Petrogas Ferndale Wharf Subsurface Reclamation Project Dredging Activities Table of Contents ____________________________________________________________________________ Petrogas Ferndale Wharf Subsurface Reclamation Project Dredging Activities Shoreline Substantial Development Permit Application Table of Contents: 1. Substantial Development Permit Application 2. Project Proposal and Extended Responses Document 3. Bargain and Sale Deed 4. Whatcom Evidence of Development before 1976 5. DNR Aquatic Lands Lease 20-A08488 6. Vicinity Map, Site Plan, Design Drawings, Bathymetric Data (2 copies) 7. Critical Areas Assessment (2 copies) 8. SEPA checklist 9. Nearby Property Owners list and self-adhesive mailing labels Petrogas Ferndale Wharf Subsurface Reclamation Project Dredging Activities Project Proposal and Supplemental Application Extended Responses Project Proposal: Since the construction of the Pier in 1965, sediment transport and deposition at the pierhead has resulted in the loss of approximately 5-8 feet of underkeel clearance along the west edge of the Pier. This clearance is critical to safe operation of the ships. The accumulated sediments have resulted in more frequent reberthings of ships during tidal changes. To address this issue, in August 2019, Petrogas submitted to the US Army Corps Dredged Materials Management Office (DMMO), a Tier 1 report to begin the process of planning for maintenance dredging at the Petrogas Pier. Petrogas is currently developing a Sediment Sampling and Analysis Plan (SSAP) by way of the sediment sampling experts at Anchor QEA, in coordination with the DMMO, to collect core samples of the sediment to characterize the sediment quality. The results of this sampling and analysis will be submitted to the DMMO to determine what options are available for proper disposal of dredged sediment. Petrogas is proposing to dredge up to 12,000 cubic yards of sediment to re-establish the original -38 ft of depth at Mean Lower Low Water (MLLW) to reduce the frequency of reberthing. The reduction in tugboat traffic and mooring operations will result in a safer overall operation and reduce environmental impacts. The dredging prism would be approximately 850 ft north to south along the west head of the Pier, up to 60 ft wide and -8 ft maximum depth from current lidar reading to the -38 ft MLLW design water depth, not including overdepth. The bathymetric data shows the sediments have accumulated close to the Pier structure where the piles have disrupted sediment transport. Dredging activities will be focused near the edge of the pier. A conversation has been started with the aquatics land owner, the Washington State Department of Natural Resources (DNR), regarding disposal options. It was proposed that if the dredged sediments were of suitable quality, that they be used to fill in the depressions to the west of the Pier. These depressions are the remnants of two removed mooring buoys. You can see these in the attached Bathymetric Map as the two large blue depressions within the Aquatic Lease Boundary. Based upon the bathymetric data, the mooring buoy depressions are roughly 250 ft wide and 13 feet deep, with approximately 23,500 cubic yards of available space. The DNR is supportive of this proposal pending verification that the sediment is sufficiently clean. Please see the letter from the DNR dated November 1, 2019, attached to the project description. 1 Petrogas Ferndale Wharf Subsurface Reclamation Project Dredging Activities Project Activities: To prepare the site for sediment removal, Petrogas is planning to pull the 16 historic abandoned pile stubs identified during the post Fender Repair Project underwater inspection. If the pile stubs cannot be successfully pulled, they will be cut off below the mudline. These piles are on the immediate north and south ends of the fenders and increase sediment deposition. Pile removal will be completed per the most current version of the Washington Department of Natural Resources Derelict Creosote Piling Removal Best management Practices. Petrogas is planning to dredge by means of mechanical bucket dredging using a crane and barge. The barge will spud in to stabilize the equipment while working. The spoils will be deposited on a barge for open water disposal or if deemed unsuitable, delivered to an approved upland solid waste facility. The overall dredge design depth is -38 feet (not including 2 ft of overdepth) MLLW. Project Construction Sequence: 1. Dredging will take 15-25 days assuming weather is appropriate. Accounting for regular monthly ship traffic, total project time is estimated to take up to 2 months. ● The contractor is planning to dredge by means of mechanical bucket dredging using a crane and barge. ● The barge will spud in to stabilize the equipment while working. ● As work is done, multibeam sonar will be used to measure the depth of the cut and ensure the dredging is done to the design specifications. ● As the sediment is dredged, the spoils will be deposited on a barge for open water disposal or if deemed unsuitable, delivered to an approved upland solid waste facility. ● The overall dredge design depth is -38 feet (not including 2 ft of overdepth) MLLW. ● The dredge bucket will not over-penetrate surface sediments, which can cause sediment to be expelled from the vents in the bucket, or cause sediment to become piled on top of the bucket, and then become eroded during bucket retrieval. ● The bucket will be closed smoothly when it is collecting dredge material. ● The method of operating the dredge will be modified based on changing site conditions, such as tides, waves, currents, and wind. ● Multiple bites while the bucket is on the bottom will not be permitted. ● Dredged material aboard the barge will be observed daily for the presence of fish to ensure that they are not being entrained by the clamshell bucket. If 2 Petrogas Ferndale Wharf Subsurface Reclamation Project Dredging Activities entrainment occurs, crane operation will be slowed to increase opportunity for fish to avoid the bucket. ● 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. ● Water quality will be monitored during dredging to ensure compliance with Washington State Surface Water Quality Standards (WAC 173-201A) or per the terms of the project permits. 2. If open water disposal is approved the following methods will be used: Using GPS, a tug boat will orient the barge at the disposal site. A front-end loader will scoop sediment from the deck of the barge and offload it over the edge of the barge. As the sediment deposits on the seafloor, the tug captain will track the location of the boat to distribute the sediment as evenly as practicable over the disposal site. This method allows for more even distribution of sediment when compared to a dump scow. This also reduces the impacts on benthic biota that reside in the sediments allowing for earlier recolonization of the surface sediments. Project Schedule: The project will be planned and completed during Washington State Department of Fish and Wildlife (WDFW) and United States Army Corps of Engineers (USACE) designated in-water work windows to minimize impacts on the local biota and critical habitat. Supplemental Application Extended Responses 1. Property Description: The property is a timber pier structure located at 4050 Mountain View Road, Ferndale, Washington. The pier, which was originally constructed in 1965, has undergone frequent routine repairs to maintain it in a fully serviceable condition. The structure serves as a loading point for LPG (Liquid Petroleum Gas). The pier is also a receiving point for raw aluminum ore, which is offloaded from ships with a clamshell transfer bucket and conveyed to shore with an enclosed conveyor belt system. The conveyance pipe for Intalco Aluminum Corporation’s main wastewater and stormwater outfall also runs along the pier to a diffuser below the surface of the water. The Pier serves as a deep water port on the east bank of the Strait of Georgia, a large marine inlet with heavy commercial boat traffic. The area is zoned heavy impact industrial and is neighbor to other industrial facilities that refine and distribute petroleum and smelt aluminum. 3 Petrogas Ferndale Wharf Subsurface Reclamation Project Dredging Activities Adjacent properties to the pier include oil refineries to the north and south, an LPG terminal facility to the southeast, an aluminum smelter to the east and railway property running north-south. 2. Shoreline Designation Regulations Per 23.90.120(B)(1)(c): This project is permitted as Maintenance dredging for the purpose of restoring a lawfully established development. Per 23.90.120 (4) Spoils Disposal: Petrogas has developed a Sediment Sampling and Analysis Plan (SSAP) by way of the sediment sampling experts at Anchor QEA, in coordination with the US Army Corps of Engineers Dredged Materials Management Office (DMMO), to collect core samples of the sediment to characterize the sediment quality. The results of this sampling and analysis will be submitted to the DMMO to determine what locations are available for proper disposal of dredged sediment. The selected location will either be a DMMO approved open-water disposal site or the sediment will be sent to an approved upland landfill. Either result will meet the Whatcom County spoils disposal regulations when combined with project BMPs and mitigation measures. 23.90.120 Dredging. 23.90.120(5) Minimum Requirements: a. A description of the purpose of the proposed dredging and an analysis of compliance with the policies and regulations of this program: See the Substantial Development Permit (this document) b. A detailed description of the existing physical character, shoreline geomorphology and biological resources provided by the area proposed to be dredged, including: See the Critical Areas Assessment. ​ i. A site plan map outlining the perimeter of the proposed dredge area.