Attach_18_-_Amend_0001_Tulageak_Statement_of_Work_0001.pdf

Solicitation 140L0623R0021 – Statement of Work (SOW) – REV

Tulageak Test Well #1 & Surface Remediation

National Petroleum Reserve - Alaska

Table of Contents

1.0 INTRODUCTION

1.1 Bureau Mission

1.2 Project Background

1.3 Project Scope

2.0 GENERAL REQUIREMENTS

2.1 Definitions

2.2 Contract Management

2.3 Key Personnel

2.4 Place of Performance

2.5 Transportation

2.6 Hours of Work

2.7 Reporting

2.8 Post Award and Status Meetings

3.0 PERFORMANCE REQUIREMENTS

3.1 Precondition Items

3.2 Planning Documents

3.3 Community Outreach

3.4 Mobilization

3.5 Demobilization

3.6 Field Sampling Plan and Surface Cleanup Plan

3.7 Field Sampling, Surface Clean Up and Remediation

3.8 Plugging and Abandonment of the Well Bore

3.9 Final Closeout

4.0 GOVERNMENT FURNISHED INFORMATION

5.0 DELIVERABLE REQUIREMENTS and SCHEDULES

5.1 General

5.2 Schedule

1.0 INTRODUCTION

1.1 Bureau Mission

The Bureau of Land Management’s (BLM) mission is: To sustain the health, diversity, and productivity of America's public lands for the use and enjoyment of present and future generations. It administers more public land over 245 million surface acres than any other Federal agency in the United States. Most of this land is located in the 12 Western states, including Alaska.

1.2 Project Background

Between 1944 and 1982, the U.S. Navy and the U.S. Geological Survey (USGS) conducted a program of exploratory and scientific drilling on Alaska’s North Slope in the Naval Petroleum Reserve No. 4 – now called the National Petroleum

Reserve in Alaska (NPR-A). In 1976, the Federal Government was given responsibility for managing the NPR-A, and in

1982 the BLM inherited the responsibility to assess, plug, and clean up wells the U.S. Navy and USGS left behind.

Since 1982, the BLM has worked to catalog and remediate these “legacy wells.” Some wells are still being used for scientific research, while others require remediation work. In order to take the next step toward full remediation of the wells, the BLM compiled the 2013 Legacy Wells Summary Report, which is a comprehensive site-by-site assessment of the condition of remaining inherited wells, and the 2020 Legacy Wells Strategic Plan, which lays out a dynamic and flexible near-term strategy for addressing some of the highest priority wells, while reemphasizing BLM’s commitment to achieving full remediation of all inherited wells.

1.2.1 Tulageak Test Well #1

The USGS contracted Huskey Oil to drill the Tulageak Test Well # 1 in 1981 as documented in the Drilling History

(Attachment 3). This site consists of a well inside of a constructed wooden cellar, a pad, a flare pit, and a reserve pit. The reserve and flare pits have subsided to the point where water flows freely into each other as well as surrounding ponds.

The site is approximately 25 miles southeast of Utqiagvik. Updated Coordinates from 2022 are provided in the Site

Inspection (Attachment 4).

Waste associated with this site includes wood pilings that were used as the foundation for the initial drilling and small amounts of scattered debris. The southernmost pilings are now within the shoreline of the reserve pit. During the winter of

2019 the Tulageak #1 reserve pit was characterized for future clean-up operations. Arsenic exceeded the ADEC Method

Two soil cleanup level of 12 micrograms per kilogram (mg/kg) in approximately 80 percent of the samples collected from the well sites. The detected arsenic concentrations were considered typical of the region and attributed to native soils, as opposed to an anthropogenic contaminant from past drilling activities. DRO exceeded the Alaska Department of

Environmental Conservation (ADEC) Method One soil cleanup level of 500 mg/kg in one borehole each within the reserve pit, flare pit, and well area. The full report can be found in Attachment 5.

Tulageak Test Well #1 has a wellhead with a closed and operational gate valve and cap. The rat hole is within the cellar and is open to the environment. A mouse hole approximately 6 inches high is outside of the cellar and is open to the environment. At the conclusion of the drilling and evaluation operations, two cement and mechanical plugs were set in the wellbore with the top of the second plug at 2,600 feet. From 2,000 feet to the surface, the hole is filled with diesel fuel overlying 600 feet of mud. There is no Arctic Pack in any of the remaining casing annuluses. The 9 ⅝-inch surface casing has cement from 2,720 feet to surface with cement in the 9 ⅝-inch by 20-inch casing annulus from 105 feet to surface.

The wellbore schematic is depicted in Attachment 6.

1.2.2 West Dease Legacy Well Site

The West Dease #1 site is 27 miles southeast of Utqiaġvik and approximately 3 miles southeast of the Tulageak #1 well site. Updated coordinates are in the site inspection report (Attachment 7). The site consists of a well contained within a wooden cellar, a pad, a flare pit, and a reserve pit. There are two small piles of drilling muds on the pad. The well cellar and wellhead are still intact. Wooden pilings extend from the wellhead to the northeast. The pilings were cut off at ground level upon cessation of drilling operations. The reserve pit and flare pit are now connected by a small body of water that resulted from the ground thawing. The pad is less than ¾-mile from the coastline. The well is currently in use by USGS as a temperature monitoring well. There is evidence that Arctic fox have a den in the well pad. An environmental status report was generated in 1992 (Attachment 8).

1.2.3 East Simpson #1 Legacy Well Site

The East Simpson #1 wellsite area is 56 miles southeast of Utqiaġvik and approximately 30 miles southeast of the

Tulageak #1 well site. Updated coordinates are in the attached site inspection report (Attachment 9). The site consists of a well contained within a wooden cellar, a pad, a flare pit and a reserve pit. The reserve pit has expanded outward as tundra has thawed. In the process, the southernmost wooden pilings are now contained in the reserve pit. The flare pit walls have eroded into the reserve pit. Water flows from the reserve and flare pit to nearby surface waters during breakup. The well is currently in use by USGS as a temperature monitoring well. The 2013 summary report mentions USGS survey markers halfway between the well and the coastline. An inspection from 2022 found the same marker only a few feet from the coastline. An Environmental status report was generated in 1992 (Attachment 10).

1.3 Project Scope

The BLM anticipates awarding a contract for the base requirement of Plugging and Abandonment (P&A) of Tulageak

Test Well #1, including the remediation and excavation of drilling mud and cuttings from the reserve pit and surrounding area. Transport and disposal of excavated mud and cuttings to an approved facility will be necessary.

Optional line items included in this contract are for the delineation and characterization of the well sites and reserve pits of West Dease #1 and East Simpson #1 to ADEC standards.

In 1995 the ADEC considered the reserve pits at Tulageak #1, West Dease #1 and East Simpson #1 to be ‘Closed As Is’.

The reserve pits are ADEC special solid waste facilities under 18 AAC. 60.440.

This contract optional tasks do not include any remediation or plug and abandonment activities at the West Dease #1 or

East Simpson #1 sites. The optional tasks are solely to delineate and characterize as described in section 3.10.

The proposed project would occur within or adjacent to habitat for the Beaufort Sea and Chukchi Sea populations of polar bears. To identify and avoid polar bear den sites the following are required prior winter work activities:

-Aerial FLIR (Forward Looking Infrared Thermal Imaging) for two (2) surveys ideally 2-3 weeks apart during

December 2023 and January 2024. These surveys shall include proposed routes, the well sites, camp locations and water source lakes.

-SnowDens 3D predictive snow drift modeling using real time weather data and Digital Elevation Model data to predict potential polar bear denning habitat. An initial SnowDens 3D model would be completed during the first week of December 2023. This modeling effort would be used to review the proposed route locations and identify areas of potentially suitable denning habitat for the aerial infrared den detection surveys. A second SnowDens 3D model would then be completed 7 days before scouting of the snow trails (if more than a month has passed from the initial model run). The second model run would be used to make adjustments to the proposed routes and to identify areas to survey using the handheld thermal camera during route scouting and construction.

The data from the FLIR surveys and SnowDens 3D modeling will be used to adjust snow trail locations to avoid areas with drifted snow and potential polar bear den sites. Results of the SnowDens 3D models would be loaded into the on-board vehicle computers to ensure areas of potential den sites are located and surveyed with the handheld thermal imaging camera during scouting, construction, and use of snow trails. No snow trails would be constructed within 1 mile of observed, known, or suspected polar bear dens sites.

2.0 GENERAL REQUIREMENTS

This section describes the general requirements of this contact.

2.1 Definitions

Unless Noted Otherwise (UNO) herein, the following definitions will apply within this contract:

Alaska Administrative Code, Title 18 – A body of State laws regarding Environmental Conservation.

Alaska State Department of Environmental Conservation (ADEC) - ADEC is responsible for regulating the

Environmental Conservation Regulations per the Alaska Administrative Code, Title 18.

Alaska Oil and Gas Conservation Commission (AOGCC) - AOGCC is responsible for protecting the public interest in exploration and development of oil and gas resources in its full life-cycle, inclusive of the final Plugging and

Abandonment (P&A) efforts.

BLM -The BLM is responsible for managing the land and issuing use authorizations for all activities that occur within the

NPR-A. The Contractor will be responsible for providing the BLM a Work Plan and other relevant plans necessary to obtain a use authorization for access to the NPR-A (i.e., Waste Management Plan, Subsistence Plan, etc.) as a part of their

Precondition Items compliance. Based on the proposed activities, the Contractor will be required to comply with the applicable tailored stipulation package in order to minimize the potential impacts that are identified and are consistent with the current NPR-A Integrated Activity Plan Record of Decision.

Day – means, unless otherwise specified, a calendar day.

Plugging and Abandonment (P&A) - To place cement plugs into wellbore and abandon it in accordance with regulatory requirements. A well is abandoned when it reaches the end of its useful life or is a dry hole. The casing and other equipment is removed and salvaged. Cement plugs are placed in the borehole to prevent migration of fluids between the different formations. The surface area around the wellhead is reclaimed.

Remediation – The completion of plugging the well bore to regulatory standards and surface cleanup activities at a legacy well site.

U.S. Fish and Wildlife Service, Alaska Region (USFWS) - USFWS is responsible for working with others to conserve, protect and enhance fish, wildlife, plants and their habitats for the continuing benefit of the American people. Endangered species consultation will occur with the USFWS pursuant to the Endangered Species Act and the Marine Mammals

Protection Act and will either be initiated by the BLM or by the Contractor depending on the activity.

2.2 Contract Management

The Contractor shall manage the overall timeliness and completeness of work and timely provide quality, pertinent information when identifying problems that arise. The Contractor shall seek to ensure customer satisfaction and professional and ethical behavior of all Contractor personnel.

The Contractor shall establish clear organizational lines of authority and responsibility to ensure effective management and successful integration and coordination among all activities, resources and Subcontractors needed to fulfill the requirements.

The Contractor shall be responsible for any subcontract management necessary to integrate work performed under this contract and shall be responsible and accountable for subcontractor performance on this requirement. The prime

Contractor will manage work distribution to ensure there are no Organizational Conflict of Interest (OCI) considerations.

2.3 Key Personnel

The Contractor shall provide personnel who are qualified and competent to perform the work to be accomplished under this contract. At a minimum, the contractor shall have on staff and/or obtain by subcontracting key personnel to fulfill the functions listed below during the performance of the project.

Project Manager: One (1) senior level staff with experience in arctic plugging and abandonment operations and/or remediation services in an arctic environment.

Senior Petroleum Engineer: One (1) Alaska-registered professional engineer with experience in arctic plugging and abandonment operations.

Site Superintendent: One (1) site superintendent with experience specifically related to well plugging and abandonment operations.

Administrative POC: One (1) individual dedicated to delivering reports and required daily/weekly updates.

Additional requirements would be to coordinate regularly scheduled meetings with the BLM to communicate status of mobilization, ongoing surface work and demobilization. Meetings may occur more than once a week depending on real-time changes or potential permitting deviations in the field.

Qualified Environmental Professional: One (1) project chemist/environmental scientist or similar with experience related to preparing sampling and analysis plans, quality assurance project plans, laboratory selection, performing field screening, collecting analytical samples, performing project level data quality management, and/or evaluating data usability. The individual shall be responsible for collecting all analytical samples and evaluating the analytical data for usability. The individual shall be ADEC qualified persons as defined in 18

Alaska Administrative Code (AAC) 75.333.990 (100).

Additionally, the Contractor shall identify the position(s) responsible for the following:

• Position with full authority to act for the contractor on all contract matters.

• Position responsible for overall management of the contract including quality assurance and quality control of all deliverables.

• Position responsible for day-to-day operations on the project site to include controlling the schedule and ensuring coordination with subcontractors.

• Position present onsite for the duration of the major phases of work, (mobilization/demobilization, well plugging and abandonment and surface clean up).

2.4 Place of Performance

National Petroleum Reserve-Alaska (NPR-A), southeast of Utqiaġvik. Two sites are along the coastline west of Dease

Inlet and one site along the coastline west of Smith Bay on Cape Simpson.

2.5 Transportation

The Contractor shall be responsible for transporting all personnel, equipment and supplies to the project site.

2.6 Hours of Work

The Contractor shall be responsible for establishing the hours of work requirements for their employees and subcontractors.

2.7 Reporting

The Contractor shall prepare and submit reports as specified herein. The Contractor shall prepare other reports as needed and as required by the BLM or any regulatory agency that has issued a permit for the site work or has other authority over the work activities or the site. Examples of such reports may include, but are not limited to, Surface Reports, Spill

Reports and Accident Reports.

2.7.1 Daily Quality Control Reports (DQCRs)

For all mobilization efforts, the contractor shall maintain current DQCRs providing factual evidence that required quality control activities and/or tests have been performed. These records shall include descriptions of both conforming and deficient work of subcontractors and suppliers and shall include, at a minimum, the following information:

• Contract number;

• Date or dates covered by the report;

• Weather conditions encountered;

• Contractor;

• Test and/or control activities performed, control phase (preparatory, initial, follow-up), results, and deficiencies, if any, along with corrective action taken;

• Health and safety summary, including daily safety meeting, worker protection levels, accidents, and corrective actions;

• Work performed including location, description, and by whom;

• Summary of instructions received from the government and any conflicts with plans or contracts;

• Any potential or encountered delays, with explanation;

• Contractor's verification statement that equipment and materials incorporated in the work and workmanship comply with the contract; and

• Photographs of field activities labeled with the Contract Number, Location, Contractor/Photographer, Photograph Number, Date, Time, Description, and Direction of View.

• Documentation of wildlife interaction in accordance with any permitting stipulations

2.7.2 Monthly Status Reports

The Contractor shall prepare monthly status reports consisting of a brief summary of work that has been performed, work underway, work planned for the upcoming month, status of laboratory reports and data received, outstanding laboratory reports or other outstanding data, progress payment tracking and associated work summaries, and other pertinent project information. Each status report shall state whether current work is on schedule.

2.8 Post Award and Status Meetings

2.8.1 Contract Award Post Award Conference

The contractor shall organize and lead a post-award meeting within 14 days of the Notice to Proceed (NTP) at a time and location acceptable to the Government. The contractor will include the Government project team and contractor personnel responsible for project execution and quality control. Meeting objectives shall include identification of anticipated project milestones and key issues related to the project.

2.8.2 Project Status Meetings

The Contractor shall schedule and participate in three (3) project status meetings during critical project activities (work plan comment resolution, field work, and report comment resolution). These meetings may be conducted via teleconference. The contractor shall provide an agenda to all team members prior to each meeting and complete the meeting minutes at the end of each meeting.

2.8.3 Project Permitting and Stipulation Kick-off Meeting

The Contractor shall schedule and host (may be virtual) a kick-off meeting prior to the start of any work. This meeting shall cover all permit stipulations granted to the contractor for all operations. Depending on permitting and work season there may be more than one meeting needed.

2.8.4 Project Kick-off Meeting and Employee Orientation

The Contractor shall schedule and host (may be virtual) a kick-off meeting 2-4 weeks prior to the start of winter work

(mobilization). This meeting shall cover the plan of operations, roles and responsibilities of contract employees, and introduction to point of contacts between the contractor and BLM. Provide information to all personnel involved concerning applicable stipulations, Required Operating Procedures, standards, and specific types of environmental, social, traditional, and cultural concerns that relate to the region. Any required training required for wildlife interaction shall be addressed during this meeting, depending on the needed training another meeting may need to occur.

3.0 PERFORMANCE REQUIREMENTS

All deliverables shall be provided in the format per Section 5.0 Deliverable Requirements and Schedules.

3.1 Precondition Items

The Contractor shall identify and obtain all requisite precondition items applicable for the place of performance.

Precondition items include all local (borough), state, and federal permits, agreements, authorizations, notices, and stipulations from any entity having jurisdiction/ownership of the land/property to be affected, inclusive of land that must be traversed to access each well site. The Contractor shall apply for and secure a Right of Way (ROW) from the BLM prior to start of the project. The Contractor shall be compliant with applicable laws and regulations per the applicable jurisdiction/ownership of the land/property to be affected. Depending upon the applicable precondition items required and based upon the Contractor proposed activity (work), the Contractor shall comply with onsite inspections, other stipulations and any subsequent correction items that may result.

The Government may undertake or award other contracts for additional work at or near the site of the work under this contract. The Contractor shall fully cooperate with the other contractors and with Government employees and shall carefully adapt scheduling and performing the work under this contract to accommodate the additional work, heeding any direction that may be provided by the Contracting Officer. The Contractor shall not commit or permit any act that will interfere with the performance of work by any other contractor or by Government employees.

For the Tulageak Project the BLM has prepared and submitted an Incidental Harassment Authorization (IHA) for compliance with the Endangered Species Act (ESA) and the Marine Mammal Protection Act (MMPA). Additionally, the

BLM will initiate consultation with the U.S. Fish and Wildlife Service (USFWS) and the National Marine Fisheries

Service (NMFS) as appropriate. The IHA application will include pre-determined route options that the contractor can pick from to get to and from the site(s) (Attachment 11).

3.2 Planning Documents

The Contractor shall prepare and submit draft and final versions of the planning documents. The following planning documents provide the basis to fulfill all tasks required by the contract. Plans shall be customized in accordance with

Precondition Item requirements. All planning documents shall be submitted as individual plans. Any Contractor driven deviations to the plan(s) and impacts to the project (including timing) will be the responsibility of the Contractor unless otherwise determined by the Contracting Officer.

3.2.1 Work Plan

The Contractor shall prepare a detailed and comprehensive plan for work to be performed. No work at the site shall be performed until the Final Work Plan is accepted. The Work Plan shall be prepared in a systematic and logical format so that performance requirements may be readily referenced and understood by all personnel performing the work and by all persons reviewing the plan.

The Work Plan shall include, but is not limited to:

• Introduction: The goals of the project, and the expected results.

• Site Background and Physical Setting: Current understanding of the physical setting of the site, the site history, and existing information on the condition of the site.

• Work Plan Rationale: The Work Plan approach illustrating how the activities will satisfy contract requirements.

• Contract Tasks: All tasks to be performed during the contract, including applicable laws and regulations for each task. Task descriptions shall include the technical approach and details of the plug and abandonment of test wells, applicable plans/drawings, removal, and containerization of fluids from test wells, transportation, disposal activities, and sampling and analysis plans.

• A list of all applicable permits and/or authorizations required to be obtained to perform the proposed tasks, including the name of regulatory agency responsible for issuing the authorization.

• Key Personnel: Key personnel to be used on the project and their responsibilities.

3.2.2 Project Schedule

The Contractor shall submit a detailed schedule showing the periods in which work will be performed and milestone dates to complete the planning, mobilization/demobilization, fieldwork, and reporting tasks. The project schedule shall be provided in Gantt chart format and shall include dates for starting and completing critical features of the work.

3.2.3 Site Safety and Health Plan

The Contractor shall develop and follow a Site Safety and Health Plan (SSHP) for all field activities associated with this contract and for all persons performing work under this contract. The SSHP shall be developed and maintained in compliance with the most recent requirements OSHA standard 29 Code of Federal Regulations (CFR) 1910 and all applicable Federal, State, and local safety and occupational health laws and regulations. Where the requirements of applicable laws, criteria, ordinances, regulations, and referenced documents vary, the most stringent requirements shall apply.

All abandonment procedures must meet Federal requirements as identified under the Bureau of Land Management’s

Onshore Oil and Gas Order #2.

Well control equipment such as BOPE will be required in accordance with Onshore Oil and Gas Order #2 as if we were drilling due to unknown pressures and nature of some wells. Additionally, all BOPE closing rams shall be hydraulically activated.

Mishap Notification and Investigation: In the instance where Government personnel are injured and become incapacitated to the point where they can’t report a mishap themselves, the Contractor shall initially respond to the life and safety needs of such an incapacitated individual and then shall promptly report pertinent facts regarding mishaps by notifying the CO, COR and/or other applicable individuals as soon as feasibly possible. The Contractor and its Subcontractors (as applicable) shall cooperate fully in any resulting safety investigation.

General Public: Where the instances exist, the Contractor shall be diligent in providing safety measures for keeping the general public from access to the work site and protecting them from harm in the general vicinity.

Weather: The Contractor shall remain vigilant regarding weather conditions that can be harmful to life and safety of the employees and shall take the appropriate precautionary actions to assure that life and safety are preserved. The Contractor shall also assure that equipment failure due to weather conditions is mitigated; equipment vital to the success of the requirements is of special concern.

The Contract Price Schedule (Attachment 1) includes a separate Firm Fixed Price Unit contract line item number (CLIN) for Inclement Weather Days. Inclement weather is defined as low visibility and/or temperatures causing unsafe working conditions that require shutdown of work (typically below -50 degrees Fahrenheit or above 30 degrees Fahrenheit).

Specific conditions warranting shutdown of work due to inclement weather are subject to CO approval. The Contractor shall communicate any inclement weather conditions to the CO and COR as soon as practicable and at least within 24 hours of occurrence. Delays less than six (6) hours shall be billed at 50% of the established day rate (unit price) in the

Contract Price Schedule. Delays of six (6) hours or more may be billed at the full day rate (unit price) in the Contract

Price Schedule. Any billing under CLIN 2 requires Contracting Officer approval.

The following items, if applicable, are considered allowable costs for calculating Inclement Weather Day rates:

1. Salaried employees (i.e., Project Manager (PM), Assistant Project Manager, Superintendent, Assistant

Superintendent, Quality Control, Safety Officer, Environmental Manager, etc.)

2. Engineering Costs

3. Labor Costs for Corresponding Phase of Work

4. Travel, Lodging, and Per Diem (as established by Federal Travel Regulations)

5. Scheduling

6. Field Equipment and Associated Support Equipment

7. Additional Equipment in the Field or on Site Required for the Corresponding Phase of Work

Equipment rates may include operating costs of all fuel, oil, lubrication, supplies, small tools, necessary attachments, ground engaging components, tires and tracks, routine repairs, and maintenance (cost of major repair and overhaul is not allowed per Federal Acquisition Regulation (FAR) 31.105(d)(2)), depreciation, storage, insurance, and all incidentals.

3.2.4 Environmental and Resource Protection Plans

The Contractor shall prepare a comprehensive Environmental Protection Plan. The Contractor has responsibility for adequate and continuing control of pollutants and other environmental protection measures. Additional requirements may be found in the Environmental Assessment as posted on the BLM E-Planning website as referenced in section 4. These plans may be subject to additional iterations throughout the permitting process. The Environmental and Resource

Protection Plans shall include, but shall not be limited to, the following (as applicable):

• Spill Prevention and Cleanup Plan

• Wildlife Interaction Plan o Shall include mitigation measures as appropriate from the Environmental Assessment (EA) process.

o Polar Bear Interaction Plan shall meet at a minimum all the requirements outlined in the BLM provided Polar Bear Interaction plan (Attachment 12, and any additional requirements identified in the IHA).

• Water Usage and Source Plan o Methods of protecting surface water and groundwater during work activities, including storm water management and storm water pollution prevention plans as applicable.

• Winter Activities Travel Plan o Estimated vehicle weight, psi distribution and maximum anticipated load weight o Estimated round trips for overland o Estimated aircraft take-off and landings o Invasive species protection methods o Program for handheld FLIR during trail construction o All anticipated routes for overland access (Attachment 11)

▪ Include map detailing the routes and intended use

▪ Table of Section, Township and Ranges crossed by each route

▪ Shape files for the routes depicted in Attachment 11 may be obtained from the BLM.

• Summer Activities Travel Plan o Estimated take-offs and landings

• Cultural Resources

A list of Federal, State, and local laws, regulations, and permits concerning environmental protection, pollution control, and pollution abatement that are applicable to the Contractor proposed operations and the requirements imposed by those laws, regulations, and permits.

• Methods for protection of features to be preserved within authorized work areas, as applicable (landscape features, air and water quality, fish and wildlife, soil, and historical, archaeological, and cultural resources).

• Procedures to provide the required environmental protection, to comply with the applicable laws and regulations, and to correct pollution due to accident, natural causes, or failure to follow the procedures of the Environmental Protection Plan.

• Plan showing the proposed activity in each portion of the work area and identifying the areas of limited use or nonuse. Plan should include measures for marking the limits of use areas and drawings showing locations of all proposed brine and cement mixing areas, material storage areas, structures, and sanitary facilities.

3.2.5 Waste Management Plan

The Contractor shall prepare a plan detailing the manner in which wastes will be managed both onsite and offsite. As appropriate and as applicable, this plan shall include any wastewater generated, pumped, or collected as part of any field activities. The plan shall identify facilities to be used for treatment, storage, and/or disposal of the various waste streams including but not limited to the drilling mud and cuttings, contaminated soils, investigation generated materials, well bore fluids, etc. or recycling; shall identify whether transfer facilities are to be used; and how the wastes will be tracked to ultimate disposal or recycling.

3.2.6 Quality Control Plan

The Contractor shall provide a Quality Control Plan (QCP) describing the Contractor’s systematic methods to maintain an effective quality control program ensuring services are performed in accordance with the contract. At a minimum, the

QCP shall include a description of the quality control organization with a chart showing lines of authority, and acknowledgment that the QCP staff shall implement preparatory, initial, and follow-up control phases for definable features of work.

3.2.7 Other Additional Plans

The Contractor may be required to provide additional plans pursuant to Required Operating Procedures specified in the

2020 NPR-A Integrated Activity Plan Record of Decision (see Section 4.0 of this document). The determination of the additional plans required to be submitted will be made in conjunction with the permitting described in Section 3.1 above.

3.3 Community Outreach

The Contractor shall develop, implement, and document a Community Outreach Plan to inform local communities of work activities (i.e., radio ads, newspaper ads, community meetings) as applicable. Outreach efforts shall be targeted and customized to inform impacted communities (i.e., plans concerning navigational landmarks for subsistence hunters shall be targeted to community members). The contractor shall not release any project information to the public without prior approval of BLM in accordance with section 3.1 and 5.0 of this SOW. Notifications shall be provided at least 30 days prior to notice of scheduled work.

3.4 Mobilization

The Contractor shall transport all equipment, supplies, materials, temporary facilities, and personnel to perform the plug and abandonment field work and reserve pit remediation work at Tulageak and characterization at each additional well site. For pre-determined access see section 3.1 and Attachment 11.

3.5 Demobilization

The Contractor shall demobilize all personnel, equipment, excess materials, and waste well materials brought to the site or generated at the site during the work described in this scope of work. For pre-determined access see section 3.1 and

Attachment 11.

3.6 Field Sampling Plan and Surface Cleanup Plan

The Contractor shall develop a plan to conduct a site investigation to determine if there was a release of contaminants in the soil and/or water that may warrant further investigation, as well as locate surface debris to be removed. Draft plans shall be submitted to BLM for review and coordination with ADEC as appropriate. BLM will provide comments to the

Contractor to incorporate into the final Plan(s).

3.6.1 Field Sampling Plan

The Contractor shall provide a Field Sampling Plan for contaminants for each legacy well site designed to identify likely source areas, chemicals of concern, and the method of investigation to determine the presence or absence of contaminants.

The Field Sampling Plan shall incorporate all known historical information and the most current understanding of the exploration activities that took place, site use, and include individual site-plan figures of the historical layout if known, identifying specific areas to investigate, areas of potentially similar use to investigate and proposed soil sample locations.

The sampling strategy will include identifying areas based on field observations (i.e., disturbed ground, odors, staining, or stressed vegetation), proximity to the well head, and reasonable expectations of site used based on similarities to sites where activities were known. Additional details for sampling minimum requirements are as follow:

A. Sampling Requirements for Wellhead and Cellar Area

a. Propose initial wellhead and cellar area sampling (pre-disturbance for work) to include the collection of a minimum of three discrete surface and subsurface samples within approximately 15 to 20 feet of the wellhead. The sample locations are to be determined in the field by a combination of field screening results, noticeable unnatural soil stains, stressed vegetation, or previously disturbed areas.

b. Propose sampling for excavated soils and solids in accordance with ADEC guidance for field sampling.

c. Propose wellbore fluid sampling based on known or suspected contaminates of concern.

d. Additional sampling may be required based on results and specific well areas.

B. Requirements for Remediation of Reserve Pit, Flare Pit and Other Disturbed Areas

a. The contractor shall provide a sampling analysis program consistent with all appropriate regulations and requirements per ADEC for reserve pit closure, flare pits and other disturbed areas.

b. The contractor shall also provide a base line sampling program for any areas that will be utilized for interim storage of wastes and confirmation sampling once these sites are closed out.

c. Treatment of reserve pit or flare pit fluids may be required based on sampling results and regulatory requirements.

C. For Optional Sites Only: Delineation and Characterization of Reserve Pit, Flare Pit and Other Disturbed Areas

a. The contractor shall provide a sampling plan for site delineation and characterization meeting ADEC guidance for site characterization. The plan shall include:

i. Proposal to characterize and determine the lateral and vertical extent of drilling waste at the site.

ii. Proposal to characterize reserve pit and flare pit fluids if present.

b. If limited historical information exists, the Field Sampling Plan shall include a methodical sampling strategy designed to investigate the site and area surrounding the well head, likely to have supported the field operations, including where releases were most likely although not evident.

3.6.2 Surface Clean Up Plan

The Contractor shall provide a Surface Cleanup Plan that includes a site inventory of all surface debris and contaminants including the well cellar, reserve pit and flare pit, to be removed at the legacy well site. The site inventory shall include indexed photos of the site and a fully scaled, geo-referenced site map inclusive of a keyed itemization of surface debris defining the location, type of debris, and size.

The Surface Cleanup Plan shall be developed to identify how the debris and contaminants will be removed, any possible issues and risks that may affect the potential removal of certain debris, and any types of equipment that might be required to accomplish the removals. The plan shall provide information on the equipment and materials needed for this project and how it will be used. In addition, the Contractor shall address the timeframe of this operation and how it will be scheduled and relate to other phases of the project. Specifically, the contractor will identify how the fluids from the reserve pit will be removed and handled. The contractor shall identify what measures or contingencies will be in place to deal with metallic and solid waste that may be encountered during the excavation of the reserve pit. The plan shall discuss how the drilling waste will be managed and transported for disposal.

3.7 Field Sampling, Surface Clean Up and Remediation

The Contractor shall implement the approved Final Sampling and Surface Cleanup Plans for the Legacy Well site.

3.7.1 Field Sampling Plan and Clean Up Plan Documentation

The Contractor shall provide a Sampling Report to document the results of the field sampling. Draft reports shall be submitted to BLM for review and coordination with ADEC as appropriate. BLM will provide comments to the Contractor to incorporate into the Final report.

Field screening will be an acceptable method of contamination detection during field operations. All field screening protocols will be addressed proposal and reflected in the sampling program for this site. This should include any analytical confirmation of field results and QA/QC.

The Contractor shall provide a Final Site Inspection Report certifying work has been completed in accordance with the

Site Cleanup Plan. This report shall include photos of soil removal and surface debris removal and proof of disposal of both as applicable.

3.7.2 Surface Clean up and Remediation of Tulageak Reserve Pit

Execute the approved plan for removal of all solid waste and drilling waste within the reserve pit and flare pit of the

Tulageak #1 Legacy Well Site and surrounding area, including the pilings. The pilings shall be cut to surface level or just below. This plan shall be in accordance with all state and federal regulations. Estimated area of impact is defined in the

Tulageak #1 Legacy Well Site Reserve Pit and Flare Pit Delineation and Field Sampling Report from August of 2019

(Attachment 5). The plan shall not include long term staging of any excavated materials. All contaminated solids and materials should be removed from site by end of winter activities and transported to appropriate disposal sites. Propose and execute a plan for confirmation sampling to ADEC standards to confirm complete removal of wastes.

3.8 Plugging and Abandonment of the Well Bore

The Contractor shall determine and implement the requirements needed for successfully plugging each well bore to meet the requirements depicted in the individual wellbore diagrams provided by BLM by performing the following:

3.8.1 P&A Design

The Contractor shall develop an approach and method of execution for Plugging and Abandonment (P&A) of Tulageak

Test Well #1 in accordance with the wellbore diagrams provided by BLM and Onshore Oil and Gas Order #2. The

Contractor shall submit a P&A Design (Sundry Notice 3160-5) to the BLM. BLM will coordinate with AOGCC and provide comments to the Contractor. The Contractor shall incorporate comments and produce the final P&A Design.

Design shall incorporate the following products and procedures as appropriate for the well:

Drilling Muds: Drilling mud used for plugging operations shall be a brine water and weighing agent slurry. Additives shall be environmentally safe, containing no heavy metals, and be provided in sufficient quantities on the well site to contain the well bore pressure.

Cement: Cement used for plugs shall be competent for use in permafrost.

Water: Water used for drilling and cementing operations shall be potable water. If the water is from a non-potable source the water shall be tested to ensure compatibility with the cement. The Contractor shall submit a copy of the compatibility test to the Contracting Officer.

3.8.2 P&A Equipment and Goods

At a minimum, the Contractor shall provide the following:

Completion/Work Over Rig: A rig capable of reaching the PBTD of Tulageak #1 is required. The rig shall be furnished with crew and supervision. Provide the manufacturer's name, size and capacity for the rig and the following required accessory equipment:

• Workstrings included shall be adequate for circulation of drilling mud/fluids and cement. Based on the requirements of the specific well additional types of workstrings may be required. This includes but is not limited to any necessary bits, scrapers or overshots depending on the scope of work identified in section 3.8.3.

• Downhole tools include any cast iron bridge plugs or cast-iron cement retainers, annulus casing packers (cement platform) appropriately sized for the casing string involved, junk baskets sized for the plugs/platforms and tubing punches (or similar) as needed.

Well Control Equipment: The well control equipment shall consist of a hydraulic full opening valve capable of providing full closure of the wellbore during non-operational periods.

Circulating Equipment: The circulating equipment shall consist of the mud pump and mud tanks. The mud pump shall be capable of discharge volumes and discharge pressures required for the individual wells. A sufficient number of mud tanks shall be furnished to contain the drilling mud required for plugging operations.

Cementing Equipment: The cementing equipment shall be capable of batch mixing of cement slurry. A mud/multi-purpose pump shall be provided that is capable of pumping the cement slurry to the plug depths as specified.

Storage Tanks - Well Fluids: A sufficient number of storage tanks shall be furnished to contain all well fluids circulated from the well during plugging operations.

Plug and Abandonment Marker: Shall be a metal plate at least 1/4" thick and welded in place. A weep hole shall be in the plate. The following shall be inscribed on the plate:

1. Well name and number

2. US Well Number (API#)

3. Federal lease number

4. AK PTD #

3.8.3 P&A of Tulageak Test Well #1

Contractor shall propose a plan for the plug and abandonment of Tulageak Test Well #1 including removal and disposal of diesel and drilling mud from the wellbore and any wellhead debris in compliance with Onshore Oil and Gas Order #2.

P&A design should include a plan to tag and confirm the depth of the current shoe plug (~2600 feet) and test the integrity of the 9-5/8” casing. In addition to the surface plug P&A design should plan for the potential need of additional cement

(~150 feet) based on finding of shoe plug and integrity test. Due to the coastal proximity of this well the cut off depth will be a minimum of 10 feet below sea level. Further details for the well can be found in Attachments 2 and 4.

3.8.4 P&A Effort

Utilizing the Final P&A Design, the Contractor shall meet the objectives depicted in the wellbore diagram for each individual well.

• The wellhead and/or casing shall be removed to a minimum of 10-feet below sea level.

• The Contractor shall notify the COR immediately of changes to the P&A Design and/or issues that could prevent meeting objectives within the contract parameters.

3.8.5 Polychlorinated Biphenyl (PCB) Contamination Sampling and Analysis

Wells that have fluid in the wellbore shall have a sample taken of the liquid. Reserve pit, flare pit, drilling waste piles and other areas that may contain drilling mud or cuttings shall also be sampled. A field test will be performed on-site for PCB contamination. All samples, whether positive or negative for PCBs based on the field test will then be analyzed in an

ADEC and Environmental Laboratory Accreditation Program (ELAP) certified fluid testing lab for detailed PCB levels.

If PCB contaminants are found, procedures for removal and disposal will occur in accordance with ADEC regulations.

3.8.6 Final P&A Certification

The Contractor shall execute the Final P&A Design at each Legacy Well site and provide a Professional Engineer stamped letter certifying the P&A was fulfilled per the Final P&A Design plan.

3.8.7 Final Remediation and Pit Closure

The Contractor shall execute the approved excavation and remediation of the Reserve Pit, Flare Pit and clean-up of all associated debris at the Tulageak site and provide a Final Report or similar to satisfy the requirements of ADEC Site

Closure.

3.9 Final Closeout

The Contractor shall submit 2 project close-out reports: one for the site, as well as a summarization of the specific outreach efforts conducted, the outcomes, and the impacts to the affected communities. This project close-out report shall consist of: Sundry Notice 3160-5, Well Completion or Recompletion Report and Log, and P&A Technical memorandum.

The second closeout report shall include summarization of all surface activities including mobilization and demobilization routes and any other information required in final reporting of all permits.

3.10 Accommodations

The Contractor shall provide suitable living accommodations and provisions for up to two visiting government representatives as specified in the contract. At a minimum, government personnel will be on site to witness the plugging and abandonment of the well.

3.11 Optional Tasks

3.10.1 Option 1. Characterization of West Dease #1 Well Site and Reserve Pit

Complete all performance objectives outlined in the SOW section 3.6.1.C. A work plan including the sampling plan shall be submitted to BLM prior to the start of operations. For this Optional Task the following shall be generated and submitted with the final reports:

- An inventory of all solid waste present on and adjacent to the well pad.

- A map showing the extent of sampling locations and delineation of drilling mud location.

- An excavation plan for the reserve pit including a volumetric estimate of drill mud and cuttings, flare pit and other identified areas of contamination including an as built diagram/isopach map to reference for future http://doa.alaska.gov/ogc/forms/forms.html remediation work.

- Representative sampling of the water column of the reserve pit.

All sampling reports shall be submitted to BLM upon completion. A GPS log of all sampling locations shall be provided. Winter and summer activities are likely needed to acquire requested data. Further details can be found in

Attachments 7 and 8.

3.10.2 Option 2. Characterization of East Simpson #1 Well Site and Reserve Pit

Complete all performance objectives outlined in the SOW section 3.6.1.C. A work plan including the sampling plan shall be submitted to BLM prior to the start of operations. For this Optional Task the following shall be generated and submitted with the final reports:

- An inventory of all solid waste present on and adjacent to the well pad.

- A map showing the extent of sampling locations and delineation of drilling mud location.

- An excavation plan for the reserve pit including a volumetric estimate of drill mud and cuttings, flare pit and other identified areas of contamination including an as built diagram/isopach map to reference for future remediation work.

- Representative sampling of the water column of the reserve pit.

All sampling reports shall be submitted to BLM upon completion. A GPS log of all sampling locations shall be provided.

Winter and summer activities are likely needed to acquire requested data. Further details can be found in Attachments 9 and 10.

4.0 GOVERNMENT FURNISHED INFORMATION

General information is available on-line at the following web addresses:

• 2013 Legacy Wells Summary Report

• 2020 Legacy Wells Strategic Plan

• USGS 305 Reports or similar

• NPR-A Integrated Activity Plan Record of Decision

• BLM Permit Stipulations

• History of Drilling Operations https://pubs.usgs.gov/of/1999/ofr-99-0015/Wells/WellIdx.htm

• Water-Quality and Soil Assessment at 28 Exploratory Wellsites in the National Petroleum Reserve in Alaska, 1989-90 https://pubs.usgs.gov/of/1991/0458/report.pdf

• Bureau of Land Management (n.d.). NEPA Register. E-Planning. https://www.blm.gov/programs/planning-and-nepa/eplanning

• SnowDens 3D Modeling

Statement of Work Attachments

Attachment 3.