary molting area is Ledvard Bay (NMFS 2011). The spring lead system includes
the Ledvard Bay Critical Habitat Unit and represents the only open-water area along their migratory path
(BOEMRE 2011). Similarly, the Steller's eiders (Polsticta stelleri) return to the Arctic as spring thaw
allows, migrating north in May and June (NMFS 2011). Along open coastline. Steller's eiders usually
remain within about 400 m (1.312 ft) of shore in water less than 10 m (33 ft) deep but thev can also be
found in waters well offshore in shallow bays and lagoons or near reefs (USFWS 2000a as cited in NMFS
2011).
Most king eiders (Somateria spectabilis) begin to migrate through the Chukchi Sea during spring and
arrive in the Beaufort Sea by the middle of May, with males typically preceding females (Barry 1968 as
cited in MMS 2007). In the Beaufort Sea, the location and timing of offshore leads along the Chukchi Sea
is major factor determining routes and timing of king eider migration (Barry 1986 as cited in MMS 2007).
Powell et al. (2005 as cited in MMS 2007) reported that Ledvard Bay may be a critical stopover area for
foraging and resting during spring migration. Oppel (2007. pers. commun. as cited in MMS 2007)
reported extensive use of the spring lead system by king eiders. According to Oppel (as cited in MMS
2007). 80 king eiders were satellite-tagged between 2002 and 2006. Of these. 23 died or the transmitter
failed. Of the remaining 57 birds. 54 (95 percent) were documented to stage in the Ledvard Bay vicinity
(nearshore waters between Cape Lisburne and Peard Bay). The typical staging time in Ledvard Bay was
17-24 days (range 1-48 days) (MMS 2007).
Table 5-2. Shorebirds in the Beaufort and Chukchi Seas
Common name
Scientific name
Breeds in
Beaufort Sea
Breeds in
Chukchi Sea
Sandhill crane
Grus Canadensis
X
X
Black-bellied plover
Pluvialis squatarola
American golden-plover
Pluvialis dominica
X
X
Semipalmated plover
Charadrius semipalmatus
X
X
Whimbrel
Numenius phaeopus
X
X
Hudsonian godwit
Limosa haemastica
Bar-tailed godwit
Limosa lapponica
X
X
Ruddy turnstone
Arenaria interpres
X
X
Black turnstone
Arenaria melanocephala
Great knot
Calidris tenuirostris
X
Sanderling
Calidris alba
Semipalmated sandpiper
Calidris pusilla
X
X
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Western sandpiper
Calidris mauri
X
X
White-rumped Sandpiper
Calidris fuscicollis
X
X
Baird's Sandpiper
Calidris bairdii
X
X
Pectoral sandpiper
Calidris melanotos
X
X
Buff-breasted Sandpiper
Trvngites subruficollis
Dunlin
Calidris alpine
X
X
Long-billed dowitcher
Limnodromus scolopaceus
X
X
Common snipe
Gallinago gallinago
X
X
Red-necked phalarope
Phalaropus lobatus
X
X
Red phalarope
Phalaropus fulicaria
X
X
Pelagic cormorant
Phalacrocorax pelagicus
X
X
Lesser yellowlegs
Tringa flavipes
Wandering tattler
Heteroscelus incanus (sometimes
placed with Tringa incanus)
X
Red-necked stint (rufous-necked
stint)
Calidris ruficollis
Table 5-3. Raptors in the Beaufort and Chukchi Seas
Common name
Scientific name
Breeds in
Beaufort Sea
Breeds in
Chukchi Sea
Northern harrier
Cirus cyaneus
X
X
Rough-legged hawk
Buteo lagopus
X
X
Bald eagle
Haliaeetus leucocephalus
Golden eagle
Aquila chrvsaetos
X
X
Peregrine falcon
Falco peregrines
X
X
Gyrfalcon
Falco rusticolus
X
X
Snowy owl
Bubo scandiacus
X
X
Short-eared owl
Asio flammeus
X
X
Merlin
Falco columbarius
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Table 5-4. Seabirds in the Beaufort and Chukchi Seas
Common name
Scientific name
Breeds in
Beaufort Sea
Breeds in
Chukchi Sea
Red-throated loon
Gavia stellate
X
X
Pacific loon
Gavia pacifica
X
X
Yellow-billed loon
Gavia adamsii
X
X
Arctic loon
Gavia arctica
Common loon
Gavia immer
Red-necked grebe
Podiceps grisegena
X
X
Northern fulmar
Fulmarus glacialis
Pomerine jaeger
Stercorarius pomarinus
X
X
Parasitic jaeger
Stercorarius parasiticus
X
X
Long-tailed jaeger
Stercorarius longicaudus
X
X
Mew gull
Larus can us
X
X
Herring gull
Larus argentatus
Glaucous gull
Larus hyperboreus
X
X
Sabine's gull
Xema sabini
X
X
Glaucous-winged gull
Larus glaucescens
Ivory gull
Pagophila eburnean
Ross' gull
Rhodostethia rosea
Black-legged kittiwake
Rissa tridactyla
X
X
Arctic tern
Sterna paradisaea
X
X
Common murre
Uria aalge
X
Thick-billed murre
Uria lomvia
X
Black guillemot
Cepphus grille
X
X
Pigeon guillemot
Cepphus Columba
X
Horned puffin
Fratercula corniculata
X
Tufted puffin
Fratercula cirrhata
X
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Fork-tailed storm-petrel
Oceanodroma furcata
Kittlitz's murrelet
Brachvramphus brevirostris
X
Dovekie
A He alle
X
Crested auklet
Aethia cristate Ha
Least auklet
Aethia pusilla
Parakeet auklet
Aethia psittacula
Short-tailed shearwater
Puffinus tenuirostris
Table 5-5. Waterfowl in the Beaufort and Chukchi Seas
Common name
Scientific name
Breeds in
Beaufort Sea
Breeds in
Chukchi Sea
Mallard
Anas /jlatvrhvnchos
X
X
Tundra swan
Cvgnus columbianus
X
X
Greater white-fronted goose
Anser albifrons
X
X
Snow goose
Anser caerulescens
Canada goose
Branta canadensis
X
X
Emperor goose
Anser canagicus
X
X
Green-winged teal
Anas crecca
X
X
Black brant (or brent)
Branta bernicla nigricans
X
X
Northern pintail
Anas acuta
X
X
Northern shoveler
Anas clypeata
X
X
American wigeon
Anas americana
Greater scaup
Avthva marila
X
X
Common eider
Somateria mollissima
X
X
King eider
Somateria spectabilis
X
X
Oldsquaw or long-tailed duck
Clangula hvemalis
X
X
Black (or Common) scoter
Melanitta nigra
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Surf scoter
Melanitta perspicillata
White-winged scoter
Melanitta fusca
Red-breasted merganser
A1erg us serrator
X
X
Harlequin duck
Histrionicus histrionicus
X
Barrow's goldeneye
Bucephala islandica
5.7. Threatened and Endangered Species
The Endangered Species Act requires federal agencies to consult with the USFWS and NMFS if the
federal agency's actions could beneficially or adversely affect any threatened and endangered species or
their designated critical habitat. In this case, the federal action agency is EPA, and the federal action is the
issuance of the Geotechnical GP.
The action could affect listed species under the jurisdiction of both the USFWS and NMFS. This section
gives an overview of the listed species (endangered, threatened, proposed, and candidate in the Area of
Coverage including reasons for listing. Overviews of potential effects on the species and their critical
habitat from the geotechnical discharges are discussed in Section 6.3. I he BE for the Geotechnical GP, as
well as the BEs for the Beaufort and Chukchi Exploration NPDES General Permits, provide a detailed
analysis of the potential effects of the permit action on the listed species. Table 5-6 summarizes the 10
species listed.
Table 5-6. Summary of Endangered Species Act-listed, proposed, and candidate species occurring
in the Area of Coverage
Common
name
Scientific name
ESA status
Critical habitat
designated
within the Action
Area
Reason for ESA listing
Bowhead
whale
Balaena
mysticetus
Endangered
No
Effects on population due to historic commercial
whaling, habitat degradation, and ongoing
whaling in other countries and other
anthropogenic related disturbances
Fin whale
Balaenoptera
phvsalus
Endangered
No
Effects on population due to historic commercial
whaling, habitat degradation, and ongoing
whaling in other countries and other
anthropogenic related disturbances
Humpback
whale
Megaptera
novaeangliae
Endangered
No
Effects on population due to historic commercial
whaling, habitat degradation, and ongoing
whaling in other countries and other
anthropogenic related disturbances
Polar bear
IJrsus maritimus
Threatened
Yes
Global climate change and its effects on Arctic
sea-ice is the primary threat to polar bear
populations
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Spectacled
eider
Somateria
fischeri
Threatened
Yes
The causes of the spectacled eider's population
decline are currently unknown; however, it is
likely due to loss of habitat
Steller's
eider
Polsticta stelleri
Threatened
No
The causes of the Steller's eider population
decline include increased predation, over
hunting, ingestion of lead shot, habitat loss,
exposure to environmental toxins, scientific
exploitation, and the effects of global climate
change
Bearded
seal,
Beringia
DPS
Erignathus
barb at us
nauticus
Threatened
No
Effects on bearded seal populations have
included direct harvesting, indirect mortalities as
a result of fisheries, mortalities resulting from
marine mammal research activities, and the
effects of global climate change in the Arctic
environment
Ringed
seal, Arctic
subspecies
Phoca hispida
hispida
Threatened
No
Effects on ringed seal populations have included
direct harvesting, indirect mortalities as a result
of fisheries, mortalities resulting from marine
mammal research activities, and the effects of
global climate change in the Arctic environment
Pacific
walrus
Odobenus
rosmarus
divergens
Candidate
No
Effects on walrus populations have included
historic commercial hunting, pollution and noise
disturbances related to the oil and gas industry,
and the effects of global climate change in the
Arctic environment
Yellow-
billed loon
Gavia adamsii
Candidate
No
Yellow-billed loons are vulnerable to population
decline because of their small population size,
low reproductive rate, and specific breeding
habitat requirements
EPA has completed the informal ESA Section 7 consultation process with USFWS and NMFS and will
continue this process during the public review and comment period for the draft Geotechnical GP. On
December 20. 2013. EPA sent the Biological Evaluation (BE) to the USFWS and NMFS requesting
concurrence on the agency's determinations that issuance of the Geotechnical GP may affect, but is not
likely to adversely affect the ESA listed species or their designated critical habitat areas. EPA
supplemented the BE on February 11. 2014 with additional analysis for the Pacific walrus, a candidate
species, and requested to "conference'1 on the effects of the Geotechnical GP on this species.
On January 31. 2014. the USFWS concurred with EPA's determinations for the polar bear, spectacled
eider, and Steller's eider, and designated spectacled eider critical habitat. In a separate letter on March 13
2014. the USFWS concluded that the Geotechnical GP is not likely to jeopardize the continued existence
of the Pacific walrus. In a letter dated March 19. 2014 NMFS. concurred with EPA's determinations that
issuance of the Geotechnical GP may affect, but is not likely to adversely affect the bowhead. fin, and
humpback whales, and bearded and ringed seals.
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5.8. Essential Fish Habitat
EFH is the waters and substrate (sediments, and the like) necessary for fish to spawn, breed, feed, or grow
to maturity, as defined by NMFS for specific fish species. In the Area of Coverage, EFH has been
established for snow crabs, Arctic cod, saffron cod, and Pacific salmon (chinook, coho, pink, sockeye,
and chum). Juvenile and adult life stages of each EFH species are present within the Area of Coverage.
The Magnuson-Stevens Fishery Conservation and Management Act (January 21, 1999) requires EPA to
consult with NMFS when a proposed discharge has the potential to adversely affect EFH. Table 5-7 lists
the EFH species potentially present in the Area of Coverage. The Geotechnical BE includes an evaluation
of EFH and EPA's determination of no adverse effect from the permit action.
Table 5-7. EFH species potentially present in the Area of Coverage
Common name
Scientific name
Pacific salmon- chinook, coho, pink, sockeye, chum
Oncorhynchus tshawvtscha, 0. kisutch, 0. gorbuscha,
0. nerka, 0. keta
Arctic cod
Boreogadus saida
Saffron cod
Elegin us gracilis
Opilio snow crab
Chionoecetes opilio
5.9. Subsistence Activities and Environmental Justice Considerations
Environmental justice (EJ) is the fair treatment and meaningful involvement of all people regardless of
race, color, national origin, or income with respect to the development, implementation, and enforcement
of environmental laws, regulations, and policies. Executive Order 12898, Federal Actions to Address
Environmental Justice in Minority Popidations and Low-Income Popidations, and the accompanying
Presidential memorandum, directs each federal agency to consider EJ as part of its mission and to develop
strategies to achieve environmental protection for all communities to the greatest extent practicable and
permitted by law.
EPA's tribal trust responsibilities and government-to-government consultation requirements are covered
under a separate Executive Order and agency policies. However, the issues and concerns shared with EPA
by tribal governments are also considered in this EJ analysis because of related issues and concerns
among all Arctic communities regarding safety of subsistence foods and cultural impacts, including the
continuation of the subsistence way of life. The North Slope, Northwest Arctic and Bering Sea
communities are predominantly Alaska Native. EPA is taking the approach that if the Geotechnical GP
action is protective of subsistence resources, then it will be protective of all residents of the communities.
EPA developed an EJ analysis in support of the Beaufort and Chukchi Exploration NPDES General
Permits (AKG282100 and AKG2881000, respectively) (USEPA 2012c). As the EJ analysis evaluated and
considered the potential impacts to the same communities from similar discharges, EPA believes the EJ
analysis is also relevant for the Geotechnical GP. Please refer to the EJ Analysis for additional details.
While there are many subsistence resources harvested in the Area of Coverage, there is one particular
traditional cultural activity that is a key component of Inupiat culture and way of life. The bowhead whale
hunt involves most of the community in some part of the hunt, and the proceeds are shared and enjoyed in
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feasts and celebrations. Where in many aspects of Inupiat life cultural changes have taken place at the
expense of tradition, the whale hunt remains "key to the survival of [Inupiat] culture" (Brower et. al 1998
as cited in NMFS 2013). The Western Arctic bowhead whales (Balaena mysticetus) migrate annually
from wintering areas in the northern Bering Sea, through the Chukchi Sea in the spring, and into the
Canadian Beaufort Sea where they spend the summer. In the autumn they return to the Bering Sea to
overwinter. Eleven Alaskan coastal communities along this migratory route participate in traditional
subsistence hunts of these whales: Gambell, Savoonga, Little Diomede, and Wales (on the Bering Sea
coast); Kivalina, Point Lay, Point Hope, Wainwright, and Barrow (on the coast of the Chukchi Sea); and
Nuiqsut and Kaktovik (on the coast of the Beaufort Sea). The bowhead whale hunt constitutes an
important subsistence activity for these communities, providing substantial quantities of food, as well as
reinforcing the traditional skills and social structure.
The Northwest Arctic coastal and Bering Sea communities that participate in the bowhead whale hunt
share many common features with the North Slope Borough coastal communities. These include many
lifestyle, environmental, social, economic, and cultural conditions that determine health outcomes, such
as reliance on subsistence resources, remote location, small population comprised mainly of Inupiat
people, limited infrastructure, housing type, and limited economic opportunities. Seventy-two percent of
adults in the Northwest Arctic Borough reported participating in hunting, fishing, and harvesting for
subsistence (Poppel et al. 2007; NMFS 2013).
Spring subsistence hunting occurs in the villages of Point Hope. Wainwright. and Barrow. Subsistence
hunting of bowhead whales during the fall westward migration occurs at Kaktovik. Nuiqsut. and Barrow
(MMS 2006).
Nuiqsut: Nuiqsut whalers only conduct bowhead whaling during the fall. Nuiqsut whalers search for
whales on areas north and east of Cross Island, usually in water depths greater than 66 feet. These whalers
primarily use Cross Island as their base while thev are hunting bowhead whales. Nuiqsut whalers usually
land 3 or 4 whales per year. Currently, beluga whales are not a prevailing subsistence resource in Nuiqsut.
Spotted seals are typically hunted in the nearshore waters off the Colville River Delta in the summer
months. Bearded seals are generally hunted during July, with some hunting occurring also in August and
September. Ringed seals are primarily hunted in the winter or spring. Other subsistence activities include
fishing, waterfowl and seaduck harvests, and hunting for walrus, polar bears, caribou, and moose (NMFS
2013a).
Kaktovik: Kaktovik whalers conduct bowhead whaling during the fall. Kaktovik whalers hunt for whales
east, north, and occasionally west of Kaktovik. Beluga whales are not a prevailing subsistence resource;
Kaktovik hunters may harvest one beluga whale in conjunction with the annual bowhead hunt. It appears
that most Kaktovik residents obtain beluga through exchanges with other communities. Bearded seals are
generally hunted during July, with some hunting also occurring in August and September. Ringed seals
are primarily hunted in the winter or spring. Other subsistence activities include fishing, waterfowl and
seaduck harvests, and hunting for walrus, polar bears, caribou, and moose (NMFS 2013a).
Barrow. Spring bowhead whale hunting generally occurs from April to June. Barrow whalers hunt from
ice leads from Point Barrow southwestward along the Chukchi Sea coast to the Skull Cliff area. Fall
bowhead whale hunting occurs in August to October from approximately 10 miles west of Point Barrow
to the east side of Pease Inlet. The northern boundary of the fall whaling area is 30 miles north of Point
Barrow and extends southeastward to a point approximately 30 miles off Cooper Island. Beluga whaling
occurs from April to June in the spring leads between Point Barrow and Skull Cliff; later in the season,
belugas are hunted in open water around the barrier islands off Elson Lagoon. Walrus are harvested from
June to September from west of Barrow southwestward to Peard Bay. Polar bear are hunted from October
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to June generally in the same vicinity used to hunt walrus. Seal hunting occurs mostly in winter, but some
open-water sealing is done from the Chukchi coastline east as far as Pease Inlet and Admiralty Bay in the
Beaufort Sea (MMS 2007).
Wainwriaht. Spring bowhead whaling occurs from April to June in the spring leads offshore of
Wainwright. Wainwright whalers hunt beluga whales in the spring lead system from April to June, but
only if no bowheads are in the area. Later in the summer, from July to August, belugas can be hunted
along the coastal lagoon systems. Walrus hunting occurs from July to August at the southern edge of the
retreating pack ice. From August to September walrus can be hunted at local haulouts with the focal area
from Milliktagvik north to Point Franklin. Polar bear hunting occurs primarily in the fall and winter
around lev Cape, at the headland from Point Belcher to Point Franklin, and at Seahorse Island (MMS
2007).
Point Lay: Because Point Lav's location renders it unsuitable for bowhead whaling, beluga whaling is the
primary whaling pursuit. Beluga whales are harvested from the middle of June to the middle of July. The
hunt is concentrated in Naokak and Kukpowruk Passes south of Point Lav where hunters use boats to
herd the whales into the shallow waters of Kasegaluk Lagoon where thev are hunted. If the July hunt is
unsuccessful, hunters can travel as far north as Utukok Pass and as far south as Cape Beaufort in search of
whales. When ice conditions are favorable. Point Lav residents hunt walrus from June to August along the
entire length of Kasegaluk Lagoon, south of lev Cape, and as far as 20 miles offshore. Polar bear are
hunted from September to April along the coast rarely more than 2 miles offshore (MMS 2007).
Point Hove: Bowhead whales are hunted from March to June from whaling camps along the ice edge
south and southeast of the point. The ice lead is rarely more than 6 to 7 miles offshore (MMS 2007).
There is no fall bowhead hunt in Point Hope because the whales migrate on the west side of the Bering
Strait, out of range of the Point Hope whalers (NMFS 2013b). Beluga whales are harvested from March
to June in the same area used for the bowhead whale hunt. Beluga whales can also be hunted in the open
water later in the summer from July to August near the southern shore of Point Hope close to the beaches,
as well as areas north of the point as far as Cape Dyer. Walrus is harvested from May to July along the
southern shore of the point from Point Hope to Akoviknak Lagoon. Point Hope residents hunt polar bear
primarily from January to April and occasionally from October to January in the area south of the point
and as far out as 10 miles from shore (MMS 2007).
5.9.1. Importance of Subsistence
The Inupiat consider subsistence to be more than just a "way of life," and for the people who live along
the Beaufort Sea and Chukchi Sea coasts, subsistence is their life (Maclean 1998). Subsistence defines the
essence of who they are, and it provides a connection between their history, culture, and spiritual beliefs.
An essential component of Inupiat values is the sharing of subsistence resources among families, friends,
elders, and those in need. "[Virtually all Inupiat households depend on subsistence resources to some
degree" (NSB 2004, NMFS 2013).
Subsistence activities are assigned the highest cultural value by the Inupiat and provide a sense of identity
in addition to the substantial economic and nutritional contributions. Many species are important for the
role they play in the annual cycle of subsistence resource harvests, and each subsistence food resource
plays an important role. Loss of access to any subsistence food resource could have serious effects. When
a subsistence resource is unavailable for any reason, families will adapt and redirect harvest effort
towards other species, but the contribution of some resources to the annual food budget would be very
difficult to replace. Besides their dietary benefits, subsistence resources provide materials for family use
and for the sharing patterns that help maintain traditional Inupiat family organization. Relationships
between generations, among families, and within and between communities are honored and renewed
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through sharing, trading, and bartering subsistence foods. The bonds of reciprocity extend widely beyond
the permit areas of coverage and help to maintain ties with family members elsewhere in Alaska.
Subsistence resources provide special foods for religious and ceremonial occasions; the most important
ceremony, Nalukataq, celebrates the bowhead whale harvest (NMFS 2008, NMFS 2013).
The use of traditional food in the subsistence way of life provides important benefits to users. Subsistence
foods are often preferable as they are rich in many nutrients, lower in fat, and healthier than purchased
foods. Subsistence foods consist of a wide range of fish and wildlife and vegetable products that have
substantial nutritional benefits. According to the state Division of Subsistence, about 38.3 million pounds
of wild foods are taken annually by residents of rural Alaska, or about 316 pounds per person per year.
This compares to 23 pounds per year harvested by Alaska's urban residents. Fish comprise 55 percent of
subsistence foods taken annually. Ninety-two to one-hundred percent of rural households consume
subsistence-caught fish, according to the state (ADF&G 2010).
Subsistence harvesting of traditional foods, including preparation, eating, and sharing of resources
contributes to the social, cultural, and spiritual well-being of users and their communities (NMFS 2013).
Communities express and reproduce their unique identities based on the enduring connections between
current residents, those who used harvest areas in the past, and the wild resources of the land. Elders"
conferences, spirit camps, and other information exchange and gathering events serve to solidify these
cultural connections between generations and between the people and the land and its resources (NMFS
2013).
Participation in the harvesting and sharing of subsistence foods goes beyond the family and the
community. There is an extensive network of exchange that occurs between communities of the Beaufort
and Chukchi Seas and further to relatives residing in larger towns such as Anchorage and Fairbanks. For
instance, the shares of bowhead whale that each crew member receives after whaling are involved in
secondary redistribution among local relatives and those in other communities. Social and cultural
identity is strengthened by serving subsistence foods at home and at feasts and sharing subsistence foods,
particularly with elders. The foods that are exchanged strengthen family and regional ties (NMFS 2013).
5.9.2. Subsistence Participation and Diet
Diets include both traditional, or subsistence foods, and non-traditional, or store foods. Traditional diets
are associated with numerous health benefits and reduced risk of many chronic diseases including
diabetes, high blood pressure, high cholesterol, heart disease, stroke, arthritis, depression, and some
cancers (Reynolds et al. 2006; Murphy et al. 1995; Adler et al. 1996; Ebbesson et al. 1999, Bjerregaard et
al. 2005). Data from the 2003 North Slope Borough census show that virtually all Inupiat households
report relying on subsistence resources to some extent, and that subsistence foods make up a large
proportion of healthy meals (Circumpolar Research Associates 2010, NMFS 2013). The North Slope
Borough also has among the highest per capita harvests of subsistence food in Alaska (McAninch 2010).
Residents have expressed concerns about environmental contamination, particularly as it relates to
contamination of subsistence food sources. In a recent survey, 44 percent of Inupiat village residents
reported concern that fish and animals may be unsafe to eat (Poppel et al. 2007, NMFS 2013).
Environmental contaminants have the potential to affect human health in a number of ways. First
exposure to contaminants via inhalation, ingestion, or absorption may induce adverse health effects,
depending on a number of factors, including the nature of the contaminant, the amount of exposure, and
the sensitivity of the person who comes in contact with the contaminant.
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Aside from actual exposure to environmental contamination, the perception of exposure to contamination
is also linked to known health consequences. Perception of contamination may result in stress and anxiety
about the safety of subsistence foods and avoidance of subsistence food sources (CEAA 2010, Joyce
2008, Loring et al. 2010), with potential changes in nutrition-related diseases as a result. It is important to
note that these health results arise regardless of whether or not there is any real contamination at a level
that could induce toxicological effects in humans; the effects are linked to the perception of
contamination, rather than to measured levels (NMFS 2013).
Below is a brief summary of subsistence resources harvested by the North Slope coastal communities and
generally represented of other Bering Sea and Arctic communities. Subsistence foods include fish, seal,
walrus, beluga and bowhead whale from the Beaufort and Chukchi Seas, as well as land-based animals
and certain migratory birds and eggs. More information can be found in the ODCEs for the Beaufort and
Chukchi Exploration NPDES General Permits. Table 5-8 below summarizes the percent total subsistence
harvest by species (NMFS 2013).
Table 5-8. Percent total subsistence harvest by species
Species
Barrow
(1987-1989)
Wainwright
(1987-1989)
Point Lay
(1987)"
Point Hope
(1992)
Kaktovik
(1992-1993)
Nuiqsut
(1993)
Bowhead whale
38%
35%
63%
6.9%
63%
29%
Beluga whale
--
--
1%
40.3%
--
--
Seals
6%
6%
6%
8.3%
3%
3%
Walrus
9%
9%
27%
16.4%
--
--
Fish
11%
11%
5%
9%
13%
34%
Polar bear
2%
2%
2%
--
1%
--
Waterfowl
4%
4%
2%
2.8%
2%
2%
Bowhead Whale. The bowhead whale is hunted by the Chukchi communities in the spring; however,
Barrow residents also hunt the bowhead whale in the fall (MMS 2008) and the communities of Point
Hope, Point Lay, and Wainwright have reported successful whale hunts in the fall. Nuiqsut and Kaktovik
conduct hunting activities in the Beaufort Sea in the fall. Bowhead whale hunting can occur anywhere
from 1 miles to more than 10 miles offshore depending on the location of open leads and weather
conditions (SRB&A 2011). In 1977 the International Whaling Commission established an overall quota
for subsistence hunting of the bowhead whale by the Alaskan Inupiat. The Alaska Eskimo Whaling
Commission regulates the quota, and it annually decides how many bowheads each whaling community
may take.
Bowhead whales are hunted from open leads in the ice (e.g., areas of open water) during the spring
months of March and April when pack-ice conditions deteriorate and during the fall in open water,
typically between late August and early October. No other marine mammal is harvested with the intensity
and concentration of effort that is expended on the bowhead whale (MMS 2008).
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Beluga Whale. Beluga whales hunting begins at the spring whaling season through June and occasionally
in July and August in ice-free waters. Belugas are generally harvested incidental to the bowhead hunt or
after the spring bowhead season ends. Beluga whales are harvested in the leads, in the lagoon systems
along the coast, and in the outer coast of the barrier islands.
Seals. Seals are hunted year-round, but the bulk of the seal harvest takes place during the open-water
season, with breakup usually occurring in June. In spring, seals can be hunted once the landfast ice has
retreated. While seal meat is eaten, the dietary significance of seals primarily comes from seal oil, served
with almost every meal that includes subsistence foods. Seal oil also is used as a preservative for meats,
greens, and berries. Also, sealskins are important in the manufacture of clothing and, because of their
beauty, spotted seal skins often are preferred for making boots, slippers, mitts, and parka trim. In practice,
however, ringed seal skins are used more often in making clothing, because the harvest of this species is
more abundant (MMS 2008; SRB&A 2011).
Ringed seals are the most common hair seal species harvested, and spotted seals are harvested only in the
ice-free summer months. Ringed seal hunting is concentrated in the Chukchi Sea, although some hunting
occurs off Point Barrow and along the barrier islands that form Elson Lagoon. The hunting of bearded
seals is an important subsistence activity because the bearded seal is a preferred food and because bearded
seal skins are the preferred covering material for the skin boats used in whaling. Six to nine skins are
needed to cover a boat. For those reasons, bearded seals are harvested more than the smaller hair seals.
Walrus. The major walrus hunting effort coincides with the spring bearded seal harvest. The walrus is
hunted primarily during June to August by the Chukchi communities, but it also is hunted by boat during
the rest of the summer along the northern shore, especially along the rocky capes and other points where
they tend to haul out (MMS 2008; SRB&A 2011). Walruses are incidentally taken during whaling and
seal hunting by Nuiqsut and Kaktovik (MMS 2008); though they are rarely seen because the communities
are located east of the walruses" optimum range.
Fishes. The harvesting of fish is not subject to seasonal limitations, a situation that adds to their
importance in the communities" subsistence diet. A variety of fishes are harvested in the marine and
freshwater habitats along the coast, within the shores of barrier islands, and in lagoons, estuaries, and
rivers. Fish are eaten fresh or frozen. Because of their important role as an abundant and stable food
source, and as a fresh food source during the midwinter months, fish are shared at Thanksgiving and
Christmas feasts and given to relatives, friends, and community elders. Fish also appear in traditional
sharing and bartering networks that exist among North Slope communities. Because it often involves the
entire family, fishing serves as a strong social function in the community.
Waterfowl. Since the mid-1960s, waterfowl and coastal birds as a subsistence resource have been
growing in importance. The most important subsistence species of birds are the black brant, long-tailed
duck, eiders, snow goose, whitefronted goose, Canada goose, and pintail duck. Other birds, such as loons,
occasionally are harvested. Waterfowl hunting occurs mostly in the spring, from May through early July;
normally, a less-intensive harvest continues throughout the summer and into the fall. In the summer and
early fall, such hunting usually occurs as an adjunct to other subsistence activities, such as checking
fishnets (MMS 2008).
Eggs from a variety of species still are gathered occasionally, especially on the offshore islands where
foxes and other predators are less common. Waterfowl, hunted during the whaling season (beginning in
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late April or early May) when their flights follow the open leads, provide a source of fresh meat for
whaling camps.
Polar Bear. Polar bears are harvested during the winter months on ocean ice and along ocean leads
(MMS 2008), although they are hunted less actively than in the past (MMS 2008).
5.10. Climate Change and Effects on Subsistence
Climate in the Arctic is showing signs of rapid change; nevertheless further study is needed to better
understand the changes that have been observed and their significance to the Arctic Climate Region as
well as global climate change (NMFS 2013). Evidence of climate change in the past few decades,
commonly referred to as global warming, has accumulated from a variety of geophysical, biological,
oceanographic, atmospheric, and anthropogenic sources. Since much of this evidence has been derived
from relatively short time periods, and climate itself is inherently variable, the recent occurrence of
unusually high temperatures may not necessarily be abnormal sinco it could fall within the natural
variability of climate patterns and fluctuations. However, with that possibility, it should be noted that
evidence of climate changes in the Arctic have been identified ami appear lo generally agree with climate
modeling scenarios. Such evidence suggests (NMFS 2013):
• Air temperatures in the Arctic are increasing at an accelerated rate
• Year-round sea ice extent and thickness has continually decreased over the past three decades
• Water temperatures in the Arctic Ocean have increased
• Changes have occurred to the salinity in the Arctic Ocean
• Rising sea levels
• Retreating glaciers
• Increases in terrestrial precipitation
• Warming permafrost in Alaska
• Northward migration of the treeline
The implications of climate change on subsistence resources are difficult to predict, although some trends
are consistent and anticipated to continue. The North Slope communities and their reliance on subsistence
resources will be stressed to the extent the observed changes continue. Those stressors could include
alterations to traditional hunting locations, increases in subsistence travel and access difficulties, shifts in
migration patterns, and changes to seasonal availability of subsistence resources (MMS 2008).
Through the traditional knowledge gathering process for the Beaufort and Chukchi Exploration NPDES
General Permits, the following observations regarding changes in ice conditions and effects on wildlife
and subsistence activities were shared (SRB&A 2011):
• Marine mammals such as seals and walrus are congregating in large groups because of lack of ice,
becoming skinnier from having to travel farther, and more frequently coming to shore when no
offshore ice is available on which to rest.
• Changes in timing and nature of break up (earlier) and freeze up (later) have caused the hunting
season to be shorter and residents to have fewer opportunities, such as increased difficulty
harvesting from the ice. Additionally, hunters might have to travel farther, which increases overall
risks, costs, and dangers from rotten ice.
• Warming of the temperatures and permafrost has contributed to spoiling of harvested meat.
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• At the same time, some subsistence activities in certain areas have become easier because of open
leads closer to shore than in the past.
• Lack of ice and the habitat it provides affects marine mammal distribution, particularly bearded
seals, walruses, and polar bears.
The main impacts of climate change on cetaceans would result from habitat changes (e.g.. ice melting)
that might impact prey migration, location, or availability as well as potentially impacting existing
migratory routes and breeding or feeding grounds. Because of the Arctic Ocean's relatively low species
diversity, it may be particularly vulnerable to trophic-level alternations caused by global warming
(Derocher. Innn and Stirling 2004 as cited in MMS 2007). For example. Mecklenburg et al. (2005 as
cited in MMS 2007) show that changes in the arctic ice cover are affecting arctic fish (Loeng 2005 as
cited in MMS 2007). In Hudson Bay. Gaston. Woo, and Hipfner (2003 as cited in MMS 2007) concluded
that the decline in arctic cod and increase in capelin and sand lance were associated with a general
warming of the waters and a significant decline in the amount of ice cover. Their evidence suggests that
the fish community in northern Hudson Bay shifted from Arctic to Subarctic from 1997 onwards, which
was reflected in dramatically altered diets of thick-billed murres (Uria lomvia) in the region. Likewise-
fish assemblages and populations in Alaska have undergone observable shifts in diversity and abundance
during the last 20-30 years. Changes in distributions of important prey species, such as arctic cod, could
have cascading effects throughout the ecosystem. The arctic cod is a pivotal species in the arctic food
web, as evidenced by its importance as a prey item to belugas, narwhals, ringed seals, and bearded seals
(Davis. Finlev. and Richardson 1980 as cited in MMS 2007). In arctic regions, no other prey items
compare with arctic cod in abundance and energetic value. Arctic cod are believed to be adapted to
feeding under ice and ice-edge habitat is critical to cod recruitment (Tynan and DeMaster. 1997 as cited
in MMS 2007).
As described earlier in this document, the group of bowhead whales (Balaena mvsticetus) that inhabit the
Bering-Chukchi-Beaufort seas is important to the viability of the species as a whole and is a species of
very high importance for subsistence and to the culture of Alaskan Native peoples of the northern Bering
Sea, the Chukchi Sea, and the Beaufort Sea (MMS 2006). While data do not vet exist to quantitatively
predict how changes in sea ice will affect the population dynamics of Bering-Chukchi-Beaufort bowhead
whales, the importance of sea ice to the Arctic ecosystem suggests that the changes determined through
predictive modeling will have a significant impact on the ecology of this species. Moore and Laidre
(2006) constructed a conceptual model of the influence of sea ice cover on bowhead prev composition
and availability, based on the underlying pathways that affect zooplankton. Bowhead whales feed on
zooplankton produced locally within a foraging area (i.e.. Calarms spp.) and on zooplankton advected to
foraging areas from elsewhere (Calanus spp. and Thvsanosessa spp.) (Lowrv et al. 2004 as cited in Moore
and Laidre 2006). Moore and Laidre (2006) noted that sea ice can influence both: (1) the production path
through impacts on predictable solar forcing (i.e.. the seasonal light cycle) and water stratification, and/or
(2) the advective path through impacts on the dynamics of water flow (i.e.. currents and upwelling).
driven by highly variable atmospheric (wind) forcing. Increased primary production will augment the
bowhead prev base only if it remains well coupled with zooplankton life cycles (Hansen et al. 2002 as
cited in Moore and Laidre 2006).
While bowhead whales do not appear to be food limited at present, if primary production becomes
decoupled with the vertical migration of zooplankton (e.g.. Niehof 2000 as cited in Moore and Laidre
2006). or the increasing fetch of open water enhances storm-driven mixing and retards stratification
required for peak production in the Arctic (e.g.. Yang et al. 2004 as cited in Moore and Laidre 2006). any
gain in bowhead prev base could be short lived. Some ecosystem models suggest that reductions of ice
cover over the deep Canada Basin may ultimately result in less energy transfer to higher trophic levels
(Walsh et al. 2004 as cited in Moore and Laidre 2006). Ultimately, any decoupling of the system that
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reduces secondary production will have negative effects on upper trophic levels, including bowhead
whales (Moore and Laidre 2006).
Potential impacts on bowhead whales from climate change (MMS 2007) include:
• Decreases in ice cover with the potential for resultant changes in prev-species concentrations and
distribution; related changes in bowhead whale distributions; changes in subsistence-hunting
practices that could result in smaller, younger whales being taken and, possibly, in fewer whales
being taken.
• More frequent climatic anomalies, such as El Ninos and La Ninas, with potential resultant
changes in prey concentrations.
• A northern expansion of other whale species, with the possibility of increased overlap in the
northern Bering and/or the Chukchi seas.
A diminishing ice pack actually might increase the range of certain whales, such as the bowhead;
alternatively, this same situation could diminish phvtoplankton production, which would lead to declines
in key cetacean prey species, such as copepods and plankton-feeding fish that are preferred food for
narwhals and beluga whales. A reduced ice pack also could expose whales to increased Arctic ship traffic
(Burns 2000 as cited in MMS 2007). The timing and sequence of whale migration also may be a function
of ice cover and could negatively affect the feeding and reproduction of ice-associated cetaceans, such as
bowheads and belugas. Changes to polvnvas and ice leads, important in the distribution and migration of
bowheads in winter and spring, could have a major impact on bowhead behavior (Huntington and
Mvmrin 1996; Lowrv 2000; Parson et al. 2001; NRC 2003; USEPA 1998; National Assessment Synthesis
Team 2000; Environment Canada 1997; IPCC 2001; BESIS Project Office 1997 as cited in MMS 2007).
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6. DETERMINATION OF UNREASONABLE DEGRADATION
This section presents a discussion of EPA's evaluation of the 10 ocean discharge criteria and EPA's
determinations regarding unreasonable degradation.
Under EPA's regulations, no NPDES permit may be issued if it is determined to cause unreasonable
degradation of the marine environment. EPA considers the 10 ocean discharge criteria and other factors
specified in 40 CFR 125.122(a)-(b) when evaluating the potential for unreasonable degradation.
Unreasonable degradation of the marine environment means:
• Significant adverse changes in ecosystem diversity, productivity and stability of the biological
community within the area of discharge and surrounding biological community.
• Threat to human health through direct exposure to pollutants or through consumption of exposed
aquatic organisms.
• Loss of aesthetic, recreational, scientific or economic values which is unreasonable in relation to the
benefit derived from the discharge.
According to EPA's regulations, when conducting its evaluation, EPA may presume that discharges in
compliance with CWA section 301(g), 301(h), or 316(a), or with state water quality standards, do not
cause unreasonable degradation of the marine environment, 40 CFR 125.122(b). In addition, EPA may
impose additional permit conditions to ensure that a discharge will not result in unreasonable degradation.
In cases where sufficient information is available to determine whether unreasonable degradation of the
marine environment will occur, 40 CFR 125.123(a) and (b) governs EPA's actions. Discharges that cause
unreasonable degradation will not be permitted. Other discharges may be authorized with necessary
permit conditions to ensure that unreasonable degradation will not occur.
In the circumstances where there is insufficient information to determine, before permit issuance, that a
discharge will not result in unreasonable degradation, EPA may permit the discharge, if EPA determines
on the basis of available information that:
• Such discharges will not cause irreparable harm to the marine environment during the period in
which monitoring is undertaken.
• There are no reasonable alternatives to the on-site disposal of these materials.
• The discharge will be in compliance with all permit conditions established pursuant to 40 CFR
125.123(d).
Based on the information provided Sections 1-5 above and the evaluation provided below, EPA has
determined that the discharges authorized by the Geotechnical GP will not cause unreasonable
degradation of the marine environment. EPA's ocean discharge criteria evaluations, related findings and
determinations are discussed in this section.
6.1. CRITERION 1
The quantities, composition, and potential for bioaccumulation or persistence of the
pollutants to be discharged.
Based on information provided by AOGA (2013), EPA estimates that approximately 100 geotechnical
boreholes will be drilled per year in federal waters within the Area of Coverage of the Beaufort and
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Chukchi Seas during the 5-year term of the general permit. Additionally, for purposes of the ODCE, EPA
assumes four equipment feasibility testing activities would occur each year (two per sea), for a period of
7-10 days per event, totaling 20 events during the term of the permit. Each related activity would result in
a seafloor disturbance of approximately half of a typical mudline cellar dimension; therefore, EPA's
assumption is the area of disturbance from equipment testing would disturb an area that is approximately
10 by 20 feet, generating a total of approximately 235,000 gallons of cuttings materials to be discharged
during the 5-year permit term. EPA also assumes drilling fluids would not be used for geotechnical
related activities. Section 3 of this ODCE characterizes the types and quantities of discharges that would
occur during the geotechnical surveys and related activities. The potential impacts of those discharges are
the focus of this section.
While water-based drilling fluids are not expected to be used to drill shallow geotechnical boreholes, they
may be used for deeper holes to lubricate the drill bit and stabilize the borehole. The limitations and
conditions of the permit ensure that drilling fluids and drill cuttings do not contain persistent or
bioaccumulative pollutants. For example, if barite is added to the drilling fluids, then mercury and
cadmium in stock barite must meet the limitation of 1 mg/kg and 3 mg/kg, respectively, which indirectly
controls the levels of other metal constituents in the discharge. The drilling fluids must also meet the
suspended particulate phase toxicity testing requirements and cannot be discharged if an oil sheen is
detected. During spring and fall bowhead hunting activities in the Chukchi and Beaufort Seas.
respectively, the Geotechnical GP restricts the discharges of drilling fluids and drill cuttings (Discharge
001). In addition, the Geotechnical GP requires an inventory and reporting of all chemicals added to the
system, including limitations on chemical additive concentrations.
Discharges of cuttings not associated drilling fluids, cement slurry and the miscellaneous discharges (i.e.,
deck drainage; sanitary and domestic wastes; desalination unit waste; bilge water; boiler blowdown; fire
control system test water; non-contact cooling water; and uncontaminated ballast water) are not expected
to carry pollutants that are bioaccumulative or persistent.
Finally, the Geotechnical GP includes a seasonal prohibition that restricts all discharges into the spring
lead system in the Chukchi Sea within the 3-25 mile corridor prior to July 1. EPA has included this
restriction based on the relative nearshore location of the spring lead system in the Chukchi Sea, its
particular importance for feeding, migration, and calving of bowhead whales, and its importance to
various marine mammal species and seaducks. as discussed above in Section 4.3.4. This seasonal
prohibition provides ongoing protection of this critical area during a sensitive period.
EPA's selection of the July 1 date is based on many factors, including consideration of the traditional start
of oil and gas activities in the offshore Arctic, which usually occurs on or after July 1. with activity
continuing for approximately 120 days during the open water (ice-free) season (Shell 2014). This date
also corresponds with NMFS' estimate of completion of the spring bowhead migration (NMFS 2011) and
its standard restriction under the Marine Mammal Protection Act (MMPA) prohibiting vessel entry into
the Chukchi Sea through the Bering Strait prior to July 1 (NMFS 2012). In keeping with that estimate.
NMFS applied a restriction in the 2012 Incidental Harassment Authorization to Shell, which prohibited
vessel entry into the Chukchi Sea through the Bering Strait prior to July 1 (NMFS 2012).
6.1.1. Seafloor Sedimentation
The water-based drilling fluids and drill cuttings, including materials from the mud pit cleanup
(Discharge 001), cuttings not associated with drilling fluids (Discharge 011), and cement slurry
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(Discharge 012) are discharged at the seafloor. In low-energy environments within shallower waters,
currents do not play a role in moving deposited material from the bottom or mixing it into sediments, as
shown by the modeling results discussed in Section 3.4. However, the deposited materials may be mixed
vertically with natural sediments by physical resuspension processes and by biological reworking of
sediments by benthic organisms or marine mammals. Ice gouging could also mix deposited materials into
seafloor sediments. The relative contribution of those processes to sediment mixing has not been
quantified.
6.1.2. Benthic Communities
While the scale and scope of geotechnical surveys and related activities are much less than drilling of
exploration wells, data from Dunton et al. (2009) investigations at old drill sites were reviewed for the
ODCE. Benthic habitats in Camden Bay in the Beaufort Sea to characterize baseline conditions at the
Sivulliq prospect and recovery at a former exploratory drill site (Hammerhead) were investigated. At 45
sites, 10 of which were in the area of the Hammerhead former drill site, the species composition of the
infaunal community along with density, biomass, and stable isotopic composition (C-13 and N-15) were
determined through sediment grab samples. Comparison of results from the other 35 Sivulliq sites to the
10 Hammerhead sites indicated that previous drilling activities (which were conducted in 1985) did not
have a measurable impact on the occurrence or trophic structure of the infaunal community after 23 years.
Marine invertebrates were also collected by Battelle et al. (2010) in the Burger and Klondike survey areas
of the Chukchi exploration area, where exploration drilling occurred in 1989, to measure metals
concentrations in tissue. Comparison of metal (arsenic, barium, chromium, copper, iron, mercury, lead,
and zinc) concentrations in the Astarte clam in the Chukchi Sea, to concentrations in clams collected in
the Beaufort Sea in 2008 were not significantly different. Concentrations of arsenic, cadmium, mercury,
and manganese were significantly higher in crabs collected in the Klondike survey area than crabs
collected in the Burger survey area. The study did not determine a reason for the difference, but it
suggests that differences in metal concentrations were from differences in the water column or food.
Measurable effects on benthic communities have the potential to impact fish resource, particularly benthic
feeders. However, scientific evidence suggests that drilling discharges and cuttings have minor effects on
adult fish health (NMFS 2013, Hurley and Ellis 2004). Based on these results and the numbers of
projected boreholes, spacing of the boreholes, and estimated discharges from geotechnical surveys and
related activities (see Section 2.0), it is not expected that sedimentation would be persistent or produce
irreversible effects on benthic structure and diversity.
6.1.3. Trace Metals
Several studies have evaluated the solubility of trace metals found in barite, a key ingredient in drilling
fluids. Crecelius et al. (2007) evaluated the release of trace components from barite to the marine
environment, including seawater and sediment pore water, under varying redox conditions. Solubility of
barium and other metals in barite were tested under specific laboratory conditions, where salinity was 30
ppt; temperature was 40 °F to 68 °F (4 °C and 20 °C); pH ranged from 7 to 9; and pressure was 14 and
500 pounds per square inch. In containers with static seawater from the Gulf of Mexico, concentrations of
cadmium, copper, mercury manganese, and zinc gradually increased through leaching over time. Results
showed that temperature and pressure had little effect on solubility; however, pH had the greatest effect
on concentrations of mercury and zinc, which increased as pH increased. When exposed to flowing
seawater (by passing seawater through the containers at a constant rate), at pH 8 for 24 hours, the release
rate of cadmium, copper, mercury, lead and zinc were greatest during the first several hours. Dissolved
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concentrations of those metals in the flowing seawater approached concentrations found in coastal
seawater after 24 hours. The addition of natural sediment, however, reduced the release of metals to the
static water column compared to barite alone, indicating that organisms living on or near the sediment
would not be exposed to the elevated concentrations of dissolved metals. Crecelius et al. also notes that
the static experiments are worst-case scenarios because in open water, natural systems field currents and
diffusion would further dilute metals.
Crecelius et al. (2007) also investigated leaching of metals from barite in anoxic sediment. Barium, iron,
manganese, and zinc were found to be more soluble under anoxic conditions in pore water, but
concentrations of cadmium, copper, mercury, methylmercury, and lead were not significantly different
from un-amended sediment. The results suggest that metals would form insoluble sulfide minerals under
anoxic conditions, and therefore, would not be bioavailable to benthic organisms.
Neff (2008) used the results from Crecelius et al. (2007) to determine the bioavailable fraction of metals.
Neff used a distribution coefficient, which is the factor that predicts partitioning of the metal between the
solid phase and dissolved in a liquid phase, for each metal between barite and seawater, and barite and
pore water. The distribution coefficients indicate that metals (barium, cadmium, chromium, copper,
mercury, lead, and zinc) are more likely to remain associated with barite by a minimum of 2.5 orders of
magnitude than to dissolve in seawater. Distribution coefficients for metals between barite and pore
water, at pH levels similar to the pH of digestive fluids of benthic organisms, show that all metals other
than cadmium were more likely to remain associated with barite particles. Cadmium was the most
bioavailable metal for bottom-dwelling organisms that could ingest barite particles. Likewise, MacDonald
(1982) also concluded that metal solubility from barite is low according to thermodynamics and that low
solubility results in metal concentrations are comparable to coastal ocean dissolved metal concentrations.
Those studies demonstrate that trace metals are generally unavailable to marine organisms in detrimental
concentrations. Furthermore, the studies suggest that trace metal concentrations in a mixture of barite and
seawater are close to natural coastal concentrations, although a number of metals precipitate out as
insoluble metal sulfides.
6.1.4. Persistence
Snyder-Conn et al. (1990) studied the persistence of trace metals in low-energy, shallow Arctic marine
sediments. In that study, sediment samples were collected at three exploratory well sites in the shallow,
nearshore Beaufort Sea and compared to four control locations. Exploratory drilling had occurred at the
experimental sites between 1981 and 1983, and sediment samples were collected in 1985. Samples were
collected at five stations (at approximately 25-meter (82-foot) intervals) along three to four transects
established at sites where drilling fluids and cuttings had been discharged. Average sediment
concentrations for aluminum, arsenic, barium, chromium, lead, and zinc were elevated compared to the
average reference station concentrations. The author suggested that the persistence resulted from poor
dispersion because of the low energy of the marine environment in those shallow locations.
Long et al. (1995) applied the sediment guidelines to the concentration samples obtained in the Snyder-
Conn study. They concluded that concentrations for chromium, lead and zinc were below the effects
range median, and arsenic was below the effects range low. Concentrations below the effects range low
represent a low risk for aquatic toxicity, and an effects range median concentration means concentrations
greater than the effects range low, which could result in adverse effects.
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In order to help establish a baseline data set, Trefry and Trocine (2009) collected samples at a total of 46
stations in the Beaufort Sea. These included surface and subsurface sediment samples as well as water
samples. Samples were collected at 10 locations near the former Hammerhead exploratory well drilled in
1985 and 1986 in the Beaufort Sea, 19 random background stations collected north and south of the
former Hammerhead drill site, 12 locations in the areas of the Sivulliq drill site and 5 locations along a
possible pipeline corridor. Surface sediment samples were collected at all 46 locations and analyzed for
total trace metals and polynuclear aromatic hydrocarbons. Additionally, 19 samples from 4 sediment
cores were analyzed for total trace metals. Results indicate surface and subsurface sediment
concentrations of aluminum, iron, cadmium, mercury, vanadium and zinc were at background values at
all 10 locations near the former Hammerhead exploratory well, whereas maximum concentrations of
silver (0.40 micrograms per gram (|ug/g)), chromium (135 f_ig/g), copper (58.3 f_ig/g), lead (49.2 f_ig/g), and
selenium (2.0 j_ig/g) were above background concentrations at one surface sediment Hammerhead station.
Sediment concentrations for cadmium, mercury, zinc and silver were all below the minimum
recommended sediment quality guidelines (effects range low).
Concentrations of barium were at background levels for 42 of the 46 stations. However, concentrations
from four surface samples collected within -100 meters of the former Hammerhead drill site, plus
samples from sediment cores at two stations at the former drill site contained elevated barium
concentrations. It was concluded that the barium enrichment was most likely due to the presence of barite
from residual drilling mud and cuttings.
In 2008, a Chemical Characterization Program, a component of the Chukchi Sea Environmental Studies
Program, sampled and analyzed baseline concentrations of metals and hydrocarbons in sediments and
tissues at 34 stations at the Burger survey area and 31 stations at the Klondike survey area. Five of the
stations in each survey area were at the historical drill sites. A total of 80 sediment samples were analyzed
for hydrocarbons and metals while a total of 79 marine invertebrate samples also were analyzed for
hydrocarbons and metals.
The study also found that all sediment concentrations of silver, aluminum, cadmium, chromium, iron,
manganese, and zinc were at background values; however, concentrations of barium were elevated at
three sampling sites at the historic drill sites at stations approximately 0.2 nautical miles (nmi) from the
original discharge location (Battelle et al. 2010). The study noted slight elevations in concentrations of
lead at two sites, and elevated concentrations of copper and mercury at one site at historic drill sites,
which is consistent with the presence of residual barite. Metal concentrations at all sites were not present
at concentrations higher than the effects range low derived by Long et al. (cited in Battelle et al. 2010).
In conclusion, the relatively high energy currents in both the federal waters of Chukchi and Beaufort Seas
are expected to disperse trace metals that could be discharged during geotechnical surveys and related
activities. In addition, studies of sediment metal concentrations in areas where previous exploration
drilling activities occurred—which produce much higher discharge volumes when compared to
geotechnical activities—show that metal concentrations are not persistent and decrease to levels below
risk-based sediment guideline concentrations. Finally, hydrocarbons are not expected to be present as a
result of geotechnical surveys or related activities. The maximum depth of boreholes drilled under the
Geotechnical GP is 499 feet below the seafloor, which is well above the known depths of hydrocarbon-
bearing zones.
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6.1.5. Bioaccumulation
Heavy metals, such as mercury, cadmium, arsenic, chromium, and lead can bioaccumulate depending on
their chemical speciation. Existing data are not adequate to quantify the potential bioaccumulation from
exposure to exploratory oil drilling operations. Available data suggest, however, that because the
bioavailability of trace metals from barite is quite low, the bioaccumulation risks are also expected to be
low (Crecelius et al. 2007; Neff 2008, 2010). Additionally, several field studies show that metals in water-
based drilling fluids and drill cuttings are not bioavailable (i.e., the extent to which a chemical can be
absorbed by a living organism) because they are present almost exclusively as extremely insoluable
materials (Neff 2010). Studies conducted with cold-water amphipods evaluated their absorption of metals
when exposure to water-based fluids for a period of 5 days. In that study, Neff removed one-half of the
amphipods for analysis after 5 days of exposure, while the remaining half were placed in clean flowing
seawater for 12 hours. All the exposed amphipods accumulated small amounts of copper and lead but not
chromium, mercury, or zinc during exposure. The amphipods lost some of the accumulated copper and
lead during 12 hours in clean seawater, suggesting that the accumulated metals are released rapidly due to
lack of absorption beyond the external body surfaces (Neff 2010). That suggests that bioaccumulation of
metals from water-based drilling fluids is low. Neff (2010) cites bioaccumulation studies conducted by
Northern Technical Services (NTS) in 1981 using species present in the Beaufort Sea, which shows a
small amount of accumulation of chromium and iron in fourhorn sculpin, and a small amount of iron in
saffron cod that were exposed to mixtures of water-based fluids at concentrations of 4 to 17 percent.
Table 6-1 lists concentration of metals in Beaufort Sea amphipods before and after exposure to a 20%
mixture of XC-polymer drilling fluids for five days and after return to clean seawater for 12 hours. Metals
concentrations are mg/kg dry weight (ppm) (From NTS 1981 as cited by Neff 2010).
Table 6-1. Concentrations of metals in Beaufort Sea amphipods (in ppm)
Exposure
Chromium
Copper
Mercury
Lead
Zinc
Unexposed
2.7
5.1
0.07
11.0
123
5 Days
2.7-3.6
8.0-9.3
0.05-0.07
11.8-13.6
107-137
5 Days & 12
Hour Purge
3.0-3.2
6.9-7.1
0.04-0.05
10.2-12.3
110-114
Similar concentrations could occur in the Beaufort and Chukchi Seas during discharges of water-based
drilling fluids (if used) to conduct geotechnical surveying activities, but discharge volumes would be
much reduced, the metals have low bioavailability to marine organisms, and the concentrations would not
be expected to persist in the receiving water environment.
6.1.6. Control and Treatment
EPA utilized best professional judgment to incorporate technology-based effluent limitations required by
the ELGs in 40 CFR Part 435, Subpart A, to the discharges of water-based drilling fluids and cuttings
from geotechnical surveying activities. Those ELGs include an acute (96-hour) effluent toxicity limit of a
50 percent lethal concentrations (LC50) of a minimum 30,000 ppm suspended particulate phase (SPP) on
discharged drilling fluids. The 30,000 ppm SPP concentration (3 percent by volume) would be lethal to
50 percent of organisms exposed to that concentration. That limit is a technology-based control on the
toxicity of drill cuttings and fluids. The 30,000 ppm SPP limitation is both technologically feasible and
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economically achievable, and it is the best available technology established nationally (USEPA 1993).
Under the ELG, if SPP concentrations less than 30,000 ppm result in a LC50 response, then additives to
drilling fluids would be substituted to ensure a less toxic discharge.
The Geotechnical GP establishes the ELG limits for mercury and cadmium concentrations (1 mg/kg and 3
mg/kg, respectively) in stock barite. EPA has determined that the limitation indirectly controls the levels
of toxic pollutant metals because barite that meets the mercury and cadmium limits is also likely to have
reduced concentrations other metals (USEPA 1993). Additional permit requirements include no discharge
during bowhead hunting activities in the Beaufort and Chukchi Seas and no discharge if an oil sheen is
detected. Finally, the Geotechnical GP also includes a requirement to conduct a post-activity
environmental monitoring for boreholes that utilize water-based drilling fluids and where an EMP has not
been completed pursuant to the Beaufort and Chukchi Exploration NPDES General Permits. For these
reasons and based on the discussions above, it is not expected that the Geotechnical GP would result in
discharges of pollutants in quantities or composition that would bioaccumulate or persist in the marine
environment.
6.2. CRITERION 2
The potential transport of such pollutants by biological, physical, or chemical processes.
6.2.1. Biological Transport
Biological transport processes include bioaccumulation in soft or hard tissues, biomagnification, ingestion
and excretion in fecal pellets, and physical reworking to mix solids into the sediment (bioturbation).
Biological transport processes occur when an organism performs an activity with one or more of the
following results:
• An element or compound is removed from the water column
• A soluble element or compound is relocated within the water column
• An insoluble form of an element or compound is made available to the water column
• An insoluble or particulate form of an element or compound is relocated
The ODCE supporting the Arctic general permit (AKG280000) provides a detailed literature review of
bioaccumulation, biomagnifications, and bioturbation (USEPA 2006). Little information is available to
assess the biomagnification of drilling fluid discharges components; however, one study suggests that
barium and chromium could biomagnify. In an in vitro experiment, the mean barium level in
contaminated sea worms was 22 j_ig/g, whereas the controls contained 7.1 j_ig/g. Chromium levels were
1.02 j_ig/g in contaminated worms and 0.62 f_ig/g in controls. In both cases, concentrations in depurated
worms were not significantly different from controls (Neff et al. 1984). Studies on biological transport
show that depuration (removal of the organism from the contaminate source) can reduce concentrations of
contaminants in tissue.
Bioturbation, the process of benthic organisms reworking sediment and mixing surface material into
deeper sediment layers, is another mode of biological transport. Whereas sea worms and other benthic
organisms have the ability to move material locally, gray whales and walrus move tremendous amounts of
sediment in the Beaufort and Chukchi Seas. Nelson et al. (1994) analyzed feeding pits created by gray
whales and furrows created by walruses. Combined, the two species are estimated to move more than 700
million tons per year of sediment according to current population estimates. The study acknowledges
some limitations in the analysis, but it estimates that walruses disturb between 24 and 36 percent of the
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Chukchi seafloor annually (Nelson et al. 1994). No research was identified to quantify the extent of
effects resulting from bioturbation of discharges associated with drilling discharges, particularly those
from geotechnical surveys and related activities, although bioturbation is expected to dilute any effects of
the solids component of the discharges.
6.2.2. Physical Transport
Physical transport processes include currents, mixing and diffusion in the water column, particle
flocculation, and discharged material settling to the seafloor. Pacific Ocean currents dictate the direction
of transport in the Arctic Ocean: generally moving northward from the Bering Sea through the Chukchi
Sea (Weingartner and Okkonen 2001). Flow is divided along the near-shore, the Central Channel
(between Herald and Hanna shoals), and the Herald Canyon (Woodgate et al. 2005). Spall (2007)
estimates the residence time of water in the Chukchi Sea to be less than 1 year. Water temperature factors
into the localized effects of mixing and diffusion. The effect of temperature changes associated with
large-scale currents are beyond the scope of this evaluation. Localized diffusion and mixing of the
discharges covered under the Geotechnical GP are driven by the depth of the receiving water, rate of
discharge, speed of local currents, and depth of the outfall beneath the surface.
The depth, rate, and method of the individual discharges influence their physical transport in the
environment. The majority of geotechnical surveys and related activities in the Chukchi and Beaufort
Seas would occur in the open water season (i.e., July to October) and during ilie winter months when
landfast or bottom-fast ice is present, particularly in the Beaufort Sea. The Geotechnical GP prohibits all
discharges on the ice surface. The water-based drilling fluids and drill cuttings, and cuttings not
associated with drilling fluids, would be deposited on the seafloor during open water periods.
EPA's depositional modeling calculated the depositional thickness of drilling fluids and drill cuttings
(Discharge 001) at 1-meter, 10-meter, and 100-meter distances from the discharge location based on
certain assumed discharge rates and current speeds (Table 6-2). Based on a discharge rate of 1,093
gal/day and current speeds ranging from 0.02 to 0.40 m/s, the depositional thickness ranges from 1.52
mm to 30.33 mm (0.06 to 1.19 inches) at a 1 meter (3.3 feet) distance from the discharge location. At 10
meters (32.8 feet) and 100 meters (328 feet) distances from the discharge location, and assuming the same
discharge rate and ranges of current speeds, the thickness of drilling fluids and drill cuttings are 0.48-9.59
mm (0.02-0.38 inches) and 0.15-3.03 mm (0.006-0.38 inches), respectively.
Table 6-2. Deposition thickness for combined drilling fluids and cuttings discharges from
geotechnical surveys
Case ID
Current
Speed
(m/s)
Discharge
Rate
(gal/day)
Discharge
Rate
(cm/s)
Thickness at
lm
(mm)
Thickness at
10 m
(mm)
Thickness at
100 m
(mm)
1
0.02
322
14.17 E-6
8.94
2.83
0.89
2
0.02
651
28.64 E-6
18.07
5.71
1.81
3
0.02
1093
48.08 E-6
30.33
9.59
3.03
4
0.10
322
14.17 E-6
1.79
0.57
0.18
5
0.10
651
28.64 E-6
3.61
1.14
0.36
6
0.10
1093
48.08 E-6
6.06
1.92
0.61
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7
0.30
322
14.17 E-6
0.60
0.19
0.06
8
0.30
651
28.64 E-6
1.20
0.38
0.12
9
0.30
1093
48.08 E-6
2.02
0.64
0.20
10
0.40
322
14.17 E-6
0.45
0.14
0.04
11
0.40
651
28.64 E-6
0.90
0.29
0.09
12
0.40
1093
48.08 E-6
1.52
0.48
0.15
Resuspension or deposition processes tend to occur near the seafloor with some particles gradually being
dispersed by currents and waves (Hurley and Ellis 2004 cited in MMS 2007). Regional and temporal
variations in physical oceanographic processes that determine the degree of initial dilution and waste
suspension, dispersion, and drift, have a large influence on the potential zone of influence of discharged
materials.
Ice gouging occurs by sea ice grounding against the seafloor occurring highest in the stamukhi ice zone.
The amount and effect of ice gouging activity in the Area of Coverage is not well documented; however,
a study in the Beaufort Sea shows that ice gouging plays a greater role in the reworking of bottom
sediments than depositional processes. The deepest water depth where ice gouging has been observed in
the Canadian Beaufort Sea is 38 m. Ice gouge survey data in the Chukchi Sea are sparse (MMS 2008).
Reimnitz et al. (1977) found that portions of a study area experienced a complete reworking of sediments
to a depth of 20 centimeters (7.9 inches) over a 50-year period. Ice gouging is not expected to play a
substantial role in the transport of sediments resulting from discharges authorized under the Geotechnical
GP because of the relatively small volumes and the ocean depths and current speeds at the locations of the
expected discharges would contribute to quick dispersion of the discharges.
6.2.3. Chemical Transport
Chemical processes related to the discharges are the dissolution of substances in seawater, complexing of
compounds that might remove them from the water column, redox/ionic changes, and adsorption of
dissolved pollutants on solids. Chemical transport of water-based drilling fluids is not well described in
the literature. However, despite limitations in quantitative assessment, some studies of other related
materials suggest broad findings that are relevant. Those studies show that chemical transport will most
likely occur through oxidation/reduction reactions in native sediments, and in particular, changes in redox
potentials will affect the speciation and physical distribution (i.e., sorption-de sorption reactions) of water-
based drilling fluid constituents.
6.2.4. Metals
Most research on chemical transport processes affecting offshore oil and gas discharges focuses on trace
metal and hydrocarbon components. The water-based drilling fluids associated with geotechnical surveys
include seawater, viscosifier, and barite. Bentonite clays are generally used to provide viscosity to
suspend barite and cuttings, as well as for filtration control (Neff 2010). Barite is a weighting agent that
contains several metal contaminants, including arsenic, cadmium, lead, mercury, and zinc. Those trace
metals are discussed below as they pertain to chemical transport processes.
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Trace metal concentrations are elevated in the Chukchi Sea compared to those in the eastern Arctic
Ocean; it is thought that the naturally elevated concentrations are from Bering Sea water that passes
through the Chukchi Sea (MMS 2008).
Barite solubility in the ocean is controlled by the sulfate solubility equilibrium. And in particular, the
calculated saturation levels for barium sulfate in seawater range from concentrations of 40 to 60
micrograms per liter (j^ig/L) at temperatures from 34 to 75 °F (Houghton et al. 1981; Church and
Wolgemuth 1972). Background sulfate concentrations in seawater are generally high enough for
discharged barium sulfate to remain on the seafloor upon discharge.
Kramer et al. (1980) and MacDonald (1982) found that seawater solubilities for trace metals associated
with powdered barite generally result in concentrations comparable to coastal ocean dissolved metal
levels. Exceptions were lead and zinc sulfides, which could be released at levels sufficient to raise
concentrations in excess of ambient seawater levels. MacDonald (1982) found that less than 5 percent of
metals in the sulfide phase are released to seawater. Other trace metals are associated with the metal
sulfides inclusions in the barite solids (Neff 2008). Neff (2008) estimates partitioning coefficients (the
ratio of concentrations of a substance in two separate components of a mixture) for metals between barite
and seawater, which suggest that cadmium and zinc were the most soluble metals in seawater; however,
those metals were still relatively unavailable with the likelihood of the dissolved fraction being nearly 2.5
orders of magnitude more likely to be associated with barite solids than dissolved, therefore not available
for chemical transport.
Dissolved metals tend to form insoluble complexes through adsorption on fine-grained suspended solids
and organic matter, both of which are efficient scavengers of trace metals and other contaminants.
Laboratory studies indicate that a majority of trace metals are associated with settleable solids smaller
than 8 micrometers (Houghton et al. 1981).
Trace metals, adsorbed to clay and silt particles and settling to the bottom, are subject to different
chemical conditions and processes than metals suspended in the water column. Absorbed metals can be in
a form available to bacteria and other organisms if at a clay lattice edge or at an adsorption site (Houghton
et al. 1981). The water-based drilling fluids discharges from geotechnical surveying activities, when used,
are expected to occur at small volumes, be short term in duration and conducted intermittently, and the
majority of the trace metals are expected to adsorb to fine sediment particles and remain settled on the
seafloor.
6.2.5. Organics
Organic substances, such as oil and grease or petroleum hydrocarbons, are not expected to be present in
the marine environment as a result of discharges from geotechnical surveys and related activities. The
Geotechnical GP does not apply to geotechnical activities greater than 499 feet below the seafloor
surface, which is well above the known hydrocarbon-bearing zones in the Beaufort and Chukchi Seas.
The Geotechnical GP also requires waste streams known to have potentially oily wastes, such as deck
drainage and bilge water to be treated with an oil-water separator prior to discharge. Discharges that have
an oil sheen are prohibited. Effluent limits and monitoring requirements are also established for all
discharges.
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6.3. CRITERION 3
The composition and vulnerability of the biological communities that might be exposed to
such pollutants, including the presence of unique species or communities of species, the
presence of species identified as endangered or threatened pursuant to the Endangered
Species Act, or the presence of those species critical to the structure or function of the
ecosystem, such as those important for the food chain.
6.3.1. Water Column Effects
The solid component of water-based drilling fluids and cuttings (001), cuttings not associated with
drilling fluids (Oil), and cement slurry (012) are not expected to contribute significantly to turbidity in
the water column as the discharges occur at the seafloor. Section 3.4 summarizes the estimated the area of
seafloor that might be covered with drilling fluids and drill cuttings given different assumed rate of
discharge and current speeds.
Miscellaneous discharges from stationary vessels conducting geotechnical surveys and related activities
are not expected to cause effects within the water column as concentrations in the effluent are limited. For
example, discharges of sanitary waste water must meet quality and technology-based effluent limits for
fecal coliform bacteria, total residual chlorine, pH, total suspended solids, and biochemical oxygen
demand. The requirements and limitations established in the Geotechnical GP ensure protection of the
receiving water quality within the water column.
6.3.2. Benthic Habitat Effects
Solids in the discharges of water-based drilling fluids and cuttings (001), cuttings not associated with
drilling fluids (011), and cement slurry (012) would accumulate on the seafloor near the activity locations
(see Table 6-3). The extent of solids accumulation would vary depending on the diameter and depths of
the geotechnical boreholes and on the nature and extent of the related activity. It is possible that benthic
communities (algae, kelp, invertebrates) would be impacted near the immediate areas of discharge.
Drilling fluid (if used) and cuttings deposition will not result in significant discharges to the seafloor.
Table 6-3 summarizes the amount of water-based drilling fluids and drill cuttings discharged for each
borehole, based on average size borehole diameters and three general depths of each borehole. The
estimates include a conservative assumption that water-based drilling fluids would be used to collect all
boreholes during the open water season.
Table 6-3. Summary of water-based drilling fluids and drill cuttings produced per borehole, by
depth (AOGA 2013)
Drill
Season
Borehole
Diameter2
Cuttings and Drilling Fluids Discharged1 per Borehole by Depth
Depth: 50 feet
Depth: 200 feet
Depth 499 feet
Cuttings
Drilling
Fluids3
Total
Cuttings
Drilling
Fluids
Total
Cuttings
Drilling
Fluids
Total
Open
Water
7 inches
11 ft3
22 ft3
33 ft3
48 ft3
89 ft3
137 ft3
124 ft3
223 ft3
347 ft3
8 inches
15 ft3
22 ft3
37 ft3
64 ft3
89 ft3
154 ft3
165 ft3
223 ft3
388 ft3
9 inches
20 ft3
23 ft3
43 ft3
85 ft3
89 ft3
174 ft3
213 ft3
223 ft3
437 ft3
On-Ice
8 inches
15 ft3
4
15 ft3
65 ft3
-
65 ft3
166 ft3
-
166 ft3
1 Conversion: 1 cubic foot (ft3) = 7.480 U.S. gallons.
2 Borehole diameters range between 4 and 12 inches. This table reflects discharge volumes for an average size diameter
borehole.
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3 Drilling fluids are not expected to be used for boreholes drilled at 50 feet or less below the seafloor surface; however, the
volumes are included here to provide estimates sufficient to cover all possible scenarios.
4 Water-based drilling fluids are not expected to be used for this activity.
Lethal and sub-lethal adverse effects on benthic organisms could potentially result from burial under the
accumulated materials within a short distance from the individual geotechnical borehole. Due to the short
duration of geotechnical borehole drilling and related activities (i.e., 1-3 days per borehole; 7-10 days per
equipment testing event), the relatively small volumes of drilling fluids (if used) and cuttings generated
when compared to exploration well drilling, the expected areas of deposition and thickness, and the
distances between geotechnical and related activities, benthic habitat effects are likely to occur in a
limited area and the extent and durations of effects are expected to be short-term.
6.3.3. Threatened and Endangered Species
Eight threatened and endangered species occur in the Area of Coverage: two avian species (spectacled
eider, and Steller's eider), three cetacean species (bowhead, fin, and humpback whales), two pinnipeds
(bearded and ringed seals) and one carnivore (polar bear). The Pacific walrus is a candidate species. The
potential effects on these species include behavioral changes resulting from noise, vessel activity, and
potential limited exposure to contaminants. The BE developed in support of the permit addresses the
potential impacts associated with geotechnical surveys and related activities. As discussed under Criterion
1, bioaccumulation within prey is not expected to be an exposure pathway to those species. On the basis
of the transient use of the area by the species, the limited areal extent of the potential impacts, and the
overall mobility of the species, impacts from geotechnical surveys and related activities will not cause
unreasonable degradation of the marine environment.
6.4. CRITERION 4
The importance of the receiving water area to the surrounding biological community,
including the presence of spawning sites, nursery/forage areas, migratory pathways, or areas
necessary for other functions or critical stages in the life cycle of an organism.
The Area of Coverage provides foraging habitat for a number of species including marine mammals and
birds. Bowhead whale migrations occur through the southeastern portions of the area by following open
water leads generally in the shear zone as they move from the Bering Sea to the Beaufort Sea in the
spring. Participants in the traditional knowledge workshops in Barrow identified an important bowhead
feeding habitat area in the Beaufort Sea area north of the barrier islands, Cooper Island, Nuwuk,
Tulimanik Island and the area northeast of Barrow (SRB&A 2011). The importance ofhabitat for beluga
feeding areas closer to shore and concentrated in Kugrua Bay, Smith Bay, the Big Colville River, and
Elson Lagoon were noted as well as the importance ofhabitat and migratory paths in Simpson Cove,
Camden Bay, Kaktovik Lagoon, Bernard Harbor, Griffin Point and Demarcation Bay for beluga,
bowhead, orca, narwhal, and gray whales (SRB&A 2011). The spring migration of bowhead whales
would generally be over before the discharges from geotechnical activities begin, the earliest of which
would occur in July. Bowhead whales traverse back through the area in the fall at greater distances from
shore with their path crossing through the active leases (see Error! Reference source not found, and
Error! Reference source not found.). Fin whales feed throughout the Chukchi Sea during the summer
months, although little is known about their migratory pathways.
The ice patterns are a major determinant of the distribution of marine mammals in the Area of Coverage.
The importance of pack ice (which extends poleward), fast ice (which is attached to shore), and the flaw
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zone or leads, (between the pack and fast ice, also called the spring lead due to its seasonal
characteristics) changes over the course of the year. Polar bear dens are found near fast ice and pack ice.
Fast ice provides optimum habitat for ringed seal lair construction and supports the most productive
pupping areas. While geotechnical surveying activities may occur during the winter months when landfast
ice is present, the Geotechnical GP prohibits all discharges onto ice.
The Geotechnical GP also prohibits all discharges within the 3-25 mile corridor in the Chukchi Sea prior
to July 1. As discussed above, the spring lead system occurs within the Area of Coverage, most
prominently along the coast between Point Hope and Point Barrow. Each spring, beginning in March until
June, bowhead whales use the spring leads to migrate from their winter grounds in the Bering Sea to their
summer grounds in the Canadian Beaufort Sea. This period is also an important calving and feeding
period. The spring lead system also provides important habitat for beluga whales and other marine
mammals such as seals species, and coastal and marine birds. The seasonal prohibition ensures that
appropriate protections are included for the receiving water and surrounding biological communities
considered under Criterion 4.
Macroalgae, including kelp beds are important habitats for various fish species within the Area of
Coverage. Areas of concentrated macroalgal growth that have been identified include Skull Cliff and an
area approximately 25 kilometers (13.5 nmi) southwest of Wainwright in water depths of 11 to 13 meters
(36 to 43 feet).
Larger river systems and estuaries provide important spawning and rearing areas for anadromous fishes.
Most marine species spawn in shallow coastal areas during the winter. Shallow coastal areas, barrier
islands, and offshore shoals provide rich benthic feeding habitat for whales, seals, walruses and other
species, as well as marine birds and waterfowl. Shallow coastal areas and barrier islands are located
outside the Area of Coverage for the Geotechnical GP.
Designated critical habitat (molting areas) for spectacled eider in the Area of Coverage includes Ledyard
Bay within 40 nmi from shore (see Error! Reference source not found.). The region surrounding
Barrow has been identified as being important to the survival and recovery of the Alaska-breeding
population for Steller's eiders; however, that area is not designated as critical habitat. Designated critical
habitat for polar bear also occurs within the Area of Coverage as well as seasonal bowhead whale
migration routes. EPA's inclusion of the Chukchi Sea spring lead system seasonal restriction ensures
protection for this important environment and the many ecological services it provides during the critical
spring migration period. By not authorizing any discharges within the 3-25 mile deferral corridor prior to
July 1. the potential for unreasonable degradation of biological communities, migratory pathways, and
sensitive habitat areas is avoided. Additionally, the clarification and revision of testing frequencies for
drilling fluids and drill cuttings (Discharges 001) and sanitary wastewater (Discharge 003). will not affect
the quality of the receiving water, as discussed further below under Criterion 10.
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175°0'0"W
170°0'0"W
-L
165*0*0"W
-L
160°0'0"W
"It
TETRATECH
1 in = 60 miles
SCALE IN MILES
160°0'0"W
Sources (1) Alaska State Geo-Spatial Data Clearinghouse
http//www asgdc state a* us/ (2) Bureau of Ocean Energy Managment
Regulation and Enforcement http://wwwboemre.gov
foffshore'mapping/alaska htm#GlS (3) AK Depart of Natural Resoucres Data -
Costal Management Program- Digitized from Bowhead Whale Subsistence
Senitivlty Map http.z/Wwwalaskacoast state.ak us/Drstrict'FinalPlans'
North Slope/Appendix %20B%20Maps/Bowhead%20Whale%20
Subsistence%20Sensitivity%20v3 pdf (4) Shoal boundaries interpolated from
bathmetry coverages collected from USGS Alaska Science Center - Bering
and Chukchi Sea Databases http //alaska
usgs.gov/soence/biology/walrus/bertng/bathy/index html
155°0'0"W
CHUKCHI SEA OIL AND GAS
LEASES WITH SEASONAL
BOWHEAD WHALE
MIGRATION ROUTES
Figure 6- 1. Seasonal bowhead whale migration routes in the Chukchi Sea,
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j3arrovw
Beaufort Federal
iOil & Gas Leases
rSiiJirh
B jflj-E
Tes/jg/fBOR
Prudhoe£
Deadhorse'
Kaktovik
Nuiqsutj
70°0'0"N-
^ 73 ALASKA
145J0'0"W
\
-
*—- TL
^ \
iii ar cation
| 1 BEAUFORT SEA
' 1 FEDERAL LEASES"'
SEASONAL BOWHEAD
i/VHALE RANGES'
—I SPRING-MARCH
THROUGH JUNE1
—i SUMMER-JUNE
— THROUGH AUGUST*
r—i FALL-SEPTEMBER
THROUGH NOVEMBER
j3 MAJOR LAKES
— MAJOR RIVERS'
© ALASKA TOWNS/CITIES
It
TETRATECH
11n = 60 miles
SCALE IN MILES
BEAUFORT SEA OIL AND GAS LEASES
WITH SEASONAL BOWHEAD WHALE
MIGRATION ROUTES
140 J0'0"W
I
75*OOl,N-
Beaufort Sea I
Area of Coverage j
i
J
i
Figure 6- 2. Seasonal bowhead whale migration routes in the Beaufort Sea.
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Chukchi General Permit
Area of Coverage-
¦Ha una
'¦ Shoal.
Chukchi Sea
Federal'.Oil &
Gas.Leas.es.
¦Beard
\BavM
Smith t
» Bay i
\ Wainwrightj
fTesliekmili
>. f 'kake
Waimvright Inlet
i*i *6 V*
Point Lay;
Thompt
it
TETRATECH
1 in = 60 miles
SCALE INI MILES
-70WN
I
155*0'0"W
ESA DESIGNATED
CRITICAL HABITAT
Sources: (1) Alaska State Geo-Spatial Data Clearinghouse
http:/Avww.asgdc.state .ak.us/(2) Bureau of Ocean Energy
Managment.Regulation and Enforcement
http:/Awvw.boemre.gov/offshore/mapping/alaska.htm#GIS
(3) Shoal boundaries interpolated from bathmetry coverages
collected from USGS Alaska Science Center - Bering
and Chukchi Sea Databases http://alaska .usgs.gov/science/
biology/walrus/bering/bathy/index.html (4) USFWS Critical
Habitat http://criticalhabitat.fws.gov/crithab/
LEGEND:
H MAJOR LAKES1
MAJOR RIVERS1
0 ALASKA TOWNS/CITIES1
C.H! AREA OF COVERAGE / ACTION ARE/?
~ CHUKCHI SEA FEDERAL LEASES 2
Z Z SHOAL3
POLAR BEAR
CRITICAL HABITAT 4
SPECTACLED EIDER
CRITICAL HABITAT 4
155*0"0"W
i
N
A
—i r~
170*0'0"W
I
Herald
Sh oal
Figure 6- 3. Designated critical habitat areas in the Chukchi Sea
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6.5. CRITERION 5
The existence of special aquatic sites including, but not limited to, marine sanctuaries and
refuges, parks, national and historic monuments, national seashores, wilderness areas, and
coral reefs.
No marine sanctuaries or other special aquatic sites, as defined by 40 CFR 125.122, are in or adjacent to
the Geotechnical GP Area of Coverage. The nearest special aquatic site—the Alaska Maritime National
Wildlife Refuge (Chukchi Unit)—is approximately 60 miles to the southeast of the Chukchi Sea. The
refuge provides habitat to a number of arctic seabird species and encompasses shoreline areas from south
of Cape Thompson (located approximately 26 miles to the southeast of Point Hope) to Cape Lisburne. No
other marine sanctuaries or other special aquatic sites are in or adjacent to the Area of Coverage. Based
on the analysis of Criteria 1, 2, and 3, the Alaska Maritime National Wildlife Refuge would not be
affected by authorized discharges.
The NHPA requires federal agencies to ensure that any agency-funded and permitted actions do not
adversely affect historic properties that are included in the National Register of Historic Places or that
meet the criteria for the National Register. The Geotechnical GP requires a baseline site characterization
at each location or submission of existing, representative baseline data. Information gathered from the
baseline site characterization or existing data will assist EPA with compliance with Section 106 of the
NHPA and ensure potential historic properties are not affected by the permit.
6.6. CRITERION 6
The potential impacts on human health through direct and indirect pathways.
Human health within the North Slope and Northwest Arctic Boroughs is directly related to the subsistence
lifestyle practiced by the residents of the villages along the Chukchi and Beaufort Sea coasts. In addition
to providing a food source, subsistence activities support important cultural and social connections. While
a wide variety of species are harvested, marine mammals compose an essential part of the diet providing
micronutrients, omega-3 fatty acids, and anti-inflammatory substances (MMS 2008). A number of studies
have documented the increase in adverse health effects with the reduction in subsistence foods and
subsequent increases in store-bought food (MMS 2008).
Exposure to contaminants through consumption of subsistence foods and through other environmental
pathways is a well-documented concern. Concern has also been expressed over animals swimming
through plumes containing drilling fluids, cuttings, and other effluent (SRB&A 2011). Concerns have
also been voiced about krill and other small species taking up drilling fluids and then passing
contaminants up the food chain (SRB&A 2011).
O'Hara et al. (2006) reported on the essential and non-essential trace element status of eight bowhead
whale tissue samples that were collected during 2002-2003. This study focused on comparing whale
tissue metal concentrations to published national and international food consumption guidelines. Using
these guidelines, calculations of percent (%) Recommended Daily Allowance of essential elements in 100
g portion of bowhead tissues were provided. Results were also compared to element concentrations from
store purchased food.
Three non-essential metals important for toxicological assessment in the arctic food chain include
cadmium (Cd), mercury (Hg), and lead (Pb). For most arctic residents Hg is a major concern in fish and
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seals. However, Hg concentrations in bowheads are relatively small compared to other marine mammals,
and are below levels used by regulatory agencies for marketed animal products. Compared to other
species of northern Alaska, bowhead whale tissue samples from this study had similar or lower
concentrations of Hg. Liver and kidney are rich in essential and non-essential elements and have the
greatest concentration of Cd among the tissues studied, while Hg, Pb, and arsenic (As) are relatively low.
The kidney of the bowhead whale is consumed in very limited amounts (limited tissue mass compared to
muscle and maktak); and liver is consumed rarely.
The study concluded that, as expected, most of the tissues from bowhead whales used as foods are rich in
many elements, with the exception of blubber. While a broad range of Cd was found in kidney and liver
samples, data is lacking with respect to bioavailability of Cd and the effects of food preparation
techniques on Cd concentrations. Lastly, the bowhead tissues studied had element concentrations similar
to those found in store-bought meat products.
Species of interest from a subsistence standpoint are expected to spend minimal amounts of time, if any,
in the plume for miscellaneous discharges because of its rapid dilution (see Section 3.4.3). Additionally,
since the discharges of water-based drilling fluids and drill cuttings will occur at the seafloor, only
localized and short-term physical effects to benthic communities are expected. The Geotechnical GP also
prohibits the discharge of drilling fluids and drill cuttings during spring and fall bowhead whale hunting
activities and requires baseline site characterization at each location or submission of existing,
representative baseline data, and post-activity environmental monitoring for activities that utilize drilling
fluids. Based on the preceding discussions, the discharges under the Geotechnical GP are unlikely to
create pathways that could result in direct or indirect human health impacts.
6.7. CRITERION 7
Existing or potential recreational and commercial fishing, including finfishing and
shellfishing.
The Arctic Management Area, as it pertains to fisheries management, covers the Beaufort and Chukchi
Seas from the Bering Strait north and east to the Canadian border (NPFMC 2009). The Northwest Pacific
Fishery Management Council developed a fisheries management plan (FMP) for fish resources in the
Arctic Management Area in 2009. The FMP governs all commercial fishing including finfish, shellfish,
and other marine resources with the exception of Pacific salmon and Pacific halibut (NPFMC 2009). The
policy prohibits commercial fishing in the area until sufficient information is available to enable a
sustainable commercial fishery 10 proceed (74 FR 56734). The FMPs applicable to salmon and Pacific
halibut fisheries likewise prohibit the harvest of those species within the Arctic Management Area.
Amendment 29 of the Bering Sea/Aleutian Islands King and Tanner Crabs FMP prohibits the harvest of
crabs in the area as well (74 FR 56734). Because commercial fishing is not permitted in the area, that
aspect of Criterion 7 would not be affected by the discharges authorized under the permit.
The Magnuson-Stevens Fishery Conservation and Management Act (January 21, 1999) requires EPA to
consult with the NMFS when a proposed discharge has the potential to adversely affect (reduce quality or
quantity or both of) EFH. EPA has determined, based on the EFH assessment, that the discharges will not
adversely affect EFH.
Subsistence fishing, defined as, "noncommercial, long-term, customary and traditional use necessary to
maintain the life of the taker or those who depend upon the taker to provide them with such subsistence,"
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is not affected by the FMP (50CFR216). The most recent subsistence data (ADF&G Subsistence
Community Profile Database) for North Slope Borough communities indicate that subsistence fishing
occurred in the past (and might be ongoing) with the harvest of salmon species, flounder, cod, and smelt.
Considering that the discharges would meet federal water quality along with the findings presented for
Criteria 1 through 4, EPA does not anticipate significant adverse direct or indirect effects resulting from
the authorized discharges on subsistence fishing.
6.8. CRITERION 8
Any applicable requirements of an approved Coastal Zone Management Plan.
The Alaska Coastal Management Program expired on June 30, 2011. As of July 1, 2011, there is no
longer a CZMA program in Alaska. Because a federally approved CZMA program must be administered
by a state, the National Oceanic and Atmospheric Administration withdrew the Alaska Coastal
Management Program from the National Coastal Management Program. See 76 FR 39,857 (July 7, 2011).
As a result, the CZMA consistency provisions at 16 U.S.C. 1456(c)(3) and 15 CFR Part 930 no longer
apply in Alaska. Accordingly, federal agencies are no longer required to provide Alaska with CZMA
consistency determinations.
6.9. CRITERION 9
Such other factors relating to the effects of the discharge as may be appropriate.
6.9.1. Environmental Justice
EPA has determined that the discharges authorized by the Geotechnical GP will not have a
disproportionately high or adverse human health or environmental effects on minority or low-income
populations living on the North Slope, Northwest Arctic, and Bering Sea. In making that determination,
EPA considered the potential effects of the discharges on the communities, including subsistence areas,
and the marine environment. EPA's evaluation and determinations are discussed in more detail in the EJ
Analysis for the Beaufort and Chukchi Exploration NPDES General Permits, and summarized below.
Since the EJ Analysis evaluated and considered the potential impacts to the same communities from
similar discharges, EPA believes the EJ Analysis is also relevant for the Geotechnical GP.
Executive Order 12898 titled. federal Actions To Address Environmental Justice in Minority Populations
and Low-Income Populations states, in part, that "each Federal agency shall make achieving
environmental justices part of its mission by identifying and addressing, as appropriate,
disproportionately high and adverse human health or environmental effects of its programs, policies, and
activities on minority populations and low-income populations . . . The order also provides that federal
agencies are required to implement the order consistent with and to the extent permitted by existing law.
In addition, EPA Region 10 adopted its North Slope Communications Protocol: Communications
Guidelines to Support Meaningful Involvement of the North Slope Communities in EPA Decision-Making
in May 2009. Consistent with the order and agency policies, EPA has taken efforts to provide tribal
entities and North Slope, Northwest Arctic, and Bering Sea communities with information about the
Geotechnical GP development process, and to simultaneously seek early input into the EPA evaluations.
The Geotechnical GP implements existing water pollution prevention and control requirements to ensure
compliance with CWA requirements, including preventing unreasonable degradation of the marine
environment. As discussed in this ODCE, EPA evaluated the potential for significant adverse changes in
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ecosystem diversity, productivity, and stability of the biological communities within the Area of
Coverage.
This ODCE evaluates the potential for bioaccumulation, pollutant transport, and significant adverse
changes in ecosystem diversity, productivity and stability of biological communities in the Area of
Coverage. The ODCE also evaluates environmentally significant or sensitive areas that are necessary for
critical stages of marine organisms, the roles of these areas in the larger biological community and the
vulnerability of these areas to potential discharges. The ODCE further evaluates the potential for loss of
esthetic, recreational, scientific and economic values, and impacts to recreational and commercial fishing.
Each of these criteria relate directly to concerns raised regarding availability of subsistence resources,
potential bioaccumulation and food tainting, human health, and overall species impacts. Overall, based on
the analysis in the ODCE, the geotechnical surveying discharges authorized will not result in adverse
impacts under each of these criteria, as defined by the CWA.
The ODCE also evaluates the threat to human health through the direct physical exposure to discharged
pollutants and indirect threats through consumption of aquatic organisms exposed to pollutants
discharged under the Geotechnical GP. Human health is directly related to the subsistence practices of
native communities. Subsistence areas and related subsistence activities provide food and support cultural
and social connections. EPA considered the information obtained from residents and participants in the
Traditional Knowledge workshops (conducted during development of the Beaufort and Chukchi
Exploration NPDES General Permits) related to these important factors. These factors were a part of the
overall evaluation framework of this ODCE and the Geotechnical GP development processes. Based on
the input received, EPA included provisions, requirements, and restrictions in the Geotechnical GP to
ensure impacts would not occur through direct or indirect pathways. Additionally, under the CWA, EPA
has the authority to make modifications or revoke permit coverage if it identifies a basis to conclude that
discharges will cause an unreasonable degradation of the marine environment.
The following are the permit terms and conditions that address the issues and concerns resulting from the
EPA's community outreach efforts, and have also been incorporated into the Geotechnical GP:
1. Prohibit all discharges (Discharges 001-012) within the 3-25 mile corridor in the Chukchi Sea
prior to July 1 0.
2. Prohibit the discharges of water-based drilling fluids and drill cuttings (Discharge 001) to federal
waters of the Chukchi Sea during the spring bowhead hunting activities, starting on March 25.
The spring bowhead whale hunting restriction is unique to the Geotechnical GP because the area
of coverage includes the 25-mile lease sale deferral area in the Chukchi Sea, in which bowhead
whale hunting activities occur.
3. Prohibit the discharges of water-based drilling fluids and drill cuttings (Discharge 001) to federal
waters of the Beaufort Sea during the fall bowhead hunting activities, starting August 25. Under
prohibitions 2 and 3, discharges may not be resumed until bowhead whale hunting has been
completed by the respective villages.
4. Include chemical additive inventory and reporting requirements, with reporting and limits on
chemical additive concentrations.
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5. Incorporate environmental monitoring requirements that include collection of baseline site
characterization data for each location, or submission of existing, representative baseline data for
geotechnical surveys and related activities locations and post-activity monitoring when water-
based drilling fluids are used.
6. Require effluent toxicity characterization of the following waste streams if chemicals are added to
the system: deck drainage (Discharge 002), desalination unit wastes (Discharge 005), bilge water
(Discharge 006), boiler blowdown (Discharge 007), fire control system test water (Discharge
008), and non-contact cooling water (Discharge 009).
7. Prohibit the discharge of all waste streams (Discharges 001-012) to stable ice.
In summary, EPA carefully considered the potential environmental justice impacts related to the
Geotechnical CP's authorized discharges, especially the potential for disproportionate effects on
communities and residents that engage in subsistence activities. Based on EPA's analysis and the permit
conditions described above, EPA has determined that the discharges authorized by the Geotechnical GP
will not cause unreasonable degradation of the marine environment, as defined by the CWA. For similar
reasons, EPA concludes that that there will be no disproportionately high and adverse human health or
environmental effects on minority or low-income populations residing on the North Slope, Northwest
Arctic, and Bering Sea communities.
6.9.2. Combined Effects with Exploration Discharges
The discharges proposed to be authorized under the Geotechnical GP are similar to the discharges from
exploration activities, but at lower volumes. Since discharges from geotechnical surveys and related
activities may occur within the same geographic areas as exploration well drilling, this ODCE evaluates
the potential effects from the combined discharges to ensure unreasonable degradation does not occur.
Table 6-4 compares anticipated discharge volumes from geotechnical surveying activities with discharge
volumes evaluated for the Chukchi Exploration NPDES General Permit (AKG-28-8100). The discharge
volumes for geotechnical surveying activities are presented as per shallow and deep borehole, as well as
estimated activity level of 100 boreholes per year in federal waters. The discharge rates are based on
maximum pumping capacity of the units associated with each waste stream; actual discharges are
expected to be at lower volumes. The estimated cuttings discharges from geotechnical related activities
are captured in Discharge 011.
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Table 6-4. Estimated discharge volumes of waste streams associated with geotechnical surveys per
borehole and per year compared with discharges associated with a single exploration well in the
Chukchi Sea
Discharge
Estimated
Discharge
Volume1 per
Shallow
Geotechnical
Borehole
Estimated Discharge
Volume2 per Deep
Borehole
Estimated
Discharge
Volumes per
Year3
Estimated Discharge
Volumes5 per
Exploration Well6 in
the Chukchi Sea
U.S. Liquid Gallons (gal)
gal/Well
Water-based drilling
fluids and drill
cuttings (001)7
7,000s
21,0008
1,232,000s
741,378s
Deck drainage (002)
2,000
6,000
352,000
61,740
Sanitary wastes (003)
2,473
7,418
435,186
67,199
Domestic wastes
(004)
21,000
63,000
3,696,000
700,009
Desalination unit
wastes (005)
109,631
328.892
19,294,977
846,713
Bilge water (006)
3,170
9,510
557,927
42,000
Boiler blowdown
(007)
N/A
-
--
16,380
Fire control system
test water (008)
2,000
6,000
352,000
6,594
Non-contact cooling
water (009)
2,726,234
8,178,703
479,817,254
197,398,473
Uncontaminated
ballast water (010)
504
1,512
88,704
4,829,963
Drill cuttings not
associated with
drilling fluids (Oil)10
N/A11
--
--
--
Cement slurry (012)
1
3
114
42,000
1 Source: Shell's NPDES Permit Application Form2C (April 3, 2013) andL. Davis (personal communication, August 7,2013).
2 Source: AOGA Geotechnical Activities Information Paper (5/14/2013 and Revised 9/17/2013)
3 Shallow boreholes: Depth < 50 feet
4 Deep boreholes: Depth > 50 and < 499 feet
5 Source: ODCE for the Chukchi Exploration General Permit (AKG-28-8100, USEPA 2012b)
6 Two to three exploration wells could potentially be completed in one open water drilling season with one well completed
between 30 and 45 days.
7 Discharged at the seafloor and may include mud pit cleanup materials. As a worst case estimate, EPA assumes all 100
boreholes would utilize water-based drilling fluids, which would result in approximately 4,800 gallons of mud pit materials
discharged per year.
8 Conservative estimates that include entrained seawater and do not account for soil boring sample removal.
9 For purposes of comparison, this volume represents Discharge 001 (water based drilling fluids and drill cuttings) and
Discharge 013 (muds, cuttings and cement at the seafloor) under the Chukchi Exploration NPDES General Permit (AKG-28-
8100).
10 Discharge 011 includes the cuttings materials generated from geotechnical related activities. For purposes of the ODCE, EPA
assumes one equipment feasibility testing activity would result in a seafloor disturbance of approximately half of a typical
mudline cellar dimension, generating a total of approximately 235,000 gallons of cuttings materials would be discharged
during the 5-year permit term.
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11 Discharge Oil may also include cuttings from shallow boreholes. While the majority of shallow boreholes may not use water-
based drilling fluids, to provide a conservative estimate, EPA assumes drilling fluids would be used and the volumes are
captured above under Discharge 001.
While exploration activities occur within active lease locations, geotechnical surveys and related activities
may occur within the lease locations as well as areas between the leases and shore. While it is possible
that an exploration well and geotechnical surveys and related activities could occur within the same lease
area (each lease block is the size of 3 square miles), it is unlikely that they would occur at the same time.
For example, geotechnical surveying would occur at certain lease locations to evaluate the stability of the
subsurface for potential placement of a jack up rig prior to the actual exploration activity. Similarly, the
feasibility testing of mudline cellar equipment (i.e., geotechnical related activities) would be conducted
prior to the technology being used for construction of a mudline cellar at that location in support of
exploration activities.
Also, as discussed in Section 2.1, the spacing of the geotechnical survey boreholes will vary, with some
as close as 10 to 15 feet apart to others as far as 32,800 feet apart, depending on the specific goals of the
geotechnical activity (i.e. jack up rig spud can or pipeline). Approximately 10 geotechnical borings could
be conducted in federal waters of the Chukchi Sea within the area deferred from leasing by BOEM 3 to
25 miles from the shoreline. Discharges from geotechnical surveys within the deferral area (only
authorized after July 1) would not cause a "combined effect" as there are no active leases in this area. The
federal waters lease deferral borings are expected to be shallow (< 50 feet) borings to investigate the
physical properties of the sediments along potential pipeline routes (AOGA 2013). The spacing of
geotechnical related activities is not expected to cause an overlap in deposition as the scope of those
activities are limited (i.e., two events per sea per year), resulting in a relatively small volume of
discharges.
EPA modeled discharge scenarios from exploration activities in both the Beaufort and Chukchi Seas to
support the Exploration NPDES General Permits (Hamrick 2012). Using the Chukchi Sea as an example,
the expected discharge scenarios from exploration drilling are assumed as follows:
• Exploration activities would be conducted at water depths of 40-50 meters (131-164 feet);
• Discharges would occur near the surface;
• Current speeds are assumed at 0.05 meters per second (m/s) to 0.3 m/s where discharges are likely
to occur.
For the 51 model scenarios modeled by EPA at the acceptable water depth (deeper than 5 meters), 8
scenarios fall within those conditions. The model results for those scenarios indicate maximum deposition
thicknesses ranging from 0.008 to 0.024 centimeters (0.003 to 0.009 inches) along the current direction.
Those scenarios, however, include total discharges of drilling fluids and drill cuttings ranging from 750 to
1,000 barrels (bbl). Scaling the results upward to reflect total discharges of up to 5,000 bbl, the maximum
deposition thicknesses would range from 0.03 to 0.13 centimeters (0.01 to 0.05 inches). For all scenarios,
the maximum predicted deposit was approximately 2 centimeters (0.8 inches), and the median for all
scenarios was a deposit of approximately 0.2 centimeters (0.07 inches). Under most conditions, the
majority of the solids are deposited within 1,000 meters (3,280 feet) of the discharge (Hamrick 2012).
Even though geotechnical surveys and related activities are not expected to occur within the same general
area as exploration drilling, in most cases, it is not expected that the discharges would cause a
depositional overlap.
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Additionally, miscellaneous discharges will also occur from geotechnical vessels that are similar to those
from exploration facilities. Those discharges must meet the effluent limits established by EPA in
compliance with technology-based and state and federal water quality standards (see Section 6.10,
below).
The effects from discharges from geotechnical surveys and related activities combined with discharges
from exploration drilling are not expected to result in unreasonable degradation of the marine
environment for the reasons discussed in Criteria 1 through 8, as well as the following:
• The timing of geotechnical surveys and related activities likely will not coincide with exploration
well drilling within the same general area.
• The anticipated areal extent and depositional thicknesses of the drilling fluids and drill cuttings
materials from both activities will not cause long-term effect by the receiving biological and
physical marine environment.
• The effluent limitations, restrictions, and monitoring requirements established by the Geotechnical
and Beaufort and Chukchi Exploration NPDES General Permits ensure protection of the marine
environment (see discussion under Criterion 10. below).
6.10. CRITERION 10
Marine water quality criteria developed pursuant to CWA section 304(a)(1)
Parameters of concern for effects on water quality in discharges from geotechnical surveys and related
activities, include metals, oil and grease, chlorine, and TSS. EPA has promulgated recommended marine
criteria (objectives) pursuant to CWA section 304(a)(1). Current criteria are summarized in tabular form
at http://water.epa.gov/scitech/swguidance/waterqualitv/standards/current/index.cfm and summarized in
Table 6-5 below.
This ODCE evaluates discharges to the Chukchi and Beaufort Seas authorized under the Geotechnical GP
in reference to those criteria. The following discussion addresses each parameter and notes the
clarifications EPA has made to the Geotechnical GP.
Table 6-5. Marine water quality criteria developed pursuant to CWA section 304(a)(1)
Saltwater Aquatic Life
Human Health Consumption
CMC2 (Acute)
CCC3 (Chronic)
(Organisms Only)
Pollutant1
fig/L
fig/L
fig/L
Cadmium5
40
8.8
4
Chlorine
13
7.5
—
Mercury5
1.8
0.94
—
Methylmercury5
1.8
0.94
0.3
Oil and Grease
Narrative6
--
pH
--
6.5-8.5
--
TSS
Narrative7
--
Temperature
Species Dependent8
--
1 Source: http://water.epa.gov/scitech/swguidance/standards/criteria/current/index.cfm
2 Criterion maximum concentration
3 Criterion continuous concentration
4 EPA has not calculated criteria for contaminants with blanks
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5 A priority pollutant, defined by EPA as a set of regulated pollutants for which the agency has developed analytical test
methods. The current list of 126 priority pollutants can be found in Appendix A to 40 CFR Part 423.
0 For aquatic life: (a) 0.01 of the lowest continuous flow 96-hour LC50 to several important freshwater and marine species, each
having demonstrated high susceptibility to oils and petrochemicals; (b) levels of oils or petrochemicals in the sediment which
cause deleterious effects to the biota; (3) surface waters shall be virtually free from floating nonpetroleum oils of vegetable or
animal origin, as well as petroleum-derived oils (USEPA 1986).
7 The depth of light penetration not be reduced by more than 10 percent (USEPA 1986).
8 (a) The maximum acceptable increase in the weekly average temperature resulting from artificial sources is 1°C (1,8°F) during
all seasons of the year, providing the summer maxima are not exceeded; and (b) daily temperature cycles characteristic of the
water body segment should not be altered in either amplitude or frequency (USEPA 1986).
6.10.1. Oil and Grease
For oil and grease, the permit contains requirements that prohibit the discharges if oil is detected through
a static sheen test and/or visual observation. Furthermore, the permit requires treatment of certain
discharges, such as deck drainage, bilge, and ballast water, treated through an oil-water separator before
discharge. Therefore, the water quality criterion for oil and grease is expected to be met. This requirement
remains unchanged.
6.10.2. pH
The permit requires pH monitoring for Discharges 001, 002, 004, 005, 006, 007, 008, and 010 as well as
limiting pH to 6.5-8.5 for the discharges of sanitary wastes (Discharge 003) and noncontact cooling water
(Discharge 009) if chemicals are added to the system. EPA has provided clarification that pH testing for
Discharge 001 must occur once per season; however, additional testing is required if a new drilling fluid
formulation is used during the season to conduct geotechnical activities. This clarification is not expected
to affect the quality of the receiving water or applicable water quality criteria.
6.10.3. Metals
The source of metals in drilling fluids is barite; therefore, a concern for effects on water quality in
discharges of the drilling fluids and drill cuttings. To control the concentration of heavy metals, EPA
promulgated limitations for cadmium and mercury in stock barite. These limitations are applied based on
best professional judgment on the discharges of drilling fluids and drill cuttings. Metals concentrations in
discharges including drilling fluids and cuttings are therefore expected to also meet water quality criteria.
EPA has provided clarification that stock barite testing for Discharge 001 must occur once per season;
however, additional testing is required if a new lot or supply of barite is used during the season to conduct
geotechnical activities. This clarification is not expected to affect the quality of the receiving water or
applicable water quality criteria.
Table 6-6 summarizes the federal water quality criteria for metals.
Table 6-6. Federal water quality criteria for metals
Pollutant
Marine (Aquatic Life)
Acute Criteria (jig/L)
Marine (Aquatic Life)
Chronic Criteria (jig/L)
Human Health
Criteria
(Consumption of
Organisms)
Acute Criteria (jig/L)
Arsenic
69
36
0.14
Cadmium
40
8.8
NA
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Chromium
(VI)
1,100
50
NA
Copper
4.8
3.1
NA
Lead
210
8.1
NA
Mercury
Methylmercury
1.8
0.94
0.3
Nickel
74
8.2
4,600
Zinc
90
81
26,000
6.10.4. Chlorine
Chlorine is a parameter of concern because it is used to disinfect san itaiy effluent. Fhe applicable effluent
limitation guidelines require that discharges of sanitary effluent from facilities that are continuously
manned by 10 or more people meet the effluent limitation of 1 milligrams per liter (mg/L) as the
maximum daily limit for residual chlorine, which should be maintained as close as possible to this
concentration. The Geotechnical GP applies this effluent limitation, including an average monthly of 0.5
mg/L, which limits the long-term average to concentrations that are expected to meet applicable water
quality objectives. The Geotechnical GP requires monthly testing for total residual chlorine.
In addition, the Geotechnical GP requires monthly testing for fecal coliform to ensure consistency with
the Alaska water quality standards and the regulations at 40 CFR 140.3. Monthly testing is appropriate
given the sizes of the geotechnical survey vessels, limited number of personnel, and the short duration
spent at each geotechnical surveys and related activities site location (one to ten days). These changes are
not expected to affect the quality of the receiving water or applicable water quality criteria.
6.10.5. TSS
Discharges of drilling fluids and discharges of sanitary effluent are expected to contain settleable solids
and TSS, which contribute to turbidity. The Geotechnical GP applies the maximum daily and average
monthly effluent limitations for TSS according to secondary treatment standards for discharges of
sanitary effluent based on best professional judgment. The permit also contains an effluent toxicity
limitation for suspended particulate phase material in discharges of water-based drilling fluids and
cuttings. Those effluent limitations remain unchanged and are expected to also be protective of water
quality.
6.10.6. Temperature
The permit authorizes discharges of non-contact cooling water (Discharge 009). which has higher
temperatures than the receiving water body. In order to assure protection of the characteristic indigenous
marine community of a water body segment from adverse thermal effects: (a) the maximum acceptable
increase in the weekly average temperature resulting from artificial sources is 1° C (1.8° F) during all
seasons of the year, providing the summer maxima are not exceeded; and (b) daily temperature cycles
characteristic of the water body segment should not be altered in either amplitude or frequency. It is
expected that complete mixing will occur within a short distance from the discharge point and the
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temperature of the discharge will not exceed any temperature water quality objectives. The Geotechnical
GP's requirements for temperature monitoring of Discharge 009 remain unchanged.
6.11. Determinations and Conclusions
EPA has evaluated the 12 discharges for the Geotechnical GP against the ocean discharge criteria. Based
on this evaluation, EPA concludes that the discharges will not cause unreasonable degradation of the
marine environment under the conditions, limitations, and requirements established by the permit.
With regard to discharge of drilling fluids and drill cuttings, this ODCE identifies recent studies that show
that trace metals commonly associated with water-based drilling fluids and drill cuttings are not readily
absorbed by living organisms (see Section 6.1.3). In addition, data suggest that bioaccumulation risks are
expected to be low because the bioavailability of trace metals in drilling fluid components (i.e., barite) is
low. Furthermore, another study shows that amphipods exposed to metals that are bioavailable will
accumulate small amounts of copper and lead; but copper and lead levels are quickly reduced in those
individual amphipods exposed to 12 hours of seawater without elevated metal concentrations. Other
studies show that bioaccumulation of barium and chromium can occur in benthic organisms; but pollutant
accumulation decreases once organisms are removed from the contamination source (see Section 6.1.5).
Together, those studies suggest that bioaccumulation of trace metals from water-based drilling fluids is
low and reversible.
In addition, while increased sedimentation from drilling fluids and cuttings can affect benthic organisms
in the discharge area, the effects are limited to the small discharge area and have been shown to have few
long-term impacts. Several studies document the resilience of affected benthic communities in
reestablishing affected areas within months after discharges cease. Also, other studies of former offshore
exploration drilling locations show that trace metal concentrations in seafloor sediment are not persistent,
and decrease to levels below risk-based sediment guideline concentrations (see Section 6.1.4). These
studies demonstrate that discharge of drilling fluids and cuttings will not result in an unreasonable
degradation of the marine environment during or after discharge activities. Finally, the discharges from
geotechnical surveys and related activities are very short in duration and long-term widespread impacts
are not anticipated.
The ODCE also addresses concerns related to the consumption of subsistence resources and public health
(see Sections 5.9, 6.6, and 6.9). EPA has evaluated the discharges and does not anticipate a threat to
human health through either direct exposure to pollutants or consumption of exposed aquatic
organisms. EPA is also mindful of concerns about the potential changes in the behavior of subsistence-
related marine resources, i.e., their avoidance of drilling discharges and deflection from traditional
migratory paths might result in adverse effects on subsistence communities. For example, if the
subsistence-related marine resources move farther away from subsistence-based communities, there is the
potential for increased risks to hunter safety because of the additional time and farther distances traveled
offshore in pursuit of the marine resources. Likewise, deflection of subsistence-related marine resources
could reduce subsistence harvest and reduced consumption of subsistence resources, which could cause
adverse effects on human health. To address these concerns on an ongoing basis and to ensure that no
unreasonable degradation of the marine environment occurs, EPA requires environmental data to be
collected if drilling fluids are used and assessment of the potential deflection and avoidance effects on
marine resources during periods of high levels of discharge of non-contacting cooling water.
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All other waste streams that will be authorized by the Geotechnical GP (e.g., sanitary and domestic
wastes, deck drainage, bilge water, ballast water) do not contain pollutants that are bioaccumulative or
persistent. The Geotechnical GP contains effluent limitations and requirements that ensure protection of
the marine environment.
Finally, in accordance with 40 CFR 125.123(d)(4), the Geotechnical GP states that EPA can modify or
revoke permit coverage at any time if, on the basis of any new data, EPA determines that continued
discharges might cause unreasonable degradation of the marine environment Thus, EPA will be able to
assess new data that is submitted in the required monthly and annual reports for each operator as a means
to continually monitor potential effects on the marine environment and to take precautionary actions that
ensure no unreasonable degradation occurs during the permit term.
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8. GLOSSARY
amphipods. A large group of crustaceans, most of which are small, compressed creatures (e.g., sand
fleas, freshwater shrimps).
anadromous. Migrating from the sea to fresh water to spawn. Pertaining to species such as fish that live
their lives in the sea and migrate to a freshwater river to spawn.
annulus. Space between drill-string and earthen wall of well bore, or between production tubing and
casing.
ballast water. Harbor or seawater added or removed to maintain the proper ballast floater level and ship
draft and to conduct jack-up rig related sea bed support capability tests (e.g., jack-up rig preload
water).
barite. Barium sulfate; a mineral frequently used to increase the weight or density of drilling mud. Its
relative density is 4.2 (or 4.2 times denser than water).
bathymetric. Pertaining to the depth of a water body
benthic. Dwelling on, or relating to, the bottom of a body of water; living on the bottom of the ocean and
feeding on benthic organisms.
best management practices (BMPs). Schedules of activities, prohibitions of practices, maintenance
procedures, and other management practices to prevent or reduce the pollution of "waters of the United
States." BMPs also include treatment requirements, operating procedures, and practices to control
plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.
bilge water. Water which collects in the lower internal parts of the facility's hull.
bioaccumulation. Used to describe the increase in concentration of a substance in an organism over time
biochemical oxygen demand (BOD). A measure of the amount of oxygen utilized by the decomposition
of organic material, over a specified time period (usually 5 days, designated BOD5), in a wastewater
sample; it is used as a measurement of the readily decomposable organic content of a wastewater.
Biocide. Any chemical agent used for controlling the growth of or destroying nuisance organisms (e.g.,
bacteria, algae, and fungi).
bioturbation. The stirring or mixing of sediment or soil by organisms, especially by burrowing or boring
boiler blowdown. The discharge of water and minerals drained from boiler drums to minimize solids
build-up in the boiler.
borehole. A 4 - 12 inch diameter hole drilled to assess the subsurface characteristics of the seafloor.
Boreholes may be shallow (depth < 50 feet) or deep (depths > 50 feet and < 499 feet).
BP J. Best Professional Judgment as described in 40 CFR §§ 122.43, 122.44 and 125.3.
brackish. Mixed fresh and salt water.
Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE). Part of the
Department of the Interior, responsible for overseeing the safe and environmentally responsible
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development of energy and mineral resources on the Outer Continental Shelf. Renamed Bureau of
Ocean Energy Management (BOEM).
caisson. A steel or concrete chamber that surrounds equipment below the waterline of an Arctic drilling
rig, thereby protecting the equipment from damage by moving ice.
cement slurry. The cement-bentonite mixture that may be used to plug a geotechnical borehole.
cetacean. A group of marine mammals, including whales, dolphins, porpoises.
circumboreal. Around the northern hemisphere in the higher latitudes.
conductor casing. Generally, the first string of casing in a well. It can be lowered into a hole drilled into
the formations near the surface and cemented in place; or it can be driven into the ground by a special
pile drive (in such cases, it is sometimes called drive pipe); or it can be jetted into place in offshore
locations. Its purpose is to prevent the soft formations near the surface from caving in and to conduct
drilling mud from the bottom of the hole to the surface when drilling starts. Also called conductor
pipe.
copepods. Any of a large subclass of minute crustaceans common in fresh and salt water, having no
carapace, six pairs of thoracic legs but none on the abdomen, and a single median eye.
core. The undisturbed cylindrical sediment sample recovered from the borehole to the facility for
laboratory analysis.
cone penetration test (CPT). An in situ method used to determine the geotechnical engineering
properties of soils and delineating soil stratigraphy (rock layers.
corrosion inhibitors. A chemical substance that minimizes or prevents corrosion in metal equipment.
cottids. A family of demersal fish in the order Scorpaeniformes, suborder Cottoidei (or sculpins), found
in shallow coastal waters in the northern and Arctic regions.
critical habitat. A habitat determined to be important to the survival of a threatened or endangered
species, to general environmental quality, or for other reasons as designated by the state or federal
government.
cuttings. Small pieces of rock that break away because of the action of the drill bit teeth. Cuttings are
screened out of the liquid mud system at the shale shakers and are monitored for composition, size,
shape, color, texture, hydrocarbon content and other properties by the mud engineer, the mud logger,
and other on-site personnel.
deck drainage. Any waste resulting from deck washings, spillage, rainwater, and runoff from curbs,
gutters, and drains including drip pans and work areas within facilities subject to the general permit.
demersal fish. Fish found living on or near the bottom of the sea, feeding on benthic organisms,
including cod, haddock, whiting, and halibut.
desalination unit wastes. Wastewater associated with the process of creating fresh water from seawater.
domestic waste. Materials discharged from sinks, showers, laundries, safety showers, eyewash stations,
hand-wash stations, fish cleaning stations, and galleys.
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drilling fluids and drill cuttings. Particles generated by drilling into subsurface geological formations
and carried out from the hole with the drilling fluid (e.g., seawater with additives) and discharged at
the seafloor; this also includes discharge of residual drilling fluids from the mud pit (during mud pit
clean-up operations). Drilling fluids are used in rotary drilling operations to clean and condition the
borehole and to counterbalance formation pressure. Examples of drill cuttings include small pieces of
rock varying in size and texture from fine silt to gravel.
drill cuttings not associated with drilling fluids. The particles generated by drilling into subsurface
geologic formations (soil and rock layer) and carried out from the subsurface hole with seawater and
discharged at the seafloor. Examples of drill cuttings include small pieces of rock varying in size and
texture from fine silt to gravel.
drilling fluid additives. Natural thickeners (i.e., Attapulgite clay), a densifier or weighting agent (i.e.
barium sulfate; Barite), and/or a lubricant (i.e., polymer gel).
echinoderms. Marine animals with a five-rayed symmetry, including sea lilies, feather stars, starfish,
brittle stars, sea urchins, and sea cucumbers.
effluent. Wastewater, treated or untreated, that flows out of a treatment plant, sewer, or industrial outfall.
Generally refers to wastes discharged into surface waters.
effluent guidelines. EPA documents that set effluent limitations for given industries and pollutants.
effluent limitation. Restrictions established by a state or EPA on quantities, rates, and concentrations in
wastewater discharges.
epibenthic. Living above the bottom. Also demersal.
epipelagic. The uppermost, normally photic layer of the ocean between the ocean surface and the
thermocline, usually between depths of 0-200 meters; living or feeding on surface waters or at
midwater to depths of 200 meters.
epontic. Used of an organism that lives attached to the substratum. (Lincoln R.J., G.A. Boxshall, and P.F.
Clark. A Dictionary of Ecology, Evolution, and Systematics. Cambridge University Press, 1982.).
estuarine. Living mainly in the lower part of a river or estuary; coastlines where marine and freshwaters
meet and mix; waters often brackish.
exploratory well. Any well drilled for the purpose of securing geological or geophysical information to
be used in the exploration or development of oil and gas resources.
fire control system test water. The water released during the training of personnel in fire protection and
the testing and maintenance of fire protection equipment.
free oil. Any oil contained in a waste stream that when discharged will cause a film or sheen upon or a
discoloration of the surface of the receiving water.
geotechnical surveying and related activities. Geotechnical surveys conducted to evaluate the
subsurface characteristics of the seafloor and related activities in federal waters of the Beaufort and
Chukchi Seas. Geotechnical surveying involves disturbance of the seafloor. Specifically, borings are
collected to assess the structural properties of subsurface soil conditions for potential placement of oil
and gas installations, which may include production and drilling platforms, ice islands, anchor
structures for floating exploration drilling vessels, and potential buried pipeline corridors.
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Geotechnical surveys result in a disturbance of the seafloor and may produce discharges consisting of
soil, rock and cuttings materials, in addition to facility-specific waste streams authorized under the
general permit.
geotechnical "related activities." Result in a disturbance of the seafloor and produce similar discharges.
Geotechnical "related activities" may include feasibility testing of mudline cellar construction
equipment or other equipment that disturbs the seafloor, and testing and evaluation of trenching
technologies.
geotechnical facility. Includes any floating, moored or stationary vessels, jack-up or lift barges with the
capacity to conduct geotechnical surveying or related activities.
infauna. Benthic fauna living in the substrate and especially in a soft sea bottom.
intertidal (littoral) zone. Shallow areas along the shore and in estuaries that are alternately exposed and
covered by the tides. Many juvenile fishes are regularly found in this area. Some amphibious fishes
live permanently in this zone; others are occasional visitors.
isobath. A contour line on a map connecting points of equal depth in a body of water.
Jack up drilling rig. A mobile bottom-supported offshore drilling structure with columnar or open-truss
legs that support the deck and hull. When positioned over the drilling site, the bottoms of the legs rest
on the seafloor. A jack-up rig is towed or propelled to a location with its legs up. Once the legs are
firmly positioned on the bottom, the deck and hull height are adjusted and leveled.
landfast ice. Landfast ice, or fast ice, which is attached to the shore, is relatively immobile and extends to
variable distances off shore: generally 8- to 15-m isobaths, but it can extend beyond the 20-meter
(65.6-foot) isobath.
leads. Transient area of open water in sea ice that arises through the dynamical effects of oceanic and
atmospheric stresses, such as tides, acting to pull the sea ice floes apart.
marine sanitation devices (MSD). Any equipment for installation onboard a vessel that is designed to
receive, retain, treat, or discharge sewage, and any process to treat such sewage.
methylmercury. A form of mercury that is most easily bioaccumulated in organisms. Methylmercury
consists of a methyl group bonded to a single mercury atom, and is formed in the environment
primarily by a process called biomethylation. Mercury biomethylation is the transformation of divalent
inorganic mercury (Hg(II)) to CH3Hg+, and is primarily carried out by sulfate-reducing bacteria that
live in anoxic (low dissolved oxygen) environments, such as estuarine and lake-bottom sediments.
microalgae. A classification of algae that are defined according to the size of the plant where the body of
the plant is small enough that it requires magnification to observe.
mud pit. The unit where the drilling fluids (muds) are mixed prior to use during drilling operations. For
the purposes of this general permit, discharges from the mud pit (including mud pit clean-up) must
occur at the seafloor and are authorized under Discharge 001.
mysids. Group of small, shrimp-like crustaceans characterized by a ventral brood pouch. Important food
items for many fishes.
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nearshore zone. The region of land extending between the backshore, or shoreline, and the beginning of
the offshore zone. Water depth in this area is usually less than 10 meters (33 feet).
nektonic. Actively swimming organisms able to move independently of water currents.
nitrification. The biological oxidation of ammonia with oxygen into nitrite followed by the oxidation of
those nitrites into nitrates.
non-contact cooling water. Water used for contact, once-through cooling, including water used for
equipment cooling, evaporative cooling tower makeup, and dilution of effluent heat content used for
cooling that does not come into direct contact with any raw material, product, by-product, or waste.
NPDES general permit. The discharge of pollutants into the state's surface waters is regulated through
National Pollutant Discharge Elimination System (NPDES) permits. General permits are written to
cover a category of dischargers instead of an individual facility.
Offshore Operators Committee (OOC). A nonprofit organization composed of persons, firms or
corporations owning offshore leases and any person, firm or corporation engaged in offshore activity
as a drilling contractor, service company, supplier, or other capacity.
pack ice. Ice that is not attached to the shoreline and drifts in response to winds, currents, and other
forces; some prefer the generic term drift ice, and reserve pack ice to mean drift ice that is closely
packed.
pelagic. Living and feeding in the open sea; associated with the surface or middle depths of a body of
water; free swimming in the seas, oceans or open waters; not in association with the bottom. Many
pelagic fish feed on plankton; referring to surface or mid water from 0 to 200 meters depth.
phytoplankton. A plant plankton; a rapid buildup in abundance of phytoplankton, usually in response to
nutrient buildup, can result in a bloom; microscopic plant life that floats in the open ocean.
polychaetes. Segmented marine annelid worms that can be found living in the depths of the ocean,
floating free near the surface, or burrowing in the mud and sand of the beach.
polynyas. An area of open water in sea ice.
pud cans. In addition to their legs, jack ups are supported by two different systems of stabilization.
Jackup legs are supported on the sea floor via either mats or spud cans, which are cylindrically shaped
steel shoes with pointed ends, similar to a cleat. Spud cans are attached to the bottom of each leg, and
the spike in the can is driven into the ocean floor, adding stability to the rig during operations.
pressure ridges. A ridge produced on floating ice by buckling or crushing under lateral pressure of wind
or ice.
rubble fields (ice). A jumble of ice fragments or small pieces of ice (such as pancake ice) that covers a
larger expanse of area without any particular order to it. The height of surface features in rubble ice is
often lower than in pressure ridges.
sanitary waste. Human body waste discharged from toilets and urinals.
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soil boring. The act or process of making a hole in subsurface geological formations (soil and rock
layers) to obtain representative data (physical core samples and/or electronic CPT soundings).
soil boring cuttings. Particles generated by drilling into subsurface geological formations (soil and rock
layers) and carried out from the borehole with the drilling fluid (e.g., seawater with or without
additives). Examples of soil boring cuttings include small pieces of rock varying in size and texture
from fine silt to gravel.
soil boring (or core) sample. The cylindrical portion of the subsurface geological formations (soil and/or
rock layers) that is recovered to the deck of the facility for analysis.
SPP. Suspended particulate phase and refers to the bioassay test procedure, "Suspended Particulate Phase
(SPP) Toxicity Test," which is published in Appendix 2 of 40 CFR Part 435 Subpart A.
stable ice. Ice associated with landfast or bottom-fast ice that is stable enough to support geotechnical
equipment staged on the ice surface.
static sheen test. The standard test procedures in Appendix 1 to subpart A of 40 CFR part 435 that have
been developed for this industrial subcategory for the purpose of demonstrating compliance with the
requirement of no discharge of free oil.
stock barite. The barite that was used to formulate a drilling fluid.
stratification. Separating into layers.
total suspended solids (TSS). A measure of the suspended solids in wastewater, effluent, or water
bodies, determined by tests for total suspended non-filterable solids.
water-based drilling fluid (WBF). Drilling fluid that has water as its continuous phase and the
suspending medium for solids, whether or not oil is present.
weighting materials. A high-specific gravity and finely divided solid material used to increase density of
a drilling fluid. (Dissolved salts that increase fluid density, such as calcium bromide in brines, are not
called weighting materials.) Barite is the most common, with minimum specific gravity of 4.20 g/cm3.
zooplankton. Animal plankton; animals (mostly microscopic) that drift freely in the water column.
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