City of Hoquiam Permit Review

40600-HS-PER-55037 Revision 3 Proposed Grays Harbor Potash Export Facility Prepared for State Environmental Policy Act Checklist BHP

Prepared by WSP USA

A17.0202.00 31 July 2019

City of Hoquiam Planning and Building Division 609 8th St. Hoquiam, WA 98550-3522 Tel: 360-532-5700 ext. 211, Fax: 360-538-0938 Website: www.cityofhoquiam.com

Table of Contents Section Page A. BACKGROUND ...... 2 B. ENVIRONMENTAL ELEMENTS ...... 15 1. EARTH ...... 15 2. AIR ...... 22 3. WATER ...... 31 4. PLANTS ...... 57 5. ANIMALS ...... 64 6. ENERGY AND NATURAL RESOURCES ...... 81 7. ENVIRONMENTAL HEALTH ...... 82 8. LAND AND SHORELINE USE ...... 100 9. HOUSING ...... 109 10. AESTHETICS ...... 109 11. LIGHT AND GLARE ...... 110 12. RECREATION ...... 112 13. HISTORIC AND CULTURAL PRESERVATION ...... 116 14. TRANSPORTATION ...... 122 15. PUBLIC SERVICES...... 129 16. UTILITIES ...... 129 C. SIGNATURE ...... 130 References ...... 132

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LIST OF ACRONYMS AND ABBREVIATIONS ASCE American Society of Civil Engineers ASIL Acceptable Source Impact Level BACT best available control technologies BMPs best management practices CFR Code of Federal Regulations CUP Conditional Use Permit DAHP Washington State Department of Historic Preservation DMMO Dredged Material Management Office DMMP Dredged Material Management Program DNR Washington State Department of Natural Resources DPM diesel particulate matter DPSs Distinct Population Segments Ecology Washington State Department of Ecology EFH Essential Fish Habitat EIS Environmental Impact Statement ELLW extreme low low water EPA Environmental Protection Agency ESA Endangered Species Act ESUs Evolutionarily Significant Units FAA Federal Aviation Administration FEIS Final Environmental Impact Statement FEMA Federal Emergency Management Agency FIRM Flood Insurance Rate Map GHG greenhouse gas GHNWR Grays Harbor National Wildlife Refuge GIS geographic information system HAPs hazardous air pollutants HIA Health Impact Assessment HMC Hoquiam Municipal Code IDA Dark-Sky Association IES Illuminating Engineering Society IHA Incidental Harassment Authorization IMSBC International Maritime Solid Bulk Cargoes JARPA Joint Aquatic Resources Permit Application KCl potassium chloride Ldn lowest-measured day-night average sound level LWD Large woody debris MBTA Migratory Bird Treaty Act MHHW mean higher high water MLLW mean lower low water mtpa million metric tons per annum NAAQS National Ambient Air Quality Standards NEHRP National Earthquake Hazard Reduction Program

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NEPA National Environmental Policy Act NHPA National Historic Preservation Act NMFS National Marine Fisheries Service NOAA National Oceanic and Atmospheric Administration NOC Notice of Construction NPDES National Pollutant Discharge Elimination System NRCS Natural Resources Conservation Service NRHP National Register of Historic Places NSPS new source performance standards OHWM Ordinary high water mark ORCAA Olympic Region Clean Air Agency PHS Priority Habitat and Species PM particulate matter PSAP Puget Sound and Pacific Railroad Quinault Quinault Indian Nation RCW Revised Code of Washington SEPA State Environmental Policy Act SLM Sound level meter SPCC spill prevention, control, and countermeasures SQERs Small Quantity Emission Rates SR State Route SWPPP stormwater pollution prevention plan TAP toxic air pollutant TESC temporary erosion and sediment control UPRR Union Pacific Railroad USACE U.S. Army Corps of Engineers USCG U.S. Coast Guard USDA U.S. Department of Agriculture USFWS U.S. Fish and Wildlife Service WAC Washington Administrative Code WDFW Washington State Department of Fish and Wildlife WISAARD Washington Information System for Architectural and Archaeological Records Database WQC Water Quality Certification

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ENVIRONMENTAL CHECKLIST Purpose of checklist: The State Environmental Policy Act (SEPA), Chapter 43.21C RCW, requires all governmental agencies to consider the environmental impacts of a proposal before making decisions. An environmental impact statement (EIS) must be prepared for all proposals with probable significant adverse impacts on the quality of the environment. The purpose of this checklist is to provide information to help you and the agency identify impacts from your proposal (and to reduce or avoid impacts from the proposal, if it can be done) and to help the agency decide whether an EIS is required. Instructions for applicants: This environmental checklist asks you to describe some basic information about your proposal. Governmental agencies use this checklist to determine whether the environmental impacts of your proposal are significant, requiring preparation of an EIS. Answer the questions briefly, with the most precise information known, or give the best description you can. You must answer each question accurately and carefully, to the best of your knowledge. In most cases, you should be able to answer the questions from your own observations or project plans without the need to hire experts. If you really do not know the answer, or if a question does not apply to your proposal, write, “do not know” or “does not apply.” Complete answers to the questions now may avoid unnecessary delays later. Some questions ask about governmental regulations, such as zoning, shoreline, and landmark designations. Answer these questions if you can. If you have problems, the governmental agencies can assist you. The checklist questions apply to all parts of your proposal, even if you plan to do them over a period of time or on different parcels of land. Attach any additional information that will help describe your proposal or its environmental effects. The agency to which you submit this checklist may ask you to explain your answers or provide additional information reasonably related to determining if there may be significant adverse impact. Use of checklist for nonproject proposals: Complete this checklist for nonproject proposals, even though questions may be answered “does not apply.” IN ADDITION, complete the SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS (part D). For nonproject actions, the references in the checklist to the words “project,” “applicant,” and “property or site” should be read as “proposal,” “proposer,” and “affected geographic area,” respectively.

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A. BACKGROUND 1. Name of proposed project, if applicable: Grays Harbor Potash Export Facility

2. Name of applicant: BHP Billiton Canada, Inc. (BHP)

3. Address and phone number of applicant and contact person: Val Bond BHP 130 Third Avenue South Saskatoon, SK S7K 1L3 306-385-8400

4. Date checklist prepared: July 2019 Note: The SEPA checklist for the proposed project was originally prepared and submitted in August 2017. It was revised in December 2017 to incorporate the proposed mitigation plan and revised wetland delineation and supplemented with an addendum in August 2018. Please see the SEPA Executive Summary (BHP July 2019) for a summary of changes to the proposed project and analysis conducted. This version replaces all prior versions of the SEPA checklist. 5. Agency requesting checklist: City of Hoquiam

6. Proposed timing or schedule (including phasing, if applicable): Construction of the project is proposed to start in 2020 and end in 2024/2025. Operations are proposed to start in 2024/2025 upon completion of construction. While there is no proposed phasing for the project, some of the construction work will need to take place at specific times of the year. Work below the mean higher high water (MHHW) elevation will be conducted only during the in-water work window that is ultimately approved for the project, which includes the following timing restrictions.

• Work below ordinary high water mark (OHWM) will be conducted between July 16 (12:01 am) and February 14 (11:59 pm) • Impact pile driving will only occur between October 1 (12:01 am) and February 14 (11:59 pm) to protect eulachon and green sturgeon • No nighttime dredging will occur between October 1 (12:01 am) and November 30 (11:59 pm)

This work window is consistent with the approved work window for marine waters of Grays Harbor – Tidal Reference Area 16 (all saltwater in Grays Harbor easterly of 123 degrees 59 minutes W longitude and westerly of the Union Pacific Railroad bridge across the Chehalis River). This work window also includes additional restrictions to the timing of impact pile driving and nighttime dredging, which were developed in coordination with the Quinault Indian Nation (Quinault).

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Construction activities with the potential to affect nesting migratory birds, such as tree and vegetation removal, would also be conducted consistent with the provisions of the Migratory Bird Treaty Act (MBTA), which requires that nests of migratory birds be removed only at times when nests are inactive. Tree and vegetation removal would be conducted outside the active nesting season to the extent practicable. If any tree or vegetation removal is required within the time when nests could potentially be active (generally January to August), pre-disturbance nest surveys would be conducted to document whether any trees or vegetation to be removed contain active nests. Construction of the compensatory wetland and aquatic mitigation site, and the proposed overwater structure and pile removal activities, would be conducted concurrently with construction activities at the Project Site, to minimize temporal loss of wetland or aquatic habitat function. 7. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes, explain. There are no planned activities beyond those identified in the project description. 8. List any environmental information you know about that has been prepared, or will be prepared, directly related to this proposal. The following documents were prepared for the proposed project. All documents listed below may be found on the BHP Digital Information Room at: https://www.bhp.com/environment/regulatory-information/potash-export-facility-at-grays- harbor/digital-information-room

• Executive Summary (BHP July 2019) • Rail Considerations Related to the BHP Proposed Grays Harbor Potash Export Facility (Kittelson & Associated [Kittelson] August 2019) • Joint Aquatic Resources Permit Application (JARPA), Rev. 1 (WSP July 2019) • Mitigation Plan, Rev. 2 (WSP July 2019) • IDD#1 Mitigation Site – Hydraulic, Surface Water, Groundwater, and Coastal Assessment (Golder July 2019) • Land Use Permit and Shoreline Master Program Application Narrative, Rev. 1 (WSP July 2019) • City Land Use Permit Application, Rev. 1 (BHP July 2019) • City Shoreline Permits Applications, Rev. 1 (BHP July 2019) • Critical Areas Assessment, Rev. 2 (WSP July 2019) • City Critical Areas Checklist (WSP July 2019) • Alternatives Analysis, Rev. 2 (BHP July 2019) • Grays Harbor Consultation Summary Report, Rev. 1 (BHP July 2019) • Eelgrass Survey and Tier 1 Delineation (WSP July 2019) • Air Quality and Greenhouse Gas Analyses; includes Diesel Particulate Matter Health Impact Assessment, Rev. 1 (Ramboll July 2019) • Wetland and Waterbody Delineation and Assessment (Terminal 3 Project Site), Rev. 4 (June 2019)

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• Archaeological Monitoring Results for the BHP Billiton Canada, Inc. Proposed Grays Harbor Potash Export Facility Mitigation Area, IDD No. 1 and Historic Context for Mitigation Area, POGH Terminal 4, Rev. 2 (ICF June 2019) • Geotechnical Engineering Report (Shannon & Wilson June 2019) • Biological Evaluation, Rev.2 (WSP May 2019) • March 2019 Fifth Quarter Groundwater Monitoring Report (Terminal 3) (BergerABAM May 2019) • March 2019 Fourth Quarter Groundwater Monitoring– IDD No. 1 Site Summary Report (BergerABAM May 2019) • Determination Regarding the Suitability of Proposed Dredged Material (February 2019) • Dredged Material Characterization Report, Rev. 2 (BergerABAM January 2019) • Port of Grays Harbor Authorization: IDD#1 Mitigation Site letter (Port of Grays October 2018) • Olympic Region Clean Air Agency (ORCAA) Notice of Construction (NOC) Application, Rev. 1 (Ramboll September 2018) • Maintenance Dredging Technical Memorandum (BergerABAM September 2018) • Proposed Wetland Mitigation Site: IDD #1 Wetland and Waterbody Delineation and Assessment (BergerABAM August 2018) • Summary of 3-D Overwater Shading Modeling (BergerABAM July 2018) • Visual Analysis (BergerABAM June 2018) • Phase II Environmental Site Assessment (BergerABAM March 2018) • Site Flooding Assessment Including Sea Level Rise Analysis (Amec Foster Wheeler February 2018) • Cultural Resources Technical Report (Terminal 3 Project Site), Rev. 1 (ICF February 2018) • Noise Assessment Report (Ramboll December 2017) • Traffic Impact Analysis (Kittelson November 2017) • Phase I Environmental Site Assessment (BergerABAM July 2017)

This SEPA checklist (and as applicable the supporting studies) addresses the Project Site, mitigation sites, and adjacent areas as identified. Additionally, select analyses include the following expanded areas.

• Grays Harbor – to evaluate impacts to marine waters, habitat and species from vessel traffic, spills, and noise. • Open ocean – to evaluate potential impacts to marine waters, habitat and marine mammals from vessel traffic and potential spills from Grays Harbor to the edge of the continental shelf (approximately 40 nautical miles offshore). • The Puget Sound and Pacific Railroad (PSAP) rail line from Hoquiam to Centralia – to evaluate potential impacts from additional train traffic including risks of incidents (e.g., derailment, accidents, spills) and increased vehicle traffic wait times.

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• Project Site to the project mine in Saskatchewan, Canada – to evaluate in state and out of state locomotive emissions relative to Scope 3 greenhouse gas (GHG) analyses. • Project Site to shipping destinations in the Pacific Rim – to evaluate in state and out of state vessel emissions relative to Scope 3 GHG analyses. 9. Do you know whether applications are pending for governmental approvals of other proposals directly affecting the property covered by your proposal? If yes, explain. There are no known pending applications for other projects or proposals directly affecting the properties for this proposed project. This SEPA checklist also considers the potential for cumulative impacts of the proposed project. Cumulative impacts consider the impacts from past activities and other reasonably foreseeable construction and development projects in the vicinity of the project that are known or are projected to occur during approximately the same time frame as the proposed project. The contribution of the proposed project to cumulative impacts is discussed under each environmental element section of the checklist. The following projects would considered in the cumulative impacts analysis.

Contanda Terminal Expansion Project: Contanda Terminals LLC, formerly the Westway Terminal Company LLC, is currently proposing an expansion of its existing methanol bulk storage facility at Terminal 1 of the Port of Grays Harbor (Contanda Project). Contanda’s current proposal replaces a previous proposal, called the Westway Expansion Project (ICF 2016), which would have expanded the facility at Terminal 1 to receive, store, and load for off-site transport crude oil. Ecology and the City of Hoquiam are currently reviewing the SEPA analysis that has been completed for the Contanda Project, and the City of Hoquiam is currently reviewing the project’s permit applications (Contanda 2019).1 This project is located approximately 2.5 miles east of the Project Site.

Aberdeen-Hoquiam North Shore Levee Project: The North Shore Levee project includes 5.7 miles of levee between the Wishkah and Hoquiam Rivers to protect against coastal flood events, as well as upgrades to and expansion of stormwater pump systems to improve drainage. The proposed levee will run through low, flat, mostly developed urban and suburban areas around the cities of Hoquiam and Aberdeen. The purpose of the planned levee is to protect East Hoquiam and a large portion of Aberdeen from damaging floods, and to reduce the financial burden of flood insurance and floodplain development regulations. The protected areas will be removed from the Special Flood Hazard Area Zone AE and placed in a Zone X. At its westernmost point, the levee will run along the east side of the Hoquiam River, approximately 1.5 miles east of the Project Site.

Dredging Projects: The cumulative impacts analysis included an evaluation of other reasonably foreseeable dredging activities in Grays Harbor. These include dredging of the navigation channel and turning basin by the U.S. Army Corps of Engineers (USACE), maintenance dredging of existing berths and the Westport Marina by the Port of Grays Harbor, and other dredging activities at private facilities.

1 Although the Westway project was withdrawn and replaced by the Contanda proposal, the environmental information prepared for the Westway Final Environmental Impact Statement (FEIS), including the analysis of existing conditions in Grays Harbor, remains relevant and applicable to the proposed Contanda Project, as modified by Contanda’s January 2019 SEPA Evaluation (Contanda 2019).

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10. List any government approvals or permits that will be needed for your proposal, if known. Anticipated project permits and approvals for the proposed Grays Harbor Potash Export Facility include the following. Federal Approvals/Permits • USACE – Section 10 Rivers and Harbors Act Permit, and Section 404 Wetland Fill Permit including analysis for compliance with applicable federal requirements including but not limited to − National Environmental Policy Act (NEPA) Review − Section 408 (project is subject to review but likely will not require a permit). − Section 106 Cultural Resources Review. − USACE Dredged Material Management Office (DMMO) – Dredged Material Disposal Suitability Determination and approval of open-water disposal of dredged materials (February 19, 2019). • U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS) – Endangered Species Act (ESA) Consultation • NMFS – Essential Fish Habitat (EFH) Consultation • National Oceanic and Atmospheric Administration (NOAA) -- Marine Mammal Incidental Harassment Authorization • U.S. Coast Guard (USCG)-- Private Aids to Navigation Review • Federal Aviation Administration (FAA) -- Aviation Obstruction Evaluation State Approvals/Permits • Ecology – 401 Water Quality Certification (WQC), Coastal Zone Management Act Consistency Determination, Shoreline Conditional Use Permit and Variance, National Pollutant Discharge Elimination System (NPDES) Construction Stormwater Permit and Industrial Stormwater Permit • Washington State Department of Fish and Wildlife (WDFW) – Hydraulic Project Approval • Washington State Department of Natural Resources (DNR) – Aquatic Lands Authorization • DNR – Use Authorization (dredged material placement) • Washington State Department of Historic Preservation (DAHP) – Review Local Approvals / Permits • City of Hoquiam – Shoreline Substantial Development Permit, Shoreline Conditional Use Permit (subject to final approval by Ecology), Shoreline Variance (subject to final approval by Ecology), Critical Areas Review, Land Use Conditional Use Permit, Floodplain Permit, Construction Permits (Grading, building and trades, etc.), Binding Site Plan, Street Vacation. 2 • ORCAA – NOC Order of Approval • Port of Grays Harbor – Approval of Option Agreement and a Lease Agreement • City of Aberdeen – shoreline and critical areas authorization (for proposed mitigation activities at Terminal 4)

2 As a related action, the City will vacate of a portion of Airport Way, located east of Paulson Road and North of the City’s sewer lagoon, and a portion of Paulson Road, located east of the City’s sewer lagoon and north of 5th Street Extended (Ordinance No. 2019-03).

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11. Give a brief, complete description of your proposal, including the proposed uses and the size of the project and site. There are several questions later in this checklist that ask you to describe certain aspects of your proposal. You do not need to repeat those answers on this page. (Lead agencies may modify this form to include additional specific information on project description.) A complete description of the proposed project follows, including a description of proposed mitigation activities. In accordance with the guidance for this section (above), more detailed information on certain aspects is provided later in the checklist. A complete set of figures (sheets) showing the proposed facility is provided on Sheets 1 through 36 (attached). BHP proposes to redevelop the Port of Grays Harbor’s (Port) existing Terminal 3 facility and adjacent parcels in the City of Hoquiam, Washington (City), as a bulk potash-export facility. The term “potash” can refer to a variety of mined and manufactured salts that contain a water-soluble form of potassium. The type of potash that would be exported at this facility is called Muriate of Potash, which is mostly potassium chloride (KCl) with a small amount of sodium chloride. Potash is a key ingredient in agricultural fertilizer, including common household garden fertilizers. Potash is non-flammable, non- combustible and is considered non-toxic to aquatic species. Similar to table salt, potash is mildly corrosive to metals, and is water-soluble so it requires a dry location for storage. Potash is processed into granular solid particles that are up to 3/16 inch (4 millimeters) in size and ranges from pink to red in color. BHP anticipates a growing demand for potash in emerging global markets where economic growth is driving increased agricultural production. The proposed new terminal is needed to provide storage and loading of the product onto oceangoing bulk carriers for shipment to overseas markets located primarily on the Pacific Rim. The proposed potash export facility site is herein referred to as the “Project Site” (see Sheets 2 through 15). The proposed project will redevelop the Project Site for the unloading and storage of potash transported to the site via rail from the Jansen Mine in Saskatchewan, Canada, for shipment to international markets via oceangoing vessels. The proposed project will be developed to support the shipment of up to 8 million metric tons per annum (mtpa) of potash. The upland portion of BHP’s proposed Project Site will include rail-unloading and storage facilities, a conveyor system for transferring potash from the rail-unloading area to the storage facilities or directly to the shiploader, and administrative and maintenance buildings. The shiploader and new berth facility will be located directly west of the existing Port of Grays Harbor Terminal 3 dock located in Grays Harbor (Sheets 9 and 10). The Port will retain ownership of the Terminal 3 dock. The potash will be transported from the mine to the proposed export facility via rail. The two Class 1 railroads serving the Grays Harbor area are the BNSF Railway and the Union Pacific Railroad (UPRR). The PSAP is the short line carrier that manages traffic from those carriers for the last 60 miles into Grays Harbor from Centralia. A comprehensive compensatory wetland and aquatic habitat mitigation project will be constructed on an area of developed industrial land at the mouth of the Hoquiam River, known as the Port of Grays Harbor Industrial Development District Parcel No. 1 site (Sheets 1 and 16). This mitigation site is referred to as the “IDD#1 Site.” The proposed mitigation at the IDD#1 Site is discussed throughout this checklist, specifically in sections B3 (Water), B4 (Plants), and B5 (Animals). Additional compensatory mitigation will be provided in the form of removal of creosote-treated piles and a derelict overwater structure from nearshore aquatic habitats at and adjacent to the Port’s Terminal 4 site near the mouth of the Chehalis River (Sheets 1 and 31). The location of the pile removal

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and overwater structure removal is referred to as the “Terminal 4 site.” The proposed aquatic habitat mitigation at Terminal 4 is discussed throughout this checklist, specifically in sections B3 (Water), B4 (Plants), and B5 (Animals). The project also includes preservation of an approximately 71.5-acre parcel of high-quality floodplain wetlands and forested buffer on the Hoquiam River, approximately two miles north of the mouth of the River (referred to herein as the “Hoquiam River Preservation Site”) (Sheets 1 and 32). These activities are discussed throughout this checklist, specifically in sections B3 (Water), B4 (Plants), and B5 (Animals). Complete information on the proposed mitigation may be found in the Mitigation Plan (WSP July 2019). BHP will establish a procedure that outlines a consistent process for identifying, recording, addressing and reporting of community complaints, concerns and grievances. This can be used to report transportation related items but can also be used to report any operational issue. The procedure will be advertised publically and a toll-free hotline and/or email address will be publicized for members of the general public to access. Information acquired through this process will be recorded for immediate action by BHP during normal business hours and reported at a corporate level on an annual basis. In addition, information collected will provide BHP with further understanding of local issues and concerns and will be incorporated on an annual basis into local stakeholder engagement management plans for the company. Project Site: Existing Conditions The Project Site includes both upland and in-water areas. The upland portion of the site is approximately 212 acres comprising parcels owned by the Port, the City, and private entities (Sheet 2). The upland portion of the Project Site is bounded by State Route (SR) 109/West Emerson Avenue to the north, Airport Way/Moon Island Road to the south, and Paulson Road to the west. A relatively undeveloped area extends east from the Project Site to South Adams Road. SR 109 is the main arterial within the City, running east to west. The other surrounding roadways are local roads serving residential, commercial, and industrial land uses. The City’s former wastewater pond is located on the southwest portion of the site. Additional details on existing conditions at the Project Site are provided in Section 8 (Land and Shoreline Use). Proposed Site Facilities/Improvements The proposed Grays Harbor Potash Export Facility (proposed project) will include construction of the following features and associated site improvement activities.

• Marine shiploading structures and ship berth • Railcar unloading facility, including railcar unloading facility gates, hoppers, and equipment • Potash storage building • Administration building, maintenance building, and associated roadways and parking • Fueling station • Site access gate • Site entry overpass at south entrance from Airport Way for vehicular traffic • Utilities (water, electricity, sewer, and stormwater) • Electrical substation(s) (up to three to support operations at the site)

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• Rail improvements, including an 8,500-foot rail loop with two inbound tracks, one outbound track, and one unloading track • A perimeter rail track maintenance road • Stormwater management ponds • Dredging to accommodate and maintain new berth pocket • Covered conveyors, dust collectors, and other transfer facilities A detailed description of these project elements and their operational function, where applicable, follows. The project facility is illustrated on Sheets 1 through 12. Marine Structures The proposed marine structures include an in-water access trestle with wharf conveyor, dual quadrant pile-supported shiploader with steel trusses, mooring dolphins, catwalks, shiploader support structures, and a maintenance access/platform (Sheets 9 and 10). In-water work will only occur during designated in-water work windows discussed in Section A.6.

The existing Terminal 3 dock will remain and will likely be used during construction and future maintenance of the facility. Anchorage in the inner harbor or offshore is not presently considered in the operations plan as current practice is for vessels to maintain a holding pattern offshore.

Steel piles with steel pile caps, steel beams, and steel deck with grating will support the mooring structure. Steel up-stands will support the pivot loads for the quadrant loaders. The quadrant beams will consist of steel beams with extended flanges for walkways on both sides of the crane rail.

The berthing dolphins will be steel pile-supported structures with steel pile caps and are equipped with mooring bollards for ship mooring lines and fendering systems. The two mooring dolphins are pile-supported structures with steel pile caps and quick-release hooks for lines (Sheets 9 and 10). 3 Mooring dolphins are accessed via steel catwalks. The catwalk decks will be grated to allow light penetration.

A combination of vibratory hammer and impact hammer will be used to install the in-water steel piles. It is anticipated piles will be vibrated to a depth near the design tip elevation, followed by impact hammer to the design tip elevation. The characteristics of the substrate and the location of the pile driver will determine the extent to which the pile is advanced by the vibratory method. An impact pile driver will complete driving the pile to the specified depth and load. An impact pile driver will also be used to proof a portion of the piles (approximately 25 percent) after they are driven to design depth with a vibratory hammer. Piles will be driven open-ended.

The marine terminal will require approximately 199 48-inch-diameter steel piles with reinforced concrete pile caps, precast box beams, and composite concrete deck topping. This pile total includes approximately 40 piles as a contingency for the final design.

3 Dolphins are generally divided into two types: namely, berthing dolphins and mooring dolphins. Berthing dolphins assist in berthing of vessels by taking up some berthing loads, keep the vessel from pressing against the pier structure, and they serve as mooring points to restrict the longitudinal movement of the berthing vessel. Mooring dolphins are used for mooring only, and ropes are used to securing the vessels to them. They are also commonly used near pier structures to control the transverse movement of berthing vessels.

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Construction may also require up to 48 temporary piles. Temporary piles may be installed for the mooring of a work barge during the construction and as templates to aid in the installation of the pile groupings. Temporary pile use will depend on the method of construction for support platforms, transfer tower platforms, access support platform, and pivot supports, as they are located in shallow water and may not be accessible by barge. Temporary piles will likely be 24-inch-diameter, open- ended steel pipes, driven solely with a vibratory pile driver. The temporary piles will be removed using vibratory equipment after construction of the relevant feature is completed. Please see Sections B-3 (Water) and B-5 (Animals) for discussion of how impacts to water and marine life will be addressed.

Railcar Unloading The railcar unloading facility (Sheet 6) will consist of an enclosed concrete receiving structure measuring approximately 32 feet wide by 190 feet long by 35 feet deep (below grade) topped by an approximately 26 feet high concrete and steel building of the same footprint. Trains will progress continuously through the railcar unloading facility at about 0.3 mile per hour. The rail cars will be covered when within the facility. The bottom gates on rail cars will be opened to unload the potash into an enclosed receiving hopper and closed when complete before leaving the unloading facility. The entire unloading operation will occur under cover.

Product Storage Building An enclosed storage building will be constructed on the north side of the Project Site to store and protect potash from the elements while waiting for shipment. The storage building will be constructed of a steel frame with tensioned fabric cover designed to keep moisture and precipitation away from the potash product. The product storage building will be approximately 245 feet wide, approximately 141.5 feet high at the apex, and approximately 1,550 feet long. The storage volume of the building will be a maximum of 265,000 tons of potash. The building will be supported by a concrete slab on a steel and timber pile foundation. The storage building will be surrounded by a concrete wall encircling the building. The wall will be 5 feet high and will serve to protect the building and product stored there in the event of flooding. The wall will prevent stormwater/floodwater from coming into contact with the potash product, dissolving, and/or entraining potash into surface water. See Sheet 3 and Sheet 5.

Shiploading Potash will be transported to the ship at the berth directly from the railcar unloading facility or from the product storage building via conveyor. The shiploader will be designed to reduce dust emissions and prevent spills, thereby maintaining water quality. The shiploader will include belt covers, covered transfers, and a telescoping chute to prevent product spills and emission of fugitive dust during operations. The shiploader will also include instrumentation, such as radar, lasers, etc., which, combined with the automated control system, will prevent conveyors from operating unless they are over a vessel hold, thereby preventing accidental discharge of potash into the environment. Operations will require belts to be completely discharged into vessel holds prior to removing the shiploader booms from over a vessel.

There will be 4 vessels per week at the facility, and up to 220 vessels per year. Vessel loading will take place over approximately 14 hours, on average, with individual vessels remaining at berth for an average of approximately 18 hours. The facility will accommodate the loading of one vessel at a time.

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Shiploading systems (Sheets 9 and 10) will be designed for loading vessels with capacities of 20,000 to 82,000 dead-weight tonnage. Larger vessels may not be fully loaded based on berth and channel water depths. The average shiploading rate is estimated to be approximately 4,000 tons per hour. Conveyor systems will be inspected prior to start-ups to determine that no fugitive product is on the conveyance as it passes over the water from the shiploader to the vessel hold. All conveyors are covered, up to the shiploader loading spouts. Vessels will be inspected and secured prior to the beginning of shiploading operations. The dual quadrant nature of the shiploader allows up to two vessel holds to be loaded concurrently as operations allow. The loading spout(s) will be placed over the holds designated by the individual vessel's loading plan. Shiploader cascade chutes will be used to minimize dust by curtailing freefall of the product. The bottom of the chutes will be positioned as low as possible in the ship’s hold to further minimize free fall and associated dust. Loading by a shiploader will pause while shiploaders are repositioned to the various holds to provide controlled and level loading of the vessel.

Administration and Maintenance Building The administration and maintenance buildings (Sheet 3) will each consist of one approximately 38,000-square-foot, one-story (30 feet high) building. The administration building will house administrative offices, washrooms, change rooms, and lunchrooms. The proposed maintenance building will house maintenance equipment, supplies, parts replacement storage, and repairs.

At this time, it is estimated that the workforce for the proposed project —including management, system and equipment operators, and maintenance trades—will be approximately 40 to 50 people, comprising full time and casual positions.

Concrete/Asphalt Pavement and Gravel Surfacing A parking lot will be constructed adjacent to the administration building on the southeast portion of the site. The access roadways, parking lot, and walkways will be constructed using asphalt pavement and/or gravel.

Fueling Station A fueling station will be located to the northeast of the maintenance building (Sheet 3). The fueling station will be used to fuel onsite equipment (e.g., emergency generator) and vehicles, as needed. The fueling station will meet federal and Ecology standards, as well as the stormwater control provisions in the facility’s stormwater pollution prevention plan. Double walled aboveground tanks will be used and will be located within a concrete secondary containment area. The fueling island pad adjacent to the tanks will be impervious and graded with a center drain that will convey to a dead-end sump with capacity for potential spills. The fueling area will be covered under a metal roof supported by steel stanchions to minimize corrosion of the fuel pump equipment and protect electrical connections. Additionally, the roof will be equipped with fire-suppression equipment.

Vehicle Site Access The site will be accessed from a driveway on Airport Way on the south side of the Project Site (Sheet 3). A new grade separation will be constructed for vehicles to pass over the rail loop. The grade separation will be located at the south end of the site.

Emergency access will be through the Project Site via a perimeter rail track maintenance road, allowing access to areas south of the PSAP rail corridor between the Hoquiam River Bridge and the Project Site when trains on route or departing the site are restricting access.

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In an action related to the project, the City of Hoquiam approved an ordinance on June 10, 2019 to vacate an existing section of Airport Way/Paulson Road (Ordinance No. 2019-03) in the southwest corner of the Project Site (Sheet 3).

Utilities The site is served by existing utilities necessary to support facility operations. Utilities include potable water (City), sanitary sewer (City), storm sewer (Port), electrical (Grays Harbor Public Utility District), and communications services. Services will tie into the existing utilities serving the site. Electrical conduits will either be underground or run along the conveyance structures. Up to three onsite substations will be constructed to support the operations at the facility. No new above- ground electrical lines are proposed for the project.

Sewage from the maintenance building will be discharged by gravity to a lift station and pumped to the existing sanitary sewer main for disposal and treatment via the City of Hoquiam public wastewater system. All utility providers will be responsible for completing their required regulatory permits/applications.

Rail Improvements The project includes installation of a rail loop on site consisting of multiple tracks: two inbound tracks, one outbound track, and one unloading track. This track configuration, under normal operations, allows the site to accommodate a fully loaded train onsite at any time onto one of the arrival tracks, and then have an outbound track available for that unit train once it departs the unloading track that it used during train unloading operations. The extra inbound track provides additional capacity for non-typical train-sequencing events where an additional train has arrived early and it then becomes necessary to accommodate an additional loaded train onsite while still unloading the previous, not-yet-departed train. The rail loop size and configuration were designed to accommodate the entire unit train on site during delivery of potash and during unloading operations to maintain security and minimize the trains’ off-site traffic impacts. The proposed project is designed for unloading of potash from one unit train at a time on a single track. Potash is transported by unit trains, as it is the most efficient and cost-effective movement of trains within the rail corridors. This is because the entire product on a unit train goes to a single destination and does not require stops at other facilities to offload railcars or require the separation of cars from the train during normal loading or unloading operations. Potash unit trains will consist of 177 rail cars requiring a minimum of 8,500 feet of track to safely accommodate the entire train on site during arrival, unloading, and departure. The approximately 11-degree turning radius of the track was designed to accommodate the unit trains on site and to allow the placement of the support structures (product storage building, conveyors, administration building, etc.) within the rail loop and away from overwater and wetland areas, minimizing product spill risk and impacts to wetlands as much as practicable while remaining in compliance with the FAA regulatory air space restrictions.

Each railcar will carry approximately 114 tons of potash for a total train shipment size of 20,000 tons of potash per unit train. The facility will generate an average of 1.25 trains per day (roughly 2.5 train trips entering or exiting the Project Site per day) and up to 8 to 10 trains per week (16 to 20 train trips per week). Railcars conveying the potash to the facility will be fully enclosed to protect the product from precipitation and other contaminants.

The new rail loop tracks will be constructed on the site using both wood and/or concrete ties, as determined by the specific use of the track. Grading will be required for track bed construction and a new access/inspection road located along side of the tracks. Clean crushed rock and sand subballast

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and ballast will be imported from an approved commercial source and will provide a structural base for track installation. Approximately 62,000 cubic yards of subballast and ballast will be used.

Stormwater Management As described in more detail in Section B-3-c (Water Runoff), stormwater discharge will occur through existing outfall facilities or on-site infiltration. On-site infiltration is only planned for those areas where infiltration currently occurs that will remain unchanged after construction. Stormwater management will include construction of four new large-sized retention ponds and five small retention ponds located adjacent to the storage feed and direct load conveyors as shown on Sheet 3.

Dredging The proposed berth and dredging will be located west of, and adjacent to, the existing Terminal 3 dock as shown on Figures 3 and 9. The new berth will align with and be adjacent to the Terminal 3 berth and extend to the north side of the navigation channel. The face of the new mooring structure will align with the face of the Terminal 3 existing dock to minimize dredging, ease ship berthing, and provide increased access to deep water. Complete details on the proposed dredging are provided in Section A-3 (Water).

Conveyor System Potash will be transported via a covered conveyor system from the railcar unloading facility to the product storage building and from the product storage building to the shiploader, or from the railcar unloading facility directly to the shiploader. Certified scales will be situated between the railcar unloading facility and the product storage building and between the product storage building and shiploader for monitoring and inventory control purposes. The conveyor system will be covered to prevent rainwater from coming into contact with and dissolving the potash.

Conveyors will be of conventional design with belts, covers, side skirts, spill pans, and maintenance walkways on both sides (Sheet 4). The conveyors will be 60 inches wide except for the reclaim conveyor located within the storage building, which will be 72 inches wide. Gravel or paved access roads for maintenance will be located beneath each conveyor. Conveyor transfers will minimize vertical drops and direct impact of material at transfer points, and will be equipped with skirting systems to minimize spillage. Transfer points will be equipped with dust collection.

Conveyors will be fully automated, starting up and shutting down in a controlled sequence, and will be instrumented to confirm normal operation and provide warning of potential fault conditions.

Mitigation Sites: A mitigation sequencing process has been applied throughout the design of the project, consistent with federal, state, and local regulatory guidance. This mitigation sequencing process consists of a sequence of steps that begins with avoiding impacts to the extent practicable, minimizing and/or rectifying impacts, and finally providing compensatory mitigation for wetland and aquatic impacts. The project has been designed to avoid and minimize impacts to aquatic resources and other sensitive habitat features to the greatest extent practicable, and these impact avoidance and minimization measures are provided in an Alternatives Analysis that was prepared for the project (WSP June 2019) and are summarized in this document. The proposed compensatory mitigation for the project has been designed and sited consistent with USACE, Ecology, WDFW, and City policies and guidance on compensatory mitigation for wetland and

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aquatic impacts. The mitigation will provide a suite of functional improvements to wetland and aquatic habitats that will result in no net loss of habitat functions or values, as described in more detail in Section B.3.a.2 below. IDD#1 Site – Wetland and Aquatic Habitat Creation and Rehabilitation Mitigation will be constructed on an area of developed industrial land east of the Project Site at the mouth of the Hoquiam River, known as the IDD#1 Site (Sheets 1 and 16). The mitigation project at the IDD#1 Site will create approximately 10.75 acres of wetland and rehabilitate approximately 23.49 acres of existing low-quality emergent wetland to high-quality salt marsh. It will also create approximately 5.17 acres of enhanced forested and scrub-shrub wetland buffer at the site by establishing and planting a 110-foot buffer along the northern and western boundaries of the site. Terminal 4 Pile and Overwater Structure Removal The applicant will remove approximately 1,368 piles from nearshore waters of Grays Harbor in the vicinity of the Port of Grays Harbor’s Terminal 4 near the mouth of the Chehalis River (Sheets 1 and 31). Pile and structure removal will provide both in-kind mitigation for benthic habitat and overwater coverage impacts associated with the new terminal as well as out-of-kind habitat mitigation in the form of water quality improvements. The proposed pile and overwater structure removal will occur within Port-owned lands at the Terminal 4 site, or within lands within the Port Management Area established at that location. Approximately 203 of the pilings are currently located within the Port Management Area. The remaining 1,165 piles located east of the Terminal 4 site are on aquatic land currently owned by Washington State DNR but are expected to become part of the Port’s Port Management Area after the Port’s purchase of the adjacent site is completed (the process is currently underway and is expected to be complete in 2020). Hoquiam River Preservation Site – Wetland and Forest Buffer Preservation The applicant will preserve an approximately 71.5-acre parcel of high-quality floodplain wetlands and forested buffer on the Hoquiam River, approximately two miles north of the mouth of the River (referred to herein as the “Hoquiam River Preservation Site”) (Sheets 1 and 32). This will preserve approximately 59.9 acres of Category I wetlands. Preservation of the wetlands at the Hoquiam River Preservation Site will provide out-of-kind mitigation for indirect wetland impacts at the Project Site, by protecting these wetlands from a direct and present development threat. These include threats from timber harvest, industrial development, residential development, agriculture and hobby farming, and high-intensity recreation No ground-disturbing work is proposed at the Hoquiam River Preservation Site; therefore, this site is not discussed in sections of this checklist where the question is not applicable to the activity proposed (i.e., wetland and buffer preservation) at the Hoquiam River Preservation Site. 12. Location of the proposal. Give sufficient information for a person to understand the precise location of your proposed project, including a street address, if any, and section, township, and range, if known. If a proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit any plans required by the

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agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to this checklist. Project Site: The Project Site is located on the southeast corner of SR 109 and Paulson Road in the city of Hoquiam. The Project Site is located on portions of tax parcels (056401000102, 517100331005, 517100331007, 056401000101, 056401000102, 517101021001, 517101012001, 517101011001, 056401000600, 517101011004, 056401000501, 056401000801, 056401000400, 056401000301, 056401000201, 056401100204, 056401100202, 056401100100, 056401000302, and 056401100203) and located in portions of Sections 3 and 10, Township 17 North, Range 10 West of the Willamette. See attached Vicinity Map (Sheet 1). Mitigation Sites: See attached Vicinity Map (Sheet 1) for the location of all mitigation sites. IDD#1 Site The IDD#1 Site is located in the City of Hoquiam, along Earley Industrial Way on the north shore of Grays Harbor and along the west bank of the Hoquiam River at its mouth in Sections 11 and 12, Township 17N, Range 10W, Hoquiam Quadrangle. The wetland and aquatic habitat mitigation will be conducted on tax parcels 056400600102, and 056400400100 (two lots are included within this parcel). Terminal 4 Terminal 4 is located east of IDD#1 in the City of Aberdeen at the mouth of the Chehalis River in Sections 17 and 18, Township 17N, Range 9W, Aberdeen Quadrangle. Pile removal and overwater structure removal will occur on a portion of tax parcel 029902000200 and on adjacent state-owned aquatic lands. Hoquiam River Preservation Site The site is located approximately 2 miles north of IDD#1 in Grays Harbor County, adjacent to the Hoquiam River in Section 35, Township 18N, Range 10W, Hoquiam Quadrangle. The property consists of one tax parcel (181035310010). B. ENVIRONMENTAL ELEMENTS 1. EARTH a. General description of the site (circle one): flat, rolling, hilly, steep slopes, mountainous, other. The risk of landslide hazards, mass wasting events, debris flows, and rockfalls at the site are low because of the relatively flat nature of the sites. For these reasons, neither the Project Site nor the IDD#1 Site is considered to be an erosion or landslide hazard area. Project Site: The upland portion of the Project Site is flat and consists of in-water and upland properties on the shoreline of Grays Harbor west of the Hoquiam River, approximately 20 feet above mean sea level (Sheets 2 and 3). Mitigation Sites: The IDD#1 Site is surrounded by an elevated berm surfaced with a gravel pathway around the west, south, and east sides of the site. The Terminal 4 site is located entirely within the water. The Hoquiam River Preservation Site consists of a flat area of floodplain wetland adjacent to the Hoquiam River, and an adjacent forested hill slope.

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b. What is the steepest slope on site (approximate percent slope)? The risk of landslide hazards, mass wasting events, debris flows, and rockfalls at the site are low because of the relatively flat nature of the sites. For these reasons, neither the Project Site nor the mitigation sites are considered to be an erosion or landslide hazard area. Project Site: The site, while generally flat, has undulating topography with the average slope across the Project Site generally less than 5 percent. The shoreline bank is generally about 5 feet high and is armored with rock riprap. The shoreline slope ranges from approximately 25 to 50 percent. Mitigation Sites: The IDD#1 Site is relatively flat, and the steepest slopes present on the site (approximately 50 percent) are associated with the berm that is located along the outer boundary of the site. The upper surface of the berm is located at approximately +16 feet NAVD88, and the side slopes of the berm are approximately 50 percent. The upland area adjacent to Terminal 4 is flat. The Hoquiam River preservation site consists primarily of flat floodplain wetlands. Microtopography within the wetland portion of the site is undulating and hummocky. The adjacent hill slope within the forested buffer portion of the site is a steep southern aspect slope of approximately 80 percent. c. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If you know the classification of agricultural soils, specify them and note any agricultural land of long- term commercial significance and whether the proposal results in removing any of these soils. Project Site: The portion of the Project Site that is located on the Port’s Terminal 3 property is built upon historically placed fill material. Beginning in the 1960s, tideflats were filled with dredged material, and a levee and dike system was established as part of an urban renewal project. The site was used as a log sorting, storage, and processing facility in the 1970s, 1980s, and early 1990s, and additional surface rock was placed over portions of the site to develop the site for these activities. Forty-nine soil samples were collected at the Project Site during soil sampling and installation of groundwater sampling wells (August 2017, and March and June 2018). While soil conditions varied across the site, in general, surface soil profiles consist of 1/2-inch gravel fill from 0 to approximately 5 feet below ground surface (bgs) with alternating layers of 1/2-inch gravel fill with mixed coarse sand, silty sand, and silt from 5 feet bgs to the completed depth of borings (approximately 15 feet bgs). A geotechnical engineering report for the Project Site has been prepared (Shannon & Wilson June 2019). Per the report, and based on the geotechnical investigations, the project area is predominately underlain by Holocene fill, alluvium, estuarine deposits, and deep glacial outwash deposits. The soil units encountered in the geotechnical explorations, from youngest to oldest, are as follows.

• On-shore Fill (Hf) – Engineered and non-engineered fill typically, very loose to dense, comprising soil, quarry spalls, construction debris, cobbles, boulders, wood chips, and debris. The fill will likely only be encountered at onshore locations. • Estuarine Deposits (He) – Estuary deposits of the current and ancestral Chehalis River. Clayey silt to silty clay with interbedded, silty sand. Local concentrations of organic-rich silt.

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• Alluvium (Ha) – River or creek deposits, normally associated with historic streams, including overbank deposits. Typically, these deposits are very loose to medium dense silts, sands, and gravels; they can include very soft to stiff clay, silt, peat, and wood debris. • Advance Outwash (Qva) – Glaciofluvial sediments deposited as the glacial ice advanced. Clean to silty sand, sandy gravel; dense to very dense. There are no agricultural soils on the Project Site, and there are no designated agricultural lands of long- term commercial significance in the City of Hoquiam. Mitigation Sites: IDD#1 Site The mitigation site is located on historical tideflats filled with dredged material from the Chehalis River in the mid-20th century. The soil encountered in the 40 soil samples collected during the site investigation and well installation completed for the project in June 2018 includes the following.

• Poorly graded sand from 0 to 5 feet below ground surface (bgs) • Alternating layers of silty sand, sandy silt, and silt from 5 feet bgs to the completed depth of borings (15 to 20 feet bgs) • Areas of wood debris, including burned/charred wood, were encountered in test pits on the northeast corner and near the southwest corner of the site at depths ranging from 4 to 8 feet bgs There are no agricultural soils on the IDD#1 Site, and there are no designated agricultural lands of long- term commercial significance in the City of Hoquiam. Terminal 4 The Terminal 4 site is covered by water. Sediments consist of fine-grained sand and silts. According to the City of Aberdeen comprehensive plan, there are no designated agricultural lands of long-term commercial significance on or near Terminal 4. Hoquiam River Preservation Site The USDA Natural Resources Conservation Service (NRCS) maps soils at the site as primarily Ocosta silty clay loam, which is a hydric soil and is not a prime agricultural soil. No soils would be removed as a result of the proposal. d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe. Based on the geotechnical engineering analysis conducted and described below, there is a minimal risk that soil liquefaction and ground shaking during earthquakes will cause injury/death and structural damage. Project structures will be designed to comply with current seismic codes and to incorporate other design elements, such as the addition of piles to structure foundations, to reduce this risk. Additionally, the Project Site and Mitigation Sites are not considered to be within a volcanic hazard area. Project Vicinity (All Sites): Soils mapped at the sites by the USDA NRCS are rated as having a slight potential for erosion hazard, which indicates a low level of risk of erosion (USDA-NRCS 2017).

According to the DNR Natural Hazards online mapper, the Project Site and IDD#1 have a moderate to high liquefaction susceptibility and are a National Earthquake Hazard Reduction Program (NEHRP) site Class D to Class E (DNR 2017). Layer information for NEHRP seismic site class states “Site classes C, D,

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and E represent increasingly softer soil conditions which result in a progressively increasing amplification of ground shaking.” The sites are therefore considered to be a seismic hazard area.

The cities of Hoquiam and Aberdeen do not designate tsunami events as a type of seismic hazard. However, WAC 365-190-120 provides that “areas subject to severe risk of damage as a result of…tsunamis” be considered seismic hazard areas. The potential impact of a tsunami at the Project Site was considered according to the Tsunami Hazard Maps of Southwest Washington, prepared by the Washington Geological Survey and modeled on a L1 Cascadia Subduction Zone earthquake scenario (Eungard et al. 2018). During this event, modeled inundation at the site appears to be mostly between 0 to 5 feet. South of the Airport Way roadway, inundation is predicted to be as high as 15 feet. Currents are mapped as high at the shoreline (>9 knots) but mostly 0 to 3 knots across the Project Site. (Ausenco February 2019). During an event, the tsunami would be expected at the Project Site approximately 50 minutes after ground-shaking occurs. Therefore, the Project Site and mitigation sites are within a tsunami hazard area. The Grays Harbor County 2018 Multi-Jurisdiction Hazard Mitigation Plan (July 2018) defines and identifies “critical facilities and infrastructure,” which warrant further consideration over tsunami hazards; the Proposed Project is not a critical facility according to the hazard mitigation plan. The DNR Natural Hazards mapper indicates that the nearest faults are located west of the Project Site, near the mouth of Grays Harbor, and to the northwest near Ocean Shores; therefore, the likelihood of surface faulting or fault rupture at the sites is relatively low. The DNR Natural Hazards mapper indicates that the sites could potentially be affected by volcanic ash because of potential volcanic hazards to the east (Mount Rainer, Mount St. Helens, and Mount Adams), however the Project Site and mitigation sites are not considered as within a volcanic hazard area. Other potential or known geologically hazardous areas are discussed under the critical areas discussion in Section 8 (Land and Shoreline Use) of this checklist. Project Site: The geotechnical report for the Project Site (Shannon & Wilson June 2019) examined potential unstable soils, including the following tasks.

• Liquefaction assessment based on extrapolated soil data for marine facilities. This liquefaction assessment was based on the requirements of American Society of Civil Engineers (ASCE) 7-05. • Geotechnical foundation analysis for static and for Design Earthquake per ASCE 7-05, 2/3 of Maximum Considered Earthquake (MCE) loading conditions for the offshore marine structures. • Model and run non-linear, two-dimensional (2D) dynamic finite-difference analyses for the storage building and offshore marine facilities based on the report data and extrapolated data. • Determine the extent of recommended ground improvements at marine structures to achieve the required performance for Design Earthquake, per ASCE 61-14 for berth, trestle, and storage building. • Simplified pile foundation analysis for the marine structures with GROUP Software (ENSOFT) or similar 3-D soil structure interaction software. • Complete preliminary geotechnical investigation. This investigation consisted of four onshore cone penetration tests. Shannon & Wilson completed additional geotechnical investigations at the in-water portion of the site in November 2018. The results (Shannon & Wilson June 2019) indicate that the sediment in the in-water

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portion of the site includes tidal sand and silt deposits underlain by dense sand and gravel at a depth of approximately 45 feet below mudline surface. The geotechnical recommendations contained in the report relate to the preliminary seismic design including strong ground motions, liquefaction potential, lateral spreading, and lateral pile resistance. The facility design was based in part on the recommendations summarized in this report, including ground improvement (e.g. pile foundations) beneath the project storage building. e. Describe the purpose, type, total area, and approximate quantities and total affected area of any filling, excavation, and grading proposed. Indicate source of fill. Project Site: Construction: Grading will be needed to prepare the building sites, rail footprint, and other site components. Approximately 550,000 cubic yards of material will be excavated at the Project Site, from within an area approximately 122 acres in size, associated with trenching for buried utilities, road construction, and building excavations. Approximately 550,000 cubic yards of total fill will be required at the Project Site, within an area approximately 85 acres in size, which includes approximately 62,000 cubic yards of subballast and ballast material for the construction of the rail track. A total of approximately 122 acres of the site will be graded to prepare the site. Fill materials will be commercially produced soil, ballast, subballast, etc. Crushed rock subballast and ballast will be imported from certified, commercial sources and will provide a structural base for track installation. The only fill that will be placed in wetlands at the Project Site is that required for the rail foundations in the north and east portions of the rail loop, small portions of the product storage building, and some conveyor foundations (see Section A-3 [Water]). This represents approximately 150,000 cubic yards of material. The remaining open areas of the former City wastewater pond on the southwest portion of the Project Site will likely be filled with clean fill material excavated from on site or from the proposed mitigation site. The total volume of the fill needed will be determined in final design. Details on the proposed dredging during construction are provided in Section A-3 (Water). Operation No fill, excavation, or grading work would occur on the upland areas of the Project Site after construction is completed. Details on the proposed maintenance dredging are provided in Section A-3 (Water). Mitigation Sites: Construction Estimates calculated based on the grading plan described in Part VI of the Conceptual Mitigation Plan indicate that the construction of the mitigation site at IDD#1 will require the removal of approximately 205,087 cubic yards of material from the site, from within an area approximately 34.18 acres in size to excavate the wetlands and tidal channels. The results of soil sampling conducted at the site in June 2018 indicate that the majority of this material will be suitable for disposal in clean landfills or other upland disposal locations that are permitted for placement of clean material. Approximately 5,192 cubic yards of fill material will be needed for the construction of the pedestrian trail at the site. No fill or grading is proposed at either the Terminal 4 or the Hoquiam River preservation sites.

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Operation None. No fill, excavation, or grading work would occur at IDD#1 after construction is completed. f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe. Soils mapped at the sites by USDA NRCS are rated as having a slight potential for erosion hazard, which indicates a low level of risk of erosion (USDA-NRCS 2017). The Best Management Practices (BMPs) described below that will be employed during project construction will reduce these impacts. There is no erosion risk from operational use of the Project Site. There is no erosion risk from construction at Terminal 4, as all construction work will be in-water, and no erosion risk at the Hoquiam River Preservation Site because no ground-disturbing activities will occur there. Construction Impacts (All Sites): For the purposes of this SEPA checklist, construction impacts are defined as temporary impacts that will occur during project construction. Erosion during construction is possible during site clearing and grading or other soil-disturbing activities at the Project Site and IDD#1. The sites are relatively level with minimal erosion potential (see [d] above). However, significant erosion at the Project Site or IDD#1 site caused by clearing, grading, and/or filling is unlikely because of the following existing conditions:

• Soils mapped at the site are rated as having a slight potential for erosion hazard, which indicates a low level of risk of erosion, • The use of typical best management practices (BMPs) to control erosion, • Compliance with the requirements of the NPDES Construction Stormwater Permit, • The Industrial Stormwater permit that will be obtained for the project, and • The resultant Stormwater Pollution Prevention Plans (SWPPP) to be prepared therewith. No erosion is anticipated at Terminal 4 as all construction work is over-water or in-water. No ground disturbing work would take place at the Hoquiam River preservation site.

Proposed mitigation measures to address erosion are presented in Section B.1.h below.

Operation Impacts (Project Site): No erosion is anticipated to occur on the Project Site once construction is complete. Operational activities will take place on cleared and prepared surfaces, and the proposed stormwater system on site will address any potential runoff. See Section 3 (water) for a description of the proposed stormwater system. g. About what percent of the site will be covered with impervious surfaces after project construction (for example, asphalt or buildings)? Project Site: Impervious surfaces associated with the export facility will consist of buildings, rail lines, inspection roads, site access roads, parking, and walkways. At present, approximately 45 percent (95 acres) of the 212-acre Project Site is covered in impervious surfaces. The proposed facility would increase this to 61 percent (130 acres). Impervious surfaces were approximated based on current design plans and consistent with Ecology’s guidance on what is considered an impervious surfaces (e.g., ballast and gravel surfaces were considered impervious).

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Mitigation Sites: IDD#1 Site No impervious surfaces are proposed at the IDD#1 site. A portion of the existing berm would be removed as part of the wetland and aquatic habitat enhancements, which will result in a reduction in the net quantity of impervious surface at the site. The proposed public access enhancements at the IDD#1 site would include a pervious pedestrian trail. Terminal 4 No impervious surfaces are planned. Mitigation activities will involve the removal of a 2,147 square foot overwater structure, thereby decreasing the impervious surfacing at the site. Hoquiam River Preservation Site There is no existing impervious surface at the site, and none would be added by the proposal. h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: Construction Mitigation: All Sites An NPDES construction stormwater permit will be required for construction at both the Project Site and the IDD#1 site. This permit will require the preparation of a Temporary Erosion and Sediment Control (TESC) plan, a construction SWPPP, identification and implementation of BMPs to control the risk of erosion and monitoring of site activities and stormwater discharges for compliance with permit standards. Site BMPs may include use of mulch; silt barriers; containment systems; and interim stormwater controls, cover measures (straw or plastic), preservation of existing vegetation to the extent practicable and reseeding of areas temporarily disturbed by construction. A grading permit will also be obtained prior to construction activities. The SWPPP and TESC will identify the specific BMPs for the location/conditions. IDD#1 Site Grading and site preparation of the IDD#1 Site will conducted consistent with the mitigation plan and a grading permit that will obtained prior to construction activities commencing on the site. Prior to commencement of grading and excavation at the site, erosion and sediment control measures will be established at the site consistent with the Construction SWPPP for the project. These will likely include typical construction BMPs such as silt fences and stabilized construction entrances. The existing culvert and tide gate at the eastern boundary of the site will also be blocked off to isolate the interior of the site from tidal influence, and to allow any runoff from the site during construction to be contained. The culvert will remain blocked until the final grades within the interior of the site have been established, and until intertidal portions of the site have been seeded and planted as described in the Revised Mitigation Plan. Once seeds have germinated and the interior portions of the site are stabilized, final excavation and grading of the tidal channel openings and the outer berm will occur. Once seeds have germinated and the interior portions of the site are stabilized, the outer berms will be breached, and the interior of the site will be exposed to the natural tidal cycle of the Harbor. Terminal 4 Work will be in-water or over-water, and will not result in upland erosion at these sites. BMPs to control sediment as it relates to water quality and fish and wildlife are identified in those sections of the checklist.

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Operation Mitigation (Project Site): Once constructed, operations at the Project Site will be subject to the identified geologic hazards that are mapped for the general area, specifically liquefaction, seismic and tsunami hazards. The structures will meet the standard requirements of the International Building Code and other applicable city/state standards that contain specific standards for addressing seismic risks. The proposed project will be developed to incorporate the geotechnical recommendations and design standards enumerated in Section 4 of the geotechnical report (Shannon & Wilson, Inc. June 2019). More detailed building design measures to address liquefaction and seismic hazards will be determined during building design and permitting. The proposed project will also comply with Grays Harbor County’s Tsunami Warning Plan, which includes a variety of methods to warn of a tsunami and a detailed map of areas subject to tsunami hazards, evacuation routes, and assembly areas. An emergency response plan will be developed in compliance with regulatory and industry standards, and will contain safety procedures to be taken in the event of an earthquake, tsunami or other emergency concerns. Workers at the site would respond to warnings and follow established evacuation routes to areas of safety. The proposed structure at the site located in the floodplain (storage building) will be constructed at an elevation or flood-proofed to protect against the Federal Emergency Management Agency (FEMA)- defined 500-year flood plus climate-change-based flood elevation. The storage building will include a concrete wall extending 5 feet above the building’s concrete slab foundation, allowing the building to be sealed within the boundary wall in the event of a flood. This method of construction will likely also be protective against tsunami. Consideration of Cumulative Impacts: Potential cumulative impacts to the earth (e.g., erosion) were evaluated by considering the proposed project in addition to the Contanda Project, which both have the potential to impact earth resources through increased impervious surfaces, potential for erosion during construction or operation, and other common impacts. Most construction activities at the Contanda site would take place on existing paved surfaces, which reduces the likelihood of erosion during construction (7 of the 8.3 acres proposed for development are currently paved, and construction of the proposed project would require paving the remaining acre). In addition, the potential for increased erosion on the Contanda site is low because the Contanda site is relatively flat and is underlain by sandy, gravely soils which have a low erosion potential (Contanda 2019). The North Shore Levee project would also result the short term potential for erosion during construction activities. The Contanda Project and North Shore Levee project are both are located over a mile from the Project Site. These projects would be required to comply with federal and state regulations, best management practices, required permit conditions, and recommended mitigation. These measures would adequately address impacts and reduce the potential for the proposed project to result in cumulative impacts to earth resources. 2. AIR a. What types of emissions to the air would result from the proposal during construction, operation, and maintenance when the project is completed? If any, generally describe and give approximate quantities if known. Emissions associated with the project would consist of emissions generated during construction activities (e.g., combustion emissions from petroleum fueled vehicles and equipment and dust emissions) and operations (e.g., equipment, locomotive and vessel emissions). The Air Quality and GHG

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Analyses evaluated existing air quality relative to project emissions as they relate to applicable air quality regulations. The report also included an assessment of GHG emissions and air quality impacts from particulate matter (PM) and diesel particulate matter (DPM) emissions attributable to stationary and mobile sources associated with the proposed project (Ramboll July 2019). 4 The ORCAA Notice of Construction (NOC) Application (Ramboll September 2018) contains additional details on the modeling used to evaluate the air emissions associated with the project and assess compliance with ORCAA regulations. An overview of the assessment of the types of emissions (and quantities, where known) is provided below. Generally, the operational air impacts from the project are as follows.

• PM and visible emissions would be emitted during facility, locomotive, and vessel operations, but would not violate ambient air quality standards or any other applicable regulations. • Stationary source DPM would be emitted by diesel engines powering the emergency generator and the emergency fire water pumps, but the capacities of these engines are less than ORCAA’s threshold for emergency engines and were therefore not reviewed by ORCAA. However, diesel engine DPM emissions would be less than the statewide regulatory screening threshold. • Mobile source DPM emissions would result from diesel-powered locomotives and marine bulk vessels traveling to and from the Project Site to deliver and receive potash. Combined stationary and mobile source DPM emissions associated with the project would exceed the statewide screening threshold, but impacts would not exceed the statewide acceptable human health risk increase thresholds. • Total GHG emissions from the proposed project would represent minor contributions to local and global GHGs but would not be a significant source of emissions when compared to standard benchmarks. • Modelled ambient air concentrations of particulate matter (PM) would be less than all applicable standards. • Analyses of combined stationary and mobile source emissions predict that no significant impacts would occur as a result of criteria pollutant emissions, which will not cause or contribute to an exceedance of any ambient standard, and toxic area pollutant emissions are sufficiently low to protect human health and safety from potential carcinogenic or toxic effects. Construction Emissions: Air impacts from construction are not expected to be significant. Emissions from construction activities were evaluated in the Updated Air Quality and GHG Analysis (Ramboll July 2019). Construction phase air emissions are regulated under existing standards. Construction of the facility would include grading activities, ground improvement, and structure erection activities typical to an industrial facility. Such activities could result in temporary, localized increases in particulate concentrations due to emissions from construction-related sources. Dust from construction activities such as excavation, grading, sloping, and filling would contribute to ambient concentrations of suspended PM. Emissions from diesel equipment could reduce ambient air quality, resulting in potential health risks, although the use of

4 PM refers to solid particles and liquid droplets found in the air. PMs are categorized and regulated by the State and EPA as PM10 (inhalable particles, with diameters 10 micrometers and smaller) and PM2.5 (fine inhalable particles, with diameters 2.5 micrometers and smaller). https://www.epa.gov/pm-pollution/particulate-matter- pm-basics

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equipment that complies with applicable current regulations will minimize the potential for increased risk. Implementation of reasonable precautions during the construction phase and complying with applicable regulations regarding engines, off-site odors, and off-site dust are expected to prevent significant air quality impacts due to construction. Proposed mitigation to control air impacts from construction activities are identified below in Section 2(C). Operations/maintenance Emissions Emissions from the proposed project were evaluated in the Updated Air Quality and Greenhouse Gas Analysis (Ramboll July 2019). Emissions during operation will consist of emissions from on-site sources, such as particulate matter and visible emissions, and emissions associated with automobiles, locomotives, and vessels. Emissions of particulates, NO2, SO2, CO, toxic air pollutants, and GHGs were all evaluated. The study concluded that project emissions evaluated will be sufficiently low and will not result in impacts to “human health and safety from potential carcinogenic and/or other toxic effects" and "not cause or contribute to a violation of any ambient air quality standard." The estimated cumulative concentrations of pollutants (PM10 and PM2.5, NO2, SO2) in the existing background air quality and operational increases are all estimated to be less than the National Ambient Air Quality Standards (NAAQS) criteria. Vegetation maintenance at the IDD#1 mitigation site would likely result in some emissions commonly associated with standard landscaping equipment such as string trimmers and mowers, and would be minor. No emissions would result from mitigation actions at either Terminal 4 or the Hoquiam River Preservation Site. Summary of On-Site Emission Rates A summary of maximum potential annual criteria emissions from the potash facility is presented in Table 1 and a summary of GHG emissions in Table 2 (below). Additional details of each emission unit and emission rate calculations are presented in the air quality report (Ramboll July 2019). Note that emission rates are presented for all pollutants in tons per year except for GHG emissions which are presented in metric tonnes of carbon dioxide equivalent (CO2e) per year. Table 1 . Facility-Wide Maximum Potential Annual Criteria Pollutant Summary Category Source Emission Rates (tons/year)

NOX VOC CO PM10 PM2.5 SO2 Dust Control 0.00 0.00 0.00 10.8 4.73 0.00 Equipment

Mat. 0.00 0.00 0.00 6.75 1.02 0.00 Stationary Handling Fugitives Support Equip/ 0.094 0.011 0.11 0.053 0.018 0.026 Operations Subtotal 0.094 0.011 0.11 17.6 5.77 0.026 Line Haul Locomotive 13.9 0.555 0.008 0.34 0.33 0.013 Vessel 73.2 3.87 8.08 1.36 1.26 3.10 Mobile Tugs 14.3 0.32 2.60 0.33 0.32 0.008 Subtotal 101 4.75 10.7 2.02 1.92 3.12 Total 102 4.76 10.8 19.6 7.69 3.15

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Table 2. GHG Emissions Summary Scope Sources GHG Emissions (mtCO2e/yr) Stationary 13 1 On-site Locomotives 1,263 At-berth Marine Vessels 5,429 2 Purchased Electricity 1,213 WA Locomotives 68,926 WA Marine Vessels 1,229 3 Out-of-State Locomotives 129,648 Out-of-State Marine Vessels 690,747 Total 898,468

Stationary Sources The emergency generator and the diesel engines that power the emergency fire water pumps will be the only stationary sources of DPM emissions associated with the project (i.e., the emission units subject to air permitting). The engines will also be the only stationary sources associated with the project that are expected to emit toxic air pollutants at rates greater than regulatory de minimis levels. The emergency generator and the diesel engines (which power the emergency fire water pumps) would only be used in the event of an emergency (e.g. power outage) or during required emergency readiness testing. The emissions reductions alternatives proposed as best available control technologies (BACT) will also minimize criteria and toxic air pollutants. The maximum ambient concentration of DPM from stationary sources predicted by the dispersion model was less than the Acceptable Source Impact Level (WAC 173- 460-150), meaning no further analysis of DPM was required. Emissions from on-site sources during project operation are expected to be classified as a “minor source” with stationary source emissions, below ORCAA thresholds (WAC 173-401-530). An NOC application has been filed with ORCAA because operation of the export facility will result in an increase in the emissions of regulated air pollutants. Construction cannot commence until ORCAA issues an Order of Approval. The project is subject to compliance with ORCAA standards for PM emissions Mobile Sources Mobile source emissions will result from empty marine vessels traveling to the site to receive a load of potash, diesel-powered locomotives delivering potash to the project facility, empty trains leaving the site, and loaded marine vessels leaving the site. Locomotives are powered by diesel engines with emissions that are similar to all diesel powered engines (such as cars, trucks, construction equipment, and semis). Train emissions will vary based on the number of trains, locomotives, and the speed of the train. The unit trains arriving at the site will have up to 5 locomotives per train, and the emissions modeling assumed an average of 1.25 trains will visit the facility each day, up to 455 trains per year. The modelling further assumed that trains would idle on site up to 4 hours each day as a conservative estimate.

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Emissions will also result from the ocean-going bulk vessels transiting to and from the facility while they are at berth and from tugs and pilot boats that support vessel operations. Each vessel arrival and departure is expected to be supported by two tug boats, and the vessels will arrive once per day and spend 14 hours loading, with additional time needed for berthing, as well as operation setup and tear- down. The vessel emission factors in the air analysis were developed using the U.S. EPA’s port-related emission inventory guidance document. Combined Stationary and Mobile Sources An analysis was developed to better understand potential health impacts from DPM emission increases associated with the project (Ramboll July 2019). The analysis included quantification of DPM emission increases from both stationary and mobile sources and air quality dispersion modeling simulations to estimate DPM concentration increases in the area surrounding the facility. The health impact analysis was based on procedures used by Ecology for Second Tier Reviews of toxic air pollutants (TAPs), as outlined in WAC 173-460 and in Ecology guidance, and the format and content of the document are consistent with a Health Impact Assessment (HIA) that would be submitted to Ecology as part of a Second Tier Review. The analysis provides an incremental health risk assessment of cancer risk increases associated with exposure to DPM emissions attributable to the project. Second Tier Review procedures are provided to address exceedances of ambient TAP concentration screening thresholds predicted as part of the New Source Review (NSR) air permitting process. Because mobile sources are federally regulated they are not addressed by the air permitting process, and the regulations in WAC 173-460, including the regulatory thresholds provided therein, are not intended for assessments of mobile source TAP impacts. However, the analysis adapted the Second Tier Review methods prescribed by WAC 173-460 to assess potential DPM health impacts associated with combined project-related stationary and mobile sources, because the WAC 173-460 methodology is well- established with recognized thresholds and provides a conservative methodology for the assessment. The combined stationary and mobile source analysis resulted in total emission increases of several TAPs exceeding the Small Quantity Emission Rates (SQERs) assigned in WAC 173-460 in addition to those evaluated in the ORCAA NOC application prepared as part of the NSR process. Emission increases associated with stationary and mobile sources of these additional TAPs were included in the air dispersion modeling, and the resulting maximum concentration increases were compared to the Acceptable Source Impact Level (ASIL), as if for an NOC application. All TAP concentration increases were predicted to be less than the ASILs, except for DPM, and the HIA was developed to assess potential DPM-related health risk impacts attributable to the project. Based on the results of the HIA, DPM emission increases associated with the facility, including those attributable to stationary and mobile sources, would not exceed the acceptable risk threshold provided in WAC 173-460-090(7). GHG Emissions Emissions of the three most common (and influential) GHGs were calculated and their potential impacts assessed. The three GHGs assessed were carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). The project’s emissions are not significant relative to statewide, national, and global emissions of GHGs. The total GHG emissions from the proposed project would represent 0.10 percent and 0.015 percent of the total Washington and U.S. inventories, respectively, and 0.22 percent and 0.047 percent of the Washington and US transportation inventories, respectively, of GHG gases. They would represent 0.0021 percent of the total global inventory and 0.077 percent of the global international transportation inventory of GHG. The proposed project is not a significant source of GHG emissions when compared to any state, federal, or global emission benchmark. Both Washington State and the federal government have established thresholds for requiring reporting of GHG emissions, and the project’s emissions will

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not come close to those thresholds. The GHG emissions from the proposed stationary sources are 0.13 percent and 0.052 percent of the Washington State (10,000 mtCO2e) and federal (25,000 mtCO2e) reporting thresholds, respectively. The BHP Board is actively engaged in addressing climate change issues. BHP has been publicly reporting their operational emissions – and undertaking initiatives to reduce them – since the 1990s. In fiscal year 2018, BHP began working towards a new five-year GHG emissions reduction target. The new target, which took effect from July 1 2017, is to maintain total operational emissions in fiscal year 2022 at or below fiscal year 2017 levels while continuing to grow the business. The new target builds on BHP’s success in achieving the previous five-year target. In addition to the five-year target, BHP set the longer- term goal of achieving net-zero operational GHG emissions in the latter half of this century, consistent with the Paris Agreement.5 Ambient Impact Analysis Documentation of the methodology and results of an assessment of impacts attributable to criteria pollutant emissions from stationary sources associated with the project and of impacts attributable to combined stationary and mobile sources associated with the project is provided in Section 7 of the air analysis report (Ramboll July 2019). As is typical in the air permitting process, the air modeling analysis takes a conservative approach, providing maximum potential emission rates to the model predict worst- case ambient air concentrations, combining those predicted impacts with worst-case existing background concentrations, and comparing total predicted concentrations (i.e., project plus background) with established regulatory ambient standards. It is important to understand that this represents the maximum values modeled. Ambient air quality impacts decrease rapidly as one moves away from those locations of maximum modeled impact. As shown in Table 3 below, all predicted total concentrations are less than their respective ambient standards; therefore, no further analysis was required to demonstrate compliance with ambient standards. Although not required for the analysis developed to obtain an air permit, an analogous analysis that included combined stationary and mobile source emissions was developed; it predicted that, even when combined stationary and mobile source emissions were included in the analysis, none of the ambient standards would be exceeded, which suggests that no significant impacts would occur as a result of criteria pollutant emissions attributable to the project. Because the air dispersion modeling methodology, including the use of a model designed to not under-predict ambient concentrations, is conservative, and conservative assumptions were employed to develop model inputs, the results of a modeling analysis that indicate compliance with ambient standards (i.e., are not significant) are typically relied upon by permitting agencies, even when predicted total concentrations are just less than the applicable standard.

5 https://www.bhp.com/environment/climate-change

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Table 3. Predicted Facility-Wide Design Concentrations (Stationary and Mobile Sources Concentration (µg/m3) Pollutant Averaging Over 1 2 3 4 Period Design Background Total AAQS AAQS? (µg/m3)

PM10 24-Hour 96.7 42.1 139 150 No 24-Hour 20.5 11.6 32.1 35 No PM2.5 Annual 5.3 4.9 10.2 12 No 1-Hour 140 30.5 170 188 No 5 NO2 Annual 3.7 5.5 9.2 100 No

SO2 1-Hour 52.5 12.4 64.5 196 No

1. Design concentrations are the highest 6th-high 24-hour average PM10 concentration over five modeled years, the highest 5-year average of the 98th percentile 24-hour average PM2.5 concentrations at each receptor, and the highest 5- year average of the annual average PM2.5 concentrations at each receptor (based on guidance in the “Modeling Procedures for Demonstrating Compliance with the PM2.5 NAAQS” memorandum issued on March 23, 2010 by Stephen Page, Director of Office of Air Quality Planning & Standards ). 2. Background concentrations were calculated using the Idaho DEQ online tool https://arcg.is/1jXmHH 3. Total concentration is the sum of the design concentration and the background concentration. 4. WAC 173-476 aligns the WAAQS for PM10, and PM2.5 with the NAAQS. As a result, the WAAQS and NAAQS for PM10, and PM2.5 are identical. 5. ARM2 applied for 1-hour and annual NO2. The air quality modeling predicted that criteria pollutant emission increases attributable to the proposed project will not cause or contribute to an exceedance of any ambient standard. Cumulative Impacts: The ambient air impact analysis (above) includes existing emissions and as such is a cumulative analysis of the proposed project and existing conditions. Of the reasonably foreseeable future projects, the North Shore Levee Project and maintenance dredging activities would only temporarily increase emissions during construction/dredging activities, and these emissions would be limited by standard BMPs and compliance with regional and state emissions regulations. Long term, cumulative emissions from the proposed project and the Contanda Project would result in increased air emissions, including NO2 and DPM. Cumulative GHG emissions from the proposed BHP and Contanda projects would incrementally contribute to global GHG emissions. Many of the proposed emissions mitigations for the BHP Project are also proposed for the Contanda Project, however the latter also proposes additional measures as warranted for the transferring of bulk liquids that may, unlike potash, qualify as hazardous materials. Notably, the Contanda Project includes the installation of a marine vapor control system to control emissions of volatile organic compounds from vapors displaced during vessel loading (as necessitated when transferring oil or hazardous materials). Compliance with the applicable regulations along with implementation of the proposed mitigation measures described in Section B.2.c would reduce cumulative impacts on air quality. For these reasons, while the project will contribute incrementally to cumulative air emissions on the area, no mitigation is required to offset any cumulative impacts.

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b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally describe. There are no known sources of emissions or odor off site that would affect the project construction or project operational air emissions. c. Proposed measures to reduce or control emissions or other impacts to air, if any: Construction Mitigation (All Sites): Construction contractor(s) will be required to comply with Ecology and ORCAA regulations that require anyone generating odors that may unreasonably interfere with any other property owner's use and enjoyment of their property to use recognized good practice and procedures to reduce these odors to a reasonable minimum. Implementation of reasonable precautions during the construction phase and complying with applicable regulations regarding engines, off-site odors, and off-site dust are expected to prevent significant air quality impacts due to construction. The ORCAA permit will require that reasonable and/or appropriate precautions be taken during construction activities to prevent fugitive particulate material from becoming airborne. In accordance with WAC 173-400-040(4)(a), the owner or operator of any emission unit engaging in materials handling, construction, demolition or any other operation that is a source of fugitive emissions shall take reasonable precautions to prevent release of air contaminants from the operation. The Project will employ typical BMPs during construction, including maintenance of emission control equipment on construction vehicles and equipment, maintaining soils to prevent dust, and other typical measures. Operation Mitigation (Project Site): Stationary Sources BHP will obtain and comply with an NOC from ORCAA. Stationary sources such as diesel generators (emergency generators) are subject to ORCAA air quality regulations. ORCAA Regulation 8 (based on WAC 173-400-040) establishes general emission standards that apply to all emission units. The facility is expected to be a minor source and the ORCAA permit will require the project to address potential air impacts (e.g., emissions) from the operation of the facility. The project will use the following methods to control emissions:

• ORCAA requires all new stationary sources to employ BACT requirements for emitted pollutants. • Emergency generators and other on-site engines will meet required emissions control standards. The generators will be NSPS compliant engines that will be maintained and operated in accordance with manufacturer instruction. • Material handling and storage is enclosed and dust control (baghouses and bin vents) will be installed at the transfer points and for the shiploader. Mobile Emission Sources Locomotives Trains delivering potash to the terminal will be operated by third parties, not BHP. However, locomotives will be required to comply with EPA rules (40 CFR Part 1033, 1065, and 1068). Emissions from trains are regulated as mobile sources by the EPA. EPA has a three-part rule to reduce emissions from diesel locomotives (see below). The rule cuts PM emissions from these engines by as much as 90 percent and oxides of nitrogen (NOx) emissions by as much as 80 percent when fully implemented. The standards are based on the application of high-efficiency catalytic after treatment

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technology for freshly manufactured engines built in 2015 and later. EPA standards also apply for existing locomotives when they are remanufactured. Requirements are also in place to reduce idling for new and remanufactured locomotives.

Ocean-going vessels Vessels coming to and from the terminal will be operated by third parties. They will be subject to international and United States standards for emissions, including emissions standards for U.S. vessels (40 CFR Part 80, 89, 94 and 1042) and the International Convention on the Prevention of Pollution from Ships (MARPOL) Annex VI (see also 40 CFR Part 1043).

Particulates Sources Particulates from vessel, vehicle, and train emissions and potentially from potash loading and unloading could enter the Grays Harbor National Wildlife Refuge (GHNWR) depending on weather conditions and emissions source. Potential impacts to the GHNWR will be minimized and mitigated by the overall air quality BMPs that will be employed at the project, using the mitigation measures listed below.

• Compliance with emissions standards and permits, as required and enforced by ORCAA and other agencies, which are designed to protect public welfare, damage to property, transportation hazards, economic values, and personal comfort and well-being from any known or anticipated adverse effects of air pollutants. • Covering conveyors • All train cars carrying potash will be enclosed • Enclosed storage areas on the upland site • Covering product storage areas on vessels • Using site paving to minimize dust disturbance in driveways • Preserving on-site vegetation to the extent practicable • Shiploaders will be repositioned to the various holds while loading to provide controlled and level loading. • Dust will be controlled on site during operations through dust controls (baghouses and bin vents) at each transfer site and the railcar unloading facility. • Conveyor transfers have been designed to minimize vertical drops and direct impact of material at transfer points and will be equipped with skirting systems to minimize spillage and entry/exit curtains to minimize airflow through the transfers. Cumulative Impacts – Mitigation: The analysis conducted considered existing air quality and is therefore an analysis of cumulative impacts. The impacts and mitigation measures discussed above address cumulative air quality issues.

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3. WATER a. Surface 1. Is there any surface water body on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If appropriate, state what stream or river it flows into. Project Site: The Project Site includes approximately 26 acres of Grays Harbor as shown on Sheet 1. The marine terminal, berth, and vessel activities will occur in these areas. Grays Harbor is an estuary for six rivers (Chehalis, Hoquiam, Humptulips, Wishkah, Johns, and Elk) and several smaller creeks and tributaries within the Chehalis River Basin. The harbor is approximately 15 miles long and 13 miles wide. According to Ecology’s Water Quality Atlas mapping tool, water quality issues in Grays Harbor include impairments due to sediment, bacteria, and temperature. However, the harbor is not listed on the State’s Section 303(d) list for polluted waters. Unpublished data from WDFW reported in the Water Quality Atlas indicates that invasive green crab (Carcinus maenas) were documented east of Bowerman Airport in 2000. There are reports of the invasive New Zealand mudsnail (Potamopyrgus antipodarum) in the Chehalis River, however this species has not been documented near the Project Site or mitigation sites. A full discussion of plant and animal species, including invasive species, is provided in Sections 4 (Plants) and 5 (Animals). The Chehalis River Basin drains about 2,170 square miles and includes portions of Lewis and Thurston Counties; limited areas of Pacific, Cowlitz, Mason, Wahkiakum, and Jefferson Counties; and most of Grays Harbor County. Grays Harbor discharges to the Pacific Ocean. The in-water portion of the Project Site consists of intertidal and subtidal areas. The intertidal area consists of those areas between the OHWM elevation and the mean lower low water (MLLW) elevation that are subject to regular tidal action. The shoreline of Grays Harbor is armored with riprap along the OHWM elevation. Below this elevation, there is a relatively wide, shallow intertidal mudflat that extends for approximately 700 feet. The Washington State Coastal Atlas Map identifies this shoreline as a patchy salt marsh fringe (Ecology 2017). Most of this area is unvegetated with the exception of sporadic macroalgae, such as leafy green sea lettuce (Ulva lactuca) and rockweed (Fucus distichus) and patchily distributed non-native Japanese eelgrass (Zostera japonica) in the upper intertidal zone. (Note that no native eelgrass (Zostera marina) was found at the Project Site during the eelgrass delineation [WSP, July 2019]). Portions of the shoreline intertidal zone (outside of the Project Site) have small patches of established salt marsh vegetation, primarily seaside arrowgrass (Triglochin maritima) and pickleweed (Salicornia virginica). Intertidal habitat also occurs in the northwestern corner of the site, associated with the tidal channel that comprises Wetland C (see below). This channel is hydraulically connected to the tidal waters of Grays Harbor to the west of the Project Site via a culvert under Paulson Road. The portion of intertidal habitat that is present on the site is limited to the channel itself and its associated banks. The channel is deeply incised, and the upper terraces adjacent to the channel are not subject to tidal inundation. Vegetation in and adjacent to the channel consists primarily of reed canarygrass (Phalaris arundinacea), which is an invasive species. There is extensive intertidal salt marsh and mudflat habitat associated with the GHNWR located to the west of the Project Site. The subtidal area waterward of the MLLW elevation at the site transitions rapidly to the deep-water portions of the existing Grays Harbor Navigation Channel and the berth associated with the existing Terminal 3 dock. The USACE regularly dredges the navigation channel and turning basin to maintain a

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bottom depth of -38 feet MLLW. The Port of Grays Harbor maintains the adjacent Berth 3 to -41 feet MLLW (plus 2 feet of allowable overdredge). A Wetland and Waterbody Delineation and Assessment was completed at the Project Site (BergerABAM, June 2018), and this delineation report was updated in 2019 to reflect updates to the Wetland Rating for Wetland A (WSP 2019). The results of this wetland delineation identified the presence of three wetlands and several ditches at the Project Site (Sheet 17). A brief description of the wetlands and their characteristics is provided below. Please see the Project Site delineation and assessment report for complete details and wetland rating forms (WSP 2019).

• Wetland A is an approximately 61.90-acre, palustrine forested Category III wetland that covers the western portion of the study area. Approximately 37.20 acres of Wetland A is located within the Project Site, and approximately 24.70 acres extend off the Project Site to the east. Wetland A has been extensively modified over the course of the past 50 years through placement of fill material, ditching, and construction of upland berms. While the area in which Wetland A is located was once in the historic tideflats of Grays Harbor, the existing wetland has formed on top of dredged sands and other fill material. • Wetland B is an approximately 4.89-acre, palustrine emergent and palustrine scrub-shrub Category III wetland that is located in the northwest corner of the Project Site. Wetland B is a remnant area that has developed upon fill material and which appears to be maintained by a combination of areas of high groundwater and slowly permeable soils. The central portion of the wetland is composed of depressional areas that pond and drain to a network of ditches around the periphery of the wetland. Wetland B is adjacent to, and hydrologically associated with, Wetland C (described below) but is hydrologically distinct from Wetland C in that it is not tidally influenced. • Wetland C is an approximately 0.39-acre Category II wetland located in the northwestern corner of the Project Site. This wetland consists of two ditches that converge at a culvert near the intersection of Paulson Road and West Emerson Avenue. The culvert connects Wetland C to the GHNWR to the west. Wetland C’s hydrology is tidally influenced because of this hydrologic connection to the mudflats and salt marsh to the west. Vegetation is dominated by reed canarygrass (P. arundinacea), though cattail (Typha spp.) and willow (Salix spp.) were also noted during the site investigation. Over the course of the past 30 years, a network of stormwater ditches and treatment facilities have been excavated into the filled uplands at the site for the purpose of treating and/or conveying stormwater in association with these NPDES permits, and some of these have developed wetland characteristics. The Port and the current operator of the site continue to maintain these ditches for the purposes of stormwater treatment, conveyance, and drainage. A total of approximately 4.65 acres of ditch features were identified at the site. These ditches exhibit wetland characteristics (soils, vegetation, and hydrology), and are similar in nature and structure. Mitigation Sites: IDD#1 Site The site was historically an intertidal and salt marsh habitat contiguous with the waters of Grays Harbor and the Hoquiam River. The site was surrounding by levees and developed with various activities in the past. There is an existing culvert and tide gate on the eastern boundary of the site that occasionally allows water to enter the site and back up into a narrow ditch. Portions of the site along the southern boundary are also likely influenced to some degree by salt spray during storm events. Existing wetlands at the site are largely supported by seasonal precipitation, which allows groundwater to perch near the existing ground surface during the early growing season.

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A Wetland and Waterbody Delineation and Assessment for the IDD#1 site was completed in July 2018 (BergerABAM July 2018). Four wetlands were identified during the delineation, as well as the OHWM/MHHW of Grays Harbor and of associated ditches along the perimeter of the site. These features are summarized briefly below. Please see the IDD#1 site wetland delineation and assessment report for complete details and wetland rating forms (BergerABAM July 2018).

• Wetland A (IDD#1) is an approximately 25.2-acre, Category III palustrine emergent wetland that is located in the central portion of the IDD#1 site. This wetland has formed on dredged fill material and is likely supported by precipitation and seasonally high groundwater during the early growing season. • Wetland B (IDD#1) is an approximately 0.14-acre, Category IV palustrine wetland that is located in the northwest corner of the IDD#1 site. Wetland B is an area that has developed upon fill material and which appears to be maintained by a combination of areas of high groundwater and slowly permeable soils. Wetland B is a slope wetland that drains to the excavated ditch along the northwestern boundary of the site, part of which forms northern boundary of Wetland B. • Wetland C (IDD#1) is an approximately 0.16-acre, Category IV scrub-shrub wetland located in the northwestern corner of the study site. Wetland C is located in a slight topographic depression within an area that has developed upon fill material. • Wetland D (IDD#1) is an approximately 0.01-acre, Category IV emergent wetland located adjacent to the western border of the site. Wetland D is in a slight topographic depression within an area that has developed upon fill material. • The results of the OHWM delineation at the IDD#1 site indicate that the biological OHWM along the shoreline is relatively close to the 8.47 feet (NAVD88) MHHW elevation established by NOAA at the site. Terminal 4 Work will take place in shallow intertidal area of Grays Harbor adjacent to Terminal 4. The site is located in the Grays Harbor Estuary at the mouth of the Chehalis River as shown on Sheet 1. There is no other surface water located on or near the site. Hoquiam River Preservation Site The site consists of an approximately 71.5-acre parcel of high quality floodplain wetlands and forested buffer on the Hoquiam River, approximately two miles north of the mouth of the River. The site consists of 59.9 acres of Category 1 floodplain wetland adjacent to the Hoquiam River, and an adjacent forested hill slope. The wetlands at the site consist of Category I palustrine riverine forest, scrub-shrub and emergent wetlands. The wetlands occupy a large peninsula of level or slightly undulating floodplain abutting both west-oriented and south-oriented oxbows of the main stem Hoquiam River. The site is within the freshwater tidal fringe of the river. The linear distance of the shoreline abutting the Hoquiam River is over one mile and the condition of the shoreline is relatively undisturbed with ample over- hanging native vegetation over a mostly vertical river bank. An indication of its historic condition are the remnant piles just off-shore used for industrial log raft storage. The wetland hydrology is primarily driven by a series of freshwater tidal channels which are interconnected through the site. These drain to the largest channel that empties into the Hoquiam River in the south- eastern quadrant of the site. At the exit point, this channel is over 15-feet wide and 10-feet deep. The meandering network of channels that connect to this larger channel have generally unvegetated silt-covered channel bottoms indicating they are regularly inundated by high tides and river flows. Several remnant linear ditches also connect to these channels, and remnant fence posts indicate the site was used for agricultural activity in the past. A

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remnant footbridge of relatively sturdy construction is located across this largest channel, likely used for fishing access and hunters. Besides the natural moderate-sloping uplands bordering the eastern side of the wetlands, one 2-acre upland area is located in the southeast quadrant and appears to have been created as a future landing area. The area appears to have been filled in the 1970s or 1980s, and then abandoned, and has since become dominated with a uniform stand of red alder. The forested wetlands are dominated by mature Sitka spruce and red alder with a variety of shrub and herb layer species occupying a multi-strata understory. The average diameter (measured in inches at breast height, or DBH) of the trees exceeds 21 inches, therefore the stand qualifies as a WDFW priority habitat-mature forest according to the Wetland Rating System for Western Washington (Hruby 2014). Scrub-shrub areas are dominated by Western crabapple (Malus fusca) and Hooker’s willow (Salix hookeriana). Emergent areas are dominated by broadleaf cattail (Typha latifolia), skunk cabbage (Symplocarpus foetidus), water parsley (Oenanthe sarmentosa), Pacific silverweed (Argentina pacifica) and slough sedge (Carex obnupta). Invasive species presence is limited to Himalayan blackberry (Rubus armeniacus), which is only sparsely present at the site. Hydrologically, the wetlands consist of seasonally and occasionally flooded or inundated regimes along with areas that are only saturated. Tidal inundation occurs regularly within the channels that transect the site and within the remnant ditches. During high river flows of the Hoquiam River, the majority of the wetlands on-site are likely to experience direct flooding or inundation caused by backwater when the channels are at bank-full. There are multiple small depressions and undulations in the topography that have the potential to trap sediment during high river flows. The site is located along the shore of the Hoquiam River as shown on Sheet 1. No ground disturbing work is proposed at the Hoquiam River Preservation Site. 2. Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If yes, please describe and attach available plans. The project involves work over, in, and within 200 feet of the above referenced waterbodies. The work at each site is described below.

Project Site: Dredging The proposed depth for the new berth is -43 feet MLLW plus 2 feet of allowable overdredge. The existing depths in the new berth area currently range from approximately -32 feet MLLW to -44 feet MLLW. The dredge prism cut will range in thickness from approximately 1 foot to 13 feet below mudline. Approximately 110,000 cubic yards of material will be dredged from an area approximately 7.49 acres in size to provide sufficient draft for vessels within the proposed berth area. The proposed berth will be approximately 4.72 acres in size. Characterization of the proposed dredged material has been completed in accordance with the USACE DMMP to determine suitability for in-water disposal at an authorized placement site (i.e., the Washington State DNR Point Chehalis or South Jetty disposal sites). All of the proposed dredge material was found suitable by the DMMP as stated in the February 19, 2019 Suitability Determination for the project. The proposed action also includes maintenance dredging activities for a period of 10 years (based on the duration of the USACE Section 10/404 permit for the project, when obtained) within the new berth

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basin. The volumes and frequency of maintenance dredging events will vary based on the rate of sedimentation. Maintenance dredging at the new berth, to -43 feet MLLW (plus 2 feet of overdredge), will likely be required annually for the proposed project based on the requirements at Terminal 3. The maintenance dredging will consist of dredging up to 70,000 cubic yards per event based on the permitted maintenance dredge volume at the Terminal 3 berth and the fact that the new berth will be maintained 2 feet deeper (-43 feet MLLW plus 2 feet of allowable overdredge) than the existing Terminal 3 berth. The maintenance dredging will be completed in the same manner as that used for construction of the berth. Dredging is will be conducted using mechanical methods (clamshell bucket dredging equipment) and disposed at the Point Chehalis or South Jetty disposal sites if judged suitable for open water placement by the DMMP. The maintenance dredge material will require re- characterization 6 years after receiving a suitability determination due to the DMMP ranking the site as “low-moderate.” Activities in Wetlands Work at the Project Site will require work within wetlands, in-water and over-water work, as well as work within 200-feet of the waters described in the surface water section, Section 3(a)(1) above. See Sheet 3 for an overview of the project layout in relation to the OHWM, Sheet 21 for wetland and buffer impacts, and Sheet 22 for aquatic impacts, which includes in- and over-water work.

The project has avoided and minimized impacts to wetlands, wetland buffers, and other environmentally sensitive habitats to the extent practicable (Mitigation Plan, WSP July 2019). The project, as proposed, is the result of a multi-year planning and site evaluation effort.

The layout of the site at the facility has also undergone several iterative modifications in an effort to minimize impacts to wetlands and wetland buffer resources as well as to accommodate design requirements and site constraints as summarized in the project Alternatives Analysis (WSP June 2019; Section 5.2 and 6.0). Wetland impacts that remain after minimizing impacts to the extent practicable will be mitigated by restoring wetlands at the IDD#1 Site, removing piles and over water structures at Terminal 4, and preserving a wetland site at the Hoquiam River Preservation Site. See Section A.11 above and the end of this section below for a description of this compensatory mitigation.

Permanent Direct Wetland Impacts While wetland impacts have been avoided and minimized to the extent practicable, the project will result in permanent direct impacts (fill) to on-site wetlands and ditches. These include impacts associated with the construction of portions of the rail loop, railcar unloading facility, product storage building, conveyors, and stormwater treatment and conveyance facilities.

The layout and configuration of the rail loop is dictated by the required turn radii and length of the unit train that will be used at the site, and it is not possible for the rail loop to completely avoid wetland impacts.6 The project will result in a total of 15.53 acres of direct permanent impacts to wetlands at the Project Site. The project will also result in 2.83 acres of impacts to ditches on the

6 The layout of the storage building and other structures at the site are dictated primarily by the Federal Aviation Administration (FAA) Federal Aviation Regulation (FAR) Title 14: Aeronautics and Space Part 77 - Safe, Efficient Use, and Preservation of the Navigable Airspace (Part 77) height requirements for the approach to Bowerman Field. For this reason, many of the buildings and taller structures have been located in the northern portion of the site, where impacts to wetlands are unavoidable.

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Project Site. This represents a net total of 18.36 acres of permanent direct impact to wetlands and ditches. As detailed in this section, all impacts will be offset to obtain no-net-loss.

Permanent Indirect Wetland Impacts The project will also result in indirect impacts to wetlands, which will result from further fragmentation of the existing wetland network at the site and the associated reduction in buffer for those wetland areas that the project has avoided. Indirect wetland impacts will not result in a net loss of wetland acreage but may potentially reduce wetland function. The project will result in a total of 21.56 acres of permanent indirect impacts to wetlands at the Project Site. Ditches at the site consist of artificial structures excavated into upland fill material at the site and provide limited function, and as such will not be indirectly affected.

Activities in Wetland Buffers The City’s Shoreline Master Program establishes protective buffers for all regulated activities conducted adjacent to regulated wetlands. Base buffer widths are established based on the total point score from the wetland rating form, and the intensity of the proposed land use. Because the proposed project represents a high-intensity land use, Wetlands A, B, and C all have a 150-foot base buffer width. Ditches are exempt from regulation as wetlands under the Shoreline Master Program and as such they do not have a regulatory buffer.

Per the Shoreline Master Program, base buffer widths only apply to functioning buffers. The Shoreline Master Program clarifies that protective buffers do not include those areas functionally and effectively disconnected from the wetland, such as by a road or other structures. Most of the upland portion of the Project Site is a developed industrial site consisting of paved and/or compacted fill surfaces and/or roadways. Therefore, the functional portion of the buffers extend only from the wetland boundary to the toe of the existing fill or development that establishes the upland portion of site. The project will impact approximately 12.27 acres of existing wetland buffer at the Project Site.

Table 4 summarizes the wetland and wetland buffer impacts that would occur from the project.

Table 4.Wetland and Wetland Buffer Impacts Impact Type Identifier Wetland Rating Impact (acres) Wetland A III 13.09 Wetland B III 2.08 Permanent/Direct (Wetlands) Wetland C II 0.12 IDD#1-A III 0.24 Wetland Subtotal 15.53 Permanent/Direct (Ditches) Ditches N/A 2.83 Permanent Direct Impact Totals 18.36 Wetland A III 19.82 Permanent/Indirect Wetlands) Wetland B III 1.70 Wetland C II 0.04 Permanent Indirect Impact Totals 21.56 Temporary Wetland Impacts 25.09 Wetland Buffer Impacts 12.27

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Activities in the Shoreline Buffer The City’s Shoreline Master Program also establishes protective buffers along shorelines to retain areas of native vegetation and to allow habitat connectivity. The buffer for Type S waters of the state (including Grays Harbor) are established in Table 4-1 of the Shoreline Master Program based on shoreline environmental designation and the water dependency of a proposed land use. A functional shoreline buffer is present in the northwestern corner of the site, adjacent to the tidal portion of Wetland C. This buffer extends into the site to the south and east a maximum distance of 150 feet. Impacts to approximately 2.68 acres of shoreline buffer will result from the construction of rail improvements. Aquatic Impacts (in-water and overwater) Potential in-water and over-water impacts are associated with the construction of the shiploader facility, conveyance, and dredging needed to accommodate the ships at berth. The primary impacts associated with dredging in estuarine waters are those temporary effects associated with construction, including the potential for entrainment, temporarily increased turbidity, direct injury, and disturbance associated with construction noise. Long-term effects of dredging include the potential for effects associated with disposal of contaminated materials and changes in habitat characteristics, such as a conversion from intertidal to subtidal habitats (Nightingale and Simenstad 2001). Conversion of approximately 18,770 square feet (0.43 acre) of intertidal habitat to subtidal habitat will represent a permanent conversion from one habitat type to another. It has the potential to affect primary productivity by reducing the degree of light transmission to the benthic substrate. This has the potential to affect the specific plant and animal assemblages that can occur in that location and reduces the ability of that area to provide habitat for species that rely on intertidal conditions. This habitat conversion represents an impact to intertidal habitat function but does not represent a complete loss of habitat. The maximum extent of deepening within the intertidal portion of the dredge prism would be 4 feet. Subtidal habitats will continue to provide aquatic habitat function at the Project Site, comparable to those provided by existing subtidal habitats at the site. Dredging will be limited to the use of clamshell methods for all dredging associated with the project, to minimize impacts to the aquatic community, and in particular Dungeness crab. Tables 5 and 6 below provide a full accounting of all the aquatic impacts associated with the project. The impacts to, and proposed compensatory mitigation for, aquatic habitats are discussed in detail in Section 4 Plants (4b and 4d) and Section 5 Animals (5d) below.

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Table 5. Aquatic Impacts Area of Overwater Number of Piles Coverage (sf) Benthic Terminal Component Dimensions (ft.) Impact 24- 48-inch (sf) Solid Grated inch Steel Steel Permanent Mooring Dolphins (4) W: 21.32’ L: 32.80’ 2,799 -- 24 - 302 Berthing Dolphins (2) W: 22.96’ L: 26.24’ 1,206 -- 16 - 201 Quadrant Supports (14) W: 5.24’ L: 13.12’ 975 -- 28 - 352 Transfer Tower Platform W: 57.41’ L: 50.85’ 2,920 -- 9 - 113 (1) Support Platforms (10) W: 26.24’ L: 32.80’ 6,889 -- 48 - 604 Service Platform (1) W: 41.01’ L: 62.33’ 2,556 -- 12 - 151 1 at: 29.52’ x 42.65’ Pivot Supports (2) 3,584 -- 12 - 151 1 at: 39.37’ x 59.05’ Access Support Platform W:32.80’ L: 39.37’ 1,292 -- 6 - 75 (1) Variable Access Trestle Spans W: 14.75’ to 16.00’ 25,893 -- 4 - 50 (14) L: 97.17’ to 133.92’ Variable Walkways (20) W: 3.25 to 4.92 -- 4,279 - - - L: 28.24’ to 142.71’ Contingency Piles (40) N/A -- -- 40 - 503 Total Permanent 48,114 4,279 199 0 2,502 Temporary Temporary Piles (48) N/A -- -- - 48 151 Total Temporary -- -- - 48 151

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Table 6. Aquatic Impacts by Tidal Zone Area of Overwater Piles Dredging Coverage (sf) Habitat Zone # 48- # 24-inch Benthic Dredge Prism Solid Grated inch Steel Impact (sf) (sf) Steel Permanent Intertidal (above extreme lower low 35,360 0 81 0 1,020 18,770 water [ELLW]) Subtidal (below 12,754 4,279 118 0 1,482 0 ELLW) Total Permanent 48,114 4,279 199 0 2,502 18,770 Temporary Intertidal (above 0 0 0 * * 0 ELLW) Subtidal (below 0 0 0 * * 307,494 ELLW) Total Temporary 0 0 0 48 151 307,494 * Specific locations of temporary piles are not known. Temporary piles will be located somewhere within the established project footprint, and within the bounds of the completed eelgrass survey. The project will be designed to comply with all federal, state, and local regulations, controlling potential risks to water resources through project planning, design, and the application of required BMPs and established in-water work windows. See below. Mitigation Sites: IDD#1 Site Work at the IDD#1 mitigation site will require work within wetlands, in-water and over-water work, as well as work within 200-feet of the waters described in the surface water section, Section 3(a)(1) above. Sheet 16 shows the proposed activities at the IDD#1 site in relation to the delineated wetlands. Permanent Direct Wetland Impacts The project will result in a total of 0.24 acres of direct permanent impacts to wetlands at the IDD#1 site, which will occur as a result of the construction of the compensatory mitigation activities. These unavoidable permanent impacts are included in the mitigation accounting. The wetland impacts are the result of the re-establishment of a berm at the +16.0 foot elevation to match the elevation of the existing berm that currently surrounds the site. The berm crosses Wetland A at its narrowest point to minimize the extent of wetland impact.

Temporary Wetland Impacts The direct temporary wetland impacts on 25.09 acres will result from the construction of the compensatory mitigation site. Portions of the existing wetlands on the IDD#1 site will be graded and recontoured to establish the finished grades within the mitigation site. Existing vegetation, both native and invasive, will be removed during this process, and soils will be temporarily disturbed. These areas will be planted with native vegetation consistent with the mitigation plan, and will be restored to a more highly functioning wetland condition. The minor temporary loss of wetland function will be offset by the increased function.

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Terminal 4 The project includes the removal of approximately 1,368 piles from nearshore waters of Grays Harbor in the vicinity of the Port of Grays Harbor’s Terminal 4 near the mouth of the Chehalis River. These piles are estimated to range between 12 and 14 inches in diameter at the mudline. Removal of these piles will restore approximately 1,464 square feet of benthic habitat within an area approximately 4.35 acres in size. In addition, the project also includes the removal of a derelict concrete overwater structure that is associated with one of the groups of piles. Removal of the structure will restore an area of approximately 2,147 square feet of nearshore habitats. Pile removal activities conducted as part of the aquatic habitat mitigation activities will be conducted by either land-based or barge-mounted equipment or a combination thereof. All pile removal will occur either by vibratory extraction or by direct pulling. Demolition and removal of the overwater structure would most likely be conducted via barge-operated equipment, and all creosote-treated material, pile stubs, and associated sediments (if any) will be disposed of by the contractor in a landfill approved to accept those types of materials. Hoquiam River Preservation Site No ground disturbing work over, in, or adjacent to surface water is proposed at this site. Instead, the preservation of the Hoquiam River Preservation Site will prevent impacts likely to occur but for the preservation. The wetlands at the site are under a high level of imminent threat of development, as described in the Mitigation Plan. These include threats from timber harvest, industrial development, residential development, agriculture and hobby farming, and high-intensity recreation. Preservation of the wetlands and uplands at the Hoquiam River Preservation Site, protected by a perpetual conservation covenant, will protect these wetlands from a direct and present development threat, thereby preserving the high level of function provided by these wetlands in perpetuity, and this preservation of wetland function will provide high-quality, out-of-kind mitigation for indirect wetland impacts to wetland function at the Project Site. Cumulative Impacts: The proposed project would contribute incrementally to the cumulative amount of work done in, over, or near water in the project vicinity. Current and reasonably foreseeable projects conducted in and adjacent to waters of inner Grays Harbor, including the Contanda Project, the North Shore Levee Project, and maintenance dredging activities conducted by the USACE, the Port, and others, all have the potential to affect water resources. The Contanda Project will increase work near water but will not impact any wetlands or intertidal habitats as none are present upland and they are not proposing new in-water infrastructure. The North Shore Levee may require in-water work within the Chehalis, Hoquiam, or Wishkah Rivers, and could result in short-term water quality impacts during construction. Current and future maintenance dredging activities within Grays Harbor temporarily disturbs sediments at dredging location and placement sites. Each of these projects contributes incremental impacts to water resources. The proposed project includes compensatory mitigation for impacts to water resources that have been sized and designed to achieve no net loss in ecological function. Similarly, current and future projects, including those discussed above, will be required to secure permits for any impacts to water resources, implement a mitigation sequencing process that would result in impacts being avoided and minimized to the extent practicable, and provide compensatory mitigation to achieve the standards for no net loss of function. For these reasons, while the project will contribute incrementally to the cumulative amount of work done in, over, or near water within Grays Harbor, no mitigation is required to offset any cumulative impacts.

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3. Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill material. Project Site: Construction As described in the Earth section of this checklist, B(1)(e), fill, subballast, and ballast will be needed to prepare the building sites, rail footprint, and other site components. Approximately 150,000 cubic yards will be removed from wetlands. The amount of fill within wetlands is conservatively estimated to be approximately 140,000 cubic yards of fill. The area of wetland in which fill material will be placed is approximately 15.53 acres, as described in Section 3(a)(2) above. Fill materials will be commercially produced soil, ballast, subballast, etc. Crushed rock subballast and ballast will be imported from an approved source and will provide a structural base for track installation. Dredging Approximately 110,000 cubic yards of material will be dredged from an area approximately 7.49 acres in size to provide sufficient draft for vessels. The proposed berth and dredging will be located west of and adjacent to the existing Terminal 3 dock as shown on Sheets 11 and 12. The new berth will align with and abut the Terminal 3 berth and will extend to the navigation channel. The proposed depth for the new berth is -43 feet MLLW plus 2 feet of allowable overdredge. The existing depths in the new berth area currently range from approximately -32 feet MLLW to -44 feet MLLW. The dredge prism cut will range from approximately 1 foot to 13 feet below mudline. The previously submitted berth design included a gabion mat structure on the north slope of the proposed dredge prism. The gabion mat was eliminated from the berth design to minimize aquatic impacts after further evaluation of engineering design and adjacent Terminal 3 berth conditions. Characterization of the proposed dredged material has been completed in accordance with the USACE DMMP to determine suitability for in-water disposal at an authorized placement site (e.g., the DNR Point Chehalis or South Jetty disposal sites). All of the proposed dredged material is suitable for open water disposal based on the characterization results (DMMP suitability determination dated February 19, 2019). The volumes and frequency of maintenance dredging events will vary based on the rate of sedimentation. Maintenance dredging of up to 70,000 cubic yards will likely be required annually. The maintenance dredging will be completed in the same manner as that used for construction of the berth. Dredging is expected to be conducted using mechanical methods (clamshell bucket) and disposed at the Point Chehalis or South Jetty disposal sites if judged suitable for open water placement by the DMMP as anticipated based on the 2018 characterization results. The proposed dredging (construction and maintenance) has the potential to result in short-term effects, including temporary water quality impacts such as temporarily and localized elevated turbidity levels. The proposed project has adopted a list of impact minimization measures and BMPs to reduce, eliminate, or minimize the effects of the project on water quality (as represented by turbidity levels). Operation The maintenance dredging (described above) would be the only fill/dredge activity to take place during operation of the facility.

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Mitigation Sites: Construction In order to restore wetlands at IDD#1 to compensate for impacts to wetlands on the Project Site, estimates calculated based on the grading plan developed for the Mitigation Plan indicate that approximately 205,087 cubic yards of material will be removed from the IDD#1 site. Approximately 131,180 cubic yards of this material would be excavated from existing wetlands at the site. Excavated material, if suitable, may be reused at the IDD#1 site, Terminal 3 Project Site, or barged or trucked to a permitted upland landfill facility. The construction of the berm within the enhanced buffer will require approximately 5,192 cubic yards of material, and approximately 667 cubic yards of this material would be placed within existing wetlands at the site. Operation No fill or dredge activities will take place once construction of the mitigation at the IDD#1 site is complete. No dredge or fill activities are proposed at Terminal 4 or the Hoquiam River Site. Cumulative Impacts: The initial dredging activity and ongoing maintenance dredging associated with the proposed project will contribute incrementally to the existing dredging activities that occur in Grays Harbor (dredging of the navigation channel and turning basin by the USACE, maintenance dredging of existing berths and the Westport Marina by the Port, and maintenance dredging activities at private facilities). These ongoing activities temporarily disturb sediments at dredging locations and placement sites, and contribute incremental impacts to water resources. These events would occur with or without the project and the project is not anticipated to increase the need for maintenance dredging of the channel. The project will increase the number of days of dredging per year, and the annual volume of material dredged in the harbor. The USACE estimates annual maintenance dredging volumes for the navigation channel and existing berths of 1.7 million cubic yards. No additional dredging is proposed for the Contanda Project, and no dredging is proposed for the North Shore Levee Project. The annual maintenance dredging associated with the proposed project (approximately 70,000 cubic yards) would represent an increase of approximately 4 percent over the existing baseline condition. The proposed project has avoided and minimized impacts associated with dredging, and proposed compensatory mitigation to achieve no net loss of aquatic function. Current dredging projects have been similarly required to secure permits for these activities, and to avoid and minimize impacts to the extent practicable, and provide compensatory mitigation to achieve the standards for no net loss of function. For these reasons, while the project will contribute incrementally to the cumulative amount of dredging activity conducted in Grays Harbor, no additional mitigation is required to offset any cumulative impacts. 4. Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if known. No surface water will be withdrawn or diverted for the project. The IDD#1 site will result in the construction of surface water channels where there are not currently any. Water that will fill these channels will not be used or diverted for purposes other than filling those channels to accomplish the IDD#1 compensatory wetland mitigation objectives. 5. Does the proposal lie within a 100-year flood plain? If so, note location on the site plan. While most of the project would occur outside the 100-year floodplain, portions of the work at the Project Site and at the in-water area at Terminal 4 are within the floodplain and floodway. The work at IDD#1 Site is not within the 100-year floodplain. The Hoquiam River Preservation Site is in the floodplain

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and will be protected from future development by the proposal. Further details on the floodplain location and related proposed work are presented below by site. Project Site: The currently published FEMA FIRM (Panels 53027C0881D and 53027C0882D effective February 3, 2017) identifies the portions of the Project Site that are currently within the 100-year floodplain. The 100-year floodplain of Grays Harbor along the shoreline of the Project Site does not extend beyond the riprap- armored portion of the shoreline. However, the 100-year floodplain of the Hoquiam River does extend into the north and northeastern portions of the site, primarily into the northern portion of Wetland A. The floodplain associated with the Hoquiam River is a result of backwater flooding from Grays Harbor (Karpack 2017). While most of the project would occur outside the 100-year floodplain, portions of the proposed marine terminal, as well as portions of the rail loop and storage building, will be located within the 100-year floodplain (Sheet 19). The rail loop and building areas will be filled and result in the area being elevated above the 100-year and 500-year floodplain. The highest water levels are associated with the coastal base flood elevation and any floodplain fill will not affect flood levels within the remaining portions of the floodplain. The only fill that will be placed in floodplains is that required for the rail foundations in the north and east portions of the rail loop, small portions of the product storage building, and some conveyor foundations. The project will be required to obtain a floodplain permit from the City prior to construction approval. Floodplain permits are required for projects built within identified floodplains to identify any needed mitigation to minimize flooding hazards. The floodplain permit will require documentation that flood hazards can be avoided or appropriately mitigated. BHP will submit a complete floodplain analysis for the Project Site (documenting consistency with the maximum 1-foot net rise standard) in the future when BHP applies for the required floodplain permit. The project will be required to comply with the City floodplain requirements (HMC 11.16). City requirements specify that buildings within the 100-year floodplain must be elevated 3 feet above the flood elevation or flood proofed. In addition, any fill cannot result in more than a 1-foot rise in flood levels in the remaining portion of the floodplain. Preliminary floodplain analysis indicates that the portions of the facility located within the 100 and 500 year flood zones can be elevated above floodplain level while still maintaining clearance under the FAA regulated air surfaces. A Site Flooding Assessment and Sea Rise Analysis (Amec Foster Wheeler February 2018) identified the elevation at which the project’s structures located within the flood zone (storage building) will be designed to bring the floor elevation to a level to accommodate the 500 year flood level plus sea level rise. The City of Aberdeen is in the process of developing the North Shore Levee Project to the east of the Hoquiam River. This project will protect portions of the City from flooding. This project will effectively remove portions of the Wishkah and Hoquiam River floodplains. Studies completed for this project indicated that there will be no increase in flood levels in the remaining portions of the floodplains as a result of the levee project. The proposed facility is not expected to result in changes to flood storage, thus there are no cumulative impacts to flood storage associated with the project and the proposed North Shore Levee project. The proposed project would not would not result in a change to flood elevation. The Contanda Project will not require work within a floodplain. Studies completed for the North Shore Levee project indicated that there will be no increase in flood levels in the remaining portions of the floodplains as a result of the levee project. The proposed mitigation actions at the IDD#1 Site, including excavation of tidal channels and rehabilitation of salt marsh habitats, will return approximately 37.32 acres to elevations below the

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existing 100-year floodplain elevation. For these reasons, the proposed project would not result in cumulative impacts to floodplain function A Site Flooding Assessment has been prepared for the Project Site (Amec Foster Wheeler July 2019), which documents the current flood conditions and flood hazards at the site and assesses potential changes in flood-hazard surface elevations due to anticipated sea level rise. The study concluded that the proposed facility will not experience a material rise in water levels because of flooding (significantly less than 1 foot). Additionally, BHP evaluated the site for potential flooding mitigation needs (Ausenco January 2018) and found that the proposed elevation of the product storage building and location of the railcar unloading facility are above 500-year-plus climate-change base flood elevation. The only structure potentially impacted by flooding is the electrical room proposed at the site, which will be raised so that the floor level is approximately 7.9 feet above grade to mitigate for potential flood impacts. Mitigation Sites: IDD#1 Site The currently published FEMA FIRM (Panel 53027C0882D effective February 3, 2017) identifies the site as outside of the 100-year floodplain. The mitigation project will lower the height of the existing levee surrounding the site (from approximately +16 feet NAVD88 to approximately +13 feet NAVD88, and will also create an opening in the levee at each end of the site to allow tidal flow into the site. Terminal 4 The proposed pile and overwater structure removal will all take place in/over the floodway. The adjacent upland area is not identified as a frequently flooded area by FEMA (Panel 53207C0904D, effective February 3, 2017). Hoquiam River Preservation Site Portions of the site are located in the 100-year floodplain (Panels 53027C0669D and 53027C0882D, effective February 3, 2017). The proposed project would protect these areas at this site by prohibiting development. 6. Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge. No intentional discharge of waste materials to surface waters is expected at the Project Site, IDD#1 site, or Terminal 4 during construction or operations. Stormwater will be managed and treated on site in bioretention swales and stormwater detention pond prior to discharging the stormwater through existing outfalls at the site. See Section B.3.c.2 for more information regarding the potential for accidental discharges of potash to surface waters and mitigation measures proposed to reduce or eliminate the associated impacts below the level of significance. b. Ground: 1. Will groundwater be withdrawn from a well for drinking water or other purposes? If so, give a general description of the well, proposed uses and approximate quantities withdrawn from the well?

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Will water be discharged to groundwater? Give general description, purpose, and approximate quantities if known. Neither the Project Site nor the mitigation sites are located in a drinking water wellhead protection area (the area where groundwater flows to a water supply well). No impacts to groundwater are anticipated as a result of the project. Construction: Project Site Groundwater will be withdrawn during construction dewatering for excavation of the railcar unloading facility, but the withdrawal will not be from a well. The dewatering water will be removed from the excavation and stored on site in baker tanks. The water will be tested to determine whether contaminants are present and treated and/or disposed of consistent with regulatory requirements to the stormwater system, sanitary sewer system, or off-site disposal at an approved facility. Mitigation Sites No groundwater will be withdrawn during construction (or following construction) at the mitigation sites. Operations: No groundwater withdrawals from a well or otherwise are proposed for the operations phase of the project. 2. Describe waste material that will be discharged into the ground from septic tanks or other sources, if any (for example: Domestic sewage; industrial, containing the following chemicals...; agricultural; etc.). Describe the general size of the system, the number of such systems, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve. Construction: “Waste material” per Ecology guidance refers to “chemicals, sediments, agricultural (pesticides, herbicides, and fertilizer) runoff, wash water, logging slash, log booming or storage debris, treated wood pilings, oil or other fuels from equipment used for construction and/or operational activities.” No waste material will be discharged to the ground during construction of the project. Operation: Minimal domestic wastewater is expected to be produced during project operations and should mainly be associated with restroom operations at the facility. Once constructed, the facility anticipates employing approximately 40 to 50 people in fulltime and casual positions. Domestic sewage will be discharged to the City of Hoquiam’s sewer system. No animals will be housed at the site. c. Water Runoff (including stormwater): 1. Describe the source of runoff, (including storm water) and method of collection and disposal, if any (include quantities, if known). Where will this water flow? Will this water flow into other waters? If so, describe. Runoff at the Project Site and mitigation sites would consist of stormwater runoff. At the mitigation sites, there would be no impervious surfaces or pollution-generating surfaces to impact water quality. Runoff from the Project Site would be generated by new surfaces and on site equipment, and a stormwater system including ponds will be in place in order to treat and dispose of stormwater runoff in accordance with regulations.

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Project Site: Construction Runoff during construction could occur as a result of weather events (e.g., rain, snow). Runoff will be managed by BMPs, consistent with construction stormwater permit requirements and plans, and discharged off-site through existing outfalls following treatment. Operation Runoff from building roofs and paved areas will be infiltrated in areas where stormwater currently infiltrates that will remain unchanged after construction or collected and discharged via the proposed stormwater system (Sheet 3). The proposed Project Site stormwater facilities have been designed at a location west of the proposed unloading facility improvements so that existing drainage patterns could be preserved to the largest extent possible. Other stormwater facilities will be located along the roads providing maintenance access along conveyor routes. City stormwater regulations (HMC 11.05.620 [2][e]) require that natural hydrographic patterns and water quality be maintained. Currently, surface water and stormwater in the northern and western portions of the site generally flow to the north and west, and outfall through one of two existing culverts in the northwest corner of the site. Surface water and stormwater from the eastern and southern portions of the property generally flow south and east, and outfall to Grays Harbor via one of two existing outfalls. The stormwater treatment ponds have been sited in locations that minimize modification to the natural drainage patterns at the site. The network of stormwater treatment ponds and ditches is designed to disperse runoff according to natural flow patterns without requiring pumping. Stormwater that falls on the majority of the site currently receives no formal treatment. The project will be required to treat stormwater to meet state water quality standards, and water that is outfalling from the site will, therefore, be of similar or improved quality from the water that is currently entering off- site waters. Catch basins will be blocked in the event of a potash spill, and potentially impacted runoff will be contained and discharged to the waste water system or to an approved disposed facility if required.

Stormwater management will be conducted in accordance with state and local regulatory requirements. Stormwater discharge will occur through existing outfall facilities or on-site infiltration. Infiltration will be limited to those areas where stormwater currently infiltrates, which will remain unchanged after the facility is constructed. Stormwater management for the proposed facility will include construction of four larger retention ponds and five small retention ponds located adjacent to the storage feed and direct load conveyors as shown on Sheet 3. In the proposed locations, the network of stormwater treatment ponds and ditches would allow runoff to be collected, treated, detained, and dispersed according to natural flow patterns without requiring pumping of stormwater. Treated stormwater will then be routed to existing points of outfall along the Grays Harbor shoreline and in the northeast corner of the site. No new stormwater outfalls will be constructed. The potash has a low potential to impact the stormwater at the Project Site because the facility is designed to cover and contain the material, minimizing dust and releases of potash, thus minimizing the potential that stormwater at the site would contain potash. Clean-up of any spills of the dry material in the facility would be accomplished with vacuum equipment, and the material would be disposed off- site. The conceptual stormwater plan at the site includes stormwater detention and treatment ponds that will use existing culverts for discharge of stormwater at the site. The ponds were designed so that their containment capacity allows for peak flow rates and durations to predevelopment conditions for

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the portion of the site that drains to the Bowerman Basin. Should stormwater become contaminated with potash from a spill or release, it cannot be disposed of in the stormwater system. The project will obtain and comply with applicable permits, including an Industrial Stormwater NPDES General Permit, SWPPP, and spill prevention, control, and countermeasures (SPCC) Plan.

Mitigation Sites: IDD#1 Site A portion of the existing berm that surrounds the IDD#1 site would be removed as part of the wetland and aquatic habitat enhancements, which will result in a reduction in the net quantity of impervious surface at the site, and a reduction in the amount of runoff from these surfaces. No new impervious surfaces are proposed at the IDD#1 site. The proposed public access enhancements at the IDD#1 site include a pervious pedestrian trail. The project will obtain and comply with applicable permits, including a Construction Stormwater NPDES General Permit, SWPPP, and SPCC Plan.

Terminal 4 The proposed pile and structure removals at Terminal 4 will not result in any change in stormwater runoff. The project will obtain and comply with applicable permits, including a Construction Stormwater NPDES General Permit, SWPPP, and SPCC Plan.

Hoquiam River Site: The Hoquiam River Preservation Site will not result in any change in stormwater runoff. Cumulative Impacts: The proposed project would contribute incrementally to the cumulative amount of stormwater runoff generated within inner Grays Harbor. Current and reasonably foreseeable projects conducted in and adjacent to waters of inner Grays Harbor, including the Contanda Project also has the potential to generate additional stormwater runoff. The Contanda Project would result in an increase in impervious surface area by 1 acre. Additional runoff at the Contanda Project site would flow into the Port’s existing stormwater system similar to existing conditions. The Contanda Project will be required to address stormwater runoff in compliance with state standards. These projects would not be constructed simultaneously, and would be required to comply with federal and state regulations, BMPs, required permit conditions, and recommended mitigation. These measures would adequately address impacts and minimize the potential for the proposed project to result in cumulative impacts related to stormwater runoff. 2. Could waste materials enter ground or surface waters? If so, generally describe. Construction (All Sites): Potential impacts to water quality from stormwater runoff could occur during construction and, as a result, appropriate mitigation measures have been identified to protect water quality in compliance with city and state standards. Potential in-water impacts are associated with the construction of the shiploader facility, conveyance, and dredging needed to accommodate the ships at berth, in addition to the clearing and grading required to construct structures and construction activities required to provide the proposed mitigation at IDD#1 Site and Terminal 4. Operation (Project Site): There is a low potential that any waste materials will be generated on site during project operations that could enter groundwater or surface water. The site will have a facility-specific SPCC plan and spill kits throughout the site to prevent and minimize spills that may result from day-to-day operations at the

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site. The facility includes a fueling station that will be constructed on a concrete pad within secondary containment appropriate to the size of the station that will prevent spills outside of the containment area. Potash is not considered a hazardous material. The facility is designed to minimize dust and potential releases of potash to the environment through operational controls including covered conveyance, enclosed railcars and storage facilities, the secondary containment wall around the storage building, and dust control at all transfer points. Intentional disposal of potash in the sea is prohibited by the Marine Protection, Research and Sanctuaries Act (Ocean Dumping Act). There is risk that should an incident could occur with a loaded train or a vessel in transit that potash could be spilled and enter ground or surface waters if the spill occurs directly into a waterbody or during rainfall. Potash spills to water would be reported to Ecology because it would be considered a pollutant (when it is not being applied as a crop nutrient) under RCW 90.48.080. 3. Does the proposal alter or otherwise affect drainage patterns in the vicinity of the site? If so, describe. Project Site: The proposed export facility will impact existing drainage patterns through the creation of new structures, increased impervious surfaces, and new activities. The proposed stormwater facilities will control the drainage for the purpose of ensuring that runoff is detained and treated in accordance with County and State requirements for stormwater discharges. Mitigation Sites: IDD#1 Site The proposed mitigation at IDD#1 will affect surface water drainage patterns through the creation of new wetlands, rehabilitation of existing wetlands, and creation of new intertidal channels. As described previously, the entirety of the IDD#1 site consists of former tidelands if Grays Harbor that have been filled with dredged materials. The site has been isolated from its historic tidal influence, and the proposed mitigation actions will restore this former hydrologic and habitat function. Terminal 4 Site The proposed mitigation at Terminal 4 will take place over-water and in-water and will not alter or affect natural drainage patterns. Hoquiam River Preservation Site There will be no ground disturbing work at the Hoquiam River preservation site, and therefore there will be no impact to drainage patterns. Cumulative Impacts: The proposed project would contribute incrementally to changes in surface drainage patterns in the vicinity. Current and reasonably foreseeable projects conducted in and adjacent to waters of inner Grays Harbor, including the Contanda Project and the North Shore Levee Project will also result in modifications of surface drainage patterns. However, as described in the sections above, the proposed project includes compensatory mitigation for impacts to water resources that result in no net loss in ecological function. Similarly, current and future projects, including those discussed above, will be required to secure permits and achieve the standards for no net loss of function. For this reason, while

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the project will contribute incrementally to the cumulative amount of work done in, over, or near water within Grays Harbor, no mitigation is required to offset any cumulative impact. d. Proposed measures to reduce or control surface, ground, runoff water, and drainage pattern impacts, if any: Impact Avoidance and Minimization (Project Design) BHP selected a site within previously disturbed, industrially zoned portions of the inner Grays Harbor. The layout of the upland portion of the facility has undergone several iterative modifications in an effort to accommodate design requirements and site constraints while minimizing impacts to wetlands to the extent practicable. The project design has avoided and minimized impacts to wetlands, buffers, shoreline buffers, aquatic habitats, and other environmentally sensitive habitats to the extent practicable, while still accommodating the necessary features to meet the project purpose and need. Proposed Mitigation The proposed measures to reduce and/or control impacts to surface, ground, runoff water, and drainage pattern impacts are described below. These measures have been grouped as measures to address wetland impacts; floodplain development; stormwater impacts; dredging impacts; construction impacts; and operation. Compensatory Mitigation for Aquatic Habitat Impacts are described in Section 5e. Note that there will be no ground disturbing work at the Hoquiam River preservation site – therefore mitigation is not needed or proposed at that site. Proposed Mitigation for Wetland and Wetland Buffer Impacts BHP’s proposed project includes the following measures to reduce impacts to wetland impacts below the level of significance: As mitigation for impacts to wetlands associated with the project, BHP will create approximately 10.75 acres of wetland and rehabilitate approximately 23.49 acres of existing low quality emergent wetland to high-quality salt marsh at the IDD#1 Site. The IDD#1 site is approximately 45 acres in size and is located on the north shore of Grays Harbor, on the right (west) bank of the Hoquiam River at its mouth. The Puget Sound and Pacific Rail line runs along the northern boundary of the site, and it is bounded to the east by the Hoquiam River, to the south by the waters of Grays Harbor, and on the west by a tidal inlet and shallow drainage. Most of the site surface is flat, though depressions on the surface of the site have formed that have allowed depressional wetland areas to form over time. The IDD#1 site is former tidelands of inner Grays Harbor that were filled with dredge materials in the 1970s and has been zoned for industrial development. The mitigation project will restore tidal hydrology to the site by removing fill and excavating tidal channels to create a mosaic of tidal channels, salt marsh, palustrine emergent wetland, and enhanced scrub-shrub and forested buffer habitat at the site (Sheet 18). The mitigation at IDD#1 includes the creation of approximately 5.59 acres of low salt marsh habitat, approximately 25.27 acres of high salt marsh, and approximately 3.43 acres of palustrine wetland as a transition zone to upland buffers. The salt marsh habitats created at the site are designed to be representative of those historically found in the inner Grays Harbor and are modelled after a reference marsh system in Bowerman Basin on the GHNWR. The mitigation project will also create approximately 5.17 acres of enhanced forested and scrub-shrub wetland buffer at the site by establishing and planting a 110-foot buffer along the northern and western boundaries of the site.

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The project also includes a preservation of an approximately 71.5-acre parcel of high quality floodplain wetlands and forested buffer on the Hoquiam River, approximately two miles north of the mouth of the River (referred to herein as the Hoquiam River Site). This will preserve approximately 59.9 acres of Category I wetlands (consisting of 45 acres of mature forested wetland, 8.9 acres of scrub-shrub wetland, and 6.0 acres of emergent wetlands), along with 3.7 acres of forested uplands and an additional 7.9 acres of forested uplands and wetlands within a 150-foot buffer. A 0.3-acre remnant grove of old growth trees with Western red cedar, Douglas fir and Western hemlock is also located immediately adjacent to the wetland and lies within the area to be preserved. The size and quantity of the proposed wetland and wetland buffer mitigation have been established based on extensive discussion and coordination between agency staff from the USACE, Ecology, WDFW, and the City, conducted between 2017 and 2019. Table 6 documents the quantity of mitigation proposed for the wetland and wetland buffer impacts associated with the project. Ecology has established guidelines for mitigation ratios in Wetland Mitigation in Washington State Part 1: Agency Policies and Guidance (Ecology 2006). This guidance is established on a base assumption that the wetlands created or rehabilitated as compensatory mitigation are of the same Category and provide the same level of function as the impacted wetlands. The guidance specifically allows for reduced ratios in instances where the proposed mitigation actions will provide functions and values that are greater than those provided by the wetland being affected. Direct permanent wetland impacts will be mitigated through a combination of wetland creation and wetland rehabilitation. A total of 10.75 acres of direct wetland impact to Category III wetlands will be mitigated through wetland creation at a ratio of 1:1, with the remaining direct wetland impacts to Category III wetlands being mitigated via wetland rehabilitation at a ratio of 2:1. Impacts to the Category II estuarine ditch (Wetland C) at the Project Site will be mitigated at a ratio of 4:1. Although general agency guidance favors greater ratios, the justification for these ratios is that the mitigation will represent a high-quality wetland creation and rehabilitation project that will restore ecological function to an ecologically important site, and will also preserve a site that would otherwise be developed for industrial use. The mitigation will offset impacts to primarily moderate quality Category III wetlands at the Project Site that are already substantially ditched and/or otherwise fragmented, and which are largely isolated from other adjacent habitats as a result of prior fills and development. By contrast, the compensatory mitigation site will create and rehabilitate existing low-quality Categories III and IV wetlands at the mitigation site into high-quality Category II estuarine wetlands. Estuarine wetlands are high-value systems that the state of Washington, Grays Harbor County, and the City of Hoquiam have prioritized for protection and restoration, as described in greater detail in the Mitigation Plan (WSP 2019). Indirect permanent wetland impacts will be mitigated through a combination of wetland rehabilitation at IDD#1 and wetland preservation at the Hoquiam River site. Wetland rehabilitation will provide mitigation for indirect impact to 13.60 acres of Category III wetlands at a ratio of 1:1, and for indirect impacts to 0.04 acres of Category II estuarine wetland ditch at a ratio of 2:1. Indirect impacts to on-site wetlands will not result in a loss of wetland acreage, and are expected to result in only minor impacts to wetland function. Neither USACE nor Ecology has published formal guidance regarding mitigation ratios for indirect impacts, but both agencies have indicated that a typical approach is half the ratio of that proposed for mitigation for direct impacts. A ratio of 0.5:1 had previously been discussed with the USACE and Ecology as being a typical high-end ratio; however, the mitigation plan has been updated to reflect an updated ratio of 1:1 rehabilitation for indirect impacts. This represents a substantial lift in

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function, as the substantial enhancements to wetland and habitat function that will result from the rehabilitation at IDD#1 will greatly exceed the extent of indirect impacts to wetlands at the Project Site. The remaining indirect impacts to 7.92 acres of Category III wetland will be mitigated via preservation of 59.90 acres of Category I floodplain wetland and associated forested buffer at a ratio of greater than 7:1. This is consistent with the approach to provide mitigation for indirect impacts at a ratio of half of the ratio required for direct impacts. Ecology’s guidance suggests that standard ratios for wetland preservation, when included in combination with other forms of mitigation, range from 10:1 to 20:1 for direct impacts, as determined on a case-by-case basis, depending on the quality of the wetlands being lost or degraded and the quality of the wetlands being preserved. This suggests a recommended ratio between 5:1 and 10:1 for indirect impacts. Given the high quality of the wetlands and buffer proposed for preservation, and the high level of imminent threat to their continued function, the ratio exceeding 7:1 is consistent with the guidance. In addition, the use of preservation for indirect impacts is appropriate in that there is no net loss of wetland acreage. Construction of the project itself will not result in any temporary wetland impacts. Temporary wetland impacts associated with construction of the wetland mitigation site will be offset by the mitigation project itself. The temporary impacts will consist of vegetation removal and ground disturbance associated with grading for the mitigation site. These impacts will be fully restored once the site has been planted and seeded. Impacts to on-site ditches that were excavated into uplands at the site for purposes of treating and/or conveying stormwater will be offset through a minimum of 1:1 replacement of ditches at the Project Site. The project will result in direct impacts to approximately 2.83 acres of ditches. Ditches at the site provide limited water quality, hydrologic, and wildlife habitat function. Replacement ditches at the Project Site will provide similar levels of water quality, hydrologic, and habitat function, and as such the project will result in no net loss of function from impacts to these features. The proposed enhanced wetland buffer creation will mitigate for impacts to existing wetland buffers at the Project Site at a ratio of 1:1. Additional preservation of forested wetland buffer at the Hoquiam River site will provide additional mitigation for buffer impacts at a ratio exceeding 1:1 The existing wetland buffers that would be impacted at the Project Site are of relatively low-quality and function, as they are associated with an existing industrial site, and are generally overgrown with invasive species such as Himalayan blackberry, Japanese knotweed, and English Ivy. The enhanced wetland buffer at the mitigation site would be planted with a diversity of native trees and shrubs and would provide a high quality buffer to protect wetland functions at the mitigation site. The forested buffers at the Hoquiam River site include both forested wetlands, and upland forest that includes large-diameter old growth western red-cedar, western hemlock, Sitka spruce, and Douglas-fir. These buffers are under threat of development, and their preservation represents a protection of a high level of buffer function in perpetuity. The proposed mitigation will provide direct, in-kind mitigation for wetland and wetland buffer impacts associated with the proposed project, consistent with regulatory requirements and published guidance, and will result in no net loss of wetland function. The proposed mitigation will greatly enhance wildlife habitat, water quality, and hydrologic function within a degraded and ecologically sensitive portion of the inner Grays Harbor estuary.

51 of 135 July 2019 City of Hoquiam Planning and Building Division 609 8th St. Hoquiam, WA 98550-3522 Tel: 360-532-5700 ext. 211, Fax: 360-538-0938 Website: www.cityofhoquiam.com Table 7. Wetland and Wetland Buffer Mitigation Summary Mitigation Impact Mitigation Ratio Impact Wetland Category Mitigation Type Quantity Proposed Total Mitigation (acres) Ecology Guidance** Proposed (acres) 10.75 ac.* Wetland Creation (IDD#1) 2:1 1:1 10.75 10.75 acres wetland creation (IDD#1); Wet A III 13.09 2.34 ac.* Wetland Rehabilitation (IDD#1) 4:1 2:1 4.68 23.49 acres wetland rehabilitation Permanent/ Wet B III 2.08 Wetland Rehabilitation (IDD#1) 4:1 2:1 4.16 (IDD#1); Direct (Wetlands)

Wet C II 0.12 Wetland Rehabilitation (IDD#1) 4:1 4:1 0.49 59.90 acres wetland preservation IDD#1-A III 0.24 Wetland Rehabilitation (IDD#1) 4:1 2:1 0.48 (Hoquiam River Site) Totals 15.53 20.73 13.60 ac.* Wetland Rehabilitation (IDD#1) N/A 1:1 13.60 Wet A III 19.82 Permanent/ 6.22 ac.* Wetland Preservation (Hoquiam River Site) N/A >7:1 47.90 Indirect (Wetlands) Wet B III 1.70 Wetland Preservation (Hoquiam River Site) N/A >7:1 12.00 Wet C II 0.04 Wetland Rehabilitation N/A 2:1 0.08 Totals 21.56 73.35 Permanent/ Ditches N/A 2.83 minimum 1:1 area replacement in on-site drainage network N/A Self Mitigating Direct (Ditches) Temporary Wetland Impacts 25.09 Existing wetlands at mitigation site temporarily disturbed during construction. N/A Self Mitigating

Enhanced Wetland Buffer Creation (IDD#1) 5.17 acres enhanced wetland buffer 5.17* 1:1 1:1 5.17 (110 ft. buffer) creation Wetland Buffer Impacts 12.27 Forested Wetland Buffer Preservation 7.10* N/A >1:1 7.9 7.90 acres forested buffer preservation (Hoquiam River Site)

Wetland and Wetland Buffer Mitigation Summary 10.75 acres wetland creation; 23.49 acres wetland rehabilitation; 59.90 acres wetland preservation; 5.03 acres enhanced wetland buffer creation; 7.90 acres forested wetland buffer preservation * = quantity of impact (in acres) that is mitigated for by each mitigation type.

**=Ecology’s guidelines assume mitigation with wetlands of the same Category and quality as the impacted wetlands.

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City of Hoquiam Planning and Building Division 609 8th St. Hoquiam, WA 98550-3522 Tel: 360-532-5700 ext. 211, Fax: 360-538-0938 Website: www.cityofhoquiam.com

Mitigation for Impacts from Floodplain Development: The project will include the following mitigation measures to reduce impacts associated with development in the floodplain below the level of significance:

• The project will comply with the City floodplain requirements (HMC 11.16). • Buildings within the 100-year floodplain will be elevated 3 feet above the flood elevation or flood proofed. • In addition, any fill will not result in more than a 1-foot rise in flood levels in the remaining portion of the floodplain as authorized by HMC 11.16. Mitigation for Stormwater Impacts: The project will include the following mitigation measures to reduce impacts associated with stormwater runoff below the level of significance:

• The proposed stormwater facilities have been designed at a location west of the proposed unloading facility improvements so that existing drainage patterns could be preserved to the largest extent possible. • The project will comply with City stormwater regulations (HMC 11.05). • The project will include a new stormwater treatment ponds to treat stormwater before discharge through the existing outfalls on the site. • The stormwater treatment ponds have been sited in locations that minimize modification to the natural drainage patterns at the site. • Catch basins will be blocked in the event of a potash spill, and potentially impacted runoff will be contained and discharged to the waste water system or to an approved disposed facility. • Stormwater management will be conducted in accordance with state and local regulatory requirements. • Should stormwater become contaminated with potash from a spill or release) it cannot be disposed of in the stormwater system. The project will comply with applicable permits, including an Industrial Stormwater NPDES General Permit, SWPPP, and SPCC Plan. Mitigation for Dredging Impacts: Turbidity Minimization Measures during Dredging The proposed action includes the following impact avoidance and minimization measures to avoid and reduce the potential for adverse environmental effects associated with temporary, localized increases to turbidity resulting from dredging below the level of significance. The water quality monitoring plan will dictate monitoring requirements during dredging.

• Construction activities will be conducted in compliance with Surface Water Quality Standards for Washington (WAC 173-201A), or other conditions as specified in the WQC.

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• Appropriate BMPs will be employed to minimize sediment loss and turbidity generation during hydraulic dredging. BMPs may include, but are not limited to, the following. − No stockpiling of dredged material below MHHW, − Maintaining suction head of hydraulic dredge at the mudline to the extent practicable, − Using a buffer plate or other means to reduce flow discharge of the hydraulic dredge at the placement area, and/or − No stockpiling of dredged material below mean higher high water, − Smooth closure of the bucket when at the bottom, − Slowing the velocity (i.e., cycle time) of the ascending loaded clamshell bucket through the water column, − Pausing the dredge bucket near the bottom while descending and near the waterline while ascending, and/or − Placing filter material over the barge scuppers to clear return water. • If sediment is placed on a barge for delivery to the placement area, no spill of sediment from the barge will be allowed. The barge will be managed such that the dredged sediment load does not exceed the capacity of the barge. The load will be placed in the barge to maintain an even keel and avoid listing. Dredge Material Placement BMPs The proposed project will also use the following Dredging BMPs to reduce impacts associated with dredging below the level of significance:

• Dredging will be conducted using mechanical methods (clamshell bucket) only, and material will be disposed at the nearest DNR-managed disposal site (Point Chehalis or South Jetty) if characterization finds the material suitable for in-water placement.7 • Visual water quality monitoring and, if necessary, follow-up measurements will be conducted during dredging in accordance with a project-specific water quality monitoring plan and associated permit conditions. • Sediment placement will occur using methods that minimize sediment loss and turbidity to the maximum extent possible. • The placement activities will be visually monitored to ensure placed sediment is contained inside of the specified boundaries. Construction Mitigation (All Sites): The project will be designed to comply with all federal, state, and local regulations, controlling potential risks to water resources through project planning, design, and the application of required BMPs and reducing impacts below the level of significance.

7 The dredged materials at Terminal 3 have been found suitable for in-water placement since 2008, and the proposed dredged materials are also suitable for in-water placement (DMMP Suitability Determination, February 19, 2019).

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Construction BMPs • The project will obtain and comply with applicable permits, including a Construction Stormwater NPDES General Permit, SWPPP, and SPCC plan. • Project construction will be completed subject to a WQC and in compliance with Washington State Water Quality Standards (WAC 173-201A), including − Petroleum products, fresh cement, lime, concrete, chemicals, or other toxic or deleterious materials will not be allowed to enter surface waters or onto land where there is a potential for reentry into surface waters.

− Fuel hoses, oil drums, oil or fuel transfer valves, fittings, etc., will be checked regularly for leaks, and materials will be maintained and stored properly to prevent spills.

• The contractor will prepare a SPCC plan and use it during all in-water demolition and construction operations. A copy of the plan will be maintained at the work site. − The SPCC plan will outline BMPs, responsive actions in the event of a spill or release, and notification and reporting procedures. The plan will also outline management elements, such as personnel responsibilities, Project Site security, site inspections, and training.

− The SPCC plan will outline the measures to prevent the release or spread of hazardous materials found on site and encountered during construction but not identified in contract documents, including any hazardous materials that are stored, used, or generated on the construction site during construction activities. These items include, but are not limited to, gasoline, diesel fuel, oils, and chemicals.

− Applicable spill response equipment and material designated in the SPCC plan will be maintained at the job site. In, Over, and Near Water BMPs Typical construction BMPs for working in, over, and near water will be applied, including activities such as the following.

• Dredging will be conducted in compliance with Surface Water Quality Standards for Washington (WAC 173-201A), or other conditions as specified in the WQC. • Checking equipment for leaks and other problems that could result in the discharge of petroleum- based products or other material into waters of Grays Harbor. • Corrective actions will be taken in the event of any discharge of oil, fuel, or chemicals into the water, including − Containment and cleanup efforts will begin immediately upon discovery of the spill and will be completed in an expeditious manner in accordance with all local, state, and federal regulations. Cleanup will include proper disposal of any spilled material and used cleanup material.

− The cause of the spill will be ascertained and appropriate actions taken to prevent further incidents or environmental damage.

− Spills will be reported to Ecology Southwest Regional Spill Response Office pursuant to WAC 173-303-145 and WAC 173-182-260.

• Work barges will not be allowed to ground out.

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• Excess or waste materials will not be disposed of or abandoned waterward of ordinary high water or allowed to enter waters of the state. Waste materials will be disposed of in an appropriate manner consistent with applicable local, state, and federal regulations. • Demolition and construction materials will not be stored where wave action or upland runoff can cause materials to enter surface waters. • Oil-absorbent materials will be present on site for use in the event of a spill or if any oil product is observed in the water.

Pile Removal BMPs Pile removal BMPs will be applied, including activities such as the following.

• Removal of creosote-treated piles will be conducted consistent with the BMPs established in EPA Region 10, Best Management Practices for Piling Removal and Placement in Washington State, dated February 18, 2016 (EPA 2016).

• While creosote-treated piles are being removed, a containment boom will surround the work area to contain and collect any floating debris and sheen. Debris will be retrieved and disposed of properly.

• The piles will be dislodged with a vibratory hammer when possible and will not be intentionally broken by twisting or bending.

• The piles will be removed in a single, slow, and continuous motion in order to minimize sediment disturbance and turbidity in the water column.

• If a pile breaks above or below the mudline, it will be cut or pushed in the sediment consistent with agency-approved BMPs (USACE, DNR, Ecology and EPA).

• Removed piles, stubs, and associated sediments (if any) will be contained on a barge. If piles are placed directly on the barge and not in a container, the storage area will consist of a row of hay or straw bales, filter fabric, or similar material placed around the perimeter of the barge.

• All creosote-treated material, pile stubs, and associated sediments (if any) will be disposed of by the contractor in a landfill approved to accept those types of materials. Overwater Concrete Placement Minimization and Concrete Placement BMPs The project has been designed to minimize the placement of concrete overwater. Where possible, pre-cast concrete elements will be used for the shiploader and overwater conveyance structures.

On-site concrete placement, where needed, will follow appropriate BMPs, including the following.

• Wet concrete will not contact surface waters. • Forms for any concrete structure will be constructed to prevent leaching of wet concrete. • Concrete process water will not be allowed to enter the bay. Any process water/contact water will be routed to a contained area for treatment and will be disposed of at an upland location. Operation Mitigation (Project Site): • Secondary containment will be provided at the on-site fueling station to contain any accidental releases.

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• The facility will control risks during operations by following the Industrial SWPPP and SPCC plan to prevent liquid products from leaving the containment areas. Spill kits will be placed in strategic and easily accessible locations for use if small spills occur; containment, control, and cleanup procedures will be immediately implemented, including notifying Ecology and other resource agencies as required by law. • Stormwater treatment facilities would infiltrate stormwater runoff from new and existing impervious surfaces to the extent possible; or will be collected, treated, and discharged to the bay via existing outfalls. Stormwater treatment would comply with the most current version of Ecology’s Stormwater Management Manual for Western Washington. • All conveyors will be covered to protect the potash from exposure to rain. • Potash will be transferred to the vessels via covered conveyors in order to avoid potash blowing or spilling from the conveyors. Spill pans and side skirts will contain spills or fugitive dust from the return belt. • All equipment will be routinely checked for leaks and other problems that could result in the discharge of petroleum-based products or other material into waters of Grays Harbor. • Control of the train will be carried out through radio signals, allowing for the continuous control of train speed. In the event of an emergency stop, the control system will automatically halt the train. • Potash spills on land will be cleaned up by sweeping or vacuum truck and returning product to storage or disposal. Cumulative Impacts- Mitigation: As described in the previous sections, the proposed project would contribute incrementally to water resource impacts in inner Grays Harbor. Current and reasonably foreseeable projects conducted in and adjacent to waters of inner Grays Harbor, including the Contanda Project, the North Shore Levee Project, and maintenance dredging activities conducted by the USACE, the Port, and others, also have the potential to affect water resources. The proposed project includes compensatory mitigation for impacts to water resources that have been sized and designed to achieve no net loss in ecological function. Similarly, current and future projects, including those discussed above, will be required to secure permits for any impacts to water resources, implement a mitigation sequencing process that would result in impacts being avoided and minimized to the extent practicable, and provide compensatory mitigation to achieve the standards for no net loss of function. For these reasons, while the project will contribute incrementally to water resource impacts within Grays Harbor, no additional mitigation is required. 4. PLANTS a. Check the types of vegetation found on the site: _X_ deciduous tree: alder, maple, aspen, other _X__ evergreen tree: fir, cedar, pine, other _X_ shrubs _X_ grass ___ pasture ___ crop or grain

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___ Orchards, vineyards or other permanent crops. _X_ wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other _X_ water plants: water lily, milfoil, other ___ other types of vegetation

Project Site: The terrestrial habitat on the Project Site primarily consists of an unvegetated industrial habitat type. This habitat type consists of unvegetated areas that are completely developed with industrial infrastructure, such as buildings, rail infrastructure, roads, and other paved and/or graveled surfaces. Upland vegetation within the ruderal habitat type is primarily limited to small patches of grasses and a mix of native and non-native weedy herbaceous species, including colonial bentgrass (Agrostis capillaris), rabbitfoot clover (Trifolium arvense), and Canada thistle (Cirsium arvense). This vegetation type is typically present around the periphery of the site, along fence lines and adjacent to stormwater features. There is an area near the center of the site that was historically developed as part of previously operating industrial facilities. This area likely previously existed as a ruderal upland habitat or unvegetated industrial habitat. However, vegetation has begun to re-establish due to the lack of recent operations/disturbance on this portion of the site. The dominant species include a mix of red alder seedlings/saplings, Scouler’s willow (Salix scouleriana), Scotch broom (Cytisus scoparius), and Himalayan blackberry (R. armeniacus), as well as a mix of ruderal emergent vegetation. Functional riparian habitat is largely lacking along the shoreline of Grays Harbor at the Project Site. The portion of the shoreline that is within the Project Site is armored with riprap and the area landward consists entirely of impervious surfaces for most of the length of the shoreline. Functional riparian and related habitat is also present where associated with wetlands on site. Vegetation in the riparian areas consists of red alder (Alnus rubra) trees, with a mixed understory of Himalayan blackberry (R. armeniacus), salmonberry (Rubus spectabilis), and Indian plum (Oemleria cerasiformis). Vegetative species identified within the wetlands include red alder (A. rubra), Indian plum (O. cerasiformis), impatiens (Impatiens noli-tangere), bracken fern (P. aquilinum), soft rush (J. effusus), water parsley (O. sarmentosa), slough sedge (C. obnupta), and giant cattail (T. latifolia), among others. Himalayan blackberry is also prevalent throughout the wetlands. A survey and Tier 1 eelgrass (Zostera spp.) and macroalgae delineation was conducted at both the Project Site and IDD#1 (WSP July 2019), consistent with the requirements of the USACE “Components of a Complete Eelgrass Delineation Report” guidance. The survey documented patchy non-native Japanese eelgrass (Zostera japonica) within intertidal portions of the Project Site, but no native eelgrass (Zostera marina) beds at the Project Site. Japanese eelgrass is distributed throughout the upper intertidal zone at the Project Site between approximately +3 to +6 feet MLLW, and patchy macroalgae, such as leafy green sea lettuce (Ulva lactuca) and rockweed (Fucus distichus), is distributed in a relatively narrow band above +6 feet MLLW. Mitigation Sites: IDD#1 Site Existing vegetation at the IDD#1 site consists of common and invasive species. There are no known rare plant species at the site. Reed canarygrass (P. arundinacea) dominates large areas of the interior of the site, with lesser amounts of other emergent wetland and facultative species, including horsetail

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(Equisetum arvense), soft rush (Juncus effusus), slough sedge (Carex obnupta), bird’s-foot trefoil (Lotus corniculatus), velvet grass (Holcus lanatus), sweet vernal grass (Anthoxanthum odoratum), Kentucky bluegrass (Poa pratensis), creeping buttercup (Ranunculus repens), hairy cat’s-ear (Hypochaeris radicata), tall fescue (Schedonorus arundinaceus), Pacific silverweed (Potentilla anserina), English plantain (Plantago lanceolata), white clover (Trifolium repens), yellow glandweed (Parentucellia viscosa), sheep’s sorrel (Rumex acetosella), bedstraw (Galium trifidum), foxtail (Alopecurus aequalis), tufted hairgrass (Deschampsia caespitosa), and field bindweed (Convulvulus arvense), among others. Small patches of Hooker’s willow (Salix hookeriana) are present in some of the wetland areas. Himalayan blackberry (R. armeniacus) and Canada thistle (C. arvense) are also distributed through upland and transitional areas throughout the site. Along the southern, eastern, and southwestern boundaries of the site, the shoreline is armored with riprap and there is limited vegetation. Field bindweed (C. arvense), Himalayan blackberry (R. armeniacus), and oxeye daisy (Leucanthemum vulgare) are present along the top of the shoreward slope and found growing up through the riprap. Vegetation along the ditches on the northern boundary of the site varies between the eastern and western halves. Vegetation is predominantly of reed canarygrass (P. arundinacea), and Himalayan blackberry (R. armeniacus), with an overstory of red alder (A. rubra) and Hooker’s willow (S. hookeriana). In portions of wetland areas along the southern boundary of the site and in a small depression at the entrance to the tide gate at the eastern boundary of the site, there are patches of vegetation where salt-tolerant species, such as tufted hairgrass (D. caespitosa), Pacific silverweed (P. anserina), and Lyngbei sedge (Carex lyngbei), are dominant. These salt marsh communities are patchy and interspersed with less salt-tolerant species, such as reed canarygrass (P. arundinacea). These plant associations are likely supported by a combination of salt spray during storm events, through the existing tide gate at the eastern boundary of the site and to a lesser degree, tidal influence in groundwater. These areas are representative of the types of emergent salt-marsh plant associations that are proposed for the site, and indicative of the types of desirable native species that will likely colonize the site. The eelgrass survey and Tier 1 delineation documented patchy non-native eelgrass in the upper intertidal portion of the tidal inlet west of the site, and along the southeastern boundary of the site. The delineation also identified two small beds of native eelgrass adjacent to the western boundary of the IDD#1 site. These two native eelgrass beds are located outside of the site but within the study area for the delineation. Bed A is approximately 39.70 square feet in size with a density of approximately 20 shoots/0.25m2. Bed B is approximately 61.61 square feet in size with a density of approximately 20 shoots/0.25m2. Terminal 4 There is no known vegetation at the Terminal 4 site. The site is entirely aquatic, so no terrestrial vegetation occurs at the site, and no aquatic vegetation has been documented or is expected to occur at the site. Hoquiam River Preservation Site The forested wetlands at the Hoquiam River Site are dominated by mature Sitka spruce and red alder with a variety of shrub and herb layer species occupying a multi-strata understory. Scrub-shrub areas are dominated by Western crabapple and Hooker’s willow. Emergent areas are dominated by broadleaf cattail, skunk cabbage, water parsley, Pacific silverweed and slough sedge. Invasive species presence is

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limited to Himalayan blackberry, which is only sparsely present at the site. No ground or vegetation- disturbing work is proposed at the Hoquiam River site. b. What kind and amount of vegetation will be removed or altered? Project Site: Construction The project will require the removal and/or alteration of any existing vegetation that is within the footprint of the rail, buildings, rail unloading facility, conveyor systems, and roadways associated with the proposed facility (see Sheet 3). Approximately 36.72 acres of the site disturbance will be within unvegetated industrial area. This represents approximately 45 percent of the total site disturbance. These areas are completely or nearly devoid of vegetation and largely impervious because of the presence of concrete and/or paved surfaces, or dense rock fill material, and would not result in any measurable vegetation removal or alteration. Approximately 10.40 acres of ruderal habitat will be impacted. This represents approximately 13 percent of the total site disturbance. Upland vegetation within the ruderal habitat type is primarily limited to small patches of grasses and a mix of native and non-native weedy herbaceous species, including colonial bentgrass (A. capillaris), rabbitfoot clover (T. arvense), and Canada thistle (C. arvense). Approximately 0.66 acre of vegetation within developing upland habitats will be impacted. This represents less than 1 percent of the total site disturbance. The dominant species in these areas include a mix of red alder (A. rubra) seedlings/saplings, Scouler’s willow (S. scouleriana), Scotch broom (C. scoparius), and Himalayan blackberry (R. armeniacus), as well as a mix of ruderal emergent vegetation. Approximately 2.68 acres of vegetation within functional riparian (shoreline buffer) habitats will be impacted. This represents approximately 3 percent of the total site disturbance. Vegetation within functional riparian areas consists primarily of an overstory of red alder (A. rubra) trees, with a mixed understory of Himalayan blackberry (R. armeniacus), salmonberry (R. spectabilis), and Indian plum (O. cerasiformis). Functional riparian habitat is lacking along the shoreline of Grays Harbor at the Project Site. The portion of the shoreline that is within the Project Site is armored with riprap, and the area landward consists entirely of impervious surfaces for most of the length of the shoreline. As described above in Section B.3.a.2, the project will result in permanent direct impacts to 15.53 acres of wetlands. This represents approximately 19 percent of the total site disturbance. Vegetation within these areas would be permanently removed. Vegetation within wetlands at the Project Site is variable, and includes red alder (A. rubra), Indian plum (O. cerasiformis), reed canarygrass (P. arundinacea), impatiens (I. noli-tangere), bracken fern (P. aquilinum), soft rush (J. effusus), water parsley (O. sarmentosa), slough sedge (C. obnupta), and giant cattail (T. latifolia). Himalayan blackberry (R. armeniacus) is also prevalent throughout much of the wetlands at the site, particularly at the wetland boundary. As described above in Section B.3.a.2, the project will result in permanent direct impacts to 2.83 acres of ditches as described in Section 3.a.2 (Water) of this checklist. This represents approximately 3 percent of the total site disturbance. Vegetation within these areas would be permanently removed. Vegetation within ditches at the Project Site consists primarily of reed canarygrass, but also includes soft rush, colonial bentgrass, velvet grass, white clover, horsetail, and giant cattail. The project will result in permanent direct impacts to 12.27 acres of vegetated wetland buffers. This represents approximately 15 percent of the total site disturbance. The functional portion of wetland buffers at the project site typically extend from the wetland boundary to the toe of adjacent existing fills

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that establish the upland portion of site. Vegetation within wetland buffers consists primarily of dense stands of Himalayan blackberry, reed canarygrass, or other ruderal species. Operation Operation of the facility is not anticipated to impact vegetation at the Project Site. Mitigation Sites: IDD#1 Site The project will temporarily disturb approximately 25.09 acres of existing wetland at the IDD#1 site, during construction of the mitigation site. These impacts will be fully offset by the proposed mitigation actions which will include the establishment of a diverse native plant community of salt marsh, emergent wetland, and upland buffer species. Grading and excavation activities that will be required to construct the mitigation site will necessitate the removal of the existing vegetation throughout most of the site, with the exception of portions of two of the existing wetlands that are present within the portion of the site that will be within the enhanced buffer. The entirety of Wetland D, and the buffer portion of Wetland C are currently vegetated with appropriate native vegetation, and would not be disturbed. No grading will occur within those wetlands, so no native vegetation will be disturbed within these wetlands. Wetland B and portions of Wetland A that will occur in the buffer will be scraped down during initial site preparation to remove reed canarygrass (P. arundinacea). The upper 6 inches of these wetlands will be removed, and will be replaced with a 6-inch layer of hogfuel mulch prior to plant installation. Invasive species throughout the site (where present) will be removed consistent with the invasive species control plan (see Part VI of the mitigation plan). The two native eelgrass (Z. marina) beds are small, isolated, and are located outside of the mitigation area boundary. They will not be directly affected by the construction of the mitigation site. Impacts to these small eelgrass beds, if any, would be de minimis. While changes in hydrology at the site associated with the mitigation could over time affect these patches, the project is expected to result in a net beneficial effect to eelgrass habitat in the intertidal portions of the site. For this reason, native eelgrass beds will not be negatively affected by the project, and no compensatory mitigation is required to achieve no net loss of eelgrass habitat function. Terminal 4 No vegetation will be disturbed at the Terminal 4 pile and overwater structure removal site. Laydown areas for construction would either take place on a barge, or on the existing paved areas adjacent to the site. There is no terrestrial, riparian, or aquatic vegetation present at the site that would be disturbed. Hoquiam River Preservation Site: No vegetation will be disturbed at this site as no ground disturbing work is proposed. Cumulative Impacts: The proposed project would contribute incrementally to the cumulative amount of impacts to native vegetation communities or vegetation resources in inner Grays Harbor. Current and reasonably foreseeable projects conducted in the vicinity, including the North Shore Levee Project, also have the potential to affect native vegetation resources. The Contanda Project is located within developed areas and vegetation impacts are not anticipated from that project.

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In general, native vegetation within industrially zoned portions of the inner Harbor where development is likely to be concentrated is of limited quantity and quality. Most of the industrially zoned portion of the inner Harbor is built upon dredged fill material placed on former tideflats. There is little naturally functioning salt marsh remaining in the inner harbor and, where this habitat remains, it is not likely to be developed. Future projects will be required to secure required permits from the local jurisdictions that will require that impacts to native vegetation be avoided and minimized. Compensatory mitigation and/or restoration will be required to achieve no-net-loss of function where vegetation impacts occur in wetlands or aquatic habitats. The proposed project includes compensatory mitigation for impacts to vegetation resources that have been sized and designed to achieve no net loss in ecological function. Similarly, current and future projects, including those discussed above, will be required to secure permits for any impacts to vegetation resources, implement a mitigation sequencing process that would result in impacts being avoided and minimized to the extent practicable, and provide compensatory mitigation to achieve the standards for no net loss of function. All projects will be required to meet the no-net-loss standard as well as comply with the City of Hoquiam’s landscaping ordinance (HMC 10.05.065). For these reasons, while the project will contribute incrementally to the cumulative amount of vegetation disturbance in the vicinity, no additional mitigation is required to offset any cumulative impacts. c. List threatened and endangered species known to be on or near the site. There is no documentation of any ESA- or Washington State-listed threatened or endangered plant species on or near the Project Site, the IDD#1 site, or the Terminal 4 site (see the Critical Areas Report [WSP July 2019]). There are similarly no documented occurrences of any threatened or endangered plant species at the Hoquiam River preservation site. The USFWS has jurisdiction over ESA-listed plant species, and a review of the USFWS IPAC database for the Project Site and mitigation sites do not indicate the documented or expected presence of any ESA-listed plant species in the area. Similarly, the DNR Natural Heritage Program database does not identify the presence of any state-listed plant species at the Project Site, IDD#1 or Terminal 4, Hoquiam River site or within the vicinity. The nearest documented occurrence of a state-listed plant species in the DNR database is from a historical documented occurrence from 1982, and is located approximately 4.5 miles west of the Project Site in a forested riparian area. Note: Native eelgrass (Z. marina) is not listed on state or federal lists as threatened or endangered. See response to question (a), above, for a description of native eelgrass in the project area. d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on the site, if any: Construction BMPs (All Sites): The following measures would be taken during construction activities:

• Construction impacts would be confined to the minimum area necessary to complete the project. • Exposed soils would be stabilized with a vegetative cover or other erosion control treatment immediately following construction. • Vegetated areas temporary disturbed by construction activities would be revegetated with native vegetation within one year or one growing season after construction is complete.

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Operation BMPs (Project Site and IDD#1) Project Site: Impacts to on-site vegetation have been minimized and avoided to the extent practicable by locating buildings and road in previously disturbed areas where possible. There would be no temporary vegetation impacts, as no vegetation clearing would occur outside of areas proposed to be permanently impacted. Landscaping would be designed to satisfy City of Hoquiam Landscaping and Screening ordinance (HMC 10.05.065). A potash spill is considered to be highly unlikely to occur for the reasons detailed in Section 7 (Environmental Health). If a potash spill were to occur, it would be unlikely to affect traditional vegetation resources, including those in the vicinity of the Project Site such as grasses, reeds, or willows. This is due to the physical characteristics of potash (e.g., as a granular substance it does not “flow” or “coat” if spilled) as well as its chemical makeup, which is non-toxic (see Section 7 [Environmental Health] for additional details). Additionally, any potash spill in the dry can be completely cleaned up with manual methods (e.g., hand shovel, vacuum truck, etc.) and, in most cases, spills in moist or wet areas could be readily cleaned up to the extent practicable before the material dissolves. IDD#1 Site The creation and rehabilitation of wetlands at IDD#1 will fully offset impacts to wetlands and wetland vegetation associated with development of the Project Site. A planting plan identifying proposed native plant species is included in the Revised Mitigation Plan, as is a plan to control invasive plant species (see Part IX, Section 3). Three distinct wetland plant communities are proposed for IDD#1. These include low salt marsh, high salt marsh, and a palustrine wetland transition zone. Additionally, the plan establishes two upland buffer plant communities; scrub-shrub buffer and forested buffer. Performance standards for the mitigation actions are identified in Part VII of the Revised Mitigation Plan. The performance standards for these mitigation actions will consist of documenting completion of the proposed mitigation activities, monitoring the success and development of the mitigation, and providing long-term protection for the site. The performance standards for the compensatory mitigation include (1) documenting completion of the proposed mitigation activities, (2) monitoring the success and development of the mitigation over a 10-year period, and (3) providing long-term protection for the site. As-built documentation will be provided following site construction, providing documentation that the site has been constructed and installed as proposed in the mitigation plan. Vegetation establishment will be monitored during years 1, 3, 5, 7, and 10 following construction of the site to document the establishment and survival of vegetation, and the overall development of the site. A long-term management plan will be submitted in Year 9 that will document the plan for on-going maintenance and management of the site after the permit-required 10-year monitoring period. e. List all noxious weeds and invasive species known to be on or near the site. Plant species listed on the Washington State Noxious Weed List and known to occur on the Project Site include reed canarygrass (P. arundinacea), Himalayan blackberry (R. armeniacus), English Ivy (Hedera helix), Japanese knotweed (Polygonum cuspidatum), Canada thistle (C. arvense), giant cattail (T. latifolia), hairy cat’s-ear (H. radicata), oxeye daisy (L. vulgare), and Scotch broom (C. scoparius). Noxious weeds and invasive species that are present at the IDD#1 site include reed canarygrass (P. arundinacea), Himalayan blackberry (R. armeniacus), Japanese knotweed (P. cuspidatum), Canada thistle (C. arvense), hairy cat’s-ear (H. radicata), oxeye daisy (L. vulgare), and Scotch broom (C. scoparius).

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Japanese eelgrass (Z. japonica) is also known to occur in the harbor and was documented in the footprint of the terminal, and is classified as Weed Class C by the Washington State Noxious Weed Control Board. There are no known noxious weeds or invasive plant species at Terminal 4 site. Invasive species presence at the Hoquiam River Preservation Site is limited to Himalayan blackberry, which is only sparsely present at the site. No ground disturbing work is proposed at this site, and the project would not affect invasive species present at the site. 5. ANIMALS a. List any birds and other animals which have been observed on or near the site or are known to be on or near the site. Examples include: Birds: Hawk, heron, eagle, songbirds, other; Mammals: Deer, bear, elk, beaver, other; Fish: Bass, salmon, trout, herring, shellfish, other. The Mitigation Plan (WSP July 2019) and Critical Areas Assessment (WSP July 2019) provide an overview of the species of wildlife (including birds, fish, reptiles, amphibians, and other terrestrial and aquatic wildlife), that are known to occur on or near the Project Site, IDD#1 Site, Terminal 4, and the Hoquiam River Preservation Site. These documents also include a comprehensive discussion of the potential impacts to these wildlife species, and an accounting of the compensatory mitigation that is proposed to ensure no net loss of habitat function for these species. Terrestrial Wildlife The Project Site and IDD#1 are located in a largely disturbed industrialized area adjacent to the Grays Harbor shoreline. Much of the Project Site has been developed and is either unvegetated or only sparsely vegetated and provides little natural habitat for terrestrial species. Much of the Project Site is fenced, restricting access to and from the site from the GHNWR to the west. The IDD#1 site is currently unfenced, and is relatively more accessible to terrestrial species. Wetlands and naturally vegetated areas at the Project Site and IDD#1 provide habitat for species that are habituated to developed environments, including Columbian black-tailed deer (Odocoileus hemionus columbianus), raccoons (Procyon lotor), squirrels, mice, voles, and other small mammals, and a variety of reptiles and amphibians. The Hoquiam River site provides high quality habitat for a similarly wide variety of terrestrial species, but it is also much more highly connected to off-site forested habitats, which allows it to provide a much higher level of habitat function. Larger mammals requiring larger home ranges such as elk and black bear likely use habitats at the Hoquiam River site. The Terminal 4 site is aquatic and does not provide habitat for terrestrial species. Birds Shorebirds and Waterfowl Grays Harbor is located along the Pacific Flyway, a migratory flight corridor between Alaska and South America. It is a major staging area for migrating shorebirds in North America. Shorebirds congregate in the mudflats to feed and rest during spring and fall migrations. The GHNWR, located immediately west of the Project Site, is an area of concentrated use by migratory shorebirds during these migration periods, but also supports a variety of shorebirds year round. Common species include western sandpiper (Calidris mauri), dunlin (Calidris alpina), short-billed (Limnodromus griseus) and long-billed dowitchers (Limnodromus scolopaceus), semipalmated plover (Charadrius semipalmatus), least sandpiper (Calidris minutilla), red knot (Calidris canutus), and black bellied plover (Pluvialis squatarola). Fall migration begins as the birds migrate south from breeding

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territory. Many species continue south but Dunlin winter along the Washington coast and are present year round. A variety of waterfowl species use habitats on and adjacent to the Project Site and throughout Grays Harbor. The WDFW Priority Habitat and Species (PHS) database identifies the tidal mudflats of the GHNWR to the west of the Project Site as being a priority area for waterfowl concentration (WDFW 2017a). Common species include mallards (Anas platyrynchos), wigeon (Anas americana), blue-winged teals (Anas discors), pintail (Anas acuta), lesser scaup (Aythya affinis), mergansers (Mergus spp.), bufflehead (Bucephala albeola), common goldeneye (Bucephala clangula), and Canada geese (Branta canadensis). The upland portions of the Project Site provide little habitat for these species, though shorebirds and waterfowl were observed on the wastewater treatment lagoon and in several of the stormwater treatment ditches and ponds. Intertidal and aquatic habitats at both Project Site and IDD#1 provide foraging habitat for shorebirds and waterfowl. Other Bird Species Two snowy plover (Charadrius alexandrinus nivosus) breeding sites are known in the state of Washington; one at Leadbetter Point in Willapa Bay and the other at Damon Point in outer Grays Harbor. The Damon Point site is over 12 miles from the Project Site and is not expected to be affected by the project. Western snowy plover are not expected to occur frequently at the Project Site or vicinity, but could potentially be present in outer Grays Harbor. Critical habitat for streaked horned lark (Eremophila alpestris strigata) has been designated for streaked horned lark that includes a portion of habitat in outer Grays Harbor on the Oyhut Wildlife Area Unit and Damon Point (over 10 miles west of the Project Site). Streaked horned larks currently nest and winter on Damon Point and have also been documented nesting along the beach in that vicinity. Streaked horned larks are not expected to occur at the Project Site or within the vicinity. The marbled murrelet (Brachyramphus marmoratus) is an Endangered Species Act-listed (ESA) threatened seabird that feeds on forage fish in open marine waters. Marbled murrelets are occasionally present within the waters of Grays Harbor, but they are not expected to be present frequently at the Project Site or within the vicinity (Speich and Wahl 1995). Marine observations of murrelets typically correspond with the presence of contiguous stands of nesting habitat, which is not abundant within the action area or vicinity. PHS data reviewed for this project did not identify any marbled murrelet sites within the action area or vicinity (WDFW 2017a). The bald eagle (Haliaeetus leucocephalus) is a state-sensitive species and a state-priority species. The species was removed from the federal endangered species list in 2007 (72 FR 37346). However, it remains under the protection of the federal Bald and Golden Eagle Protection Act of 1940 and the Migratory Bird Treaty Act. There are no documented bald eagle nests or wintering areas identified at the Project Site. Osprey (Pandion halieetus) are a state-monitor species that occurs in relative abundance in the Project Site and throughout the Grays Harbor nearshore. Osprey build prominent stick nests in trees in nearshore habitats and forage for fish in marine and aquatic habitats. There is an osprey nest in the northwest corner of the site on a light pole, and osprey were observed on multiple occasions resting on the ground in ruderal habitats near the center of the site. Peregrine falcon (Falco peregrinus) is a state-sensitive species that both breeds and winters in and around Grays Harbor. Peregrine falcons typically nest on cliff ledges but also use tall, engineered

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structures, such as bridges and power poles. There are no documented occurrences of peregrine falcon at the Project Site and none were observed during the field inventory. However, they are likely present within the vicinity of the site. Fish Grays Harbor and its tributaries provide habitat for various fish species, including salmon, steelhead, bull trout, sturgeon, and a variety of forage fish species. Several of these species have special federal or state regulatory status. Salmon and Steelhead Several species of salmon and steelhead are known to occur in marine habitats of Grays Harbor. These include Chinook salmon (Oncorhynchus tshawytscha), chum salmon (Oncorhynchus keta), coho salmon (Oncorhynchus kisutch), and steelhead trout (Oncorhynchus mykiss). Most of the salmon and steelhead that use the waters of Grays Harbor come from Evolutionarily Significant Units (ESUs) and/or Distinct Population Segments (DPSs) that are not listed under the ESA. Most Chinook salmon in Grays Harbor are part of the Washington Coast ESU, most juvenile chum salmon that use the waters of Grays Harbor come from the Pacific Coast ESU, coho salmon found in Grays Harbor belong to the Southwest Washington ESU, and steelhead found in Grays Harbor belong to the Washington Coast DPS. However, juveniles of the Lower Columbia River (LCR) Chinook salmon ESU, Upper Willamette River Chinook salmon ESU, and Columbia River (CR) chum salmon ESU may occasionally be present in Grays Harbor at various times of the year depending on prevailing ocean currents. Bull Trout Bull trout (Salvelinus confluentus) in Grays Harbor belong to the Coastal/Puget Sound DPS and Grays Harbor is designated critical habitat for this DPS of bull trout. No bull trout populations have been documented in the tributaries to Grays Harbor (USFWS 2014) and major tributaries to Grays Harbor do not support bull trout spawning, rearing, or local populations. However, current and historical data indicate the presence of bull trout in Grays Harbor and the lower Chehalis River from mid-February through early July. Coastal Cutthroat Trout Coastal cutthroat (Oncorhynchus clarkii clarkii) is another trout species that is present in marine waters of Grays Harbor. Similar to steelhead, coastal cutthroat trout have both anadromous and resident life- history forms. Anadromous forms migrate from freshwater streams in late winter and spring to feed in nearshore coastal and estuarine environments. Sturgeon Green sturgeon (Acipenser medirostris) is the most broadly distributed, wide ranging, and most marine- oriented species of the sturgeon family. There are two DPSs of green sturgeon: the Southern DPS has been listed as a threatened species under the ESA (71 FR 17757) and the Northern DPS of green sturgeon remains a federal species of concern. Both DPSs are present in Grays Harbor. White sturgeon (Acipenser transmontanus) is the largest North American sturgeon. It is a slow-growing, anadromous fish with a reported lifespan of up to 100 years. White sturgeon has no special protective status but is a species of interest local tribes and the public. Forage Fish, Groundfish, and Other Fish Species The waters of Grays Harbor provides habitat for several species of forage fish, groundfish, and other fish species.

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Forage fish is a term applied broadly to several species of generally small fish that form large schools. Forage fish species include Pacific herring (Clupea harengus pallasi), surf smelt (Hypomesus pretiosus), Pacific sand lance (Ammodytes hexapterus), and northern anchovy (Engraulis mordax). These species are an integral part of marine food webs as they form an important link between primary producers and higher-level consumers. These small pelagic fish provide prey for salmon and steelhead, marine mammals, and seabirds as well as many other species. Several species of groundfish are known to rely on the waters of Grays Harbor for one or more life stages. Examples include Arrowtooth flounder (Atheresthes stomias), Pacific cod (Gadus macrocephalus), Pacific sanddab (Citharichthys sordidus), and several species of rockfish (Sebastes spp.) and sole (various spp.). These species all have varying life histories and habitat requirements, but all can be found within subtidal deep waters of Grays Harbor. Marine Mammals Marine mammals are frequently observed in Grays Harbor. California sea lions (Zalophus californianus) and harbor seals (Phoca vitulina) are the most common species. Steller sea lions (Eumetopias jubatus) are present in the Pacific Ocean adjacent to Grays Harbor and may enter the estuary on occasion. WDFW has mapped seal and sea lion haulouts in Grays Harbor and most of these are located in the north and outer-central portion of the harbor (Jeffries et al. 2000). The haulout nearest to the Project Site is located approximately 3 miles southwest of the site in the mid-harbor flats. Seals and sea lions likely forage in aquatic habitats within the harbor at the Project Site. Several species of whales are known to occur off the coast of Washington. These include blue whale (Balaenoptera musculus), fin whale (Balaenoptera physalus), humpback whale (Megaptera novaeangliae), North Pacific right whale (Eubalaena japonica), sei whale (Balaenoptera borealis), killer whale (Orcinus orca), sperm whale (Physeter macrocephalus), pygmy sperm (Kogia breviceps), common minke (Balaenoptera acutorostrata), and gray whale (Eschrichtius robustus). Of these species, only humpback and gray whale are encountered with any frequency within the waters of Grays Harbor. Gray whales pass through Washington waters twice annually, migrating between breeding grounds in Baja California and feeding grounds in Alaska. Gray whale use of Grays Harbor is well documented and they are known to enter Grays Harbor during migrations along the coast (WDFW 1997). Humpback whales are commonly found in the North Pacific Ocean, inhabiting coastal waters typically within about 50 nautical miles of the shore. Humpback whales winter in Hawaii or Mexico and migrate to the North Pacific in the summer to feed. Humpback whales occur off the coast of Washington in the vicinity of Grays Harbor, but rarely enter the inner harbor. Humpback whales are only occasionally observed inside of the mouth of Grays Harbor and on these occasions, they are most frequently observed in the outer harbor near the jetties (Calambokidis et al. 2004). Killer whales are also known to occur in Washington coastal waters and near Grays Harbor. The Orca Network database includes several records of both southern resident and transient killer whales offshore of Grays Harbor, but none within the harbor itself (Orca Network 2017). Other marine mammals common to Grays Harbor include harbor porpoise (Phocoena phocoena), Dall’s porpoise (Phocoenoides dalli), and Pacific white-sided dolphin (Lagenorhynchus obliquidens). These species are year-round inhabitants of Grays Harbor and the surrounding coastline. Marine Turtles Leatherback (Dermochelys coriacea), loggerhead (Caretta caretta), green (Chelonia mydas), and olive ridley (Lepidochelys olivacea) sea turtles occasionally occur off the coasts of Washington and Oregon.

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They occasionally wash ashore in Oregon and Washington, though Grays Harbor is not typically considered to be suitable habitat for any of these species of sea turtles. These sea turtle species nest in tropical or subtropical areas and generally migrate offshore during a portion of their lives. No designated or proposed critical habitat for any species of sea turtle occurs within the project vicinity. Marine Invertebrates A variety of marine invertebrate species are present in the waters of Grays Harbor, including Dungeness crab (Cancer magister), a variety of species of clams and oysters, and a diverse epibenthic community. These invertebrates provide forage for the fish, birds, and other wildlife in Grays Harbor, and many are also commercially and/or culturally important. Grays Harbor is an important nursery for juvenile Dungeness crab. Most adult Dungeness crab live along the open coast. Adult females molt to maturity, breed with males, extrude and carry an egg mass, and hatch larvae along the open coast. Upon hatching, larvae move to nearshore shallow waters and settle to the seabed, but many also directly enter estuaries such as Grays Harbor. Juvenile crab reside in the estuary for one to two years and then most will migrate from the estuary to reside along the coast through adulthood. At any time, the waters of Grays Harbor support populations of maturing larvae, developing juveniles, and adult crabs moving out of the estuary. Scientific literature published regarding Dungeness crab distribution in Grays Harbor indicate that most Dungeness crab production occurs in the outer portion of the Harbor. Armstrong et al. (1982) found a generally decreasing density of crabs with increasing distance from the harbor mouth and decreasing salinity. Habitat suitability at the Project Site is limited for adult Dungeness crabs, but larval and juvenile crabs likely utilize shallow nearshore waters at the site.

A variety of other invertebrate species are also present in aquatic habitats at the site and within the vicinity. These include a variety of worms, nematodes, copepods, amphipods, crustaceans, and mollusks. Several species of oysters and clams are farmed within Grays Harbor, and wild Pacific oysters are found throughout many of the intertidal and shallow subtidal zones of the Harbor. There are no known subsistence, commercial, or recreational shellfish beds within the Project Site or immediate vicinity. Approved commercial growing areas are located approximately 4.7 miles west of the project area and throughout the western portion of Grays Harbor. The nearest public beach open to recreational shell fishers is Bottle Beach, approximately 8.75 miles southwest of the project area. b. List any threatened or endangered species known to be on or near the site. The presence of threatened or endangered species within the vicinity of the project area (including vessel routes proximate to the project) was assessed in the Biological Evaluation (WSP May 2019). This information is summarized below in Table 8. This list is also applicable to the Hoquiam River preservation site.

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Table 8. Thretened or Endangered Species ESA Listing Species Name Critical Habitat Status Common Name Scientific Name ESU or DPS* Fish Chinook salmon (Oncorhynchus Lower Columbia Threatened Designated, but not tshawytscha) River ESU* in project area Upper Willamette Threatened Designated, but not River ESU in project area Chum salmon (Oncorhynchus Columbia River Threatened Designated, but not keta) ESU in project area Bull trout (Salvelinus Coastal Puget Threatened Designated confluentus) Sound DPS* Pacific eulachon (Thaleichthys Southern DPS Threatened Designated, but not (smelt) pacificus) in project area North American (Acipenser Southern DPS Threatened Designated green sturgeon medirostris) Marine Mammals Humpback (Megaptera N/A Endangered Not designated or whale novaeangliae) Proposed Killer whale (Orcinus orca) Southern Endangered Designated, but not Resident DPS in project area Fin whale (Balaenoptera N/A Endangered Not designated or physalus) Proposed Sei whale (Balaenoptera N/A Endangered Not designated or borealis) Proposed Blue whale (Balaenoptera N/A Endangered Not designated or musculus) Proposed Sperm whale (Physeter N/A Endangered Not designated or microcephalus) Proposed Right whale (Eubalaena North Pacific Endangered Designated, but not japonica) DPS in project area Marine Turtles Leatherback (Dermochelys N/A Endangered Designated, but not sea turtle coriacea) in project area Birds Marbled (Brachyramphus N/A Threatened Designated, but not murrelet marmoratus in project area marmoratus) Western snowy (Charadrius N/A Threatened Designated, but not plover alexandrinus in project area nivosus) Streaked (Eremophila N/A Designated, but not Threatened horned lark alpestris strigata) in project area Yellow-billed (Coccyzus Western DPS Designated, but not Threatened cuckoo americanus) in project area

DPS = Distinct population segment; ESU = Evolutionarily significant unit; NMFS = National Marine Fisheries Service; USFWS = U.S. Fish and Wildlife Service Source: WSP, Biological Evaluation, May 2019

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The species listed below in Table 9 and/or their designated critical habitat may have ranges that overlap with the Project Site, IDD#1, and Terminal 4 or the vicinity based on USFWS8 species lists. However, these species are not likely to be present at the Project Site or proposed mitigation sites due to a lack of suitable habitat. These species are therefore unlikely to be affected by the proposed project. Table 9. No Effect Species Species Name ESA Listing Status Common Name Scientific Name Northern spotted owl Strix occidentalis caurina Threatened Short-tailed albatross Phoebastria albatrus Endangered Oregon silverspot butterfly Speyeria zerene hippolyta Threatened Loggerhead sea turtle Caretta Endangered Green sea turtle Chelonia mydas Threatened Olive ridley sea turtle Lepidochelys olivacea Threatened Source: WSP, Biological Evaluation, May 2019 WDFW’s PHS database also identifies the following non-ESA-listed priority species and habitats as occurring or potentially occurring within or near the Project Site, IDD#1 site, and/or Terminal 4 sites:

• Gyrfalcon (Falco rusticolus) • Steelhead salmon (Oncorhynchus mykiss) • Resident coastal cutthroat salmon (Oncorhynchus clarkii) • Chinook salmon (Oncorhynchus tshawytscha) (non-ESA-listed ESU) • Chum salmon (Oncorhynchus keta) (non-ESA-listed ESUs) • Coho salmon (Oncorhynchus kisutch) Dungeness crab (Cancer magister) The WDFW Priority Habitat and Species (PHS) database also identifies a purple martin breeding area at the IDD#1 site. However, purple martin were removed from the list of WDFW priority species in 2018. WDFW PHS database identifies the following priority habitats and avian concentrations mapped within or near the Project Site.

• Freshwater emergent wetlands • Estuarine and marine wetlands • Freshwater forested/shrub wetlands • Shorebird and waterfowl concentrations

Portions of Grays Harbor also provide habitat for a variety of avian species that are identified as either State Species of Concern listed on the International Union for Conservation of Nature red-list, or on the 2016 watch list published by the North American Bird Conservation Initiative. Many of these species use habitats within the vicinity of the Project Site and the IDD#1 mitigation site, in particular, the salt marsh and intertidal habitats that are present on the GHNWR, which is located adjacent to and west of the Project Site. Many of these species use habitats within the vicinity of the project site and the IDD#1 mitigation site, in particular, the intertidal habitats at the project site and IDD#1 site, as well as the extensive salt marsh

8 U.S. Fish and Wildlife Service (USFWS). Information, Planning, and Consultation (IPaC) database. Accessed 14 August 2017 at https://ecos.fws.gov/ipac/location/index

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and intertidal habitats that are present on the GHNWR to the west of the project site. In addition to the ESA-listed whale species identified previously, several non-ESA-listed species of marine mammals are present within the waters of Grays Harbor. The most common marine mammal species within Grays Harbor are California sea lions (Zalophus californianus) and harbor seals (Phoca vitulina). Harbor seal haulout sites are located throughout the estuary, primarily in the north and central bays. The nearest haulouts to the project site are located on the mid harbor flats and shoals that are exposed at low tides, approximately 4 miles southwest of the project site. Steller sea lion (Eumetopias jubatus), and harbor porpoise (Phocoena phocoena) are also occasionally present in Grays Harbor as well as in offshore coastal waters. Other non-ESA listed whale species that may occur in the waters off Grays Harbor include the pygmy sperm whale (Kogia breviceps), minke whale (Balaenoptera acutorostrata), and gray whale (Eschrichtius robustus), which is a state-listed sensitive species. Dungeness crab is listed as a priority species by the state as a Species of Recreational, Commercial, and/or Tribal Importance. Dungeness crab is a commercially important species in Grays Harbor and is also an important resource of the Quinault. Grays Harbor is an important nursery for juvenile Dungeness crab. Most adult Dungeness crab live along the open coast. Adult females molt, breed, and hatch larvae along the open coast. Upon hatching, larvae move to nearshore shallow waters and settle to the seabed, but many also directly enter estuaries such as Grays Harbor. Juvenile crab reside in the estuary for one to two years and then most will migrate from the estuary to reside along the coast through adulthood. At any time, the waters of Grays Harbor support populations of maturing larvae, developing juveniles, and adult crabs moving out of the estuary. Scientific literature published regarding Dungeness crab distribution in Grays Harbor indicate that most Dungeness crab production occurs in the outer portion of the Harbor. Armstrong et al. (1982) found a generally decreasing density of crabs with increasing distance from the harbor mouth and decreasing salinity. Habitat suitability at the Project Site is limited for adult Dungeness crabs, but larval and juvenile crabs likely utilize shallow nearshore waters at the site. c. Is site part of a migration route? If so, explain. The Grays Harbor region, including the Project Site and the three mitigation sites, is located within the Pacific Flyway, a major north-south flyway for migratory birds extending from Alaska to the southern tip of South America. The GHNWR, adjacent to the Project Site, on the west, is an area of concentrated use by migratory shorebirds, both during seasonal migration periods and also year-round. The Harbor in general is a major staging area for migrating shorebirds in North America. Shorebirds congregate in the mudflats to feed and rest during spring and fall migrations. Common species include western sandpiper (Calidris mauri), dunlin (Calidris alpina), shortbilled (Limnodromus griseus) and long-billed dowitchers (Limnodromus scolopaceus), semipalmated plover (Charadrius semipalmatus), least sandpiper (Calidris minutilla), red knot (Calidris canutus), and black bellied plover (Pluvialis squatarola). The GHNWR also provides habitat for a variety of sensitive species. The WDFW PHS database identifies the tidal mudflats of the GHNWR as being a priority areas for waterfowl concentration. The high-quality nature of the wetlands on the GHNWR, and the importance of the GHNWR to migrating shorebirds is documented in the Revised Critical Areas Assessment (WSP July 2019) and the Revised Mitigation Plan (WSP July 2019). Aquatic habitats within Grays Harbor are important migratory habitat for several species of fish, including anadromous salmonids, green sturgeon (Acipenser medirostris), and Pacific eulachon (Thaleichthys pacificus). Sea-run coastal cutthroat trout (Oncorhynchus clarkii clarkii) migrate to and from freshwater and estuarine habitats within the Harbor. Offshore coastal waters adjacent to Grays

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Harbor are an important migratory corridor for these migratory fish species and for the species of marine mammals described previously. d. Proposed measures to preserve or enhance wildlife, if any: The proposed mitigation measures to preserve and/or enhance wildlife consist of the following, which will reduce the impacts below the level of significance: 1. Impact avoidance and minimization (project design) 2. Construction BMPs (to be employed at all sites) 3. Operation BMPs (to be employed at the Project Site) 4. Proposed compensatory mitigation (to take place at IDD#1, Terminal 4, and Hoquiam River sites) 5. Cumulative impacts and mitigation

Details are provided below.

Impact Avoidance and Minimization: BHP selected a site where the naturally functioning terrestrial wildlife habitat is of limited quantity and quality, and within previously disturbed, industrially zoned portions of the inner Grays Harbor. The layout of the upland portion of the facility has undergone several iterative modifications in an effort to accommodate design requirements and site constraints while minimizing impacts to wildlife to the extent practicable. The project design has avoided and minimized impacts to wetlands, buffers, shoreline buffers, aquatic habitats, and other environmentally sensitive habitats to the extent practicable, while still accommodating the necessary features to meet the project purpose and need. The administration and maintenance buildings, associated parking areas, and the vehicular site access infrastructure have been located in developed portions of the site and would not result in impacts to wetlands, aquatic resources, and associated buffers. The railcar unloading facility is located in an area where fill has previously been placed, which further reduced impacts to wildlife habitat in that location. The layout of the site was also designed so that noisier equipment (e.g., unloading facility) is sited on the opposite side of the facility from the GHNWR. The administration and maintenance buildings, including associated parking, are all located on the southeast corner of the site near the site's main entrance, minimizing cross-site traffic and potential associated interactions with wildlife. The unit trains on site will travel at very slow speeds (less than 6 mph), which will minimize both train-related noise and will also reduce the potential for any wildlife interactions. The size and configuration of the marine terminal structures have also been kept to the minimum necessary to support their needed functions. The terminal has been designed such that the shiploader and berth are sited in deep water, which minimizes the potential for effects to aquatic habitats. The project has also been modified to eliminate a gabion mat, which had originally been proposed to stabilize a portion of the surface of the post-dredge berth and would have replaced natural mud, sand and silt substrate with rock. BHP has also committed to restrict the dredging to clamshell methods only to minimize impacts to the aquatic environment, in particular to minimize impacts to benthic species including Dungeness crab. Structures in and over deeper water habitats have less impact to function than those in shallow water areas because they have less effect on primary productivity. Deeper water habitats are of less critical importance to sensitive species than shallower waters. Ship berthing and maneuvering activities will also occur in deep water, reducing impacts to habitat from vessel operations such as scour from propellers and thrusters. Overwater walkways will be grated to further minimize shading. Additionally, the

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shiploader is comprised of relatively narrow trestles supported between small, pile-supported platforms with relatively few piles overall. Since the shiploader and access trestles are relatively narrow structures, they do not result in a substantial benthic footprint, and the impacts associated with overwater shading is relatively low compared to that which would be associated with a monolithic structure like the adjacent Terminal 3 pier. An osprey nest that is located on a power pole on the western boundary of the site would be affected by the project, so it will be relocated as part of the project.9 Construction BMPs (All Sites) Construction BMPs will be used at all sites where and when applicable (i.e. dredging BMPs will not be needed or used at Terminal 4).

• Water Quality: Increased levels of turbidity could have temporary negative impact on wildlife habitat suitability. Best management practices to minimize turbidity impacts from dredging are described in Section 3.a.3 of this checklist. • Traffic: There is the potential for an increase in vehicular traffic during facility construction. The increased traffic has the potential to increase the risks of wildlife strikes or spills related to vehicle accidents. These impacts will be minimized and mitigated by: − Training drivers to be alert for wildlife in the area. − Equipping work vehicles with spill response kits.

• Schedule/Timing: As detailed under Section A (Background), construction work timing restrictions have been implemented to protect animal species (for example, in-water construction will be limited to the designated in-water work windows in order to protect eulachon and green sturgeon). See Noise BMPs, below. • Noise: Avoid wildlife disturbance by elevated construction noise during construction by: − Using alternative construction methods (e.g., vibratory hammer for pile driving). Pile installation will be performed to the greatest extent possible using a vibratory hammer, though piles may need to be driven to final tip elevation or proofed, as necessary, with an impact hammer.

− If nighttime construction is proposed (not currently anticipated), a Construction Noise Management Plan would be developed to ensure that nighttime construction can comply with the local requirements.

− Timing and sequencing of major noise-producing activities for periods when sensitive species are less likely to be present.

o In-water work will be conducted only during the approved in-water work window for marine waters of Grays Harbor - Tidal Reference Area 16 and in coordination with the Quinault as follows. July 16 (12:01 am) and February 14 (11:59 pm) Impact pile driving will only occur between October 1 (12:01am) and February 14 (11:59 pm)

9 The commitment to relocate the osprey nest was developed in coordination with GHNWR staff. GHNWR manager, Glynnis Nakai, indicated support for BHP's proposal to relocate the nest during a meeting on January 11, 2018. The nest relocation will be conducted consistent with the requirements of the MBTA.

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No nighttime dredging will occur between 1 October and 30 November

o Limiting the number of piles or impact hammer strikes per day o Using noise attenuating devices (e.g., bubble curtains during pile driving) Operation Mitigation (Project Site): Operation-related impacts to wildlife and wildlife habitat include those that would occur with lighting, operational noise, vehicular traffic, rail transport, vessel transport, stormwater management, and air quality. The following proposed operational BMPs will reduce impacts to wildlife and wildlife habitat below the level of significance. Lighting Nighttime lighting impacts will be minimized and mitigated by implementing the following designs.

• Directional lighting and other features such as those for Light Zone 1 (LZ1), Dark Zone, as defined by the Illuminating Engineering Society of America (IESNA) RP-33 standard would be implemented. • Lighting power densities would not exceed American Society of Heating, Refrigerating and Air- Conditioning Engineers /IESNA Standard 90.1. Areas would only be lighted as necessary for safety and comfort. • Yellow light sources will be used on site to minimize light pollution sky-glow. Glare Control • Glare is controlled by prismatic glass options; glass and diffuse options reduce glare by 95 percent. • Calculations include consideration for glare options. The Backlight, Uplight, and Glare (BUG) rating for every Illuminating Engineering Society (IES) fixture must be within limitations; all fixtures chosen will meet this requirement. • For lighting within the criteria of RP8 and Industrial RP7, lighting levels will be adjusted to be within safety guidelines and achieve even lighting (no hot spots). Light Shed • Lights will be generally aimed downward and back towards site if close to property line, thus reducing spillage. • Lighting on overwater structures will be shielded and aimed at the surface of the shiploader structure or vessel minimizing light spillage onto the water during nighttime hours. • Lighting will have shields to reduce back light if the light is close to a property boundary. • Roadway lighting is designed for safety and to meet criteria to RP8 for large trucks and vehicles. • Fixtures will be designed to point into the site to light railway and service roads. Noise Operational noise at the Project Site would occur associated with rail car movement and unloading activities, as well as on-site transport of potash via conveyors. Terrestrial noise generated during operation is expected to be similar to or less than levels of noise generated at the existing facility, which includes a wood chipping facility, heavy machinery, conveyors and a shiploader. Terrestrial noise levels during operation would be far lower than levels where physical injury would result. The range of anticipated potential wildlife reactions to elevated noise levels during operation could range from startle responses, to temporary avoidance of an area. These responses

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could in turn result in increased energy expenditure or movement into less desirable locations with potentially greater exposure to predation. These impacts will be minimized and/or mitigated by the following mitigation measures.

• Designing natural or engineered shielding for facility equipment (e.g., train unloading will take place within a covered structure) • Placing covers over powered equipment where required, • Covering conveyors • Covering the train unloading facility • Locating noise-producing equipment (e.g., train unloading facility) away from the boundary with the GHNWR Vehicular Traffic There is the potential for a minor increase in vehicular traffic when the facility becomes operational. The increased traffic has the potential to increase the risks of wildlife strikes or spills related to vehicle accidents. These impacts will be minimized and mitigated by:

• Training drivers to be alert for wildlife in the area. • Reduced onsite speed limit for vehicles operating onsite. • Equipping work vehicles with spill response kits. • Installing bike racks and showers for employees to reduce the number of employee vehicles that enter the Project Site. • Offering incentive programs for employees to commute by other means than car or to carpool. Rail Transport Increased rail traffic could affect wildlife along the existing PSAP rail line, as well as at the Project Site. Potential impacts may include increased direct mortality (collisions with moving trains), and increased exposure to pollutants (incidental leaks and spills). Additional rail traffic could increase potential for direct mortality of animals because of collisions with trains and increased predation risk. While animals along the PSAP rail line are already habituated to the movement of existing trains, increased train traffic could increase potential for strikes with animals that may be on the tracks and cannot escape a passing train. However, the animal species along the PSAP rail line are likely adapted to disturbances associated with train traffic and train speeds are 25 MPH or less so the increase in rail traffic is not likely to affect species populations or fitness. Increased rail traffic at the Project Site may also increase the potential for direct wildlife interactions. The potential for strikes of birds or other wildlife species is low, given the lack of quality habitat on site, and that species are expected to avoid the site during operations. To further decrease the potential, the unit trains on site will travel at very slow speeds (less than 6 mph), which will minimize both train- related noise and will also reduce the potential for any wildlife interactions. An increase in leaks and spills of chemicals used in routine rail operations could occur due to the increased frequency of rail traffic, both at the Project Site and along the PSAP rail line. Diesel fuel, oils, grease, and other chemicals required for rail operation and maintenance could affect wildlife through an increased potential for small leaks and spills. A spill could affect individual wildlife in

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the immediate vicinity of the spill, however most wildlife would avoid trains. Leaks or spills would be contained and cleaned up quickly per operating and maintenance protocols.

• Impacts associated with rail transport will be minimized and mitigated by : − A spill prevention plan will be developed and refined during additional consultation conducted during the permitting effort and final facility design.

− Trains are equipped with spill response kits as required under Federal Transit Administration (FTA) regulations

− Have spill response equipment (e.g., on-call vacuum truck) readily available at the facility. − Train speed will be slow when entering the site and moving around the rail loop onsite.

− The facility rail loop is sized to hold an entire unit train during unloading (i.e. the train will not interact with wildlife off the Project Site (where they are more likely to be present) once it has arrived on-site (where they are less likely to be present). Additionally, once the full unit train is on site the speed will be controlled (i.e. slow, as mentioned above) which will also minimize wildlife interactions. Marine Vessel Transport Increased vessel traffic to and from the facility has the potential to affect wildlife through increased potential for (1) bank erosion associated with propeller wash, (2) noise and visual disturbance, (3) introduction of exotic species, (4) vessel spills, (5) increased potential for vessel strikes, (6) underwater noise, and (7) increased potential for entrainment or impingement in vessel intakes. These are discussed in detail in the Biological Evaluation (WSP 2019). Propeller wash from vessels in transit, as well as wakes breaking on shore, can cause erosion along unarmored sections of shoreline. Erosion can re-suspend eroded material within the water column, increasing turbidity, which can affect habitat suitability for aquatic organisms. This suspended sediment has the potential to result in degradation of habitat suitability for fish habitat and special-status fish species. While it is possible that streambanks could potentially erode as a result of vessel wakes, erosion would not be expected to occur to an extent that could result in habitat loss or degradation of existing habitat quality. Vessels transiting to and from the facility would generate underwater and terrestrial noise, and would also represent a potential visual disturbance. Engine noise, prop movement, and the physical presence of a boat hull can disturb or otherwise temporarily displace nearby fish. Underwater noise associated with project vessels could also potentially affect marine mammals. Marine mammals rely on sound to communicate and to derive information about their environment. There is growing concern about the effect of increasing ocean noise levels due to anthropogenic sources on marine organisms, particularly marine mammals (Richardson et al. 1995). The increase in vessel traffic associated with proposed facility operation could lead to an increase in low-frequency noise. The effect of an increase in low-frequency noise would be minor because vessels are transitory and exposure would be limited to the period when the vessel is nearby. Individual fish and/or marine mammals may react to noises generated, or to the presence of vessels by changing the direction of their movements, or by increasing their swimming speed. These reactions could temporarily increase an individuals’ energy budge. Vessels can potentially import exotic and/or invasive species on their hulls and exterior equipment and/or in ballast water. Introduced species can often out-compete native species and have the potential to alter natural habitats significantly. Operators of commercial vessels have a significant economic

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interest in maintaining the underwater hull area in a clean condition The USCG has developed mandatory practices for all vessels with ballast tanks in all waters of the United States. Washington State has developed similar regulatory requirements. These practices include requirements to rinse anchors and anchor chains during retrieval to remove organisms and sediments at their place of origin; to regularly remove fouling organisms from the hull, piping, and tanks; and to dispose of any removed substances in accordance with local, state, and federal regulations. For these reasons, the potential for introduction of invasive/exotic species from vessel traffic is low. The additional vessel transits within Grays Harbor and adjacent marine waters have the potential to result in increased interactions between project vessels and marine mammals, birds, and sea turtles. The potential for a vessel strike would depend on many factors, including time of year, vessel type, vessel size, species, vessel location, vessel speed, and location of animal relative to vessel. The USCG has published Navigation Rules and Regulations that dictate vessel movements (USCG 2014). These regulations require vessels to “proceed at a safe speed so that she can take proper and effective action to avoid collision and be stopped within a distance appropriate to the prevailing circumstances and conditions.” The Navigation Rules identify some factors to be taken into account when determining what a safe speed is, which include: (1) visibility; (2) density of vessel traffic; (3) maneuverability of the vessel (stopping distance and turning ability in the prevailing conditions); (4) lighting conditions; (5) wind, sea, and current conditions; (6) the proximity of navigational hazards; and (7) the draft of the vessel in relation to water depth. Additional considerations are indicated for vessels with operational radar (USCG 2014). The likelihood of a vessel strike is low given that ship strikes remain relatively rare, unpredictable events, the vessels calling on the project would represent only a very small portion of overall vessel trips in northern pacific and the total area affected by increased vessel traffic represents only a small portion of the overall available habitat for species at risk of potential strike. It is possible for fish or other aquatic species to become entrained in or impinged on vessel water intakes for cooling, drinking water and ballast water. It is expected that vessels would arrive at the berth with no cargo and in a ballasted condition and would not take on ballast at the dock. Therefore, the only intakes that would be in operation at the dock would be cooling for auxiliary systems and drinking water and the volume of these intakes are low while at dock and in comparison to ballast intake operations. The increased potential for entrainment/impingement would have potential for impacts to fish and other aquatic species. Impacts associated with entrainment could include physical stress due to pressure changes or abrasions or mortality from contact with screens and pump impellers. The change in pressure associated with water intakes can burst the swim bladders of some species. The potential for entrainment would affect fish eggs and larval fish more than juvenile or adult fish, due to their small size and relative lack of mobility. However, adult fish would not be expected to be entrained or impinged on vessel intakes. In addition, the potential for entrainment/impingement to occur would be minimal based on the nature of the intakes, and similar to that associated with the existing baseline level of vessel traffic. Proposed Mitigation Measures to Reduce Vessel Impacts to Wildlife • The project will implement the following proposed mitigation measures for the proposed operation of the terminal: • Hull maintenance and ballast water practices, which will greatly minimize the potential for any transport of these species • All vessels with ballast tanks will comply with the USCG and Washington State mandatory practices for all vessels with ballast tanks.

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• Vessel ballast tanks will be required to contain clean seawater that has either been treated through an onboard ballast-water treatment system or collected during a mid-ocean ballast exchange. • Ballast water discharge will be managed consistent with federal and state regulations, which prohibit discharge of untreated ballast water into the waters of the United States and waters of the state unless the ballast water has been subject to a mid-ocean ballast water exchange. • BHP will prepare an invasive-species monitoring plan in consultation with WDFW, which will be implemented prior to the start of the proposed operation to reduce the potential for the introduction of invasive species. • Pilots operating vessels associated with the project must operate their vessels consistent with these regulations and safety considerations (USCG 2014). Stormwater As discussed in Section B.3.c, stormwater runoff has the potential to carry suspended solids or other potential pollutants to offsite waters. This has the potential to affect water quality in adjacent waters, which could in turn affect wildlife. Although alteration of drainage patterns at the site may potentially disrupt GHNWR hydrology by increasing runoff from increased impermeable surfaces at the Project Site, the stormwater facilities have been designed at a location west of the proposed unloading facility improvements so that existing drainage patterns could be preserved to the largest extent possible. Additionally, the nature of the product and the covered and enclosed storage and conveyance at the facility minimizes the potential for impacts to the stormwater at the site as discussed previously. The proposed mitigation measures in Section B.3.d will reduce impacts to animals below the level of significance. Compensatory Mitigation Compensatory mitigation for wetland impacts are described in Section B.3.d. As determined in the Mitigation Plan (WSP, July 2019), the proposed compensatory mitigation will fully offset functional impacts to wetland habitat functions associated with the project. Therefore the result will be no net loss of wildlife habitat function. The following section summarizes the proposed compensatory aquatic habitats. Additional details including performance standards, planting plans, monitoring and maintenance plans, and site protection and financial assurances can be found in the Mitigation Plan (WSP, July 2019). Aquatic Habitat Mitigation Mitigation consists of tidal habitat creation and enhancement at the IDD#1 site and pile and overwater structure removal at the Terminal 4 site. Table 7 below provides a summary of the proposed aquatic mitigation activities associated with the project. Tidal Channel Habitat Creation and Enhancement The mitigation project includes the creation of approximately 5,941 linear feet and approximately 0.94 acre of new fish-accessible tidal channels10 at the site. These new tidal channels will provide a network of low energy side channel habitat within a mosaic of newly restored high and low salt marsh habitats. The tidal channels have been designed based on conditions documented at a reference salt marsh in upper Bowerman Basin on the GHNWR. This reference marsh is located immediately downstream of the project site, and has elevations comparable to those that historically occurred at the IDD#1 site. A recent

10 Tidal channel acreage is in addition to, and separate from, the wetland creation and rehabilitation acreages reported in Table 5.

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comprehensive data set was collected in this reference marsh as part of a 2015 U.S. Geological Survey study on potential effects to salt marshes from sea level rise (Thorne et. al. 2015). This data included topographic and bathymetric profiles and vegetation distribution information, which informed the design of the tidal channels and the rest of the IDD#1 mitigation site. The tidal channels will be excavated to final elevations such that they are inundated throughout the typical range of flows and tidal conditions throughout the year, and such that they will not create pockets of standing water during low flow conditions. A hydraulic, groundwater, and coastal process modeling and assessment has been conducted on the proposed design of the tidal channels and associated salt marsh (Golder 2019), and the results of this modeling effort were used to refine the design and establish the final design of the site. It is anticipated that the tidal channel will be largely unvegetated, as it will be regularly inundated throughout the majority of a typical tidal cycle. This is consistent with the conditions within tidal channels at the reference marsh. Over time, some desirable aquatic macroalgae species and other aquatic vegetation will likely become established. Adjacent low salt marsh will be both seeded and planted with plugs of desirable emergent salt marsh species. Nine large woody debris (LWD) structures will be installed throughout the newly created intertidal habitats at the site. LWD structures are a restoration and mitigation component that helps build high- quality fish habitat, develops scour pools, and provides complex cover. These large wood structures will increase habitat complexity and overhead cover with interstitial spaces that will allow juvenile and adult salmonids and other native species to evade predation by mammals, birds, and fish. The structures will provide refuge and foraging opportunities for juvenile salmonids. Each structure will be composed of large-diameter untreated logs, logs with rootwads attached, and small wood debris. Logs generally will have a minimum diameter of 20 inches and be 20 feet long. Logs comprising the structure will be dragged into place, arranged, and keyed into the soil as necessary to minimize the potential for movement. It is important to note that some movement, deterioration, and accumulation of additional woody debris is expected as these features function as part of the natural system. The proposed tidal channel creation will provide both in-kind mitigation (for shoreline buffer impacts) as well as out-of-kind habitat enhancements to nearshore aquatic habitat (for impacts to aquatic habitats from new overwater structure and permanent benthic habitat impacts). Pile and Overwater Structure Removal In addition to the proposed on-site compensatory mitigation, the applicant will remove approximately 1,368 piles from nearshore waters of Grays Harbor in the vicinity of the Port of Grays Harbor’s Terminal 4 near the mouth of the Chehalis River. These piles are estimated to range between 12 and 14 inches in diameter at the mudline. The applicant will also remove a derelict concrete overwater structure that is associated with one of the groups of piles. The piles result in the direct loss of benthic habitat and serve to reduce the quality of the habitat in the area. The piles serve as habitat for non-native species, including fish and bird species that prey on native salmonids and potentially represent a source of pollutants from chemicals used for treatment. Removal of these piles will restore approximately 1,464 square feet of benthic habitat within an area approximately 4.35 acres in size. In addition, removal of the structure will restore an area of approximately 2,147 square feet of nearshore habitats. Pile and structure removal will provide both in-

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kind mitigation for benthic habitat and overwater coverage impacts associated with the new terminal, as well as out-of-kind habitat mitigation in the form of water quality improvements. Table 10. Aquatic Habitat Mitigation Summary Impact & Quantity Compensatory Mitigation Overwater Structure Pile Removal Tidal Channel Creation Removal 2,147 sf (0.05 acre) 1,464 sf (0.03 acre) 40,950 sf (0.94 acre) Quantity Impact Type (sf) Total Total Total Area Mitigation Area Mitigation Area Mitigation Ratio Ratio Ratio (sf) Accounted (sf) Accounted (sf) Accounted For (sf) For (sf) For (sf) Overwater 1:1 2,147 2,147 35,360 Coverage 0.5:1 33,213 16,607 (solid) 12,754 0.25:1 12,754 3,189 Benthic 1,020 1:1 1,020 1,020 Habitat Loss 1,482 1:1 444 444 1:1 1,038 1,038 Benthic 18,770 1:1 18,770 18,770 Habitat Modification 307,494 Temporary Modification - No Compensatory Mitigation (Dredge Prism) Totals 2,147 1,464 39,603 Source: WSP, Mitigation Plan, July 2019 Cumulative Impacts Current and reasonably foreseeable projects conducted in and adjacent to waters of inner Grays Harbor, including the Contanda Project, the North Shore Levee Project, and maintenance dredging activities conducted by the USACE, the Port, and others, will all result in effects to wildlife resources. The proposed project would contribute incrementally to the cumulative impact to wildlife resources associated with these projects. In general, industrially zoned portions of the inner Harbor, where current and future development is likely to be concentrated, provide wildlife habitat of limited quantity and quality. Most of the industrially zoned portion of the inner Harbor is built upon dredged fill material placed on former tideflats. The Contanda Project will occur entirely on existing paved surfaces and their SEPA analysis did not identify cumulative impacts to fish or wildlife species (Contanda 2019). The train and vessel traffic associated with the Contanda Project would result in similar effects to those identified for the proposed project. The North Shore Levee project would result in short term impacts to fish and wildlife during construction, and longer term impacts related to a reduction in channel migration potential and changes to flood extents, as well as long term beneficial effects including potential for reducing fish stranding and reducing pollutant loading during flooding. Current and future dredging activities result in temporary impacts to water quality and benthic habitats, and have the potential to directly affect fish and aquatic species through impingement. The combined cumulative effect of these projects has the potential to result in effects of a greater extent than the individual projects taken alone. The proposed project includes compensatory mitigation for impacts to fish and wildlife resources that have been sized and designed to achieve no net loss in habitat function. Similarly, current and future projects, including those discussed above, will be required to secure permits for any impacts to fish and wildlife resources. As such, they would be required to implement a mitigation sequencing process that would result in impacts being avoided and minimized to the extent practicable, and would be required

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to provide compensatory mitigation to achieve the standards for no net loss of function. For these reasons, while the project will contribute incrementally to the cumulative impact to fish and wildlife resources within Grays Harbor, no mitigation is required to offset any cumulative impacts. e. List any invasive animal species known to be on or near the site. There are no invasive terrestrial animal species known to be on or near the Project Site or mitigation sites. It is likely that some invasive species that are present in large areas of western Washington, such as the American bullfrog (Lithobates catesbeianus or Rana catesbeiana), could be present. Unpublished data from WDFW reported in the Water Quality Atlas indicates that invasive green crab (Carcinus maenas) were documented east of Bowerman Airport in 2000. There are reports of the invasive New Zealand mudsnail (P. antipodarum) in the Chehalis River, however this species has not been documented near the Project Site or mitigation sites.

6. ENERGY AND NATURAL RESOURCES a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc.

Construction (All Sites) Energy (electric, natural gas, petroleum fuels) will be used during construction activities to power construction equipment. Operations (Project Site): The project will use electric energy to meet the completed project’s needs. The electricity will be provided by Grays Harbor Public Utilities District and will power conveyors, the shiploader, other equipment, and support facilities (e.g., heating, lighting, etc.) needed to operate the site. The site will also include emergency diesel powered generators and fire pumps. These will be used only when power is not available to the site in an emergency or during a fire and during routine testing. The generators will only supply power to safely shut down the facility and not to operate all systems. BHP estimated the energy consumption for the proposed potash export facility for use in the air quality and GHG analysis (Ramboll July 2019). Mechanical equipment will consume 10,552,075 kilowatt hours per year (kWh/yr), the HVAC systems 959,877 kWh/yr, and the electrical, instrumentation and control technology 217,438 kWh/yr. The total energy consumption is estimated to be 11,729,390 kWh/yr. b. Would your project affect the potential use of solar energy on adjacent properties? If so, generally describe. The storage building will be tall enough to create shade on the adjacent property depending on the time of year and day. However, shade from the storage building will not affect potential use of solar energy on adjacent properties as property is either vacant, or the shade will only occur for short periods of the day. Additionally, the position of the building with its long axis running approximately east to west minimizes the size and duration of the shade extending to adjacent properties, with more shade earlier and later in the day during winter months. c. What kinds of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any: Energy conservation measures that will be part of the facility design will include the following.

• Compliance with the Washington State Energy code.

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• Selecting energy-efficient equipment, including electrical motors designed for energy efficiency • Using LED lighting at the site • Directly loading potash from trains to the ships without interim storage when a ship is at berth (eliminates the energy required to convey the potash to the product storage building prior to loading on ships). • Offering incentive programs for employees to commute by other means than car or to carpool. 7. ENVIRONMENTAL HEALTH a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste that could occur as a result of this proposal? If so, describe. The potential for environmental health hazards is discussed in response to the subsections below. The following information addresses the potential environmental impacts of a potash spill (either on dry ground or in/adjacent to waterways) at the Project Site, during transit by rail, or during transit by marine vessel. Because the environmental consequences of a derailment and spill are directly related to the location and the amount of material spilled, impacts affecting the following resources are further addressed in their respective sections of this SEPA checklist.

• Air, Section B.2 • Water, Section B.3 • Plants, Section B.4 • Animals, Section B.5 Because potash is not a hazardous substance, the risks to human health and the environment from a spill are low. Potash Spills: The potential for environmental health hazards resulting from potash being handled by the project is considered minor because potash is non-flammable and non-combustible, and is considered non-toxic to aquatic species. Potash, technically known as potassium chloride (KCI), is a naturally occurring mineral salt and a key ingredient in agricultural fertilizer, including common household garden fertilizers. Potassium chloride is also taken as a nutritional supplement for potassium. Similar to table salt, potash is mildly corrosive to metals and is water soluble, so it requires a dry location for storage. Potash is processed into granular solid particles that are up to 3/16 inch (4 millimeters) in size and range from pink to red in color. Potash is not a hazardous material and the proposed facility will not produce any type of hazardous waste as regulated by 40 C.F.R. Part 261. Because it is not considered a hazardous material, potash is not subject to the Emergency Planning and Community Right-To-Know Act or Comprehensive Environmental Response, Compensation and Liability Act. Potash does not contain any TAPs or hazardous air pollutants (HAPs). Health hazards posed by potash to humans are associated with airborne dust and particulates (not TAPs or HAPs). The project is designed to avoid and minimize the risk of potential discharge of dust on site and in compliance with air quality regulations governing the discharge of dust (as a pollutant) to the environment. To protect human health, typical personal protective equipment is used in enclosed spaces when dust is present. This measure is considered adequate by both the industry and health regulators to sufficiently protect human health in this scenario.

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The project is also designed to avoid and minimize the risk of spills on and off site. See Section B.7.a.5 (proposed measures to reduce or control environmental health hazards) for more information. Environmental Impacts of a Spill A potash spill on dry ground (whether at the Project Site or during transit by rail) would have a negligible effect, as spilled potash would be limited in area and can be recovered by typical methods (mechanical or manual equipment, including brooms and dustpans, shovel, vacuum truck, and/or backhoe) and then recovered or disposed of properly. Impacts would be limited to the area where the spill occurs. High concentrations of potash in soil can lead to reduced fertility but these affects will be minimized and mitigated by recovering spilled potash and potentially excavating and replacing top soil, if needed. The effects of a potential potash spill in water (either by a direct spill or a spill on dry land carried to water) are expected to be minimal, as potash dissolves rapidly in water and is nontoxic (United Nations Environment Programme, Organisation of Economic Co-operation and Development Screening Information Dataset, Potassium Chloride, 30 March 2003). Potash is an ionic compound that dissociates into potassium and chloride ions in water. There is limited ability to recover potash spilled directly into water because it dissolves rapidly. Some potash spilled to water may be able to be partially recovered through manual means before it dissolves completely, depending on the size of the spill and nature of the waterbody. Potential effects of a spill of potash to either a freshwater or marine aquatic system would be a temporary, localized increase in salinity. Increased salinity can affect osmoregulation in both freshwater and marine species that are intolerant to salinity changes. In a closed freshwater system, this could result in effects to species that are unable to avoid areas of elevated salinity. In a flowing freshwater system, the effect would be reduced somewhat by mixing as the higher saline concentrated water moves downstream. In the estuarine system, mobile aquatic species would be expected to temporarily avoid areas of highly saline water. Marine waters surrounding the terminal exhibit dynamic fluctuations in salinity due to the site’s proximity to the mouth of the Chehalis and Hoquiam Rivers and tidal flux and currents. Localized and temporarily elevated salinity levels would rapidly equilibrate within the harbor, particularly given the estimated flushing rate of between 0.6 days and 5 days (American Society of Limnology and Oceanography, Inc. 1979). Potassium ions are naturally abundant in marine and estuarine waters. Grasso et al (1994) evaluated the impact of sodium and potassium on environmental systems and found that potassium chloride may have less environmental impact to aquatic systems than sodium chloride. Potassium is not typically a limiting nutrient in aquatic systems, and temporarily elevated potassium concentrations would not be expected to affect aquatic vegetation growth rates. A study completed by the US Department of the Interior modelled a spill of potash as part of an evaluation of the risk of chemicals used in the Gulf of Mexico for oil and gas industry operations. The study modelled a spill of 4,717 kg (app 10,400 lbs.) of KCl to the marine environment and the results showed that a spill of that size would not exceed the aquatic toxicity threshold (Boehm et al. 2001). Potash Spill at Project Site Spills at the Project Site could result from equipment malfunction or operator error and result in small amounts (from trace amounts to pounds) of potash reaching the ground surface. This could occur at transfer points in transfer process and in handling of off-spec materials. Spills at the Project Site would be cleaned up and disposed of with on-site equipment and there is limited potential that potash could reach surface or groundwater. Potash can be dissolved and carried into aquatic systems, such as wetlands, through contact with precipitation (Herbert et al 2015). However the Project Site has been designed to avoid this potential contamination by preventing the exposure of potash to precipitation

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through the use of dust control devices and covered storage area and conveyors. In addition, stormwater from structures and developed areas at the Project Site will be collected and treated before discharge. In the event of a spill with the potential to contaminate stormwater, the stormwater flow would be controlled/diverted to prevent contact with potash. Should stormwater be contaminated with potash from a spill or release) it would not be allowed to discharge to the stormwater system. Potash Spill during Rail Transit Loaded trains traveling to the facility could have an incident (including derailment) that could result in loaded potash cars being damaged and, depending on the damage, a subsequent release of potash to the environment. Derailments can occur on mainline tracks and in railyards. Most derailments occur in yards where trains are switched, however that does not occur with unit trains. The potential for a spill is related to risk of derailment and the speed of the train. A slow moving train involved in a derailment would have a smaller risk of a spill. Trains traveling through a train yard in Aberdeen, Hoquiam, or on the Project Site will be travelling at low speeds (per existing regulations), and would therefore have a low risk for a derailment-related spill. Ecology conducted a study titled “2014 Marine and Rail Oil Transportation Study” (Ecology 2015), which analyzed the risks to public health and safety and to the environment associated with the transport of oil in Washington. Although the study focused on the transport and spills of oil (which, unlike potash, is a hazardous material), the report assessed rail hazards that are also applicable to the transport of potash or any other commodity by rail. Ecology estimates that there are 0.0046 annual mainline derailments per track mile in the U.S. or one mainline derailment for every 3.85 billion tons of freight moved. Approximately half of those derailments occur in rail yards or auxiliary tracks as noted previously (Ecology 2014). There have been an average of 45 derailments per year in Washington State between 2006 and 2013. More than 62 percent of those derailments occurred in rail yards, where speed is generally limited below 10 mph. Not every derailment results in a spill, and derailments that occur in rail yards at low speeds have a lower the likelihood of a larger spill or a spill in water (as the material can be more readily cleaned up). Ecology noted that the number of derailments has decreased in recent years, even with the addition of crude-by-rail trains to the system (Ecology 2014). During transit from the mine to the Project Site, trains transporting potash will utilize existing rail lines that cross over and run adjacent to waterbodies in the U.S. and Canada. Along the PSAP rail line there are multiple stream crossings and approximately 17 percent of the route is proximate to the Chehalis River (ICF 2016). If a derailment were to occur within these areas there is a risk that potash could reach a waterbody if a derailment occurred directly at the waterbody crossing. If a car were damaged, potash could spill out of the opening until the level of material in the car reached a point below the opening. The rate of spill and amount would be dependent on the location and size of opening in the car. Most waterbodies to be crossed are small, the railroad line is not located directly on the Chehalis River except for limited short distances and the potash will be transported in a granular form, and therefore does not flow out of an opening in a container in the same manner as a liquid product. The risk of environmental impacts from a larger spill is greater if a derailment were to occur near or over a larger body of water. Trains crossing bridges would not likely result in cars entering the waterbody as the bridge structure would contain the car and prevent it from entering the waterbody. As with other spills, the rate and amount of spill would be dependent on the location and size of opening in the car. The risk of an entire car or multiple cars reaching a waterbody is very limited as there are only limited stretches where tracks run parallel and proximate to major waterbodies. In addition, as previously noted, the majority of derailments occur in rail yards with little risk for spills to the aquatic environment.

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Lastly, potash is a granular substance and does not “flow” from a container opening in the way that a liquid would. Potash Spill during Marine Vessel Transit Potash is not listed in the hazardous materials shipping regulation (49 CFR, Table 172.101) by the U.S. Department of Transportation as it relates to marine transport. Potash is classified as Group C per the International Maritime Solid Bulk Cargoes (IMSBC) code. Class C cargos are defined by the IMSBC code as “cargoes which are neither liable to liquefy nor possess chemical hazards.” Intentional disposal of potash in the sea is prohibited by the Marine Protection, Research and Sanctuaries Act (Ocean Dumping Act). There is risk that potash could accidentally be spilled and enter surface waters if the spill occurs directly into a waterbody from a loaded vessel in transit. Vessels are designed to contain the product, however, and such a spill would be the result of an unanticipated accident. Potash spills to water would be reported to Ecology because it would be considered a pollutant (when not being intentionally applied as a crop nutrient) under RCW 90.48.080. Potential incidents associated with vessels include grounding (ship encounters bottom due to inadequate water depth), collisions with other vessels and allisions (vessel striking a fixed structure). These incidents could breach the vessel hull and allow potash to spill directly to the water or allow water into the vessel, dissolve the potash and then flow back out the breach. The risk of hull damage resulting in a potash release is minimized by nature of the vessels that will be used for the facility. This vessels have multiple separate holds and typically a double bottom that reduce the consequences of damage to the vessel and extent of cargo release in the case of an incident. The risk of a significant incident in Grays Harbor is low based on the sand and mud composition of the substrate and the two way nature of the navigation channel. A vessel running aground would likely encounter a soft bottom or side of the channel which would reduce the potential of hull damage and resulting release. The only significant fixed objects between the Project Site and the open ocean are the jetties and other shoreline protection measures (e.g., groins north of Westport) at the mouth of the harbor. The risk of a collision is minimized by the lack of cross traffic (deep draft vessels only transit in the channel) and if a collision occurs it would likely be bow to bow or a glancing strike reducing the risk of a breach of a cargo hold. The duration and magnitude of the effects of a potash spill would be highly dependent upon the volume of material spilled, and the volume, flow, and salinity of the receiving water. A large spill (loss of cargo hold or entire vessel) from a fully loaded vessel to estuarine waters in the harbor would likely result in effects associated with elevated salinity, but such a spill is considered to be highly unlikely to occur for the above-mentioned reasons. Ecology conducted a risk assessment for oil spills from commercial vessels in Grays Harbor, and vessel risk assessment, titled “Grays Harbor Vessel Traffic Risk Assessment” (Ecology 2018). The report stated that commercial vessel incidents are rare events within Grays Harbor. Although focused on oil spills, the report assessed hazards applicable to the marine transport aspect of the proposed project, including hazards to navigation and vessel incidents (e.g., collision, allision, grounding, flooding, fire/explosion, structural failure). The assessment took into consideration the vessel traffic associated with the proposed potash export facility, and identified recommendations if vessel traffic in the harbor is higher in the future than it is today. Recommendations address the following topics: aids to navigation, anchorages, the Bar and approaches, currents, response to fire/explosion, fishing vessels and fishing gear, the Harbor Safety Plan, offshore traffic, and hydrographic survey needs. Ecology and the Grays Harbor Safety Committee (along with other stakeholders) continue to monitor increases in vessel traffic and development in the region, and will enact recommendations when they deem them necessary based on traffic/development levels.

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Fuel Spills A diesel-fueling pad and associated diesel-fuel aboveground storage tanks will be located adjacent to the facility administration building to fuel equipment and vehicles on site. The risk of a spill from this facility would be minor considering that it will consist of a double-walled tank located within a containment areas. The storage volume is small and any leaks would be readily detected and captured either in the double-walled tank or in the containment area. Vehicles operating on site could also result in leaks or spills. Fuel volumes would be low and spill response kits would be readily available on-site to respond to any spill minimizing the potential risk to the environment. Any spill would be required to be reported to Ecology. Trains and vessels serving the proposed project will be fuelled by diesel or other liquid fossil fuel. There is a potential for a spill of these fuels should an incident occur in transit. The marine vessels serving the facility carry large quantities of fuel. A fuel release could occur if an incident occurred which resulted in a breach of the vessels fuel tanks. Spills from these types of vessels are relatively rare events. Ecology data for 2007–2017 show only a 1-gallon hydraulic oil spill from a cargo ship in 2011 from a large marine vessel. All commercial vessels serving the facility are required to maintain a vessel response plan including an oil spill response plan (RCW 88.46, WAC 173-182). Based on the limited number of incidents and the planning and spill response equipment available impacts from fuel spills related to marine vessel is not reasonably likely to occur. Fuel spills could also occur if locomotives collide or derail and damage fuel tanks. If a release of fuel were to result from a collision or derailment response and clean up measures would be undertaken as required by the federal and state law, including Washington State regulations under RCW 90.56. The frequency and magnitude of spills cannot be predicted but is not reasonably likely to occur with the project. 1. Describe any known or possible contamination at the site from present or past uses. Project Site: A Phase 1 Environmental Site Assessment was conducted to determine the potential to encounter contaminated materials from past fill and industrial activities (BergerABAM 2017). Subsurface investigations (BergerABAM, 2017 and 2018) were subsequently conducted to evaluate soil and groundwater conditions at the site. Dioxins/furans were encountered in site soil at concentrations greater than Model Toxics Control Act (MTCA) B criteria in soil samples collected on the northwest portion of the site in June 2018. Quarterly groundwater monitoring has been in progress at the Project Site since March 2018. Dissolved arsenic, and dioxins/furans with concentrations greater than MTCA Method A, B and/or C criteria were encountered in groundwater samples collected at the site. The concentrations of these constituents to date appear to exhibit seasonal fluctuations. Potential sources of the arsenic and dioxin/furans detected in groundwater at the site could include non-point on and/or off-site sources, such as the use of agricultural fertilizers and pesticides or fill materials at the site, or contaminated groundwater that has migrated from upgradient areas. Historical facilities that operated at the site include a former timber mill and log storage area. A log storage and sorting area occupied the north and northwest portions of the site during the timber mill operations. Dioxins/furans in soil could result from historical burning of wood or wood waste associated with the mill operations. Additionally, the site was filled using dredge material from Grays Harbor and the Chehalis River navigation channel. There is the potential that the dioxins/furans present in site soil

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could be from the dredge material placed at the site resulting from historical operations of pulp and paper mills in the area. The Port (current site owner) is working directly with Ecology regarding these findings. The Port’s consultant is working on a Conceptual Soil Management Plan for the Project Site and IDD#1 in Hoquiam. The plan will provide an overview of how impacted soils will be managed during development of the Project Site and mitigation at IDD#1. A hazardous materials management plan will be completed prior to construction that will outline soil and groundwater handling, management, and disposal protocols to be followed during construction to prevent contaminant releases that could impact human health and the environment. BHP will work with the Port to insure that any Ecology requirements, if applicable, are also followed during construction. Mitigation Sites: There is no known or anticipated contamination at either Terminal 4 or the Hoquiam River Preservation Site. There is low potential of environmental health hazards resulting from the mitigation at Terminal 4 due to the nature of activity that is limited to pile and structure removal, and which results in limited disturbance to soils and sediment. An SPCC plan will be employed at the Terminal 4 and IDD#1 site during construction activities, and no hazardous materials would be needed or kept on site once the mitigation activities have concluded. IDD#1 A Phase 1 Environmental Site Assessment was conducted at IDD#1 to determine the potential to encounter contaminated materials from past fill and industrial activities (BergerABAM 2017). Subsurface investigations (BergerABAM, 2017 and 2018) were subsequently conducted to evaluate soil and groundwater conditions at the site. cPAHs and dioxins/furans were encountered at concentrations greater than MTCA criteria in soil samples collected from the southwest and northeast portions of the IDD#1 site. Dissolved arsenic, selenium and dioxins/furans were detected at concentrations greater than applicable MTCA criteria in groundwater samples collected from the monitoring wells at the site. Groundwater concentrations of these constituents appear to exhibit seasonal fluctuations based on one year of quarterly monitoring and at some times during the year exceed MTCA Method A, B and/or C and Chronic Marine and/or Freshwater Aquatic Life Criteria. The Port (current property owner) is working directly with Ecology regarding these findings. A hazardous materials management plan will be completed prior to construction, which will outline soil and groundwater handling, management, and protocols to be followed during construction to prevent contaminant releases that could impact human health and the environment. BHP will work with the Port to ensure that any Ecology requirements, if applicable, are also followed during construction. Potential sources of the arsenic and selenium detected in groundwater at the site could include non- point off-site sources, such as the use of agricultural fertilizers and pesticides that migrated through rainwater and groundwater from upgradient of the site. The soil sampling results did not indicate the presence of an on-site source for arsenic and selenium as there were no metals exceedances of applicable criteria in any of the soil samples collected at the site. Historical facilities that operated or were present on the north and northeast portion of the site include a former wood mill, electric plant, and shantytown. The cPAHs exceedance in one soil sample (TP-16) may be the result of treated wood debris and/or historic fires (e.g., associated with the shantytown cooking, heating or waste burning fires, and/or hog fuel burning associated with the mill). Similarly,

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dioxins/furans in soil could result from historical burning of wood or wood waste either associated with the mill operations or the shantytown. The Constituent of Concern exceedances for cPAHs and dioxins/furans in the soil samples at the site are likely the result of the incorporation of wood waste and/or demolition debris from the former shantytown into the backfill on portions of the site. 2. Describe existing hazardous chemicals/conditions that might affect project development and design. This includes underground hazardous liquid and gas transmission pipelines located within the project area and in the vicinity. There are no existing hazardous chemicals or conditions at the Project Site, IDD#1, or Terminal 4 (excluding known contamination as detailed in the response above). According to the National Pipeline Mapping System, there are no underground hazardous liquid or gas transmission pipelines (or associated easements) located within the project area (the only pipeline mapped in Grays Harbor County is the natural gas transmission line serving the Grays Harbor Energy power plant near Satsop). 3. Describe any toxic or hazardous chemicals that might be stored, used, or produced during the project's development or construction, or at any time during the operating life of the project. Construction (All Sites): Construction equipment will use petroleum-based fuels and petroleum- or vegetable-based lubricants. The contractor will prepare and implement a SPCC plan to avoid, minimize, and, if necessary, respond to fuel and lubricant releases during construction. Toxic or hazardous chemicals will be stored within containment. Basic safety measures for storage of any chemicals are detailed on the individual safety data sheets, and BHP will follow those prevention, response, and storage directions. Operation (Project Site): The type of potash to be stored at the facility (KCl) is not considered or classified as a toxic or hazardous chemical. 4. Describe special emergency services that might be required. Construction (All Sites): Fire, medical, or spill cleanup services might be required during construction. These are typical of all construction activities. Otherwise, no special emergency services are required for the proposed project. Operation (Project Site): No special emergency services are anticipated to be required. BHP will be responsible for any emergency maintenance should the need arise. Spill avoidance and response plans will be developed for both construction and operations, as detailed in the response to the following section. 5. Proposed measures to reduce or control environmental health hazards, if any. Construction Mitigation (All Sites): During excavation on the Project Site and the IDD#1 Site, soils may be encountered that have the potential to contain contaminants. Areas of contaminated soil identified at the site during previously completed investigations (BergerABAM, 2017 and 2018) will be removed where the mitigation design overlaps those locations. The contaminated material will be removed and disposed of to design elevations and/or any remaining contaminated soils would be over-excavated and capped consistent with state and federal regulatory requirements. The Port of Grays Harbor is currently coordinating with Ecology’s Toxics Cleanup Program regarding the known contamination in soil at the site.

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A hazardous materials management plan will be completed prior to construction and implemented during construction in the event that unanticipated contaminated material is encountered during construction. Soils at the site will be monitored, and any soils that require cleanup or special handling because of contamination or other considerations will be handled and disposed of in accordance with relevant state and federal laws. Project construction will be completed in compliance with Washington State Water Quality Standards (WAC 173-201A), including • Petroleum products, fresh cement, lime, concrete, chemicals, or other toxic or deleterious materials will not be allowed to enter surface waters or onto land where there is a potential for reentry into surface waters. • Fuel hoses, oil drums, oil or fuel transfer valves, fittings, etc., will be checked regularly for leaks, and materials will be maintained and stored properly to prevent spills. • The contractor will prepare an SPCC plan, and it will be used during all in-water demolition and construction operations. A copy of the plan will be maintained at the work site. • The SPCC plan will outline BMPs, responsive actions in the event of a spill or release, and notification and reporting procedures. The plan will also outline management elements, such as personnel responsibilities, Project Site security, site inspections, and training. • The SPCC plan will outline the measures to prevent the release or spread of hazardous materials found on site and encountered during construction but not identified in contract documents, including any hazardous materials that are stored, used, or generated on the construction site during construction activities. These items include, but are not limited to, gasoline, diesel fuel, oils, and chemicals. • Applicable spill response equipment and material designated in the SPCC plan will be maintained at the job site. Other miscellaneous chemicals (e.g., motor oil/lubricants and cleaners) used for equipment/site maintenance will be handled and stored in accordance with a site-specific SPCC plan and SWPPP. Typical construction BMPs for working in, over, and near water will be applied, including activities such as the following.

• Checking equipment for leaks and other problems that could result in the discharge of petroleum- based products or other material into waters of Grays Harbor. • Corrective actions will be taken in the event of any discharge of oil, fuel, or chemicals into the water, including − Containment and cleanup efforts will begin immediately upon discovery of the spill and will be completed in an expeditious manner, in accordance with all local, state, and federal regulations. Cleanup will include proper disposal of any spilled material and used cleanup material.

− The cause of the spill will be ascertained and appropriate actions taken to prevent further incidents or environmental damage. − Spills will be reported to the Ecology’s Southwest Regional Spill Response Office.

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• Excess or waste materials will not be disposed of or abandoned waterward of ordinary high water or allowed to enter waters of the state. Waste materials will be disposed of in an appropriate manner consistent with applicable local, state, and federal regulations. • Demolition and construction materials will not be stored where wave action or upland runoff can cause materials to enter surface waters. • Oil-absorbent materials will be present on site for use in the event of a spill or if any oil product is observed in the water. • The following Pile removal BMPs will be followed: − While creosote-treated piles are being removed, a containment boom will surround the work area to contain and collect any floating debris and sheen. Any debris will be retrieved and disposed of properly.

− The piles will be dislodged with a vibratory hammer when possible and will not be intentionally broken by twisting or bending.

− The piles will be removed in a single, slow, and continuous motion in order to minimize sediment disturbance and turbidity in the water column.

− Removed piles, stubs, and associated sediments (if any) will be contained on a barge. If piles are placed directly on the barge and not in a container, the storage area will be contained by a row of hay or straw bales, filter fabric, or similar material placed around the perimeter of the barge.

− All creosote-treated material, pile stubs, and associated sediments (if any) will be disposed of by the contractor in a landfill approved to accept those types of materials. On-site concrete placement will follow appropriate BMPs, including

• Wet concrete will not come into contact with surface waters. • Forms for any concrete structure will be constructed to prevent leaching of wet concrete. • Concrete process water will not be allowed to enter the bay. Any process water/contact water will be routed to a contained area for treatment and will be disposed of at an upland location. Operation Mitigation (Project Site): The following measures reduce the risk of spills and release of dust:

• During transit, rail cars and ships are completely enclosed • Rail cars are unloaded in an enclosed building with bag houses to control dust • Material handling and storage is enclosed and dust control (baghouses and bin vents) will be installed at the transfer points and for the shiploader • Conveyors have spill pans and covers to prevent fugitive dust generation. • Spill pans will be cleaned by vacuuming. • Transfer tower foundations will include curbs with sumps that are separate from the stormwater system. Any spills will be first vacuumed and then washed into sump for removal by vacuum truck. • The shiploader includes a telescoping spout that extends to the bottom of the ship’s hold to avoid long product drops and dust generation.

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• Shiploader boom is positioned over vessel before conveyors are started. Conveyors will not run while extending or retracting onto vessel. Any residual material on belt would be deposited in a container or vessel hatch cover. • The shiploader will also include instrumentation, such as radar, lasers, etc., which, combined with the automated control system, will prevent conveyors from operating unless they are over a vessel hold, thereby preventing accidental discharge of potash into the environment. • Operations will require belts to be completely discharged into vessel holds prior to removing the shiploader booms from over a vessel. Fueling Station A diesel-fueling pad and associated diesel-fuel aboveground storage tanks will be located adjacent to the facility administration building to fuel equipment and vehicles on site. The project has been designed to avoid and minimize impacts associated with leaks or spills from on-site fueling operations and aboveground storage tanks. The fueling station will be covered with a metal roof. The fueling pad and tanks will be constructed on an impermeable concrete base, and the tanks will be located within a concrete secondary containment berm sized to hold 110% of the volume contained in the largest tank in the event of a rupture or spill, in accordance with Section S9.D.9 of Ecology’s Construction Industrial Stormwater General NPDES Permit. The site-specific SPCC plan and site spill kits will also be designed to prevent or minimize impacts from potential spills. Other miscellaneous hazardous material used for equipment/site maintenance will be handled and stored in accordance with a site-specific SPCC plan and SWPPP. Contamination BHP will work with the Port to ensure any contaminated material encountered or disturbed during construction is handled appropriately following Ecology guidance. Cumulative Impacts - Mitigation: The mitigation measures listed above will minimize and mitigate the proposed project’s contribution to cumulative risks associated with environmental health. The North Shore Levee project, by its nature, would not be expected to result in impacts to environmental health beyond the immediate project area, and when considered in the context of the proposed project would not result in cumulative effects. The Contanda Project presents different environmental health risks due to the nature of the materials that specific project will handle (i.e. bulk liquids including petroleum diesel, gasoline, ethanol, and others), which unlike potash are considered hazardous materials. The potential environmental health impacts from the Contanda Project are not cumulatively significant when combined with the Proposed Project because the probability of spills is low for both projects, and both projects include measures to be implemented in the event of an accidental spill. For these reasons, no mitigation is required to offset any cumulative impacts to environmental health. b. Noise 1. What types of noise exist in the area which may affect your project (for example, traffic, equipment operation, other)? Types of noise that exist in the area include rail and marine shipping traffic, air traffic at the adjacent airport, and vehicle traffic. The primary source of noise on the Project Site is from activity at the log chipping operation. This noise would not affect the construction or operation of the project as it does not include activities that are sensitive to noise.

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2. What types and levels of noise would be created by or associated with the project on a short-term or a long-term basis (e.g., traffic, construction, operation, other)? Indicate what hours noise would come from the site. A technical analysis of noise associated with construction and operation was conducted and the results are provided in the Noise Assessment (Ramboll December 2017). All noise sources, including trains arriving and departing the facility, were included in the assessment. All noise-sensitive land uses were evaluated, including the GHNWR, the high school and elementary school, John Gable Park, and residential areas. The analysis found that project-related increases over existing sound levels are not expected to result in significant noise impacts. Most nearby receivers would experience no impacts in the future with the facility, while residences very near the off-site rail line may experience moderate noise impacts. The export facility and related rail activity are not expected to result in significant noise impacts at sensitive receivers near the site (e.g., GHNWR, the high school, and residential areas), and the proposed facility is expected to comply with WAC noise limits. The Biological Evaluation (WSP May 2019) document shows that peak and cumulative underwater noise levels are not expected to rise to levels where injury to fish or marine mammals would occur. A summary of the analysis and results follows. Construction Noise: Noise from construction would include underwater and terrestrial noise originating from site preparation, construction of the on-site rail line and facilities, and construction of the wharf, including pile driving and dredging. Construction activities/equipment and pile driving would occur during daylight hours on a short-term basis. Should the project require nighttime construction (currently not anticipated), BHP or the contractor would obtain any required noise variances and would comply with any applicable nighttime noise provisions. Impacts to Humans Noise from construction activities during daylight hours (7 a.m. to 10 p.m.) is exempt from state- established noise limits. Construction noise emitted during nighttime hours (10 p.m. to 7 a.m.) would need to be controlled to enable compliance with the stricter nighttime noise limit of 50 decibels (dBA) at off-site residences if nighttime construction is proposed. Additionally, night time construction occurring between 8 p.m. and 7 a.m. would need to be controlled such that it does not result in readily audible, frequent, repetitive, or continuous noise at nearby residential locations. Construction workers would be outfitted with hearing protection equipment as needed to meet health and safety standards. Impacts to Wildlife Terrestrial Noise and Wildlife The portion of the GHNWR that is identified in WDFW PHS data as supporting priority concentrations of shorebirds and waterfowl could experience elevated terrestrial noise levels during impact pile driving at the Project Site. No work of any kind is proposed within the GHNWR itself. Terrestrial noise generated during impact pile driving and other construction and operation activities could be elevated above background levels within a maximum distance of approximately 3,200 feet. Peak terrestrial noise generated during impact pile installation has been estimated to be approximately 110 decibels (dBA), measured at 50 feet (FTA 2006). The GHNWR is located over 2,000 feet from the location of the proposed pile-driving activity associated with the shiploaders, and terrestrial noise will have attenuated by the time it reaches the GHNWR.

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The noise assessment shows that the estimated sound levels of pile driving are 69 dBA and 59 dBA at the nearest sensitive receivers. While no specific noise-response levels have been established for shorebirds, these levels are below the levels established by the USFWS for injury or disturbance of ESA- listed species, such as marbled murrelet. Pile driving activities would be temporary and restricted to daytime hours, minimizing potential impacts. Wildlife within the area of elevated noise may avoid the area or exhibit startle responses during periods of loud construction noise. As noted previously, wildlife in the area already experience noise disturbances from existing sources, including rail and vehicle traffic, marine vessels, and industrial activities such as the wood-chipping facility. Elevated terrestrial sound can also have masking effects for marbled murrelet, in which communication between birds is compromised. The distance within which masking effects could potentially occur with impact installation of 48-inch steel piles is approximately 551 feet (168 meters). No injury or disturbance thresholds have been established for marbled murrelet associated with vibratory pile driving, and marbled murrelets are not expected to be significantly affected by underwater or terrestrial noise associated with vibratory pile installation or removal activities. The project will implement a bubble curtain or similarly effective noise attenuation device during all impact pile proofing or installation. The bubble curtain will be consistent with standard NOAA Fisheries/USFWS bubble curtain specifications. Terrestrial noise generated during impact and vibratory pile driving and other construction and operation activities could be elevated above background levels within a maximum distance of approximately 3,200 feet, while underwater construction noise could potentially be elevated throughout areas of Grays Harbor within underwater line-of-sight of pile driving at the berth. Underwater Noise and Wildlife The Biological Evaluation (WSP May 10, 2019) shows that the baseline underwater noise level in the portion of Grays Harbor that is within the proposed project area is conservatively assumed to be approximately 120 dBRMS (WSDOT 2019), although actual background underwater noise levels may be higher, given the amount of vessel activity. 11 Underwater sound generated by percussive pile driving has the potential to affect fish in several ways. The range of effects potentially includes alteration of behavior to physical injury or mortality, depending on the intensity and characteristics of the sound, the distance and location of the fish in the water column relative to the sound source, the size and mass of the fish, and the fish’s anatomical characteristics (Popper and Hastings 2009). During impact pile driving and/or proofing, the cumulative underwater noise thresholds for barotrauma (208 dBSEL) and auditory injury (202 dBSEL) could be exceeded to distances of approximately 282 feet (86 meters) and 705 feet (215 meters), respectively. Pile installation will be performed to the greatest extent possible using a vibratory hammer, though piles may need to be driven to final tip elevation or proofed, as necessary, with an impact hammer. Proofing is the process of striking piles with an impact hammer to verify their load-bearing capacity. The proposed action has been designed to minimize the likelihood of any impacts resulting from pile installation activities. During the in-water work period, adult and/or juvenile salmonids, bull trout, or green sturgeon, and adult or larval Pacific eulachon could potentially be present within the action area. Run timing within the action area is different for each of these species, but it is possible that they could

11 RMS=root mean square

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be present within the action area, and could be exposed to temporarily elevated underwater noise levels resulting from pile driving. The current NOAA Fisheries noise thresholds for injury to fish (due to pile driving) are as follows (Caltrans 2012):

• Peak pressure of 206 dBPEAK • Sound exposure level (SEL) of 187 dBSEL for fish greater than or equal to 2 grams • Sound exposure level of 183 dBSEL for fish less than 2 grams

Current NOAA Fisheries thresholds for disturbance to fish are represented as an average pressure, or root mean square (RMS). The threshold for behavioral disturbance is 150 dBRMS re: 1 μPa (Caltrans 2015). The areas within the action area that experience sound pressure levels exceeding the peak and SELs for injury will be referred to as the “injury” zone, while those areas exceeding 150 dBRMS re: 1 μPa for disturbance will be referred to as the “disturbance” zone. The noise attenuation analysis conducted for this project indicates that the peak underwater noise level generated during impact pile driving is estimated to not exceed 206 dBPEAK within any portion of the action area. For this reason, ESA-listed fish are unlikely to be exposed to any single strike peak sound pressure levels that exceed the peak injury threshold. The worst-case estimate of up to 5,000 strikes per day that may be necessary to proof the 48-inch steel piles could result in exceedances of the cumulative underwater noise injury thresholds for fish greater than 2 grams (187 dBRMS) and for fish less than 2 grams (183 dBRMS) within approximately 7,057 feet (2,151 meters) and 7,067 feet (2,154 meters) of pile-driving activity, respectively. Given the nature and anticipated use of the habitat, most fish are expected to be temporarily moving through the portion of the action area where the cumulative injury thresholds could potentially be temporarily exceeded, as opposed to remaining in the area for an extended period of time. For this reason, ESA-listed fish are not expected to be exposed to the sound from all 5,000 strikes in a given day. However, it is possible that some fish present in the vicinity could be exposed to levels of cumulative underwater noise that exceed the injury threshold. Adult and juvenile bull trout and green sturgeon, and adult, juvenile, and larval Pacific eulachon could potentially be exposed to underwater sound pressure levels above the 150 dBRMS disturbance threshold throughout the aquatic portion of the action area. This has the potential to result in behavioral responses that could include temporary avoidance of the area, changes in migratory routes, or interruption of reproduction. While these behavioral responses could potentially affect some individuals, these disturbance-level effects would not be expected to rise to the level of significance. NOAA Fisheries has established Level A (injury) and Level B (disturbance) thresholds for marine mammals. Level A injury of marine mammals associated with underwater noise can occur either through peak sound pressures, or through accumulated sound pressure. The peak sound pressure thresholds established under the new guidance for low frequency cetaceans (219 dB) would not be exceeded during any project activities. The results of the model indicate that the Level A threshold for cumulative sound pressure exposure of low frequency cetaceans could potentially be exceeded out to a distance of approximately 13,025 feet (3,970 meters) during impact pile driving activities, to a distance of approximately 341 feet (104 meters) during vibratory pile driving, and to a distance of approximately 56 feet (16.9 meters) during vibratory timber-pile removal.

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In addition, the 160 dB Level B harassment threshold (behavioral disruption during impact pile driving) could also be exceeded throughout the aquatic portion of the action area during impact pile driving. Similarly, the 120 dB Level B harassment threshold could be exceeded throughout the aquatic portion of the action area during vibratory pile installation. During vibratory removal of timber piles, the 120 dB Level B harassment threshold could be exceeded to a distance of approximately 3.36 miles (5,411 meters), or to the point of nearest landfall. BHP will either secure an Incidental Harassment Authorization (IHA) for potential incidental harassment of non-ESA-listed marine mammals prior to construction, or will implement a marine mammal monitoring plan that would monitor for the presence of marine mammals and alter construction activities to avoid exposing non-ESA-listed marine mammal species to levels of underwater sound that could otherwise result in injury or harassment. Operation Noise (Project Site): The type of noises associated with this project include operation of on-site equipment, rail traffic, vehicle traffic, dredging, and shiploading. The facility will operate at all hours and noise from daily operations, could occur sporadically at any time of day. Noise from the proposed project is subject to compliance with the standards of WAC 173-60, which limits the levels and durations of noise crossing property boundaries. The majority of noise-producing activities will be enclosed in buildings (e.g., product storage building noise, railcar unloading, etc.) and the site layout has been designed to place noise-producing facilities away from the adjacent wildlife GHNWR. The facility is designed to avoid or minimize the need to couple/uncouple train cars, which will eliminate or minimize the loudest noises associated with onsite trains during unloading operations. The unit trains on site will travel at very slow speeds (less than 6 mph), which will minimize both train- related noise and will also reduce the potential for any wildlife interactions. A sound level meter (SLM) measurements were used to evaluate baseline sound levels at four locations in the project vicinity, and to assess the potential for noise impacts due to increases over baseline sound levels. The SLM and noise model receptor (R) locations are shown on Figure 2 of the Noise Assessment, and were selected to capture anticipated noise impacts to a variety of existing uses in the area, as follows:

• SLM1 – Represents a school, parks, and residences north of the Project Site and SR 101, not directly adjacent to the highway. The primary source of noise was traffic traveling on SR 101. This measurement was also used to represent the existing levels at the GHNWR. • SLM2 – Represents residences and the grade school north of the site, adjacent to SR 101. The primary source of noise was traffic traveling on SR 101. • SLM3 – Represents residences east of the site. The noise sources were primarily traffic (both SR 101 and local). • SLM4 – Represents the caretaker residence on the industrial property south of the site. The primary source of noise at this location was activity at the log chipping operation currently on the Project Site. The GHNWR was included in the noise modeling assessment, and SLM1—which is located near the high school—was selected to be representative of noise levels that would be encountered at the GHNWR (see Table 3 of the Noise Assessment). Residential noise levels were considered for the GHNWR as they provide a conservative level of noise sensitivity.

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The lowest-measured day-night average sound level (Ldn) was used to represent the GHNWR, intending to provide the most conservative result. It should be noted that the Ldn was essentially the same at SLM1 (the high school) as at SLM3 (a residential community farther away from the highway). As shown in Table 11, the model-calculated sound levels of continuous on-site sources comply with the applicable noise limits at all off-site locations. Table 11. Modeled Sound Levels of Continuous On-site Noise Sources (Leq/L25, dBA) Receptor Modeled Sound Level (a) L25 Noise Limit R1 43 50 R2 44 50 R3 45 50 R4 43 50 R5 47 50 R6 39 50 R7 39 50 R8 48 50 R9 42 50 R10 41 50

R11 (b) 51 70 Emerson Elementary 39 65 John Gable Park 30 65 Hoquiam HS 1 41 65 Hoquiam HS 2 45 65 GH Natl Wildlife Refuge 43 65

(a)The model-calculated sound levels are estimated as hourly Leqs. Although the noise limits are based on the hourly L25s, all on-site noise sources except the dust collector cleaning air bursts were assumed to operate continuously over an hour period, so the hourly Leq and L25 would be very similar. Therefore, the Leq can be used to estimate the potential L25 due to on-site sources. (b) R11 represents a caretaker residence at an industrial site. Therefore, the applicable noise limit is for an industrial noise source affecting an industrial receiver, or 70 dBA, day and night. Source: Ramboll, Noise Assessment, December 2017

Section 4.2.2 of the Noise Assessment addresses the railcar vibrators and includes quantitative information on the potential noise volumes that could be generated by the equipment. The assessment notes that, regardless of the type or quantity of vibrator selected, the railcar vibrators would be used inside of the railcar unloading building, and the building would be over 1,100 feet away from the nearest off-site sensitive receivers. Therefore, railcar vibrators are not expected to result in excessive sound levels at the nearest receivers to the railcar unloading building. Train and Marine Vessel Horns Two additional sources of short-term noise will be the intermittent train horns and marine vessel fog horns. These two noise sources are dependent on conditions at a given point in time and for operations. Off-site, the use of train horns at public highway-rail grade crossings is subject to established federal transportation rules (49 CFR Part 222) and are exempt from the state established noise limits in WAC 173-60. Existing railroad crossings in the vicinity of the site include four at-grade rail crossings between

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the site and the Hoquiam River to the east. These occur at 8th Street, 5th Street, Maple Street, and Adams Street (Kittelson 2017). Use of locomotive horns at these intersections is dictated by 49 CFR § 222.21 and horns must be sounded at least 15 second prior to the train entering the crossing. The horn noise from the additional trains associated with the proposed project (1.25 trains [2.5 train trips] per day) would be of the same length and noise level as currently required at these crossings. Similar effects would occur at all at-grade crossings along the PSAP line unless the crossing is exempted from the requirement to sound a horn. Horns from marine vessels are subject to federal navigation rules (33 CFR Part 83) which stipulate when vessels must sound their horns for navigation and safety purposes. During times of restricted visibility, vessels are subject to 83 CFR § 35, which stipulates the use of fog horns when a vessel is “in or near an area of restricted visibility, whether by day or night”. It should be noted that nighttime alone does not constitute “restricted visibility,” which is defined as “any condition in which visibility is restricted by fog, mist, falling snow, heavy rainstorms, sandstorms, or any other similar causes” (33 CFR § 83.03). Therefore vessels arriving at the proposed facility, whether at day or night, would only need to sound their fog horns during restricted visibility. Fog can be encountered at any time but conditions of fog are most prevalent in the summer when 3-10 days of fog occur per month (Gray Harbor Safety Committee 2014). Existing marine vessels using the harbor already sound horns and thus this noise is part of the background condition. The proposed project would likely increase the frequency of horn use. The noise assessment concludes that “[t]he proposed facility is expected to comply with the WAC noise limits at all nearby sensitive receiving properties.” Noise from trains, off-site or on-site, while under the control of the railroad operator and engaged in interstate commerce are not subject to the noise limits. When considering potential noise impacts from increases over existing levels, all noise sources, including trains arriving and departing the facility, were included in our assessment. The assessment found that project-related increases over existing sound levels are not expected to result in significant noise impacts. Most nearby receivers would experience no impacts in the future with the facility, while residences very near the off-site rail line may experience moderate noise impacts” (Ramboll December 2017). No specific noise-response levels have been established for shorebirds. However, operation noise has the potential to cause birds or other animals to modify behavior. The proposed facility operations are estimated to increase noise levels to area receptors over existing noise conditions by 7 decibels or less with no expected impact to shorebirds using the GHNWR. The GHNWR will experience only an estimated 2 decibel increase over existing conditions near the east boundary of the GHNWR (Ramboll December 2017). The increase in noise impacting the GHNWR will decrease (less than 2 decibel increase) with distance. It is important to note that birds currently using the ponded areas within the City's former waste water treatment pond are exposed to a number of existing sources of noise and disturbance currently operating within the vicinity, including the existing wood-chipping operation, the airport, fill activities at the pond itself and roadways. The ponded portion of the former Treatment Lagoon is in the process of being filled under separate permit, and will be removed irrespective of the project and will not be available to birds in the future. Vibration Construction Environmental vibration can result from construction activities such as heavy earth moving equipment and pile driving. Both of these activities will occur during construction of the project. The effects of ground‐borne vibration include perceptible movement of building floors, rattling of windows, shaking of

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items on shelves or hanging on walls, and rumbling sounds. In rare cases vibration can result in building damage. The nature and impact of vibration is based on the activity, the distances to structures and activities and the nature of the structure or activity. Because of the relatively large distance to adjacent structures and activities vibration during construction is not anticipated to reach levels of damage and will be short term and temporary in nature. Operations Environmental vibration during operations could occur from train and vehicle operation and from on- site equipment. The proposed project does not include the use of large trucks for operations (other than typical delivery vehicles and vibration would not likely occur from this source. The only mechanical equipment on site during operations with the potential for vibration are the rail car vibrators. This are located above ground and act on the railcar and would not be expected to convey vibration to the ground or be perceptible beyond the unloading area. Rail operations can result in vibration including operation of the locomotive and from the rail cars themselves. The effects of vibration from rail operations is directly related to the speed of the train and the distance to sensitive receptors. The Freight Railroad Administration (FRA) indicates that vibration from freight rail can impact adjacent buildings if less than 50 feet from the track. The new rail infrastructure will not be located within 50 feet of any sensitive land uses and thus no impacts from vibration are anticipated. Those structures or activities proximate to existing rail already experience vibration from existing trains and impacts would be minor. 3. Proposed measures to reduce or control noise impacts, if any: The Project Site is located within the limits of the City, and the City’s noise regulations will apply to the project. Chapter 10.05 of the HMC identifies development standards for land uses. Section 10.05.120 specifies that the noise level standards identified in Chapters 173-60 and 173-62 of the WAC apply to activities in the City. The project will comply with all applicable noise level standards or seek to obtain a noise variance from the City. As part of impact avoidance and minimization, BHP selected a site within previously disturbed, industrially zoned portions of the inner Grays Harbor. This reduces the potential for noise to disturb wildlife and/or residential areas. In addition, the layout of the site was also designed so that noisier equipment (e.g., unloading facility) is sited on the opposite side of the facility from the GHNWR. To reduce construction noise, the construction contractor will maintain construction equipment, with properly functioning mufflers, in good working order. Most construction, including pile driving, would occur during daytime hours. Because of the temporary nature of construction and lower sensitivity to noise during daytime hours, no additional construction noise mitigation is necessary for daytime construction activities. Should the project require nighttime construction (currently not anticipated), BHP or the contractor would obtain any required noise variances and would comply with any applicable nighttime noise provisions. During construction, new piles for the marine terminal will be installed primarily with a vibratory hammer to minimize noise-related impacts to aquatic species. A bubble curtain or other similarly effective noise attenuation devices will be employed during all impact pile proofing or installation. The noise assessment indicates no mitigation is necessary for operational noise from the proposed project because the noise from on-site operations will comply with applicable noise limits (WAC 173-60) using the most stringent nighttime noise limits. The facility will not result in significant noise impacts due to increases over existing levels. Potential impacts to fish (and other ESA-listed species) from

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underwater noise associated with vessels are described in the Biological Evaluation (WSP May 10, 2019), and this analysis acknowledges the potential for behavioral modifications while vessels are present. Potential noise impacts during project operations will be minimized and/or mitigated by the following.

• Outfitting equipment with noise attenuation devices • Designing natural or engineered shielding for facility equipment (e.g., train unloading will take place within a covered structure) • Placing covers over powered equipment where required • Covering conveyors • Covering the train unloading facility • For the project layout, locating noise-producing equipment (e.g., train unloading facility) away from the boundary with the GHNWR Cumulative Impacts - Mitigation Noise produced by current and reasonably foreseeable projects would result in increased noise in the area in several ways. Terrestrial noise would increase along the PSAP rail line due to increased train volumes associated with the proposed project and the Contanda Project. Underwater noise would also increase as a result of increased vessel traffic volumes associated with the proposed project and the Contanda Project. Underwater noise would also increase temporarily during maintenance dredging activities in the harbor (either by the USACE, Port, or other parties). Neither the Contanda Project nor the North Shore Levee Project would involve in water construction activities (e.g. pile driving) that would increase underwater noise in the harbor. Most noise impacts associated with rail traffic would result from train horn noise that is required for public safety, with a limited number from train wayside noise. The noise from shipping vessels (either terrestrial or underwater) associated with the Contanda and the BHP projects would represent an incremental increase when combined with the existing baseline levels of vessel traffic within the harbor. Increased vessel traffic in Grays Harbor, associated with either Contanda or the BHP Project, would not significantly increase noise levels and would do so on a temporary basis. The extent of any potential cumulative impact of noise associated with vessel traffic will be limited, given the number of vessels produced by the two projects (5 vessels per week, combined) in comparison to existing vessel traffic (7 vessels). The nearest terrestrial noise-sensitive receptors are approximately 2,000 feet from the navigation channel (birds at the GHNWR), and impacts from vessel noise would be negligible. The position of the facility in the central harbor will also limit the distance that incoming vessels will need to travel in the Navigation Channel. Project vessels will not need to travel into the inner reaches of the harbor. For this reason, while the project will contribute incrementally to the cumulative amount of noise along the PSAP rail line and within Grays Harbor, no mitigation is required to offset any cumulative impact. Local communities along the rail line have the opportunity to apply for a quiet zone to limit train horn sounding from the FRA.

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8. LAND AND SHORELINE USE a. What is the current use of site and adjacent properties? Will the proposal affect current land uses on nearby or adjacent properties? If so, describe. Project Site: The central and west areas of the Project Site comprise the Port’s Terminal 3 property, which was historically used as a log storage and export facility by Rayonier Grays Harbor from 1981 through 1999. The Port purchased the site from Rayonier in 1999. The southeast upland portion of the site and the existing Terminal 3 dock are currently used by Willis Industries, a wood chip facility. The City parcel on the southwest upland corner of the site is occupied by the City’s former wastewater lagoon (Sheet 2). The former wastewater lagoon was cleaned and formally closed under Ecology regulations prior to filling. The City is currently filling the lagoon with dredged material from the Grays Harbor federal navigation channel, landslide materials, and excess soil from other local projects. The northeast upland corner of the site (also known as the “Lamb” property) is occupied by a whiskey distillery. The remaining upland areas within the site are unused. The in-water portion of the site is approximately 26 acres and located west of and adjacent to the existing Port Terminal 3 dock, a deep-water marine terminal located in Grays Harbor. The proposed in- water portion of the facility (shiploader, associated structures, and dredge prism) will be constructed within approximately 8.3 acres of that area. DNR manages the state-owned aquatic land that is the location of the proposed shiploader and mooring facility berth area where dredging will be required to accommodate ships at berth (Sheet 3). The Port plans on extending their Port Management Area at Terminal 3 to include the in-water project area that is currently managed by DNR (the process to include this DNR land within the Port Management Area is underway, and anticipated to be complete in 2020). The Project Site is bounded on the west by Paulson Road, the active portion of the City of Hoquiam’s wastewater lagoon, and USFWS GHNWR. The City of Hoquiam’s high school, middle school, and elementary school are located approximately 850 feet directly north on the other side of SR 109. To the northeast is the Lamb property, a former machinery manufacturing facility for pulp and paper equipment, owned by Emerson St. Hoquiam LLC. The Project Site is bounded on the east by South Adams Street, commercial, and residential properties. Grays Harbor is located adjacent to the south of the Project Site. Mitigation Sites: IDD#1 Site The site was a tideflat that was backfilled to its current elevation using dredge material from the Chehalis River and navigation channel. The site is currently vacant, and is zoned for industrial development. There is no current industrial activity at the site. An overhead utility line, consisting of wooden poles and associated guy lines, currently occupies a portion of the northern boundary the site. No other structures are present on the site. There is a City pump station that is located adjacent to, but outside of, the northern boundary of the site. The Port maintains a gravel access path around the top of the outer berm, and the site is currently used by the public as an informal (and currently unauthorized) access to the shoreline for recreational purposes.

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The PSAP rail line runs along the northern boundary of the site, and it is bounded to the east by the Hoquiam River, to the south by the waters of Grays Harbor, and on the west by a tidal inlet and shallow drainage. Terminal 4 The site is a general cargo terminal operated by Port of Grays Harbor. The portion of the site identified for derelict structure/pile removal as compensatory mitigation is unused. The site is surrounded by other Port-owned industrial properties and the Chehalis River/Grays Harbor. Hoquiam River Preservation Site The site is currently vacant, and is bordered to the west and south by the Hoquiam River, and to the north and east by forest lands. b. Has the project site been used as working farmlands or working forest lands? If so, describe. How much agricultural or forest land of long-term commercial significance will be converted to other uses as a result of the proposal, if any? If resource lands have not been designated, how many acres in farmland or forest land tax status will be converted to nonfarm or nonforest use? Project Site: According to historical aerial photos (1953 through 2017, Google Earth and EDR, Inc.), the Project Site has not been used for agriculture or forestry. Per the city’s comprehensive plan, there are no designated agricultural lands of long-term commercial significance (as defined in RCW 36.70A.030 and WAC 365- 196-480) in the City of Hoquiam, and the Grays Harbor County land use plan map does not identify agricultural areas in the vicinity of Hoquiam or Aberdeen. The City designates forest lands of long-term commercial significance under their Natural Resources (NR) zoning designation, however no portion of the Project Site or adjacent parcels are zoned NR. Therefore, there are no agricultural or forest lands of long-term commercial significance on or near the Project Site. The proposed project will not result in the conversion of farmland or forest land to a nonfarm or nonforest use. Mitigation Sites: The proposed project mitigation will not result in the conversion of farmland or forest land to a nonfarm or nonforest use. IDD#1 Site According to the cultural resources report for the mitigation sites (ICF June 2019), the IDD#1 Site has been used for industrial uses, including a lumber mill, and not for agricultural uses. As noted above, there are no designated agricultural lands of long-term commercial significance in the city, and no portion of the IDD#1 site or adjacent parcels are zoned NR. Terminal 4 Per the cultural resources report (ICF June 2019), Terminal 4 has historically been used for industrial/shipping uses and not for agriculture. There are no designated agricultural or forest lands of long-term commercial significance in the City of Aberdeen, and the Grays Harbor County land use plan map does not identify agricultural areas in the vicinity of Aberdeen (the county land use plan does not designate forest lands of long-term commercial significance). Hoquiam River Preservation Site The site is not known to have been used as working farmlands or working forest lands in the past, and is not designated as agricultural or forest land of long-term commercial significance by the county. The

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proposal would protect this site from future development, and would not result in the conversion of farmland or forest land. 1. Will the proposal affect or be affected by surrounding working farm or forest land normal business operations, such as oversize equipment access, the application of pesticides, tilling, and harvesting? If so, how: The Project Site, IDD#1, and Terminal 4 are all located in industrial areas that have been urbanized and developed. There are no surrounding working farms or forest lands, therefore the project would not impact the operations of these businesses. No development is proposed at the Hoquiam River Preservation site, and there would be no impact to farm or forest operations in that area. Log truck and other support activities for working forests in the surrounding area do utilize SR 109 to travel to and from sites. The project will not impact this use of SR 109. c. Describe any structures on site. Project Site: In-Water: The pier at Terminal 3 is a deep-water berth supported by concrete and steel piling and is accessible by a single approach. The main pier structure has a concrete deck, is 120 feet wide, and extends 600 feet in an east-west direction. Five mooring dolphins are located to the east and to the west of the pier. Upland: Table 12 lists the structures located upland from the Project Site. Table 12. Structures on Project Site (Upland) Tax Parcel Description A former truck weigh station and associated office building, two 517101012001/056401000400 abandoned/derelict warehouse buildings A maintenance building currently used to service vehicles used by 56401000801 Willis Enterprises (tenant) A warehouse, a former paint shed, a former chemical storage shed, 517101011001 and a paint shop 56401000600 A warehouse building that is currently being used as a distillery

Mitigation Sites: The only existing structure at the IDD#1 Site is an overhead utility line, consisting of wooden poles and associated guy lines, which occupies a portion of the northern boundary the site. No other structures are present on the site. There is a City pump station that is located adjacent to, but outside of, the northern boundary of the site. There are no existing structures at the Hoquiam River Preservation Site. Existing structures at Terminal 4 consist of three marine piling complexes, including a concrete and wood overwater structure that originally served as a crane platform (Sheet 31). d. Will any structures be demolished? If so, what? The structures located on the Willis Industries and Terminal 3 Port properties (in tax parcels 517101012001, 056401000400, 56401000801, 517101011001, and 56401000600) will need to be demolished. No structures would be demolished at the IDD#1 site or Hoquiam River preservation site.

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Approximately 1,368 creosote-treated piles and approximately 2,147 square feet of overwater structure will be removed from the Terminal 4 area (Sheet 31). These structures do not currently support any activities. e. What is the current zoning classification of the site? The Project Site and IDD#1 site are zoned Industrial by the City of Hoquiam. Terminal 4 is zoned Industrial by the City of Aberdeen. The Hoquiam River site is zoned General Development Five (G5) by Grays Harbor County. f. What is the current comprehensive plan designation of the site? The 2009 City of Hoquiam Comprehensive Land Use Plan designates the Project Site and IDD#1 Site as Industrial District. The 2001 City of Aberdeen Comprehensive Land Use Plan designates Terminal 4 as Industrial. The 2008 comprehensive land use designations for Grays Harbor County designate the Hoquiam River site as Urbanizing. g. If applicable, what is the current shoreline master program designation of the site? The 2016 City of Hoquiam Shoreline Master Program designates the upland areas of the Project Site and IDD#1 Site as High Intensity, and portions below the OHWM as Aquatic. Likewise, the 2016 City of Aberdeen Shoreline Master Program designates the in-water portion of Terminal 4 as Aquatic, and the adjacent upland as High Intensity. The 2018 Grays Harbor County Shoreline Master Program designates portions of the Hoquiam River Site as High Intensity. The Shoreline Master Program and Land Use Application (WSP July 2019) details the project’s compliance with shoreline policies and regulations. h. Has any part of the site been classified as a critical area by the city or county? If so, specify. There are designated critical areas located on the Project Site and mitigation sites, as detailed further below. The Project Site and IDD#1 site are subject to the City of Hoquiam’s critical areas regulations. Critical areas at the Project Site and IDD#1 were assessed and documented in the project’s critical areas report (WSP July 2019). The proposed project will require a critical areas permit from the City of Hoquiam and will be evaluated against the City’s critical areas regulations under the permit review. The Terminal 4 site is subject to the City of Aberdeen’s critical areas regulations. Given the nature of the proposed mitigation activities at Terminal 4, it is not anticipated that the mitigation activities will require a critical areas permit from the City of Aberdeen; however the project will still be required to demonstrate to the City of Aberdeen that both the construction activities and completed project will comply with their critical areas regulations and Shoreline Master Program. No ground disturbing work is proposed at the Hoquiam River preservation site, and therefore there would be no impact to critical areas at that site and no critical areas review is required from the county. Although administered locally by the two cities and county, critical areas are also subject to regulations under WAC 365-196-485 and WAC Chapter 365-190. There are five categories of critical areas regulated under the WAC: wetlands, critical aquifer recharge areas, fish and wildlife habitat conservation areas, geologically hazardous areas, and frequently flooded areas. The following sections describe each of these critical areas and their presence at the Project Site and mitigation sites. Project Site Wetlands, fish and wildlife habitat conservation areas, geologically hazardous, and frequently flooded areas are present on the Project Site. As described in the Critical Areas Assessment (WSP July 2019), the project has been designed to comply with the intent and provisions of the City of Hoquiam’s Critical Areas Ordinance and Shoreline Master Program. The project has been designed to avoid and minimize impacts and to provide compensatory mitigation.

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Wetlands: The wetland delineation identified the presence of three wetlands and wetland buffers at the Project Site that meet the criteria to be considered jurisdictional under the City’s critical areas regulations (Sheet 17). A detailed discussion of wetlands at the site can be found in Section 3 and the wetland delineation report for the Project Site (WSP July 2019). Critical aquifer recharge areas: Both Aberdeen and Hoquiam have determined that there are no critical aquifer recharge areas within city limits. Therefore, CARAs will not be impacted by the project and are not addressed further in this checklist. Fish and wildlife habitat conservation areas: Fish and wildlife habitat conservation areas generally include (WAC 365-190-130):

• Areas where endangered, threatened, and sensitive species have a primary association; • Habitats and species of local importance, as determined locally; • Commercial and recreational shellfish areas; • Kelp and eelgrass beds; herring, smelt, and other forage fish spawning areas; • Naturally occurring ponds under twenty acres and their submerged aquatic beds that provide fish or wildlife habitat; • Waters of the state; • Lakes, ponds, streams, and rivers planted with game fish by a governmental or tribal entity; and • State natural area preserves, natural resource conservation areas, and state wildlife areas. The following areas are not present at the Project Site or mitigation sites and are not addressed further in this checklist: naturally occurring ponds under 20 acres, habitats or species of local importance (outside of federal and state priority species that are addressed in Section 3, above), and state natural area preserves or natural resource conservation areas. The GHNWR is located immediately west of the Project Site and is a designated national wildlife refuge. The GHNWR is designated as a critical area under several categories (fish and wildlife habitat conservation area, critical saltwater habitat, and riparian areas associated with waters of the state). Fish and wildlife habitat conservation areas on or adjacent to the Project Site include habitat where priority species have a primary association and waters of the State (Grays Harbor) and associated riparian areas. The mitigation plan (WSP July 2019) provides a comprehensive (quantitative and qualitative) assessment of the adequacy of the proposed mitigation relative to the state’s no-net-loss standard. Details on these areas and associated mitigation are also provided in Section 3 (Water), Section 4 (Plants), and Section 5 (Animals), as well as in the Biological Evaluation (WSP May 2019) and Critical Areas Assessment (WSP July 2019). Geologically hazardous areas: The same geologically hazardous area are present at the Project Site and mitigation sites. Geologically hazardous areas include liquefaction and seismic hazard areas (detailed in the response to Section 1 [Earth]). Soils mapped at the sites by USDA NRCS are rated as having a slight potential for erosion hazard, which indicates a low level of risk of erosion (USDA-NRCS 2017). Similarly, the risk of landslide hazards, mass wasting events, debris flows, and rockfalls at the site are low because of the relatively flat

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nature of the sites. For these reasons, neither the Project Site nor the IDD#1 site are considered to be an erosion or landslide hazard area. Areas subject to other geological events typically include tsunami hazard areas and volcanic hazard areas. Although the city does not designate tsunami events as a type of seismic hazard, WAC 365-190- 120 stipulates that “areas subject to severe risk of damage as a result of…tsunamis” be considered seismic hazard areas. Tsunami risks are detailed under Section 1 (Earth). The DNR Natural Hazards mapper indicates that the sites could potentially be affected by volcanic ash because of potential volcanic hazards to the east (Mount Rainer, Mount St. Helens, and Mount Adams), however the Project Site and mitigation sites are not considered as within a volcanic hazard area. The DNR Natural Hazards mapper indicates that the nearest faults are located west of the Project Site, near the mouth of Grays Harbor, and to the northwest near Ocean Shores; therefore, the likelihood of surface faulting or fault rupture at the sites is relatively low. Frequently flooded areas: Only a small portion of the northern end of the Project Site is mapped within the FEMA effective 100-year floodplain (Sheet 19). Northern portions of the site may be impacted by 100-year or larger flood events (1-percent annual exceedance probability), which could inundate areas below elevation 13.45 feet. Frequently flooded areas are regulated under HMC Chapter 11.16 – Floodplain District. According to the code, areas of special flood hazard are those identified by the Federal Emergency Management Agency’s (FEMA) Federal Insurance and Mitigation Administration in a scientific and engineering report entitled “The Flood Insurance Study for the City of Hoquiam, Washington” along with accompanying flood insurance rate maps (FIRM).The currently published FEMA FIRM (Panels 53027C0881D, and 53027C0882D effective February 3, 2017) identify the portions of the Project Site that are within the 100-year floodplain (Sheet 19). Development within any area of special flood hazard requires a building permit, per HMC 11.16.240, and will be required to meet the applicable design standards and provisions of HMC 11.16.250 and 11.16.270. The City will issue a floodplain permit as part of the grading permit and/or building permit needed to construct the Project Site. BHP prepared a flooding assessment for the site, including sea level rise analysis (Amec Foster Wheeler February 2018). The Project Site is subject to both riverine and coastal flood hazards. Only a small portion of the northern end of the Project Site is mapped within the FEMA effective 100-year floodplain. Northern portions of the site may be impacted by 100-year or larger flood events (1-percent annual exceedance probability), which could inundate areas below elevation 13.45 feet. Per the assessment, the area of potential flood impact appears to be less than expected from the FEMA Flood Hazard Zone map based on more recent topographic data now available than when FEMA developed the map. Without modifying existing site grades, flooding may affect operations at the northernmost building (covered storage area). When sea level rise is considered, the extent of inundation at the northern end of the site would increase due to flooding from the Hoquiam River. Additionally, coastal flooding would increase along the southern edge of the Project Site, inundating both Moon Island Road and Airport Way. The assessment concluded that the elevation of the covered storage building pad, critical infrastructure, and access roads can be designed sufficiently high to mitigate the flood risk.

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Mitigation Sites: IDD#1 Site Wetlands, fish and wildlife habitat, geologically hazardous and frequently flooded areas are present on the IDD#1 Site. As described in the Critical Areas Assessment (WSP July 2019), the proposed mitigation activities at the site were designed to comply with the intent of the City of Hoquiam’s Critical Areas Ordinance and Shoreline Master Program. The project has been designed to avoid and minimize impacts and to provide compensatory mitigation. Wetlands: The wetland delineation identified the presence of four wetlands and wetland buffers at the IDD#1 site that meet the criteria to be considered jurisdictional under the City’s critical areas regulations (Sheet 18). A detailed discussion of wetlands at the site can be found in Section 3 (Water) and the wetland delineation report for the IDD#1 site (BergerABAM 2018).

Critical aquifer recharge areas: None. See discussion under Project Site, above.

Fish and wildlife habitat conservation areas: Fish and wildlife habitat conservation areas on or adjacent to IDD#1 Site include habitat where priority species have a primary association and waters of the State (Grays Harbor) and associated riparian areas. The Mitigation Plan (WSP July 2019) provides a comprehensive (quantitative and qualitative) assessment of the adequacy of the proposed mitigation relative to the state’s no-net- loss standard. Details on these areas and associated mitigation are also provided in Section 3 (Water), Section 4 (Plants), and Section 5 (Animals), as well as in the Biological Evaluation (WSP May 2019) and Critical Areas Assessment (WSP July 2019).

Geologically hazardous areas: The same geologically hazardous areas are present at the Project Site and mitigation sites. See the geologically hazardous areas discussion under the Project Site, above. The proposed mitigation activities at the site will not be negatively impacted by geologically hazardous areas.

Frequently flooded areas: The currently published FEMA FIRM (Panels 53027C0881D, and 53027C0882D effective February 3, 2017) identify the portions of the IDD#1 site as within the 100-year floodplain (Sheet 20). The proposed compensatory mitigation will remove a portion of the existing levee at the IDD#1 site to restore tidal influence to the site as part of restoration efforts. The levee at IDD#1 serves to enclose the site and does not provide flood protection to the City of Hoquiam (Panel 53027c0882D). The Grays Harbor Flood Insurance Study 53027CV000A indicates that flooding in Hoquiam is caused primarily from the Hoquiam River and not from Grays Harbor or the Chehalis River. The location of the mitigation site is such that it will not influence flooding in the City.

The City will issue a floodplain permit as part of the grading permit needed to construct the IDD#1 mitigation site. Appropriate technical analysis will be provided at that time to support the floodplain permit. The mitigation project will result in a net removal of material and would not result in an increase in the flood elevation. It is important to note that while the mitigation project is not likely to result in an increase in flood elevation due to the net removal of material, HMC 11.16.250(7)(a)(i) allows for increase in flood elevation by up to 1 foot.

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Terminal 4 Fish and wildlife habitat and geologically hazardous areas are present on Terminal 4. The proposed mitigation activities at Terminal 4 will comply with the intent of the City of Aberdeen’s Critical Areas Ordinance and Shoreline Master Program. Wetlands: In- and over-water Work at Terminal 4 will take place in/over the Chehalis River. There are no wetlands present on the upland area adjacent to the site.

Critical aquifer recharge areas: There are no designated CARAs in Aberdeen.

Fish and wildlife habitat conservation areas: The Chehalis River is a priority habitat for endangered, threatened, and sensitive species, as well as a water of the state, and therefore the over-water/in-water work will take place within a fish and wildlife habitat conservation area.

Geologically hazardous areas: The same geologically hazardous areas are present at the Project Site and mitigation sites. See the geologically hazardous areas discussion under the Project Site, above.

Frequently flooded areas: Work (over-water and in-water) at Terminal 4 will take place entirely within the floodway, and will not impact flooding events. The adjacent upland area is not identified as a frequently flooded area by FEMA (Panel 53207C0904D, effective February 3, 2017).

Hoquiam River Preservation Site Wetlands, fish and wildlife habitat conservation areas, geologically hazardous areas, and frequently flooded areas are present on the Hoquiam River Preservation Site. The proposed preservation of this site will comply with the intent of the Grays Harbor County Critical Areas Ordinance and Shoreline Master Program. Wetlands: This 71.5-acre parcel contains approximately 59.9 acres of Category I wetlands (consisting of 45 acres of mature forested wetland, 8.9 acres of scrub-shrub wetland, 6.0 acres of emergent wetlands), as well as 11.6 acres of forested uplands and wetlands within a 150-foot buffer. A 0.3- acre remnant grove of old growth trees with Western red cedar, Douglas fir and Western hemlock is also located immediately adjacent to the wetland and lies within the area to be preserved. The proposed project would protect these on site wetlands in perpetuity.

Critical aquifer recharge areas: According to the Grays Harbor County Shoreline Master Program mapfolio, this site is not located within a CARA.

Fish and wildlife habitat conservation areas: The Hoquiam River site is located adjacent to the Hoquiam River, which is a priority aquatic habitat. In addition, PHS on the Web identifies priority habitats on upland portions of the site, including aquatic habitat (wetlands) and breeding areas for great blue heron (Ardea herodias). The proposed project would protect these areas

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Geologically hazardous areas: The same geologically hazardous areas are present at the Project Site and mitigation sites. See the geologically hazardous areas discussion under the Project Site, above. The proposed project would protect these areas at this site by prohibiting development.

Frequently flooded areas: Portions of the site are located in the 100-year floodplain (FEMA FIRM Panels 53027C0669D and 53027C0882D, effective February 3, 2017). The proposed project would protect these areas at this site by prohibiting development.

i. Approximately how many people would reside or work in the completed project? At this time, it is estimated that the workforce for the proposed project —including management, system and equipment operators and maintenance trades—will be approximately 40 to 50 people comprising fulltime and casual positions. j. Approximately how many people would the completed project displace? The current tenant, Willis Enterprises, employs approximately 90 people. The Willis Enterprises facility will be required to move by the proposed project. Willis Enterprises has proposed to move their current operations to a nearby property in Aberdeen, Washington. While this operation will be displaced it will be relocated to Aberdeen and no loss of jobs in the area is expected. k. Proposed measures to avoid or reduce displacement impacts, if any: No measures are proposed, as Willis Enterprises has proposed to move their current operations to a nearby property in Aberdeen, Washington. l. Proposed measures to ensure proposal is compatible with existing and projected land uses and plans, if any: The proposed development’s compatibility with existing and projected land uses is established through the project’s compliance with the City’s zoning, comprehensive plan, and shoreline master program. As previously noted, the Project Site is zoned and designated for industrial use, and the shoreline area is designated High Intensity. The proposed facility is an industrial facility that meets the zoning and intended use of the site under the city’s code, Comprehensive Plan, and Shoreline Master Program. Compatibility with existing and future land uses will be verified through the approval of the following required permits.

• Conditional Use Permit • Shoreline Substantial Development Permit • Shoreline Conditional Use Permit • Shoreline Variance • Construction Permits (Grading, building and trades, etc.) m. Proposed measures to reduce or control impacts to agricultural and forest lands of long- term commercial significance, if any: The proposed project will not have any impacts on agricultural and forest lands of long-term commercial significance, as none exist in the project vicinity, and therefore no mitigation measures are proposed.

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9. HOUSING a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low-income housing. No housing units would be required for the project. b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low-income housing. No housing units would be eliminated because of the project. c. Proposed measures to reduce or control housing impacts, if any: Not applicable. No measures are proposed as there would be no impacts. 10. AESTHETICS a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal exterior building material(s) proposed? The product storage building will be constructed of a steel frame with tensioned fabric, approximately 141.5 feet high at the apex. There are no existing or proposed structures at the mitigation sites. b. What views in the immediate vicinity would be altered or obstructed? Based on visual analysis conducted and described below, views of the site are primarily blocked by existing development and/or vegetation. The project would be visible from the north and south views, and would alter some views in the area. No views would be obstructed or materially blocked by the project. It will have no impact on residential views of the shoreline. Project Site: Based on visual analysis conducted and described below, views of the site are primarily blocked by existing development and/or vegetation. The project would be visible from the north and south views, and would alter some views in the area. No views would be obstructed or materially blocked by the project. It will have no impact on residential views of the shoreline. A visual analysis was completed to evaluate potential impacts associated with the aesthetics of the project (BergerABAM June 2018). The analysis was conducted in accordance with the City’s view corridor review process per HMC 11.05.440(2)(e). The analysis provides visual simulations and additional information on the visual impacts from the project, and identifies where visual impacts would occur (namely Hoquiam High School and Circle Drive). Existing views of the site are primarily blocked by existing development and/or vegetation. The views from the school and residences on Circle Drive would be altered; however, the impact would not block existing views of the shoreline, as the shoreline cannot currently be viewed from these locations. The proposed project would be most visible to viewers from the north and from Grays Harbor to the south of the Project Site. From both locations, the proposed project would be consistent with other development in the area and would not substantially alter the existing views. The number of potential viewers from the north would be minimal because of the generally low level of development in the area. The view impacts will primarily affect workers at the Project Site or other nearby businesses and students at the high school to the north. From the south, the project would be consistent with other development along the shoreline. The analysis concluded that the project will alter some views in the community, but will not impair or destroy any views, and will have no impact on adjacent residential views of the shoreline.

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Mitigation Sites: Views of Terminal 4 and the Hoquiam River preservation site would remain unchanged, and preservation of the latter site would result in the long-term preservation of existing shoreline views there. Views of the IDD#1 site would be improved through the proposed wetland creation and enhancement, and the creation of formal viewpoints. c. Proposed measures to reduce or control aesthetics impacts, if any: The effects to aesthetics will be relatively minor based on the configuration of the facility, existing site and nearby land use, and distance of the neighboring properties from desired sights. The facility will be aesthetically consistent with the industrial nature of the existing facility and property uses to the east and north. 11. LIGHT AND GLARE a. What type of light or glare will the proposal produce? What time of day would it mainly occur? Lighting during daylight hours is not anticipated to extend off the Project Site. The project involves nighttime safety lighting of the site when operations occur at night and may involve temporary lighting for any nighttime construction activities. Project Site: Construction Lighting used during construction at times of low light, if needed, will be used only in active work areas and for safety. Construction night-time lighting will be directional and will minimize glare and light spillage to the extent practicable. Light spillage onto adjacent properties or to water during nighttime construction will be minimized to the extent practicable using shaded fixtures and directional lighting aimed only in areas for worker comfort and safety. Operation Exterior building lights used for vehicle and worker traffic, rail unloading facility lighting, and shiploader lighting would be in use when shiploading operations extend into nighttime hours. It is possible that operations will occur at any hour on any day. Nighttime lighting at the facility could result in elevated light levels in the adjacent GHNWR and/or in the vicinity of the shiploader. Increased nighttime lighting can affect the behavior of both aquatic and terrestrial species, including potentially altering the behavior of bird resting and foraging behavior. (See Section 5 [Animals] for further discussion of these issues.) The project will incorporate lighting design and associated directional lighting to minimize glare and light spillage to the extent practicable while still providing the necessary lighting levels for workers safety. The project involves nighttime safety lighting of the site when operations occur at night and may involve temporary lighting for any nighttime construction activities.

Lighting on buildings and the shiploader will need to be consistent with FAA requirements because of the site’s proximity to Bowerman Airport and will be designed in accordance with safety associated with airport traffic. Light fixture details are as follows:

• Streetlight (ATB2): along road and side of product storage building (~164 - feet spacing) • Floodlight (PLLED): on shiploader spout • Wallpacks (W4G): at building personnel entrance

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• Stanchion/Ceiling-mounted Lights (PLED2): along conveyor walkways (9-meter spacing) • Shiploader Spout: 4 x 250 W LED floodlights (PLLED) mounted 15 meters above deck level and pointed straight down • Walkways and Stairs: 20 x 94 W LED (PLED2) stanchion-mounted lights (20 meters off ground, average) b. Could light or glare from the finished project be a safety hazard or interfere with views? Light and glare from the finished project would not create a safety hazard or interfere with views. Lighting on buildings and the shiploader will need to be consistent with FAA requirements because of the site’s proximity to Bowerman Airport and will minimize glare and be designed in accordance with safety requirements associated with airport traffic. Exterior building lights used for vehicle and worker traffic, rail unloading facility lighting, and shiploader lighting would be in use when shiploading operations extend into nighttime hours. The project will incorporate lighting design and associated directional lighting to minimize glare and light spillage to the extent practicable (see response to item [d] below). Given the site layout and relationship to other viewpoints, as described in the Aesthetics section above, while lighting may be visible from certain vantage points, it is not expected that the light or glare from the project would interfere with views. In particular, the lighting will have no impact on adjacent residential views of the shoreline. c. What existing off-site sources of light or glare may affect your proposal? Off-site lighting is typical of urban areas and consists of street and building lights. The adjacent Bowerman Airport includes high-intensity runway lights that are activated on approach. This existing lighting will not affect the project as it does not include activities that are sensitive to light. Lighting of adjacent industrial sites and the high school property to the north also have no effect on the proposal. d. Proposed measures to reduce or control light and glare impacts, if any: Project Site: The project will incorporate lighting design and associated directional lighting to minimize glare and light spillage to the extent practicable. Directional lighting will be used on overwater structures to minimize light spillage onto the water during nighttime hours. Additionally, FAA-approved lighting will be mounted on buildings and structures for aviation safety. BHP is designing site lighting to reduce impacts to adjacent areas, as noted in Section 5(d) (Proposed measures to preserve or enhance wildlife). Measures to reduce impacts from overwater shading are also described in that section. Cumulative Impacts: Maintenance dredging and the North Shore Levee Project are not anticipated to involve any lighting, although construction of the levee may result in a temporary increase in lighting at construction sites along the levee alignment. The Contanda Project will involve project lighting, however it is located on an existing industrial site that currently contains lighting, and the Contanda Project does not propose any lighting over water. In addition, the Contanda site is over 2.5 miles away from the Project Site. For these reasons, while the Proposed Project will contribute to light sources in the area, no mitigation is required to offset any cumulative impacts.

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12. RECREATION a. What designated and informal recreational opportunities are in the immediate vicinity? The Project Site is an existing private industrial facility at the Port of Grays Harbor. Given its location in Grays Harbor, there are some formal and information recreational opportunities in the area for access to other portions of the shoreline. The GHNWR is the largest formal recreational area in the vicinity of the Project Site. There is also some informal recreational activity occurring at the IDD#1 Site. These are described below. Project Site: There are no recreational opportunities on the majority of Project Site as it is a private industrial facility. Moon Island Road is located on the southern side of the Project Site and provides access to the Grays Harbor Shoreline for shoreline access and viewing opportunities, although there are not formalized or designated public recreational facilities or areas for these activities accessed via this road. The GHNWR is located immediately west of the Project Site and John Gable Community Park is located across SR 109 from the Project Site. The GHNWR provides bird watching, wildlife viewing, and hiking along the 0.72-mile Sandpiper Trail located north of Bowerman Airport approximately 1 mile west of the proposed Project Site. John Gable Community Park shares recreational facilities with Hoquiam High School, including picnic tables, baseball fields, a running track, tennis courts, and an outdoor skate park. The City is also in the process of developing a shoreline park/view point at Airport Way and Adams Street, east of the Project Site. Recreational fishing and boating occur in Grays Harbor, including within the navigation channel that will be used by the vessels. According to the Washington State Recreation and Conservation Office, there are several boat launches in the general vicinity that provide access to the harbor, namely the Hoquiam 28th Street Boat Launch and the launch at 9th Street Landing and Rayonier Point. According to WFDW, Grays Harbor is a very popular small boat fishery especially for large Chinook and Coho salmon. Major access points include the 28th Street Ramp, Westport, Ocean Shores, and Johns River. Most fishing occurs in September and early October before the commercial fishery commences. There are no federally designated scenic highways in the general vicinity of the Project Site. There are three state-designated scenic highways in the general vicinity of the Project Site; however, the Project Site is only visible from one (SR 109). SR 109 is designated as the Hidden Coast Scenic Byway by the Washington State Department of Transportation Local Programs Office, as identified in the Washington State Scenic and Recreational Highways Strategic Plan (2010 to 2030). The Project Site is located near the terminus of the scenic byway, which officially ends where SR 109 meet SR 101, in the city of Hoquiam. Portions of the byway near the site are located in an area that is industrial and urban in nature. Per the Hidden Coast Scenic Byway Corridor Management Plan (GHCOG 2011), the GHNWR and John Gable Park are identified as resources on the scenic byway. The proposed project will not impact views of or access to the GHNWR and John Gable Park and is not anticipated to negatively impact the state- designated scenic byway. The Washington State Scenic and Recreational Highways Strategic Plan identifies locations of the highest potential for protecting, preserving, and enhancing resources associated with the scenic and recreational highways program; none of the project-related locations are identified. The strategic plan also identifies locations of “highest scenic value,” including a stretch or roadway near Grays Harbor City approximately 1 mile west of the Project Site where the roadway adjoins Grays Harbor (WSDOT 2010). The Project Site would not be visible from this location.

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Mitigation Sites: IDD#1 Site The IDD#1 mitigation site in its current state provides informal (though currently unauthorized) access to portions of Grays Harbor and the Hoquiam River. There is an existing informal trail that follows the top of the berm around the waterward portion of the site, which connects with itself in a loop via an informal trail through the wetlands at the northern boundary of the site. The primary existing points of informal access to the site are via a gated entrance at the end of Earley Industrial Way in the northwest corner of the site, and via the end of K Street in the north central portion of the site. Terminal 4 Terminal 4 is an existing industrial site, surrounded by other industrial and Port-owned property. There are no recreational opportunities in the immediate vicinity of the site other than potential recreational fishing that may occur sporadically nearby. Hoquiam River Preservation Site: The site is currently vacant and surrounded by other vacant properties to the north and east, and by the Hoquiam River to the south and west. There are no recreational opportunities in the immediate vicinity of the site other than potential recreational fishing on the Hoquiam River. b. Would the proposed project displace any existing recreational uses? If so, describe. The Project Site is an existing industrial facility that does not have any recreational uses. Informal uses at the IDD#1 Site would be temporarily displaced and some areas accessed now would become inaccessible while others would be enhanced with formal viewpoints and trails. In the vicinity of the sites, existing recreational uses would be indirectly affected, but not displaced, by project construction and operation activities. Project Site: Construction The proposed facility will be an industrial site used similarly to the existing chip facility and shipping uses at the existing Terminal 3 facility. The proposed project could result in indirect impacts to recreational uses on lands adjacent to or nearby the site. Potential impacts to the recreational uses at the GHNWR, John Gable Community Park, and informal boating on the water near the Project Site could result from both the construction and operation of the proposed project. Potential construction impacts would be associated with noise from construction activities, equipment, and vehicles. Temporary impacts to recreationalists during construction include the potential for light, glare, or noise to affect human enjoyment of the walking trail or sports facilities at the community park. In addition, noise and light may temporarily disturb wildlife, which would affect wildlife viewing and birdwatching opportunities at the GHNWR. Because the John Gable Community Park is used for activities that are not affected by noise (sports fields and skate park) as opposed to those for quiet enjoyment (such as an amphitheater or camping), impacts would be minor. Wildlife viewing facilities at the GHNWR are approximately 1 mile from the Project Site and any impacts would be minor. Recreational boating may be restricted near the in-water construction areas during in-water work windows, however this impact to recreational use is minor, considering the limited area in which the restriction would occur and the availability of other boating and fishing areas throughout Grays Harbor. The area is also within an existing industrial waterway, and recreation users already experience similar activities occurring within the area.

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Operation Operation of the proposed facility is not anticipated to significantly displace or restrict access to any recreational uses as the proposed facility will be an industrial site used similarly to the existing chip facility, and shipping uses at the existing Terminal 3 facility. Passing trains could temporarily prevent access to area roadways, during train passage at a grade crossing, thereby temporarily preventing access to recreation resources if the at-grade crossing is needed to access the recreation activity. Noise from rail activity may be heard at recreational sites in the vicinity but not at levels that are significant. Similarly, recreational facilities in the area have some exposure to diesel emissions from truck traffic, trains and other diesel vehicles but not at significant levels. (See the Transportation, Noise, and Air sections for discussion of these elements.) Impacts on recreational uses in the harbor outside the channel are not expected, because vessel traffic with the proposed potash facility would be limited to the navigation channel. Major access points for recreational boaters would be distant and not affected by vessel traffic. Recreational fishing occurs primarily in the fall in the navigation channel. In general, navigation rules restrict recreational vessels, small boats and vessels engaged in commercial fishing from impeding vessels that can only operate in the navigation channel. Recreational boats and small craft are required to cede right of way to larger vessels that currently operate in the channel. Recreational fishing and boating is seasonal, and the boat density is considered low even at the height of the season. Potential conflicts are not anticipated to be frequent or to last for a substantial amount of time. Additionally, alternative fishing areas that would not be affected by vessel traffic are available. Implementation of mitigation to provide advance notice of vessel transit would reduce impacts on recreational fishing. Recreational facilities in the area are currently routinely exposed to truck traffic and other diesel vehicles that use the adjacent highway. Visual impacts would not displace any recreational uses. (See Section 10 [Aesthetics]). The recreational areas are either distant from the facility (1 mile for the GHNWR), or in the case of John Gable Park, aesthetic features do not contribute significantly to the value of the park (i.e., the park is used for baseball and skateboarding and not for access to scenic resources). Mitigation Sites: IDD#1 Site The existing informal recreational use of the IDD#1 site would be temporarily displaced during construction activities. The proposed mitigation plan includes provisions for continued public access including an access point and a trail to two viewpoints of the harbor and river. The nature of the mitigation activities are such that certain areas of the site once accessible to the unauthorized recreation activities will no longer be suitable for the activity as they will be devoted to tidal channels and wetlands. While the nature of the access will change with the project these are not considered impacts as it was not a formal recreation facility. Terminal 4 Recreational fishing in the general area could be temporarily displaced during construction activities. Once the mitigation at the site is complete, there would be no impact to existing or future recreational activities in the area.

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c. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be provided by the project or applicant, if any: Construction Mitigation (All Sites): Project Site No mitigation measures are specifically proposed to address the indirect impacts to recreation activities. Several proposed mitigation measures will, however, serve to reduce indirect impacts on recreational uses adjacent to the Project Site. These include the following.

• Light and Glare: Lights used to illuminate construction activities will be directional and directed away from adjacent properties, as well as shielded to avoid glare on adjacent lands. Lights will be shut off when not in use or otherwise needed. Illumination levels will be the minimum necessary for construction and safety standards. • Noise: Construction would comply with City and state noise regulations. HMC 10.05.120 specifies that the noise level standards identified in Chapters 173-60 and 173-62 of the WAC apply to activities in the City, including construction. Most construction, including pile driving, would occur during daytime hours. Because of the temporary nature of construction and lower sensitivity to noise during daytime hours, no additional construction noise mitigation is necessary for daytime construction activities. If nighttime construction is proposed, noise control measures are likely necessary to meet both the state and local requirements for nighttime construction, and prior to any nighttime construction, a Construction Noise Management Plan would be developed to ensure that nighttime construction can comply with the local requirements. Such a plan would likely include some or all of the measures during nighttime hours.

IDD#1 Site: Construction at the IDD#1 Site would employ the same minimization measures as noted above for the Project Site. Once constructed, the City would implement reasonable restrictions to public uses of the site, to minimize the potential for effects that could reduce the ecological function of the mitigation site. Terminal 4: Construction at the site would generally follow the same BMPs as for IDD#1 and the Project Site. However the site is not proximate to recreational uses, and construction activities are not anticipated to have any impact on recreation. Operation Mitigation (Project Site): Several permits required for the project will address and reduce potential impacts to wildlife at the GHNWR, in turn, protecting associated recreational opportunities (e.g., USACE Section 10/404, Section 7 ESA consultation, WDFW Hydraulic Project Approval, and City permits including Shorelines, Land Use, and Critical Areas). The proposed mitigation measures, as identified above, as well as requirements to be established in the required permits, are anticipated to adequately address the potential impacts to recreation from both construction and operations. Measures to reduce or control impacts to adjacent recreational areas during operations include the following.

• Light: Outdoor lighting shall be designed to control off-site light disturbances. Unless site security may be compromised, lighting shall be limited (where appropriate and safe), and the use of downward projecting lighting shall be considered over floodlights. Where practical, permanent

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outdoor lighting shall be designed for “Dark Sky” compliance per guidelines of the International Dark-Sky Association (IDA) and the Illuminating Engineering Society (IES). The outdoor lighting design shall provide the minimum lighting required for safety and will reduce light pollution to a minimum. Special consideration of light color spectrum and impact evaluation of outdoor lighting on migratory birds shall be taken. • Glare: Glare is controlled by prismatic glass options; glass and diffuse options reduce glare by 95 percent. Calculations include consideration for glare options. The BUG rating for every IES file and fixture must be within limitations; all fixtures chosen will meet this requirement. For lighting within the criteria of RP8 and Industrial RP7, lighting levels will be adjusted to be within safety guidelines and achieve even lighting (no hot spots). • Noise: The majority of noise and light-producing activities will be enclosed in buildings (e.g., product storage building noise, railcar unloading, etc.) and the site layout has been designed to place these facilities away from the adjacent wildlife refuge. The facility is designed to avoid or minimize the need to couple/uncouple train cars, which will eliminate or minimize the loudest noises associated with on-site trains during unloading operations. As with construction activities, the noise level standards identified in Chapters 173-60 and 173-62 of the WAC apply to operation activities in the City. The noise assessment concluded that noise from on-site operations would comply with the applicable noise limits and not result in significant noise impacts due to increases over existing levels. Therefore, the project will not increase noise above the set limits, and additional noise mitigation for adjacent land uses is not necessary. If applicable City noise limits were to be reached, additional measures (such as noise barriers) would be required, and would be put in place by the applicant. Cumulative Impacts: There are no anticipated cumulative impacts to recreation resources in the area as a result of the proposed project and other current and reasonably foreseeable projects. The North Shore Levee Project is not anticipated to have any impacts on recreational areas as its proposed alignment follows existing roadways. Maintenance dredging could temporarily occupy a small area that might otherwise be used for recreational fishing or tribal fishing, however this area would be small in size and only temporarily occupied by the dredging vessel. The Contanda Project will take place entirely within a developed industrial area, and will not displace any existing recreational areas. Lastly, the BHP Project is anticipated to have a positive impact on recreational resources through the creation of public access to the shoreline and viewpoints at the IDD#1 Site, and preservation of views of the shoreline at the Hoquiam River Preservation Site. For these reasons, the project is not expected to contribute to cumulative impacts to recreational resources and no mitigation measures are proposed.

13. HISTORIC AND CULTURAL PRESERVATION a. Are there any buildings, structures, or sites, located on or near the site that are over 45 years old listed in or eligible for listing in national, state, or local preservation registers? If so, specifically describe. Project Site: The Project Site was evaluated for cultural or historic resources in the Cultural Resources Technical Report (ICF February 2018). No places or objects at or next to the Project Site are listed on or proposed for national, state, or local preservation registers. None of the buildings in the APE are historically significant because, based on a review of historic aerial images and shoreline data, it was determined

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that the onsite buildings were constructed in the 1980s and thus not age eligible for the National Register of Historic Places (NRHP) cut off age eligibility of 50 years. Additionally, none of the onsite buildings have achieved significance of special importance as part of an eligible historic district (ICF February 2018). Mitigation Sites: IDD#1 Site The IDD#1 site was evaluated for cultural or historic resources in the report titled Archaeological Monitoring Results for the BHP Billiton Canada, Inc. Proposed Grays Harbor Potash Export Facility Mitigation Area, IDD#1 and Historic Context for Mitigation Area, POGH Terminal 4 (ICF June 2019). ICF recommends a finding of no historic properties affected under Section 106 of the NHPA and a finding of no cultural or historic resources impacted under SEPA if efforts are made to avoid possible intact components of IDD#1 during future project activities. Refer to the cultural resources report (ICF June 2019) for additional detail. Proposed measures to avoid, minimize, or compensate for loss, changes to, and disturbance to resources are detailed in response to question (d), below. Terminal 4 No buildings, structures, or sites, over 45 years old are listed in or eligible for listing in national, state, or local preservation registers at Terminal 4. The Terminal 4 mitigation site was evaluated for cultural or historic resources in same report as IDD#1, above (ICF June 2019). The Terminal 4 off-site mitigation area for the proposed project includes three wood piling complexes and a concrete and wood overwater structure that are older than 45 years old, which were not previously documented or evaluated for NRHP eligibility. Based the NRHP eligibility, marine piling complex 1 (including concrete and wood overwater structure), 2, and 3, are not recommended eligible for listing in the NRHP. Hoquiam River Preservation Site: The Hoquiam River site has not been formally evaluated for cultural or historic resources, and none are known to exist at this site. No ground disturbing work or development is proposed at this site, and therefore any potential resources would not be disturbed, and no impacts would occur. b. Are there any landmarks, features, or other evidence of Indian or historic use or occupation. This may include human burials or old cemeteries. Are there any material evidence, artifacts, or areas of cultural importance on or near the site? Please list any professional studies conducted at the site to identify such resources. Tribal Resources in the Project Vicinity: The Quinault Indian Nation (Quinault) is a federally-recognized tribe and sovereign government. The Quinault reservation is approximately 20 miles from the Project Site and would not be affected by the project. The Quinault have indicated that waters at the project site, the adjacent areas of Grays Harbor, and its watershed as well as areas of the Pacific Ocean are within their Usual and Accustomed areas for the harvest of fish and shellfish. The Pacific Ocean, Grays Harbor, the Chehalis and Humptulips Rivers, and their tributary rivers, streams, and wetlands provide freshwater and marine habitat that supports Chinook, chum, and Coho salmon and steelhead, White Sturgeon and Dungeness crab all of which are important to the Quinault. The upland portions of the Project Site are not currently accessed by tribal members, and use of the uplands would not affect access to the Quinault’s treaty resource areas. Within Grays Harbor, Quinault members fish for salmon, steelhead, and sturgeon using drift and set gillnets and for Dungeness crab

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using pots. Ocean fisheries include Dungeness crab; halibut; sablefish; groundfish such as rockfish, pacific cod, and whiting; and ocean Chinook and Coho. The permanent structures of the proposed marine terminal and vessels moored while loading will occupy marine areas that could be used by tribal members. Moored vessels will prevent access in the immediate area of the vessel. The berth will not be occupied at all times but at 8 mtpa could be occupied 55 percent to 75 percent of the time (55 percent is average occupancy, and 75 percent is potential occupancy on a high demand or bad weather week). Some of this berth occupancy would occur during active fishing seasons. Although berth occupancy would reduce the area of the estuary available to fishing, this is a small percentage of the total area available to fishing. The average size of the vessels moored at the berth are between 5,000 and 6,100 square meters. When in operation a single vessel located in the estuary will cover approximately 0.0024 percent of the total area of the estuary including fishing area, North Bay, and South Bay (approximately 56,005 acres). A single vessel will cover approximately 0.0082 percent of the total area available for fishing (approximately 16,220 acres). The vessels that will be moored at the berth are approximately 0.75 to 0.76 percent the width of the mouth of the estuary (4,270 meters). Therefore vessels in transit or at berth would occupy a small amount of the area available for fishing. Grays Harbor includes a federal navigation channel that is used by deep-draft vessel. If fishing in the navigation channel tribal members have to provide the right-of-way to the deep draft vessels as they pass. This could occur when vessels travel to and from the proposed terminal. Similar impacts could occur in the ocean but are not expected to be significant as vessels are not confined to a navigation channel once in the open ocean. Similar effects would occur during construction but those effects would be temporary and cease after construction is complete except for the potential for yearly maintenance dredging. Access to one of the boat launch areas used by the Quinault for fishing, the Port of Grays Harbor 28th Street boat ramp, would be temporarily delayed during train passage times. Project trains would not be required to stop at this location and access wait times would only be increased for a relatively short time (approximately 17 to 18 minutes) up to three times per day. Therefore, access impacts to this boat ramp would not be significant. In the vicinity of the Project Site, tribal members also access other natural resources such as sweetgrass (Hierochloe odorata), cattail (Typha spp.), and other grasses and willow for traditional weaving of baskets and mats and for ceremonial purposes. Bowerman Basin (adjacent to the Project Site) is known to have a large sweetgrass population. Within the project footprint there are no anticipated impacts to such vegetation. Further, the project is not anticipated to have any impacts to such vegetation outside of the project footprint. Therefore, no impacts are anticipated to the Quinault’s ability to access these resources. Vegetation impacts are discussed in Section 4 (Plants). Cumulative Impacts to Tribal Resources Vessel traffic from the Proposed Project would increase by approximately 4 vessel call per week. When combined with existing vessel traffic and the proposed Contanda Project, which anticipates 1 vessel call per week, ship traffic will increase and traffic impacts will increase. However, the majority of the time the bay and channel will remain free of any vessel. Implementation of mitigation to provide advance notice of vessel calls and movements, and work with Quinault officials to identify other measures as appropriate could reduce the potential for these impacts. This is an active harbor and port location and vessel traffic and management presently exist in the area.

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Project Site: No landmarks or evidence of prehistoric or historic archaeological sites are known to be on or next to the site nor were any identified during the 2017 cultural resources survey completed for this project. Based on the results of the cultural resources study presented in the report, ICF recommends a finding of no historic properties affected under Section 106 of the National Historic Preservation Act (NHPA) and a finding of no cultural or historic resources impacted under SEPA. Refer to the Cultural Resources Report (ICF February 2018) for additional detail. Mitigation Sites: IDD#1 Site The IDD#1 off-site mitigation area for the proposed project encompasses an area that contains a previously documented, but unevaluated site. As a result of the limitations of previous investigations, it was unclear whether deposits associated with 45GH130 would be encountered by monitoring well and test pit investigations completed for the BHP proposed mitigation project. The investigations revealed that no-such deposits were present at the depth of the proposed mitigation project-related ground disturbance in the areas included in the test pit and monitoring well installation investigations, nor did it identify any previously undocumented cultural resources. Therefore, the proposed mitigation activities at IDD#1 would not encounter any previously documented or undocumented archaeological resources. An existing archaeological site consisting of a fish weir was identified on the adjacent property to the west of the IDD#1 site. The evidence of the fish weir encountered on the west adjacent site was encountered at depths below 14 feet bgs. The fish weir was encountered on that neighboring property at depths ranging from approximately 17 to 21 feet below ground surface. The work at IDD#1 is not proposed to extend beyond 14 feet bgs around the majority of the site and an archaeologist is recommended to be present if deeper excavations are required. No evidence of the fish weir or other cultural resources were encountered during archaeologist observed test pits completed at the site (ICF June 2019). Additionally, proposed excavations on the north and northwest portions of the site will not extend beyond 4 feet bgs and cultural resources related to the former shanty town and mill/fish oil facility should not be encountered at those depths. No discrete archaeological deposits associated with 45GH130 were found and no National Register of Historic Places (NRHP)-eligible cultural resources were observed during June 2018 archaeological monitoring at the proposed IDD#1 off-site mitigation area. ICF recommends a finding of no historic properties affected under Section 106 of the NHPA and a finding of no cultural or historic resources impacted under SEPA if efforts are made to avoid possible intact components of the recorded site at IDD#1 during future project activities. Terminal 4 The Terminal 4 mitigation site was evaluated for cultural or historic resources in the report titled as noted previously. Based on the results of the archaeological monitoring effort and NRHP eligibility evaluation for the three marine piling complexes, ICF recommends a finding of no historic properties affected under Section 106 of the NHPA and a finding of no cultural or historic resources impacted under SEPA. c. Describe the methods used to assess the potential impacts to cultural and historic resources on or near the project site. Examples include consultation with tribes and the

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department of archeology and historic preservation, archaeological surveys, historic maps, GIS data, etc. Tribal Resources: BHP is consulting with the Quinault to understand the tribal use and access to fisheries and other resources and ways to respond to any concerns raised. Coordination meetings were held with the Quinault in December 2018, March 2019, and May 2019, technical meetings were held on January 23 to 24, 2019 in Ocean Shores, and a Treaty Resources Workshop was held on June 6, 2019. Coordination with the Quinault is ongoing and will continue through the SEPA review process. As noted above, site specific studies were conducted on the project and mitigation sites to determine the potential presence of archaeological and historic resources within the project limits. In addition, prior studies (such as those completed for the now cancelled Westway project), archeological reports and other available documentation. Literature recommended by the Quinault’s cultural resources specialist was also reviewed. Project Site: ICF conducted a literature review and records search using DAHP’s online Washington Information System for Architectural and Archaeological Records Database (WISAARD) to identify previously completed cultural resources studies and documented archaeological, ethnographic, and historic resources within a 1-mile radius of the APE. WISAARD contains all of the records and reports on file with DAHP, including completed cultural resources survey reports, properties listed in or determined eligible for listing in the NRHP, documentation of Washington Heritage Register-listed properties, archaeological sites, cemeteries, and inventoried built environment resources. ICF archaeologists excavated a series of mechanically excavated test units. This method was selected as opposed to other methods because it maximizes the visibility of subsurface deposits and minimize the number of sampling and logistical considerations while excavating. Two archaeologists were present during the excavation of test units: one oversaw excavations and inspected trench profile walls and the other carefully examined the spoils pile. A metal shovel was used to break up any large peds (or cohesive blocks of sediment) to inspect them for archaeological materials. No sediments that warranted additional closer inspection were identified, so no sediment samples were screened. Once each trench was completed, it was photographed and plotted using a handheld global positioning system (GPS) unit. Trench contents, stratigraphy, depth to undisturbed native landforms, and other relevant information were recorded on a standard trench summary form. No archaeological deposits were identified; therefore, no collection or analysis of artifacts was performed. Mitigation Sites: No ground disturbing work is proposed at the Hoquiam River preservation site, and this site was not evaluated for cultural resources. Cultural and historic resources on or near IDD#1 and Terminal 4 were evaluated by ICF, and the results are described in this section of the checklist and further detailed the report titled Archaeological Monitoring Results for the BHP Billiton Canada, Inc. Proposed Grays Harbor Potash Export Facility Mitigation Area, IDD#1 and Historic Context for Mitigation Area, POGH Terminal 4 (ICF June 2019). The methods used to assess these sites are described below.

IDD#1 Site ICF provided archaeological monitoring services for 25 test pits for soil sampling and the installation of five monitoring wells performed within the proposed IDD#1 offsite mitigation area between June 11 and

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June 13, 2018. An ICF archaeologist monitored ground-disturbing excavations that included borings for the installation of groundwater monitoring wells and the mechanical excavation of test pits for soil sampling and characterization at the IDD#1 site. A Cultural Resources Specialist with the Quinault also monitored ground disturbing excavations on June 11, 2018. The archaeological monitor was on-site for the duration of the ground-disturbing activities and worked alongside the biological and soil scientists, drilling crews, and excavator operator to ensure the protection of any archaeological sites or isolates that were discovered during this time. Prior to the excavation of each proposed monitoring well and test pit, the archaeological monitor inspected access routes to ensure that no archaeological materials were disturbed during mobilization and demobilization. The archaeological monitor observed all excavations at a distance that was considered to be safe but adequate for the purposes of identifying archaeological resources, and maintained visual and audio contact with the work crew at all times in the event that excavations needed to be temporarily paused to inspect a possible unanticipated discovery. Terminal 4 An ICF archaeologist performed a records search using WISAARD to identify previously documented archaeological, ethnographic, and historic resources within a one mile radius of the APE. The Port’s Terminal 4 Marine Piling Complexes #1, #2, and #3 were not included among the previously documented resources. ICF architectural historians January Tavel, MHP, and Andrea Dumovich, MA conducted desktop analysis of the Terminal 4 Mitigation Site via Google Earth aerial imagery. The Port provided reconnaissance-level field photography of existing conditions and historic photographs from the Port archives, which supported analysis of site integrity and preparation of an historic context to inform analysis of site significance. ICF architectural historians referenced the Pontoon Construction Project Draft Cultural Resources Discipline Report (ICF 2009), and conducted property-specific archival research – including examination of historic maps and documents – to support preparation of the historic context. d. Proposed measures to avoid, minimize, or compensate for loss, changes to, and disturbance to resources. Please include plans for the above and any permits that may be required. The proposed action is not anticipated to result in impacts to significant archaeological, historic or cultural resources. The following measures are proposed to avoid and/or minimize impacts to any as-yet undiscovered significant archaeological sites within the APE of the Project Site, IDD#1 site, and Terminal 4. Refer to the cultural resource reports for additional detail (ICF June 2019 and ICF February 2018). Construction (Project Site and IDD#1 Site): • Targeted Archaeological Monitoring: Archaeological monitoring would occur for all excavation exceeding 17 feet in depth at the Project Site and 12 feet in depth at IDD#1 • Development of an Unanticipated Discovery Protocol: An Unanticipated Discovery Protocol will be prepared in advance of construction that would detail protocols to be followed in the event that cultural resources or human remains are encountered during project construction activities, and provide the contact information for key individuals listed in the unanticipated discovery procedures. • Treatment of Significant Archaeological Sites: If significant archaeological sites are encountered during project-related ground disturbance, ground disturbance will cease at the location of the discovery until the appropriate treatment can be determined through consultation between BHP, the City, DAHP, and the Quinault; a memorandum of agreement describing the stipulations relating to the treatment is signed; and any treatment required prior to commencing with further ground disturbance is completed. BHP will coordinate with the Quinault through their mutual participation

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in the Grays Harbor Safety Committee, addressing issues such as management protocols and notices during construction. Operations (Project Site): • Dredging windows and ongoing coordination with the Quinault Indian Nation would occur to address potential concerns regarding tribal fisheries. • The Unanticipated Discovery Protocol would be used for any ground-disturbing activities during operations and maintenance activities. • BHP will continue to coordinate directly with Quinault regarding any impacts to its tribal fishing that may result from the Project. • BHP will coordinate with the Quinault through their mutual participation in the Grays Harbor Safety Committee, addressing issues such as vessel call and management protocols and notices during construction and operations. • BHP will work with the Grays Harbor Safety Committee, including the USCG, Port of Grays Harbor, and tribal contacts to establish procedures to announce project-related vessel traffic arrivals and departures over a designated Very High Frequency marine radio channel at least 1 hour before arriving and departing, which will minimize the potential for vessel collisions and interference with recreational and tribal fisheries.

14. TRANSPORTATION a. Identify public streets and highways serving the site or affected geographic area, and describe proposed access to the existing street system. Show on site plans, if any. Project Site The existing primary vehicular access to the Project Site is at the intersection of Moon Island Road, Paulson Road, and Airport Way. A secondary access point is located on Paulson Road, north of Airport Way. These are two-lane paved public roads. SR 109 is to the north of the Project Site and provides the main east to west access through the city of Hoquiam. SR 109 connects to U.S. Highway 101 through Aberdeen, which runs north to the Olympic Peninsula and south to Astoria, Oregon. Mitigation Sites The IDD#1 Site is accessed from the east terminus of Earley Industrial Way (on the west side of the property) or from the east terminus of K Street (on the north side of the property). Terminal 4 is accessed by East Terminal Way from East Terminal Road, south of Port Industrial Road in Aberdeen, Washington. There is no existing access to the Hoquiam River preservation site. b. Is the site or affected geographic area currently served by public transit? If so, generally describe. If not, what is the approximate distance to the nearest transit stop? Grays Harbor Transit has regularly scheduled buses that operate along SR 101 and 109. The closest stop to the Project Site is approximately 1/2 mile to the northeast of the Project Site at the intersection of SR 109 and Blaine Street. The closest stop to the IDD#1 site is at the intersection of SR 101 and 9th Street, approximately 1/4 mile to the north of IDD#1. The closest stop to Terminal 4 is at the intersection of South Park Street and Wishkah in Aberdeen, approximately 3/4 mile to the northeast of Terminal 4. The closest stop to the Hoquiam River preservation site is at the intersection of Perry Avenue and Queen Avenue, approximately 1/4 mile to the south.

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c. How many additional parking spaces would the completed project or nonproject proposal have? How many would the project or proposal eliminate? This project would provide a new, paved parking lot with approximately 50 to 60 parking spaces at the Project Site (there are no existing designated parking spaces on the Project Site). No additional parking spaces are proposed at the mitigation sites. No designated parking spaces would be eliminated as a result of the project. d. Will the proposal require any new or improvements to existing roads, streets, pedestrian, bicycle or state transportation facilities, not including driveways? If so, generally describe (indicate whether public or private). No improvements are planned to existing public roads or other public transportation facilities as part of the project. In an action related to the project, the City of Hoquiam approved an ordinance on June 10, 2019 to vacate an existing section of Airport Way/Paulson Road (Ordinance No. 2019-03). A planned on- site roadway overpass structure will be built at the south entrance from Airport Way for vehicular traffic, near the southeast corner of the facility (Sheets 3 and 7). The overpass structure will allow vehicles to access the site over the rail loop. On site roadways will allow access to the rail car unloading facility and storage building and maintenance and inspection roadways will be located along the proposed rail track including around the outside. Emergency vehicle access will be permitted through the Project Site via the perimeter rail track maintenance road. This will provide emergency vehicle access to areas south of the PSAP rail corridor (between the Hoquiam River Bridge and the Project Site) when trains are entering and leaving and temporarily impeding access to the public roads into the waterfront area and Moon Island Road. The existing informal access to the northwest corner of the IDD#1 Site would be formally established, and the existing informal and unauthorized trail would be modified from its existing condition, and improved with pervious surfacing atop a berm that would be established on the northern and western portions of the site. (Sheets 29 and 30). No changes to the existing access are proposed at Terminal 4 or the Hoquiam River Preservation Site. e. Will the project or proposal use (or occur in the immediate vicinity of) water, rail, or air transportation? If so, generally describe Project Site: The project would require use of rail and water transportation, as described below. No project-related air transportation is anticipated. The Project Site is located approximately 0.25 mile to the east of Bowerman Airfield. The project will comply with FAA provisions for lighting. Rail The potash will be delivered to the site by unit train (trains consisting of cars carrying only one product). Rail service will be scaled and provided in relation to the export facility capacity at a given time. There would be up to 8 to 10 trains per week from the potash facility. From a roadway grade crossing impact perspective, capacity operations will involve on average one BHP Project train entering and leaving the site each day, resulting in two total BHP Project train trips. A reasonable maximum scenario will result in up to three BHP Project train trips per day at the PSAP grade crossings. BHP’s planned unit trains will consist of approximately 177 rail cars, powered by up to five locomotives requiring a minimum of 8,500 feet of track to accommodate the entire train on site during unloading. The unit trains will travel along existing rail lines in Canada and the United States from the Jansen Mine to Centralia, Washington, where the PSAP rail line connects with the BNSF and Union Pacific lines. Trains will then travel the approximately 60 miles to the project along the PSAP line.

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The proposed project will contain sufficient loop tracks to fully accommodate the project related trains on the Project Site without extending beyond the Project Site onto PSAP tracks. Trains arriving in Centralia will only be dispatched to the Project Site if there is sufficient room to accommodate them on the Project Site. Once dispatched trains will move continuously to the facility and will not stop unless an unforeseen circumstance arises along the track. This will serve to reduce vehicular wait times from stopped trains at roadway crossings. Cumulative Rail Impacts The PSAP rail line is currently in place and is used by a number of trains on a daily and weekly basis. The proposed project will result in up to 8 to 10 trains per week or an average of 1.25 (2.5 one way) trains per day. Currently the rail line is used by approximately 3 train trips per day (ICF 2016) and the proposed Contanda Project would add approximately 1.1 train trips per day. As discussed in the project Rail Considerations Memorandum (Kittelson August 2019), the rail line is currently operating under capacity and can accommodate the project's added rail traffic. BHP is in continued coordination (starting in early 2018) with PSAP with regards to the additional rail traffic that will result from the proposed project. In addition to on-going maintenance activities along the rail corridor, PSAP plans to install/replace 22,800 railroad ties and surface 39 miles of the mainline between the BHP Project site and Centralia in 2019. The improvements as well as regularly scheduled operations and maintenance will help to serve both existing as well as anticipated rail traffic in the corridor (Kittelson August 2019). The PSAP track contains numerous at-grade roadways crossings. The train occupancy time (per trip) is dependent on the length and speed of the train. At 25 mph, the train occupancy time (per trip) for project-related trains for an at-grade crossing would be approximately 4 minutes. When combined with existing trains utilizing the PSAP rail line, there will be an increase in time during which moving trains prevent motor vehicle, pedestrian and bicycle traffic from crossing the rail line. The proposed project’s rail impacts on the section of the rail corridor from the Hoquiam River east to Centralia were assessed relative to an-in depth rail impact evaluation presented in the permit application for the Contanda Project proposed in Aberdeen (Kittelson August 2019). The cumulative impacts of the Contanda and BHP proposals on the PSAP rail line between Centralia and Hoquiam can be summarized as follows:

• Between Centralia and the Poynor Yards in Aberdeen, approximately 1,318 additional train trips are anticipated per year assuming development of the Contanda and BHP projects (455 loaded BHP train trips, 455 empty BHP train trips, 204 loaded Contanda train trips and 204 empty Contanda train trips). Today, the rail line serves approximately three train trips per day. Combining the Contanda and BHP rail traffic results in an average of approximately 3 additional train trips per day along the segment of the PSAP line between Centralia and the Poynor Yards in Aberdeen, but could result in an increase by as much as 5 train trips per day (2 train trips for Contanda and 3 train trips for BHP) on any given day. Per PSAP representatives, the rail line has the capacity to accommodate the anticipated train trips per day (when accounting for existing traffic and cumulative impacts). • The Contanda project would result in increased train-passing time at the at-grade crossings east of Poynor Yards beyond current wait times. The increase in time would be an additional 12 minutes once or twice per day associated with an average of 1 or 2 Contanda train trips per day. The BHP project would result in an additional 18 minutes beyond current wait times at these intersections occurring two or three times per day based on an average of 2 or 3 BHP train trips per day.

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• Based on the projected train length for the proposed project and assuming one entering and one exiting train (two train trips total) per day, the three at-grade crossings to the west of the Hoquiam River Bridge will each be occupied by a moving train approximately 40 or 60 total minutes per day (i.e., 20 minutes per occurrence two or three times a day) and all three could be simultaneously occupied for approximately 22 or 33 total minutes per day (i.e., 11 minutes of additional wait time two or three times per day). Proposed mitigation to address rail impacts is identified under Section B.14.h, below. Marine The project is designed to accommodate deep draft vessels for the export of potash. The proposed new berth would be a deep-water facility capable of mooring Handysize to Kamsarmax-class vessels (20,000 to 82,000 dead weight tonnage). It is anticipated the facility would operate on a schedule to handle an average of four export ships per week (up to 220 vessels per year). The proposed dock is in line with and downstream of the existing Terminal 3 dock. The dock and berthed ship are located adjacent to, but outside of, the Federal Navigation Channel and, therefore, the dock and moored vessel will not impact the use of or maintenance of the navigation channel. USACE regulatory requirements state that the “protection of navigation in all navigable waters of the United States continues to be a primary concern of the federal government.” The USACE will consider any impacts on navigation during its review. The location of the dock is such that it will still allow use of Terminal 3 for other vessels, such as barges delivering construction supplies to the site. All vessels calling at the port are subject to the following standards and regulations.

• Ports and Waterways Safety Act of 1972 (31 U.S.C. 1221 et seq.): Authorizes the USCG to provide for navigation and vessel safety: protect the marine environment: and protect life, property, and structures in, on, or immediately adjacent to the navigable waters of the United States. • Port and Tanker Safety Act of 1978 (33 U.S.C. 1221 et seq.): Grants the USCG broad and extensive authority to supervise and control all types of vessels, foreign and domestic, operating in U.S. navigable waters. • Navigation and Navigable Waters, Subchapter E: Inland Navigation Rules (33 CFR 83-90): Applies to all vessels on the inland waters of the United States and complement the International Regulations for Preventing Collisions at Sea 1972, which are applicable in international waters. • Washington State Pilotage Act (RCW 88.16): Establishes requirements for compulsory pilotage provisions in certain waters of the state, including Grays Harbor. Vessels will utilize the federally authorized and maintained Grays Harbor navigation project to access the Project Site from the Pacific Ocean. The Grays Harbor navigation project includes jetties and 22 miles of deep draft navigation channel that is maintained by the USACE. The channel begins 4 miles offshore, is a minimum of 350 feet wide and is maintained to a depth of -38 feet MLLW plus 2 feet of allowable overdredge. The channel acts a one way channel due to the width. Arriving and departing deep draft vessels require pilotage by a licensed Grays Harbor pilot and are assisted in the arrival and departure by tugs. Vessels operating in the harbor follow established inland navigation rules (33 CFR 83). General requirements include:

• A vessel of less than 20 meters in length, a sailing vessel, or a vessel engaged in fishing shall not impede the passage of any other vessel navigating within a narrow channel or fairway.

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• A vessel shall not cross a narrow passage or fairway if such crossing impedes the passage of a vessel that can safely navigate only within such channel or fairway. • In a narrow channel or fairway, any overtaking has to be permitted by the vessel being overtaken. • All sailing vessels, fishing vessels and power-driven vessels shall keep out of the way of a vessel restricted in the ability to maneuver. Vessels will arrive outside of the bar where they will be joined by a river pilot as required by state law. Tugs will be used to bring the vessel across the bar and into the harbor. Vessels will not enter the harbor and channel unless conditions are favorable and the berth is unoccupied. Vessels will transit the channel past the proposed berth to the turning basin upstream of the Project Site. Tugs will turn the vessel around and maneuver it back to the dock will it will moor facing downstream toward the ocean. Once the vessel is loaded a pilot will reboard the vessel for the outbound transit. Fully loaded vessels would exit only on the high tide. Tugs would assist the vessel departure from the dock and the pilot would command the vessel into the channel and across the bar where the pilot will disembark and the vessel will continue to the destination port. Cumulative Marine Vessel Impacts Grays Harbor currently receives 290 cargo vessels and 13 tankers per year. The proposed project would add up to 220 vessel trips per year. The Contanda Project has proposed an expansion of its existing facility within the City of Hoquiam that would add an additional 48 vessels per year (Contanda 2019). Table 13. Vessel Trips in Grays Harbor – Current Conditions and Proposed Project Vessels/Week Vessels/Year Current Conditions <6 Cargo Vessels 290 cargo vessels (Average)12 <1 tanker 13 tankers Contanda 1 vessel 48 vessels Proposed Potash Facility 4 vessels up to 220 vessels

Estimates indicate that there are approximately 1,275 navigable windows (times at which tidal elevations support deep draft transits of the channel) available in Grays Harbor per year (ICF 2016). A combination of the proposed project, the current traffic and the proposed Contanda Project would result in less deep draft transits than available windows indicating that there is adequate capacity within the channel to accommodate the project. The total number of vessels would remain below the number of estimated navigation windows available per year and therefore no cumulative impacts to marine navigation would occur. Tugs and pilot resources are available and would expand if necessary to meet the demand. Berth capacity is not a factor as the project will have a dedicated berth. Proposed mitigation to address marine transit impacts is identified under Section B.14.h, below. f. How many vehicular trips per day would be generated by the completed project or proposal? If known, indicate when peak volumes would occur and what percentage of the volume would be trucks (such as commercial and nonpassenger vehicles). What data or transportation models were used to make these estimates? Project Site: The project is estimated to generate a maximum of 430 vehicle trips (including occasional mail/FedEx/UPS deliveries) per day including 61 trips during the weekday a.m. peak hours (54 in and 7

12 The Westway FEIS used 2016 vessel traffic information for the current conditions.

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out) and 58 trips during p.m. peak hours (10 in and 48 out). The traffic study evaluated the effect of the project related traffic on the operation of intersections within the vicinity of the project and determined that all intersections will operate within acceptable standards (Kittelson November 2017). All level of service analyses described in the Traffic Impact Analysis were performed in accordance with the procedures stated in the Transportation Research Board 2010 Highway Capacity Manual. Mitigation Sites: No vehicular trips would be generated by the completed work at the mitigation sites. Cumulative Vehicular Traffic: The Traffic Impact Analysis concluded that the project related traffic can be safely accommodated with the existing traffic infrastructure and conditions. All current and reasonably foreseeable projects in the area have the potential to create temporary and minor traffic impacts (e.g. detours, wait times) during construction phases, including the Contanda Project and the North Shore Levee Project. It is not anticipated that maintenance dredging activities would have a measurable impact on vehicular traffic as those activities would be limited to vehicle travel to and from the location from which the dredger ship docks. Once constructed, it is not anticipated that the North Shore Levee Project would have an impact on vehicular traffic as it would not generate any vehicle trips, and the alignment would primarily follow existing roadways through Hoquiam and Aberdeen. Vehicle trips generated by the Contanda Project during construction would consist of the movement of construction vehicles to and from the site, as well as traffic generated by the estimated 80 to 100 construction workers (Contanda 2019). Once constructed, the Contanda Project will create between 4 and 20 jobs. As the Contanda Project would not create a significant number of jobs/daily traffic during operations, and is located over 2.5 miles east of the Project Site and across the Hoquiam River, it is not anticipated that the combined traffic from the Contanda Project and the BHP Project would result in cumulative impacts to vehicular traffic. g. Will the proposal interfere with, affect or be affected by the movement of agricultural and forest products on roads or streets in the area? If so, generally describe. The proposed project will not have any impacts on agricultural and forest lands of long-term commercial significance, as none exist in the project vicinity, and therefore no mitigation measures are proposed. h. Proposed measures to reduce or control transportation impacts, if any: Vehicular Transportation The Traffic Impact Analysis concludes that the proposed export facility can be constructed and operated without creating a significant impact on the transportation system from the additional vehicular traffic and therefore no specific mitigation measures are proposed to accommodate the traffic volumes associated with the Project Site. The following measure was identified in the Traffic Impact Analysis and will be implemented by the applicant to address specific conditions related to vehicular traffic.

• As part of facility site planning, on-site landscaping as well as any above ground utilities and signage will be located and maintained at the proposed site driveway on Airport Way during the site design phase to provide adequate intersection sight distance in accordance with A Policy on Geometric Design of Highways and Streets, 6th Edition and/or as per City requirements.

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There will be no transportation impacts to the mitigation sites, and no measures are proposed at these locations. BHP commits to completing a construction traffic management plan and will coordinate with the City and other interests on the preparation and review of the plan. Air Transportation The design of the project was dictated in part by the need to avoid effects on air transportation associated with the nearby Bowerman Airport. The layout of the storage building and other structures at the site are dictated primarily by the FAA FAR Title 14: Aeronautics and Space Part 77 - Safe, Efficient Use, and Preservation of the Navigable Airspace (Part 77) protected surfaces for Bowerman Airport. The height and location of the potash storage building has been modified from the original proposal to meet the requirements of FAA-regulated air navigation surfaces associated with the nearby Bowerman Airport. Consultation with the FAA resulted in the conclusion that the proposed facility does not represent an obstruction to air navigation. Rail Transportation Based on the impacts anticipated, mitigation measures are identified to address both BHP Project as well as cumulative effects due to the Contanda Project. The mitigation measures below are further detailed in the Rail Considerations Memorandum (Kittelson August 2019).

• BHP will coordinate with emergency services providers to provide emergency vehicle access via the perimeter rail track maintenance road through the BHP site. • BHP will coordinate with PSAP to establish procedures with the Hoquiam Fire Department and other applicable emergency service providers to identify actions in the case of a train occupying grade crossings west of Hoquiam River. • BHP will coordinate with PSAP to ensure that changes to the existing traffic control devices at the three existing grade crossings west of the Hoquiam River are addressed prior to the start of operations of the proposed project. Per PSAP representatives, the need for and extent of required rail improvements will likely be addressed in detail through a separate project conducted by the PSAP. • BHP will coordinate with PSAP to avoid dispatching BHP Project trains to the Project Site if there is insufficient space to accommodate the additional train within the Project Site. Vessel Transportation Additional ship traffic associated with the project will follow established rules and protocols for navigation in Grays Harbor. This includes mandatory pilotage and compliance with federal navigation rules. BHP has committed to working with the Grays Harbor Safety Committee to establish procedures regarding vessel arrival and departures. In general navigation rules restrict recreational vessels, small boats and vessels engaged in commercial fishing from impeding vessels that can only operate in the navigation channel. Therefore these vessels would need to make way for the vessels serving the facility. This situation already occurs due to existing vessel traffic and vessel operators are already of this and are used to accommodating commercial vessel traffic. The following mitigation measures will be implemented to minimize impacts from the vessel traffic associated with the proposed potash facility.

• BHP will work with the Grays Harbor Safety Committee, including the USCG, Port of Grays Harbor, and tribal contacts to establish procedures to announce project-related vessel traffic arrivals and departures over a designated Very High Frequency marine radio channel at least 1 hour before

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arriving and departing, which will minimize the potential for vessel collisions and interference with tribal fishing and recreational fishing. • BHP will coordinate with the Port of Grays Harbor to manage waiting times for vessel arrivals or departures to minimize idling vessels. • Vessels traveling to and from the facility would adhere to the Ports and Waterways Safety Act of 1972, Port and Tanker Safety Act of 1978, Navigation and Navigable Waters (Subchapter E: Inland Navigation Rules), and Washington State Pilotage Act (RCW 88.16).

15. PUBLIC SERVICES a. Would the project result in an increased need for public services (for example: Fire protection, police protection, public transit, health care, schools, other)? If so, generally describe. BHP plans to provide its own site security, utilize fire protection and emergency systems that meet or exceed applicable building standards, and it is not anticipated that the project will result in an increased need for public services. See section 14 (Transportation) for a discussion on transportation effects. In addition, BHP intends to engage with local agencies and stakeholders to participate in ongoing community planning and to provide resources for further emergency response planning actions that facilitate harbor and community communications to respond to emergency events. b. Proposed measures to reduce or control direct impacts on public services, if any. Measures to control direct impacts on public services are not proposed at this time. Operational and design measures have been incorporated to reduce emergency risks, as described in previous sections. 16. UTILITIES a. Circle utilities available at the site: electricity, natural gas, water, refuse service, telephone, sanitary sewer, septic system, other.

b. Describe the utilities that are proposed for the project, the utility providing the service, and the general construction activities on the site or in the immediate vicinity which might be needed. Grays Harbor PUD will provide electricity to the Project Site. Water/sewer will be provided through the City of Hoquiam. The proposed utilities at the facility will tie into existing utilities on site. Up to three new private substations will be installed to meet the facility’s electrical needs and nine new stormwater ponds (four large ponds and five small ponds) will be constructed on site to meet the stormwater needs (see the description under Section A-11 and Sheet 3). Additional information on the proposed stormwater system is provided under Section 3(c). The facility will be equipped with fire suppression and response equipment as required at Port and other industrial facilities. The project does not propose the installation of any new overhead (vs buried) power lines.

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C. SIGNATURE The above answers are true and complete to the best of my knowledge. I understand that the lead agency is relying on them to make its decision. Signature:______Name of Signee:____Brian Carrico, AICP______Position and Agency Organization:____Senior Project Manager, WSP USA______Date Submitted:_____August 5, 2019______

Attachments Sheets 1 to 36

Appendix A: Alternatives Analysis, Rev 2 (WSP June 2019) Appendix B: Joint Aquatic Resources Permit Application (JARPA), Rev 1 (WSP July 2019) Appendix C: Mitigation Plan, Rev 2 (WSP July 2019) Appendix D: Critical Areas Assessment, Rev 2 (WSP July 2019) Appendix E: Shoreline Master Program and Land Use Permit Application Narrative, Rev 1 (WSP July 2019) Appendix F: Wetland and Waterbody Delineation and Assessments Appendix F-1: Terminal 3 Project Site, Rev 4 (WSP July 2019) Appendix F-2: IDD#1 Site (BergerABAM July 2018) Appendix G: Eelgrass Survey and Tier 1 Delineation (WSP July 2019) Appendix H: Cultural Resources Reports Appendix H-1: Project Site, Rev 1 (ICF February 2018) Appendix H-2: IDD#1 and Terminal 4, Rev 1 (ICF June 2019) Appendix I: Traffic Impact Analysis (Kittelson November 2017) and Rail Considerations Memorandum (Kittelson August 2019) Appendix J: Air Quality and Greenhouse Gas Analyses, including Diesel Particulate Matter Health Impact Assessment (Ramboll July 2019) Appendix K: Biological Evaluation, Rev 2 (WSP May 2019) Appendix L: Geotechnical Engineering Report (Shannon & Wilson June 2019) Appendix M: Dredged Material Characterization Report, Rev 2 (January 2019) and Suitability Determination (February 2019) Appendix N: Maintenance Dredging Technical Memorandum (BergerABAM September 2018) Appendix O: Olympic Region Clean Air Agency (ORCAA) Notice of Construction (NOC) Application, Rev 1 (Ramboll September 2018) Appendix P: Groundwater Monitoring

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Appendix P-1: Fifth Quarter Groundwater Monitoring Report (Terminal 3) (WSP May 2019) Appendix P-2: Fourth Quarter Groundwater Monitoring– IDD No. 1 Site Summary Report (WSP May 2019) Appendix Q: Visual Analysis (BergerABAM June 2018) Appendix R: 3D Overwater Shading Modeling Memorandum (BergerABAM July 2018) Appendix S: Phase I and II Environmental Site Assessments Appendix S-1: Phase I Environmental Site Assessment (BergerABAM July 2017) Appendix S-2: Phase II Environmental Site Assessment (BergerABAM February 2018) Appendix T: Grays Harbor Consultation Summary Report, Rev. 1 (BHP July 2019) Appendix U: Site Flooding Assessment Including Sea Level Rise Analysis (Amec Foster Wheeler February 2018) Appendix V: Noise Assessment (Ramboll December 2017)

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References Amec Foster Wheeler. 2018. “Site Flooding Assessment Including Sea Level Rise Analysis.” February. Ausenco. 2019. “PGH Tsunami and Sea Level Rise Study Commentary.” February. Ausenco. 2018. “JOL - Potential Flooding Mitigation.” January. BergerABAM. 2015. “Port of Grays Harbor – Westport Marina, Maintenance Dredging Biological Evaluation.” March. BergerABAM. 2017. “Phase I Environmental Site Assessment.” July. BergerABAM. 2018. “Phase II Environmental Site Assessment.” March. BergerABAM. 2017. “Proposed Grays Harbor Potash Export Facility Wetlands and Waterbody Delineation and Assessment.” December. BergerABAM. 2018. “Visual Analysis.” June. BergerABAM. 2018. “Summary of 3-D Overwater Shading Modeling.” June. BergerABAM. 2018. “Wetland and Waterbody Delineation and Assessment – IDD#1 Mitigation Site.” July. BergerABAM. 2018. “Maintenance Dredging Technical Memorandum.” September. BergerABAM. 2019. “Dredged Material Characterization Report.” January. BHP. 2019. “Grays Harbor Consultation Summary Report.” July. City of Hoquiam and Washington State Department of Ecology. 2015. “Imperium Terminal Services Expansion Project Draft Environmental Impact Statement.” Hoquiam and Lacey, WA. August. Contanda Terminals LLC (Contanda). 2019. “Contanda Terminal Expansion Project State Environmental Policy Act Evaluation.” January. Available at: https://cityofhoquiam.com/public-notices/ Eungard, D.W., Forson, C., Walsh, T.J., Edison, G. & Arcas, D. 2018. “Tsunami Hazard Maps of Southwest Washington – Model Results from a ~2500-Year Cascadia Subduction Zone Earthquake Scenario. Washington Geological Survey.” May. Golder Associates, Inc. (Golder). 2019. BHP – IDD#1 Mitigation Site – Hydraulic, Surface Water, Groundwater, and Coastal Assessment. July 29, 2019. Grays Harbor Council of Governments (GHCOG). 2011. “Hidden Coast Corridor Management Plan.” June. ICF. 2016. “Final Environmental Impact Statement Westway Expansion Project.” September 2016. ICF. 2018. “Cultural Resources Technical Report (Terminal 3 project site).” February. ICF. 2019. “Archaeological Monitoring Results for the BHP Billiton Canada, Inc. Proposed Grays Harbor Potash Export Facility Mitigation Area, IDD No. 1 and Historic Context for Mitigation Area, POGH Terminal 4.” June. Karpack, Larry, P.E., Sabatine, Shaina, P.E., and Karpack, Marissa, E.I.T., 2017. “North Shore Levee, Aberdeen and Hoquiam, WA - Hydraulic Analysis and Floodplain Mapping Memorandum,” Watershed Science Engineering, May 9, 2017. Available at: https://www.ezview.wa.gov/DesktopModules/Documents2/View.aspx?tabID=34771&alias=1775 &mid=65047&ItemID=5377

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Kittelson. 2017. “BHP Billiton Canada, Inc. Proposed Grays Harbor Potash Export Facility Traffic Impact Analysis.” November. Kittelson. 2019. “Rail Considerations Related to the BHP Proposed Grays Harbor Potash Export Facility.” August. Nightingale, B. and C.A. Simenstad. 2001. Dredging Activities: Marine Issues. White Paper. Dated July 13, 2001. Seattle, WA. Available at: https://wdfw.wa.gov/sites/default/files/publications/00055/wdfw00055.pdf Ramboll. 2017. “Proposed Grays Harbor Potash Export Facility Noise Assessment.” December. Ramboll. 2018. “Olympic Region Clean Air Agency (ORCAA) Notice of Construction Application.” September. Ramboll 2019. “Air Quality and Greenhouse Gas Analyses; including Diesel Particulate Matter Health Impact Assessment.” July. Richardson, W.J., C.R. Greene, C.I. Malme, and D.H. Thomson. 1995. “Marine Mammals and Noise.” Academic Press, San Diego, CA. 1995. Shannon & Wilson. 2019. “Geotechnical Engineering Report.” June. Speich, Steven M.; and Terrence R. Wahl. 1995. “Chapter 30: Marbled Murrelet Populations of Washington — Marine Habitat Preferences and Variability of Occurrence” In: Ralph, C. John; Hunt, George L., Jr.; Raphael, Martin G.; Piatt, John F., Technical Editors. Ecology and conservation of the Marbled Murrelet. Gen. Tech. Rep. PSW-GTR-152. Albany, CA: Pacific Southwest Research Station, Forest Service, U.S. Department of Agriculture; p. 313-326. U.S. Army Corps of Engineers (USACE). 2018. Components of a Complete Eelgrass Delineation Report. 9 January. U.S. Army Corps of Engineers (USACE). 2019. “Determination Regarding the Suitability of Proposed Dredged Material.” February. U.S. Department of Agriculture – Natural Resources Conservation Service (USDA-NRCS). 2017. “Web Soil Survey.” Accessed on May 18, 2017 https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx. U.S. Environmental Protection Agency (EPA). Particulate Matter (PM) Pollution Website, "Particulate Matter (PM) Basics." https://www.epa.gov/pm-pollution/particulate-matter-pm-basics. U.S. Fish and Wildlife Service (USFWS). 2019. “List of endangered species for Grays Harbor County, supplemented with species profiles and occurrence information.” U.S. Fish and Wildlife Service (USFWS). 2017. “Information for Planning and Consultation (IPaC).” Accessed 4 May 2017 at https://ecos.fws.gov/ipac/location/index. U.S. Fish and Wildlife Service (USFWS). 2014. Draft Recovery Plan for the Coastal-Puget Sound Distinct Population Segment of Bull Trout (Salvelinus confluentus) – Volume II (of II) – Olympic Population Management Unit. Washington Department of Ecology (Ecology). 2017. “Washington Coastal Atlas mapping.” https://fortress.wa.gov/ecy/coastalatlas/tools/Map.aspx. Last accessed November 27 2017. Washington Department of Natural Resources (DNR). 2017. “Natural Hazards mapper.” Accessed on July 19, 2017 at https://fortress.wa.gov/dnr/protectiongis/geology/?Theme=natural_hazards.

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Washington Department of Natural Resources (DNR). 2001. “Washington State Shorezone Inventory.” Aquatic Resources Division, Nearshore Habitat Program. Olympia, WA. Washington State Department of Transportation, Highways and Local Programs Division. 2010. “Washington State Scenic and Recreational Highways Strategic Plan (2010 to 2030).” WSP. 2019a. “Eelgrass Survey and Tier 1 Delineation.” July. WSP. 2019b. “Alternatives Analysis.” June. WSP. 2019c. “Critical Areas Assessment.” July. WSP. 2019d. “Joint Aquatic Resources Permit Application (JARPA)” July. WSP. 2019e. “Land Use and Shoreline Master Program Permit Application Narrative.” July. WSP. 2019f. “Wetland and Waterbody Delineation and Assessment (Terminal 3 project site).” June. WSP. 2019g. “Mitigation Plan.” July 2019. WSP. 2019h. “March 2019 Fifth Quarter Groundwater Monitoring Report (Terminal 3).” May. WSP. 2019i. “March 2019 Fourth Quarter Groundwater Monitoring– IDD No. 1 Site Summary Report.” May.

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D. SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS (do not use this sheet for project actions) Because these questions are very general, it may be helpful to read them in conjunction with the list of the elements of the environment. When answering these questions, be aware of the extent the proposal, or the types of activities likely to result from the proposal, would affect the item at a greater intensity or at a faster rate than if the proposal were not implemented. Respond briefly and in general terms.

OFFICE USE ONLY 1. How would the proposal be likely to increase discharge to water; emissions to air; production, storage, or release of toxic or hazardous substances; or production of noise? Proposed measures to avoid or reduce such increases are: 2. How would the proposal be likely to affect plants, animals, fish, or marine life? Proposed measures to protect or conserve plants, animals, fish, or marine life are: 3. How would the proposal be likely to deplete energy or natural resources? Proposed measures to protect or conserve energy and natural resources are: 4. How would the proposal be likely to use or affect environmentally sensitive areas or areas designated (or eligible or under study) for governmental protection; such as parks, wilderness, wild and scenic rivers, threatened or endangered species habitat, historic or cultural sites, wetlands, floodplains, or prime farmlands? Proposed measures to protect such resources or to avoid or reduce impacts are: 5. How would the proposal be likely to affect land and shoreline use, including whether it would allow or encourage land or shoreline uses incompatible with existing plans? Proposed measures to avoid or reduce shoreline and land use impacts are: 6. How would the proposal be likely to increase demands on transportation or public services and utilities? Proposed measures to reduce or respond to such demand(s) are: 7. Identify, if possible, whether the proposal may conflict with local, state, or federal laws or requirements for the protection of the environment.

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APPENDICES