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Garcia, Jovie

Subject: FW: Nanushuk Project DEIS Comments

Attachments: image001.jpg; Nanushuk DEIS.pdf; Nanushuk DEIS Attachments.pdf

-----Original Message----- From: David R. Krause [mailto:david_krause@tws.org] Sent: Tuesday, November 14, 2017 6:03 PM To: Lyons, Ellen H CIV USARMY CEPOA (US) <Ellen.H.Lyons@usace.army.mil> Cc: Nicole Whittington-Evans <nicolewe@tws.org> Subject: [EXTERNAL] Nanushuk Project DEIS Comments Dear Ms. Lyons, Attached you will find two documents: 1) A formal comment letter on the Nanushuk Draft Environmental Impact Statement, and 2) a PDF of three associated attachments. Please let me know if you have questions. Thank you. Sincerely, David David R. Krause, MEM, MPH Arctic Lands Conservation Specialist The Wilderness Society | Alaska Regional Office Office Phone: 907.272.9453 x102 | Cell: 203.641.8216 Blockedwww.wilderness.org <Blockedhttp://www.wilderness.org/> We protect wilderness and inspire Americans to care for our wild places

November 14, 2017

Ellen Lyons, Regulatory Project Manager

United States Army Corps of Engineers

2175 University Avenue, Suite 201E

Fairbanks, Alaska 99709-4927

Ellen.H.Lyons@usace.army.mil

http://www.nanushukeis.com/

[Submitted electronically]

Re: Comments on the Nanushuk Project Draft Environmental Impact Statement

Dear Ms. Lyons,

On behalf of our one million members and supporters, please accept these comments on the

Draft Environmental Impact Statement (DEIS) for the Nanushuk Project (Project). The

Wilderness Society (TWS) has serious concerns about this development’s impacts to the

conservation values of the Colville River watershed and the National Petroleum Reserve-Alaska,

as well as to the residents of the region. While we appreciate the transparency of the Corps’

DEIS process, including posting of the presentations and transcripts from scoping meetings on

the Project website, the impacts and risks of this project should be very carefully considered as

the NEPA process moves forward.

In this letter we briefly discuss the following items: 1) alternative selection if development is to

move forward, 2) blowouts, and 3) the cumulative effects of oil development to the values of the

region.

1. Alternatives Selection

If development is to move forward, TWS supports Alternative 5 as it will result in the least

impacts to surface water and wetlands. Alternative 5 was developed following important

comments provided by residents of Nuiqsut. As discussed in the draft EIS:

Alternative 5 would have the fewest direct effects to waterbodies and floodplains because

it would have the shortest length of road in floodplains, the second lowest number of

stream crossings requiring culverts, and the fewest [vertical support members] and

bridge piles placed below [ordinary high water]. (p. ES-24)

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Additionally,

Alternative 5 would require the lowest volume of water withdrawal over the life of the

Project (866 MG). Alternative 5 would have the fewest structures in waterbodies and the

fewest potential effects on water quality from flooding, erosion, and bank failure induced

by culverts or structures in waterbodies. (p. ES-25)

Moreover, Alternative 5 would have:

The lowest direct loss of wetlands and waterbodies (299.9 acres) because of

gravel fill; the lowest number of acres indirectly affected by Project dust shadow and

gravel spray; the lowest amount of fill in Old and Young Basin Wetland Complexes

(drained lake basins, 47.7 acres) and therefore the lowest interruption of hydrologic

connectivity; the second lowest acres of new roads (196.2) and the second largest

number of acres of road upgrades (18.4), which illustrates the alternative is the second

most efficient at using existing infrastructure; and the smallest loss of wetland diversity.

(p. 3-286.)

We believe there are few downsides to selecting Alternative 5 rather than Alternative 2, as

shown by the alternatives’ similarities in Table 2.4-1. As these statements from the Executive

Summary and chapter three show, there are substantial upsides in selecting Alternative 5

involving protecting the region’s important surface water and wetland resources as well as fewer

problems from flooding, erosion, and bank failures.

2. Blowouts

One notable weakness in an otherwise well-done DEIS is insufficient discussion and analysis of

potential blowout scenarios. While it is true that blowouts may be unlikely, there are two reasons

to pay substantial attention to this significant safety and environmental concern for this project:

1.) The Repsol exploratory drilling well blowout during the winter of 2012 located not far away

from this project. Also, Repsol remains a significant owner of the Nanushuk project. 2.) The

April 2017 production well blowout BP experienced near Prudhoe Bay due to the impacts of

thawing permafrost. This latter event resulted in reservoir abandonment by BP, a new blowout-

related situation not touched upon in draft EIS Section 4.2.3.1.2.1 Well Blowouts. Each of these

items is discussed below.

As stated in the Alaska Department of Environmental Conservation’s Final Situation Report for

the Repsol February 15, 2012 blowout,1 the exploratory well drill penetrated a shallow gas

pocket resulting in a gas kick that was uncontrolled until March 18, 2012, or over a month later

(Final Situation Report is included as Attachment A). The chronology2 for the incident describes

the extreme cold during that time of year (as low as -49o F with substantial added windchill

down to -74o F), which substantially slowed down the time it took to kill the well.

1 See http://dec.alaska.gov/Spar/ppr/response/sum_fy12/120215301/120215301_sr_24.pdf. 2 See http://dec.alaska.gov/Spar/ppr/response/sum_fy12/120215301/120215301_chronology.htm.

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Approximately 42,000 gallons (1,000 barrels) of drilling muds were released to the ice drilling

pad and adjacent snow-covered tundra and an unknown amount of gas was released.

While the Repsol blowout is discussed in the DEIS (p. 4-10), the DEIS does not treat this

situation as particularly significant since no crude oil was spilled and no one was injured. TWS

respectfully disagrees. Uncontrolled gas releases are serious safety concerns and, in this case,

there also were substantial amounts of drilling-related materials released.

The BP April 24, 2017 production well blowout inexplicably is not discussed in the DEIS which

was issued on September 2017. Attachment B is a news release issued by the Unified Command

which describes this uncontrolled oil and gas release (the definition of a “blowout”),3 which

documents the need to bring in non-Alaskan contractor Boots and Coots to perform the well kill

operation during this dangerous incident.

Attachment C is an analysis BP provided to the Alaska Oil and Gas Conservation Commission

(AOGCC) in October 2017 that identifies thawing permafrost as the cause of the incident, with

the design of the well as a secondary cause. It is unclear from this analysis whether other well

designs also might be at risk. As a result of this blowout, on October 30, 2017, AOGCC issued

emergency orders to all operators on the North Slope to review their well designs and shut-in

those with similar designs by December 31, 2017.4

Blowout concerns were raised by the public and by the U.S. Environmental Protection Agency

during scoping.5 TWS requests that the Corps look again at the DEIS’ blowout discussion and

analysis and ensure that it adequately addresses the risks associated with blowouts beyond crude

oil releases. Additionally, the final EIS needs to include the BP production well blowout, BP’s

reservoir abandonment (see Attachment C), and AOGCC’s follow-up actions to this serious

incident.

3. Cumulative Effects

The National Research Council’s “Cumulative Environmental Effects of Oil and Gas Activities

on Alaska’s North Slope” (2003) is frequently referenced within the Project DEIS. While we

appreciate the use of this comprehensive document, its age presents limitations to truly

understanding the effects of development within the region. The scale and significance of new

development activities and climate change requires that a harder look be taken at all the recent

and anticipated future impacts of oil development.

3 See:

https://dec.alaska.gov/spar/ppr/response/sum_fy17/170414301/BPXAWell3UnifiedIncidentCommandPressRelease2

FINAL4172017.pdf. 4 Demarban, A., State regulators launch wide review of North Slope oil fields following BP leak, Alaska Dispatch News

(October 30, 2017), see https://www.adn.com/business-economy/energy/2017/10/30/state-regulators-launch-wide-review-of-

north-slope-oil-fields-following-bp-leak/. 5 Dowl prepared for U.S. Army Corps of Engineers, Scoping Summary Report, Nanushuk Project, Environmental

Impact Statement. See http://www.nanushukeis.com/projects/nanushukeis/documents/2016_06_29_draftssr.pdf, pp.

1, 10, 12, 13 (June 2016).

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TWS has very significant concerns about how the Project will further contribute to the

cumulative effects of oil development in Arctic Alaska. Below we discuss the cumulative

impacts to the Colville (Kuukpik) River ecosystem, as well as how this development will further

compromise subsistence practices, sociocultural systems, and the environmental justice of

residents of the region.

a. Colville (Kuukpik) River

The cumulative impacts of oil development in the Colville (Kuukpik) River delta is of particular

concern. As the DEIS describes, the Colville River drains approximately one third of Alaska’s

North Slope. However, despite the significant size of this watershed, the delta is a relatively

small feature. The delta has already been significantly altered by the Alpine Satellite

Development (Colville Delta) Projects, and the Nanushuk Project will further contribute to the

industrialization of this ecologically unique element of the region.

The Colville River delta requires special consideration because of its ecological significance.

Delta environments, compared to other elements of a watershed, disproportionately concentrate

diverse habitats, nutrient cycling, productivity of biota, and species interactions.6 As a result, the

uniqueness of this feature is crucial to the health of the entire watershed. Moreover, riparian

corridors, like the East Channel of the Colville River that abuts the project area, are important in

maintaining regional biodiversity. Research has shown that these types of dynamic

environments result in a variety of life history strategies as organisms adapt to disturbance

regimes.7 Such features are crucial to the habitats and life histories of the Colville River’s fish

and birds, many of which are important subsistence resources.

As discussed above, the Colville delta is a highly dynamic location. An additional concern is the

compounding oil spill risk within this arctic delta environment. As the DEIS describes, the

hydrology of the Colville River in the Project area is dominated by the spring breakup flood

event…with the East Channel retaining the majority (64% to 89%) of the flow during this period

(p. 3-136). Severe ice breakup events may present serious vulnerabilities to pipelines and other

infrastructure within the watershed as these seasonal events are virtually impossible to stop.

TWS requests that the analysis for severe breakup events be more thoroughly considered in light

of the severity of this risk and the values that are at stake.

b. Subsistence, Environmental Justice, Sociocultural Systems

This project will also further compromise the community of Nuiqsut’s subsistence use area and

subsistence practices. The Colville River delta and the Project area is an important subsistence

use area where hunting, fishing, and other culturally important practices occur. Like the nearby

Greater Mooses Tooth One (GMT-1) project, the Nanushuk Project will have significant impacts

to the community’s environmental justice (including potential health impacts), sociocultural

systems, and subsistence practices. 6 Hauer, F.R., H. Locke, V. J. Dreitz, M. Hebblewhite, W. H. Lowe, C. C. Muhlfeld, C. R. Nelson, M. F. Proctor, S.

B. Rood, 2016 Gravel-bed river floodplains are the ecological nexus of glaciated mountain landscapes. Sci. Adv. 2,

e1600026. 7 Naiman,R.J., Decamps, H., Pollock, M. 1993 The role of riparian corridors in maintaining regional biodiversity.

Ecological applications. 3(2), 209-212.

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With the incremental loss of lands and waters that are important to these rights and irreplaceable

values and practices, effective efforts should be made to ensure critical subsistence use areas are

identified and meaningfully protected from future oil development.

Thank you for considering these comments. Please be in touch if you have any specific

questions.

Sincerely,

David R. Krause

Arctic Lands Conservation Specialist

Alaska Regional Office

The Wilderness Society