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NEPTUNE DEEPWATER PORT PROJECT NOTICE OF PROJECT CHANGE
© Copyright 2024 by The ERM International Group Limited and/or its affiliates (‘ERM’). All Rights Reserved. No part of this work may be reproduced or transmitted in any form or by any means, without prior written permission of ERM. Page 1 5784 Widewaters Parkway 1st Floor Dewitt, NY 13214 T +1 315 445 2554 F +1 315 445 2543 erm.com Dear Ms. Kim: Environmental Resources Management, Inc. (ERM) is pleased to provide the attached Notice of Project Change Form (NPC) on behalf of Neptune LNG LLC (Neptune) for the decommissioning of the Neptune Deepwater Port (DWP) Project (Project), EEA #13641. This NPC is prepared in accordance with the Massachusetts Environmental Policy Act (MEPA) for publication on 7 February 2024 in the Environmental Monitor. Neptune proposes changes to the previously reviewed decommissioning plan for the Project. The Project will be decommissioned due to a reduced market for natural gas in the New England region. Decommissioning of the Project involves removal of some components and abandonment of others. The Project is located in Massachusetts state and Federal waters about 22 miles off the coast of Boston, Massachusetts. The DWP includes two mooring and unloading buoys in Federal waters, as well as 13.2 miles of 24-inch diameter pipeline in both state and Federal waters. The west end of the pipeline ties into Algonquin Gas Transmission, LLC’s HubLine system in state waters. The Decommissioning Plan is included as an appendix to the enclosed package and was distributed to your office on 14 December 2023 as well. The Project previously underwent MEPA review multiple times with the Executive Office of Energy and Environmental Affairs and received multiple certificates, including a Certificate on the Final Environmental Impact Report in 2006 and most recently a Certificate on a Notice of Project Change in 2008. Neptune respectfully requests that the Secretary determine the Project changes to be insignificant and further MEPA review not be required. Upon receipt of all federal, state, and local authorizations, decommissioning activities are anticipated to begin as early as January 2025. The schedule for the decommissioning activities will be defined and flexible to accommodate time of year restrictions for sensitive resources. Decommissioning is anticipated to be complete by summer of 2026. Tori Kim Massachusetts Environmental Policy Act Office 100 Cambridge Street, Suite 900 Boston, MA 02114 Transmitted via email to: Tori.Kim@mass.gov DATE 31 January 2024 SUBJECT Neptune Deepwater Port Project Notice of Project Change, EEA #13641 REFERENCE 0667298 Page 2 DATE 31 January 2024 REFERENCE 0667298 We appreciate the involvement from the MEPA Office in advance of the submission of this NPC and we look forward to coordinating with you on this Project. This filing is being made available electronically to the participants listed in the Circulation List. A hard copy is being provided to the Massachusetts Historical Commission. Should you have any questions or concerns, or would like to request a paper copy of the filing, please contact Julie McKim at 907-223-0164 or email at julie.mckim@erm.com. Sincerely, Julie McKim Managing Consultant, Scientist ENCLOSURES NPC Form NPC Project Change Description Appendices Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs MEPA Office Effective January 6, 2023 1 The information requested on this form must be completed to begin MEPA Review of a NPC in accordance with the provisions of the Massachusetts Environmental Policy Act and its implementing regulations (see 301 CMR 11.10(1)). EEA #13641 Project Name: Neptune Deepwater Port Project Street Address: Not Applicable Municipality: Offshore waters of Manchester-by- the-Sea, Beverly, Salem, and Marblehead, MA Watershed: Massachusetts Coastal, Charles, 01090001 Universal Transverse Mercator Coordinates: (UTM Zone 19 North) Latitude: 42.5280 °N Longitude: 70.6951 °W (Project Centroid) Estimated commencement date: January 2025 Estimated completion date: Summer 2026 Project Type: Deepwater Port Decommissioning Status of project design: 88% complete Proponent: Neptune LNG LLC Street Address: 1360 Post Oak Blvd., Suite 400 Municipality: Houston State: TX Zip Code: 77056 Name of Contact Person: Julie McKim Firm/Agency: Environmental Resources Management, Inc. Street Address: 5784 Widewaters Parkway, 1st Floor Municipality: Dewitt State: NY Zip Code: 13214 Phone:907-223-0164 Fax: E-mail: julie.mckim@erm.com With this Notice of Project Change, are you requesting: a Single EIR? (see 301 CMR 11.06(8)) Yes No a Special Review Procedure? (see 301CMR 11.09) Yes No a Waiver of mandatory EIR? (see 301 CMR 11.11) Yes No a Phase I Waiver? (see 301 CMR 11.11) Yes No Which MEPA review threshold(s) does the revised project meet or exceed (see 301 CMR 11.03)? Identify any new or modified review threshold(s) associated with the project change. 301 CMR 11.03(3)(b)1.f. Wetlands, Waterways and Tidelands: Provided that a Permit is required, alteration of ½ or more acres of any other wetlands Which Agency Permits does the revised project require? Federal Coastal Zone Consistency Review, Section 401 Water Quality Certification; Board of Underwater Archaeological Resources Special Use Permit issued September 2023; Chapter 91 License and Permit authorization being determined. Identify any financial assistance or land transfer from an Agency of the Commonwealth for the revised project, including the Agency name and the amount of funding or land area in acres: Not Applicable Notice of Project Change 2 PROJECT INFORMATION In 25 words or less, what is the project change? The Neptune Deepwater Port will be decommissioned, which involves removal of some components and abandonment of others. Date of publication of availability of the ENF in the Environmental Monitor: October 8, 2005 Was an EIR required? Yes No; if yes, was a Draft EIR filed? Yes (Date: May 12, 2006) No was a Final EIR filed? Yes (Date: December 12, 2006) No was a Single EIR filed? Yes (Date: ) No Have other NPCs been filed? Yes (Date(s): March 21, 2008) No If this is an NPC solely for lapse of time (see 301 CMR 11.10(2)) proceed directly to ATTACHMENTS & SIGNATURES. PERMITS / FINANCIAL ASSISTANCE / LAND TRANSFER List or describe all new or modified Agency permits, financial assistance, or land transfers not previously reviewed: Federal Coastal Zone Consistency Review, Section 401 Water Quality Certification; Board of Underwater Archaeological Resources Special Use Permit issued September 2023; Chapter 91 License and Permit authorization being determined. See Project Change Description for list of permits, reviews, and approvals for the Project. Are you requesting a determination that this project change is insignificant such that an EIR should not be required (note that the Proponent may also seek an advisory ruling under 301 CMR 11.10(6))? A change in a Project is ordinarily insignificant if it results solely in an increase in square footage, linear footage, height, depth or other relevant measures of the physical dimensions of the Project of less than 10% over estimates previously reviewed, provided the increase does not meet or exceed any review thresholds. A change in a Project is also ordinarily insignificant if it results solely in an increase in impacts of less than 25% of the level specified in any review threshold, provided that cumulative impacts of the Project do not meet or exceed any review thresholds that were not previously met or exceeded. (see 301 CMR 11.10(6)) Yes No; if yes, provide an explanation of this request in the Project Change Description below. See Section 4 of the Project Change Description. FOR PROJECTS SUBJECT TO AN EIR If the project requires the submission of an EIR, are you requesting that a Scope in a previously issued Certificate be rescinded? Yes No; if yes, provide an explanation of this request_______________. If the project requires the submission of an EIR, are you requesting a change to a Scope in a previously issued Certificate? Yes No; if yes, provide an explanation of this request_______________. Effective January 6, 2023 3 SUMMARY OF PROJECT CHANGE PARAMETERS AND IMPACTS Summary of Project Size & Environmental Impacts Previously Reviewed for Project Net Change (Decommissioning Activities) Currently Proposed (Decommissioning Activities) LAND Total site acreage N/A N/A N/A Acres of land altered N/A See Above N/A Acres of impervious area N/A N/A N/A Square feet of bordering vegetated wetlands alteration N/A N/A N/A Square feet of other wetland alteration LUW – Land Under Water LUW: 2,621,774 square feet (60.2 acres) a LUW: Net change impacts in federal and state waters 150,491 square feet (3.45 acres) b Net change impacts in state waters are -7,429 square feet (-0.17 acres) b LUW: Temporary impacts in federal and state waters are 10,253 square feet (0.24 acres) Temporary impacts in state waters are 1,760 square feet (0.04 acres) Permanent impacts in federal and state waters are 140,238 square feet (3.22 acres) Permanent impacts in state waters are -9,189 square feet (-0.21 acres) Acres of non-water dependent use of tidelands or waterways N/A N/A N/A 4 STRUCTURES Gross square footage (pipeline/manifolds) 687,895 square feet (15.8 acres) a Net change impacts in both federal and state waters are -5,780 square feet (-0.13 acres) c Net change impacts in state waters are -7,429 square feet (-0.17 acres) c Temporary impacts in federal and state waters are 7,153 square feet (0.16 acres) c Temporary impacts in state waters are 1,760 square feet (0.04 acres) c Permanent impacts in federal and state waters are -12,933 square feet (-0.30 acres) c Permanent impacts in state waters are -9,189 square feet (-0.21 acres) c Number of housing units N/A N/A N/A Maximum height (in feet) N/A N/A N/A TRANSPORTATION Vehicle trips per day N/A N/A N/A Parking spaces N/A N/A N/A WATER/WASTEWATER Gallons/day (GPD) of water use 0 d N/A N/A GPD water withdrawal N/A N/A N/A GPD wastewater generation/ treatment N/A N/A N/A Length of water/sewer mains (in miles) N/A N/A N/A a Temporary and permanent impact numbers for Neptune Deepwater Port Project taken from the most recent MEPA request, Notice of Project Change dated February 15, 2008. 5 b Net change is calculated as the currently proposed temporary and permanent (removal and additional) impacts for decommissioning activities only and not compared against the previously reviewed Project impacts. See the Project Change Description for details. c Net change is calculated as the currently proposed impacts for decommissioning activities only and not compared against the previously reviewed Project impacts. Calculations include temporary and permanent (removal and additional) impacts for the pipeline (e.g., potential jack-up rig, rock berms), concrete mattresses and debris baskets, transition manifold (e.g., manifold, overtrawlable structure, tie-in spools), north PLEM dredging, and north and south PLEMs (e.g., manifold, tie-in spools). See the Project Change Description for details. d 5,653 m3 (or 1,493,365 gallons) of seawater may be used one time to fill the pipeline if it is not filled with low pressure inert gas (i.e., nitrogen). Effective January 6, 2023 6 Does the project change involve any new or modified: 1. conversion of public parkland or other Article 97 public natural resources to any purpose not in accordance with Article 97? Yes No 2. release of any conservation restriction, preservation restriction, agricultural preservation restriction, or watershed preservation restriction? Yes No 3. impacts on Rare Species? Yes No 4. demolition of all or part of any structure, site or district listed in the State Register of Historic Place or the inventory of Historic and Archaeological Assets of the Commonwealth? Yes No 5. impact upon an Area of Critical Environmental Concern? Yes No If you answered ‘Yes’ to any of these 5 questions, explain below: PROJECT CHANGE DESCRIPTION (attach additional pages as necessary). The project change description should include: (a) a brief description of the project as most recently reviewed, (b) a description of material changes to the project as previously reviewed, (c) if applicable, the significance of the proposed changes, with specific reference to the factors listed 301 CMR 11.10(6), and (d) measures that the project is taking to avoid Damage to the Environment or to minimize and mitigate unavoidable environmental impacts. If the change will involve modification of any prior mitigation commitments or previously issued Section 61 Finding, include a description of any such changes and a draft of the modified Section 61 Finding (or it will be required in Supplemental EIR). The project change description should include a comprehensive description of the proposed project change, including a description of any work or activities associated with the original project that have occurred to date. At the discretion of the MEPA Office, an alternatives analysis for the changed component(s) of the project may be required, including a summary of alternatives considered and associated environmental impacts at a level of detail commensurate with the scope and scale of the proposed change. In addition to the required attachments, the filing should include supporting technical data (e.g., a Traffic Impact and Access Study, Stormwater Report, etc.) as appropriate. It should include a full list of mitigation commitments that remain unchanged from the previously reviewed project. See Project Change Description. 7 ATTACHMENTS & SIGNATURES Attachments: 1. Secretary’s most recent Certificate on this project See Appendix A of Project Change Description. 2. Plan showing most recent previously reviewed proposed build condition See Project Change Description (Section 2). 3. Plan showing currently proposed build condition See Project Change Description (Section 3). 4. Original U.S.G.S. map or good quality color copy (8-1/2 x 11 inches or larger) indicating the project location and boundaries See Appendix B of Project Change Description. 5. List of all agencies and persons to whom the proponent circulated the NPC, in accordance with 301 CMR 11.10(7) See Appendix D of Project Change Description. Signatures: Date Signature of Responsible Officer Date Signature of person preparing or Proponent NPC (if different from above) Keith Crane Julie McKim Name (print or type) Name (print or type) Neptune LNG LLC Environmental Resources Management, Inc. Firm/Agency Firm/Agency 1360 Post Oak Blvd 1 Beacon Street, 5th Floor Street Street Houston, TX 77056 Boston, MA 02108 Municipality/State/Zip Municipality/State/Zip 713-636-1399 907-223-0164 Phone Phone 1/31/24 1/31/24 Massachusetts Environmental Policy Act Notice of Project Change Project Change Description Neptune Deepwater Port ProjectNeptune LNG Deepwater Port Project, EEA #13641 PREPARED FOR DATE January 2024 REFERENCE 0667298 CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE: January 2024 VERSION: 1 DOCUMENT DETAILS DOCUMENT TITLE Massachusetts Environmental Policy Act Notice of Project Change Project Change Description DOCUMENT SUBTITLE Neptune Deepwater Port Project, EEA #13641 PROJECT NUMBER 0667298 Date January 2024 Version 1 Author Environmental Resources Management, Inc Client name Neptune LNG LLC MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE: January 2024 VERSION: 1 Page i CONTENTS 1. INTRODUCTION 1 2. PREVIOUSLY REVIEWED PROJECT 1 2.1 MASSACHUSETTS ENVIRONMENTAL POLICY ACT HISTORY 1 2.2 PREVIOUSLY REVIEWED IMPACTS 1 3. PROJECT DESCRIPTION 5 3.1 BACKGROUND 5 3.2 PROPOSED PROJECT CHANGE 5 3.2.1 Decomissioning Plan Changes 5 3.2.2 Permits, Reviews, and Approvals 18 3.2.3 Environmental Justice 19 4. SIGNIFICANCE OF CHANGES 19 4.1 EXPANSION OF THE PROJECT 20 4.2 GENERATION OF FURTHER IMPACTS 25 4.3 SCHEDULE AND NEW PERMITS 28 4.4 UNCHANGED MITIGATION COMMITMENTS 28 4.5 CONCLUSION 36 5. CIRCULATION LIST 36 6. REFERENCES 36 APPENDIX A MOST RECENT PROJECT CERTIFICATES APPENDIX B PROJECT FIGURE APPENDIX C DECOMMISSIONING PLAN WITH APPENDICES APPENDIX D CIRCULATION LIST MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE: January 2024 VERSION: 1 Page ii LIST OF TABLES TABLE 3 -1 SUMMARY OF DECOMMISSIONING PLAN CHANGES 7 TABLE 3 -2 ANCHOR AND ROCK BERM DIMENSIONS 13 TABLE 3 -3 MANIFOLD COMPONENTS AND DIMENSIONS 14 TABLE 3 -4 PERMITS, APPROVALS AND CONSULTATION SCHEDULE 18 TABLE 4 -1 TEMPORARY IMPACTS 22 TABLE 4 -2 PERMANENT IMPACTS 23 TABLE 4 -3 CRITERIA POLLUTANT EMISSIONS 26 TABLE 4 -4 GHG EMISSIONS 27 TABLE 4 -5 MITIGATION COMMITMENTS 29 LIST OF FIGURES FIGURE 2-1 PROJECT LOCATION MAP 2 FIGURE 2-2 SYSTEM COMPONENTS 3 FIGURE 3-1 ANCHOR ROCK BERM SCHEMATIC 12 FIGURE 3-2 SOUTH PLEM TIE-IN SPOOL 15 FIGURE 3-3 NORTH PLEM TIE-IN SPOOL 15 FIGURE 3-4 HOT TAP TRANSITION MANIFOLD 16 FIGURE 3-5 HOT TAP ASSEMBLY TIE-IN 17 ACRONYMS AND ABBREVIATIONS Algonquin Algonquin Gas Transmission, LLC BOEM Bureau of Ocean Energy Management CMR Code of Massachusetts Regulations DWP Deepwater Port EEA Executive Office of Environmental Affairs EIR Environmental Impact Report EIS Environmental Impact Statement EJ Environmental Justice EPA Environmental Protection Agency ESA Endangered Species Act FEIR Final Environmental Impact Report FEIS Federal Environmental Impact Statement MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE: January 2024 VERSION: 1 Page iii GHG Greenhouse gas HubLine HubLine system LNG Liquefied natural gas MARAD Maritime Administration MEPA Massachusetts Environmental Policy Act MP milepost Neptune Neptune LNG LLC NOAA National Oceanic and Atmospheric Administration NPC Notice of Project Change OCS Outer continental shelf PLEM Pipeline end manifold PMMP Prevention, Monitoring, and Mitigation Plan Project Neptune Deepwater Port Project ROV Remotely operated vehicle SPCC Spill Prevention, Control, and Countermeasures STL Submerged turret loading USCG U.S. Coast Guard MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION INTRODUCTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 1 1. INTRODUCTION Neptune LNG LLC (Neptune) submits this Project Change Description to accompany the Notice of Project Change (NPC) form, prepared for submission to the Executive Office of Energy and Environmental Affairs (EEA), Massachusetts Environmental Policy Act (MEPA) Office for the decommissioning of the Neptune Deepwater Port (DWP) Project (Project) in accordance with 301 Code of Massachusetts Regulations (CMR) 11.10(1). The NPC describes the proposed changes to the Project for decommissioning activities. The Project received multiple certificates through the MEPA review process for its construction. Neptune considers the project changes insignificant and further MEPA review should not be required. 2. PREVIOUSLY R EVIEWED P ROJECT 2.1 MASSACHUSETTS ENVIRONMENTAL POLICY ACT HISTORY The Project previously underwent MEPA review multiple times with the EEA. On 29 September 2005, Neptune filed an Environmental Notification Form and subsequently received a Certificate on 25 November 2005. Under MEPA, a Special Review Procedure was established for the review of construction, operation, and decommissioning of the Project. The Special Review Procedure was for administrative convenience to allow for coordinated MEPA / National Environmental Policy Act review of an Environmental Impact Statement (EIS) / Environmental Impact Report (EIR) document consistent with the requirements and constraints imposed by state and federal regulations. As a result, the US Coast Guard (USCG) was the lead federal agency in development of the EIS/EIR. The Neptune Liquefied Natural Gas (LNG) DWP License Application Final Environmental Impact Statement and Environmental Impact Report (Neptune LNG FEIS and FEIR) was prepared to satisfy MEPA and National Environmental Policy Act requirements (USCG and MARAD 2006). A Certificate on the Draft EIR was issued on 24 July 2006, and on the FEIR on 12 December 2006. On 16 February 2007, the EEA issued a finding in response to a request for an Advisory Opinion on a pipeline alignment modification that the modification would not have significant environmental consequences and therefore not require submission of an NPC. On 21 March 2008, the EEA issued a Certificate on an NPC finding that minor design changes to the shuttle regasification vehicle buoy locations and anchor orientations and change of the port construction schedule did not require further MEPA review. The most recent certificates (i.e., the FEIR Certificate, Advisory Opinion, and NPC Certificate) are included in Appendix A. 2.2 PREVIOUSLY REVIEWED IMPACTS The Project approved in the FEIR Certificate and subsequent reviews is located in federal waters about 22 miles off the coast of Boston, Massachusetts as shown in Figure 2-1 and as a standalone figure in Appendix B. The DWP includes two mooring and unloading buoys in federal waters, as well as 13.2 miles of 24-inch diameter pipeline in both state and federal waters. The west end of the pipeline ties into the Algonquin Gas Transmission, LLC’s HubLine system (HubLine) in state waters. The pipeline travels about 10 miles through the waters of the Commonwealth of Massachusetts offshore of Salem, Beverly, Marblehead, and Manchester-by-the-Sea before exiting state waters. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PREVIOUSLY REVIEWED PROJECT CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 2 The DWP consists of the following components: • A 13.2-mile, 24-inch outside diameter pipeline with a 0.5-inch wall thickness and 2.25 inches of concrete weight coating; • Sixteen anchors; • Concrete mattresses; • One transition manifold, two pipeline end manifolds (PLEM), and tie -in spools; • One hot tap assembly fitted with a 30-inch by 20-inch clamp-on tee with a 20-inch flanged isolation valve and structural brace; • Two risers and two umbilicals; • Sixteen mooring lines; and • Two submerged turret loading (STL) buoys. FIGURE 2-1 PROJECT LOCATION MAP BOEM = Bureau of Ocean Energy Management; MP = milepost; OCS = outer continental shelf; STL = submerged turret loading. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PREVIOUSLY REVIEWED PROJECT CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 3 Figure 2-2 depicts the port configuration and relationship between the components. The west end of the pipeline connects to HubLine. A plan describing the DWP components and proposed decommissioning activities was filed with state and federal agencies on 14 December 2023; the Decommissioning Plan can be found in Appendix C. The Project was commissioned in 2010. FIGURE 2-2 SYSTEM COMPONENTS The FEIR Certificate was issued based on the content of the Neptune LNG FEIS and FEIR, which included analysis of alternatives, impacts, and mitigation measures to meet the MEPA standard of adequacy for a FEIR. The scope of the analysis in the Neptune LNG FEIS and FEIR included decommissioning activities of the Project. Decommissioning, as described in the Neptune LNG FEIS and FEIR, included: • Abandonment in place of the 13.2-mile pipeline and concrete mattresses; • Purging the pipeline of gas and filling it with seawater; • Burial of the ends of the pipeline with at least 3 feet of cover or protective concrete mats; • Removal of the 16 anchors, or in the event the anchors could not be removed, cut 15 feet below the mudline and the top section removed; • Removal of the transition manifold, two PLEMs, and tie-in spools; • Closure and plugging of the hot tap assembly; • Removal of the two risers and two umbilicals; MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PREVIOUSLY REVIEWED PROJECT CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 4 • Removal of the 16 mooring lines; and • Removal of the two STL buoys. Removed components would be transported for disposal and recycling. Decommissioning would take approximately nine weeks to complete. Also, the Neptune LNG FEIS and FEIR included language suggesting that “it would be possible to leave some of the facilities’ underwater structure in place to function as an artificial reef.” The Project was reviewed pursuant to the following sections of the MEPA regulations: • 301 CMR 11.03(3)(a)(b) Alteration of ten or more acres of any other wetlands, in this case Land Under the Ocean; and • 301 CMR 11.03(7)(a)(3) Construction of a new fuel pipeline more than 10 miles in length. The outcome of the MEPA and other agency review processes resulted in the payment of millions of dollars to multiple entities to offset impacts on commercial fisheries, public enjoyment of the Boston Harbor Islands National Park, recreational users, to fund scientific data collection and studies, and to support education and preservation of the marine environment and heritage. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 5 3. PROJECT DESCRIPTION Neptune proposes to decommission the Project due to a reduced market for natural gas in the New England region. Decommissioning of the Project involves removal of some components and abandonment of others. 3.1 BACKGROUND The DWP was conceived to deliver natural gas to the supply-constrained New England region year- round. However, by the time the DWP was commissioned in 2010, the shale gas revolution had resulted in substantially greater domestic supply of natural gas, resulting in little to no need for the Project. As a result, the DWP has never operated commercially. Decommissioning of the DWP is regulated under the Deepwater Port Act of 1974, as amended. In March 2007, the Maritime Administration (MARAD) issued a license for Neptune to construct, own, and operate the DWP. Decommissioning of the DWP was included within the scope of the review during the original licensing process. In May 2023, Neptune provided MARAD with a Notice of Intent to Decommission the Neptune LNG DWP and Initial Request for Waiver. Neptune filed a Decommissioning Plan in December 2023 with MARAD and distributed the Decommissioning Plan to other federal and state agencies. Permit applications for the decommissioning work are being submitted with the goal of obtaining required authorizations and beginning decommissioning work early in 2025. The EEA has advised that an NPC should be filed for the decommissioning activities, which is the first step in the state permitting process. 3.2 PROPOSED PROJECT CHANGE The EEA has advised that decommissioning of the entire Project in both state and federal waters will be subject to review under the NPC, as deemed necessary to align with the Office of Coastal Zone Management Federal Coastal Consistency Determination review. Therefore, the entire Decommissioning Plan is included as Appendix C of this document and relevant portions addressed throughout this Project Change Description to meet MEPA requirements (M. G. L. c. 30, ss. 61- 62H) and Section 11.10 of the MEPA regulations for the NPC. The Decommissioning Plan describes Neptune’s proposed approach to decommissioning all components of the Project and is based on a thorough evaluation of the various decommissioning alternatives and their associated impacts with respect to safety, environmental, technical, societal, and economic criteria. The Decommissioning Plan is largely consistent with the anticipated decommissioning activities described in Neptune LNG DWP FEIS and FEIR (USCG and MARAD 2006). 3.2.1 DECOMISSIONING PLAN CHANGES Changes from the previously proposed Decommissioning Plan are described below. Details of the proposed decommissioning activities, as well as supporting technical information, are provided in the Decommissioning Plan (Appendix C). In summary, the proposed decommissioning activities include: • Abandonment in place of the 13.2-mile pipeline and all but 44 concrete mattresses; • Flaring the gas, then purging, cleaning, flushing, and capping the pipeline; MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 6 • Burial of the ends of the pipeline with rock berms; • Burial of the 16 anchors under rock berms; • Removal of the transition manifold, two PLEMs, and tie-in spools; • Installation of a blind flange on the hot tap assembly; • Removal of the two risers and two umbilicals; • Removal of the 16 mooring lines; and • Removal of the two STL buoys. Removed components would be transported for disposal and recycling. Decommissioning could occur over 26 weeks (see Section 3.2.1.7 for more information). Although a Decommissioning Plan was previously evaluated by the state and federal agencies concurrent with permitting of the Project (Section 2.2), the Decommissioning Plan has been modified following a rigorous alternatives analysis that considered safety, environmental impacts, technical factors, societal factors, and economic factors. Agency input obtained during interagency meetings held in 2023 factored into the alternatives assessment, which was used to develop the Decommissioning Plan. The proposed Decommissioning Plan has been selected because it will result in the least environmental impact as supported by the evaluation included in the Alternatives Analysis (Appendix B of Appendix C). Changes from the previously reviewed decommissioning activities are summarized in Table 3-1. The location of the activities, previous Decommissioning Plan, current Decommissioning Plan, and summary of changes are included in the table. Additional information regarding the changes is described below. For details regarding the methodology of unchanged aspects of the decommissioning activities (e.g., risers and umbilicals, mooring lines, STL buoys), see the Decommissioning Plan (Appendix C). Mitigation measures will be implemented during decommissioning, including development and compliance with a Prevention, Monitoring, and Mitigation Plan (PMMP), Communications Plan, Spill Prevention Control and Countermeasure (SPCC) Plan, Unanticipated Discoveries Plan, and Avoidance and Anchor Handling Plans. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 7 TABLE 3-1 SUMMARY OF DECOMMISSIONING PLAN CHANGES Project Component Location Previously Reviewed Description a Currently Proposed b Change(s) from Previously Reviewed to Currently Proposed Pipeline State and Federal Waters The base case assumption is that the flowline and gas transmission line would not be removed but would be decommissioned in place. Decommissioning is expected to include purging the pipeline of gas, flushing both the flowline and gas transmission line with seawater, and sealing each end of the flowline and gas transmission line. Decommissioning would include the following: • Closing hot tap valves and plugging the end • Pigging and flushing the pipelines • Filling the pipelines with seawater • Cutting and plugging each end of the pipelines • Burying each end of the pipelines under at least 1 meter (3 feet) of cover or covering each end with protective concrete mats, if required by the MMS Regional Supervisor. Pipeline decommissioning will occur in the three following steps: • Removal of gas via hot flaring • Purging, cleaning, and flushing • Pipeline end capping Once the pipeline has been cleaned, the pipeline will be filled with either low pressure inert gas (i.e., nitrogen) or seawater and then decommissioned in place. The three exposed end sections of the pipeline will be covered with rock berms using a rock dump vessel equipped with a fall pipe. One rock berm will be installed in state waters and the other two in federal waters. Each berm will be 32.8 feet long with a 3.28-foot berm crest and 4.92 feet high from the sea floor. The pipeline could be filled with either low pressure inert gas or seawater. Details for treatment of the purged gas provided (the gas will be removed via hot flaring). Rock berms selected for installation on the pipeline ends. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 8 Project Component Location Previously Reviewed Description a Currently Proposed b Change(s) from Previously Reviewed to Currently Proposed Concrete Mattresses and Debris State and Federal Waters The concrete mattresses would be decommissioned in place. An estimated 44 mattresses will be removed near the transition manifold and PLEMs. All remaining concrete mattresses will be decommissioned in place as these likely now serve as beneficial habitat for fish and invertebrates. Debris baskets (typically 20 feet x 8 feet x 5.5 feet) will be placed next to the removal location and would be recovered at a later date. It is estimated that each debris basket will hold approximately four mattresses, so up to eleven debris baskets will be needed. Removal of concrete mattresses near the transition manifold and PLEMs for access to the tie-in spools. Temporary impacts for debris basket use on sea floor. Anchors Federal Waters The anchor piles would be loaded onto barges and removed from the deepwater port site. In the event the anchor piles could not be removed, they would be cut 15 feet below the mudline and the top section removed. The anchors will be decommissioned in place. A rock dump vessel equipped with a fall pipe will be used to permanently cover the anchors with rock berms. Instead of removing the anchors, the anchors will be left in place and buried under rock berms. Transition Manifold, PLEMs, and Tie- in Spools State and Federal Waters Decommissioning is expected to include removing all manifolds and tie-in spools, cutting (if required). The transition manifold, overtrawlable structure, PLEMs, and associated tie-in spools will be removed. No change. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 9 Project Component Location Previously Reviewed Description a Currently Proposed b Change(s) from Previously Reviewed to Currently Proposed Hot Tap Assembly State Waters Decommissioning is expected to include closing and plugging the hot tap connection to HubLine. The tie-in spool will be removed, while the rest of the hot tap assembly, including ball and check valve and support structure, will be left in place as it is not possible to safely remove this assembly from the live HubLine. Divers will install a blind flange to the exposed end where the tie-in spool was removed. Either 1 or 2 of the concrete mattresses will be removed from where the spool meets the assembly and temporarily stored in debris baskets on the sea floor before being replaced back onto the assembly in the previous location. No change; temporary impacts associated with the debris baskets and concrete mattresses. Risers and Umbilicals Federal Waters The risers and control umbilicals would be disconnected from the riser manifolds then reeled up and disconnected from the buoys. The risers and control umbilicals would be loaded onto barges and removed from the deepwater port site. The risers and umbilicals will be recovered to the deck of a nearby light construction vessel. Umbilical fluid will be purged and flushed to deck side waste storage. The umbilical will then be fitted with recovery rigging and cut at the STL buoy and PLEM and recovered to deck. No change. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 10 Project Component Location Previously Reviewed Description a Currently Proposed b Change(s) from Previously Reviewed to Currently Proposed Mooring Lines Federal Waters The mooring lines would be disconnected from the anchor points and reeled up. The mooring lines would be loaded onto barges and removed from the deepwater port site. The wire section of the mooring line will be cut from the buoy. The mooring lines will be lifted to the deck and onboarded using a heavy winch and dragging the chain over a chute, before being stored on deck in chain boxes. This will be completed for the remaining mooring lines at south STL buoy before locating to north STL buoy and repeating the process. No portions of the mooring line will be decommissioned in place. No change. STL Buoys Federal Waters The mooring lines would be disconnected from the unloading buoys and the STL buoys would be removed. The STL buoys would be loaded onto barges and removed from the deepwater port site. The STL buoys will be recovered to deck by using the attached rigging and ship’s crane. No change. Disposal and Recycling State and Federal Waters Decommissioning would consist of the transportation of the components for disposal or recycling. Components that are removed will be transported to an onshore location for resale, or for disposal and recycling at existing facilities. No change. Schedule State and Federal Waters Decommissioning would take approximately nine weeks to complete. Decommissioning activities are anticipated to occur over approximately 181 days (26 weeks), assuming no tasks will be conducted concurrently. Increased schedule to complete decommissioning. a Taken from Neptune LNG FEIS and FEIR (USCG and MARAD 2006) and supplemented by the Prevention, Monitoring, and Mitigation Plan for the Operations Phase (Neptune 2010). b Decommissioning Plan (Appendix C). MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE: January 2024 VERSION: 1 Page 11 3.2.1.1 SURVEYS To inform the alternatives assessment and Decommissioning Plan, Neptune conducted marine surveys of the DWP. The survey began in July 2023 and concluded in November 2023. The survey included geophysical, depth of burial, infrastructure elevation, biological habitats, and visual inspection of the DWP components. More specifically: • Collection of geophysical data utilizing the multi-beam echo sounder and sub-bottom profiler; • Depth of burial of the pipeline; • Observation and mapping of the subsea infrastructure; and • Visual inspection of the current infrastructure conditions along with benthic, macrofauna, and macroflora observations. Neptune had intended to perform side scan sonar and transverse gradiometer surveys in 2023 as well, but conflicts with lobstering activity resulted in a decision to delay the side scan sonar and transverse gradiometer surveys until 2024. Neptune has been coordinating with the National Oceanic and Atmospheric Administration (NOAA) Fisheries regarding survey data needs prior to the 2023 surveys. NOAA Fisheries reviewed the 2023 Survey Plan and provided comments that were incorporated into the surveys and will be incorporated into the 2024 surveys and data output for the Essential Fish Habitat Assessment. The Massachusetts Department of Environmental Protection determined in January 2024 that no additional sediment sampling is required. Upon completion of decommissioning activities, an as-left survey will be conducted. The survey will confirm the removal and status of the sea floor, and the precise location and orientation of any infrastructure intentionally left on the sea floor. 3.2.1.2 PIPELINE The pipeline is 13.2 miles long with about 10.45 miles within state waters, and the remainder in federal waters. The pipeline is filled with about 21.8 million standard cubic feet of natural gas, assuming 1440 pounds per square inch. The planned burial specification was a nominal depth of cover of 3 feet and was intended to protect the pipeline from fishing gear and dropped objects (e.g., anchors dropped in emergency). Concrete mattresses were installed over the pipeline where burial was less than 1.5 feet and at the Hibernia crossing. Pipeline decommissioning will occur in the three following steps: 1. Removal of gas via flaring; 2. Purging, cleaning, and flushing; 3. Pipeline end capping. A jack-up rig with flare stack, or flare barge, will be near the south STL buoy in federal waters to support flaring for approximately 12 hours. If a jack-up rig is used, it will occupy approximately 4306 square feet or 0.1 acres of sea floor. Once the pipeline has been cleaned, the pipeline will be filled with either low pressure inert gas (i.e., nitrogen) or seawater and then decommissioned in MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE: January 2024 VERSION: 1 Page 12 place. Once completed and prior to capping the pipeline ends, concrete mattresses and tie-in spools will be removed (Sections 3.2.1.4 and 3.2.1.6). The pipeline will then be capped via blind flange or permanently plugged. The three exposed end sections of the pipeline will be covered with rock berms using a rock dump vessel equipped with a fall pipe. Each berm will be 32.8 feet long with a 3.28-foot berm crest and 4.92 feet high from the sea floor. With side slope gradients of 1:3, the footprint per berm is 65.6 square feet or 0.002 acre and requires about 5,170 cubic feet (or 192 cubic yards) of rock for all three berms. One pipeline end is in state waters and the other two are in federal waters. 3.2.1.3 ANCHORS The north and south STL buoys are held in place with mooring lines connected to eight steel suction caisson anchors per buoy. Each anchor has a pad eye on the outer diameter to which the mooring chain is attached. The location of the pad eyes varies (subject to holding capacity and tilt angle) ranging from 6 meters (about 20 feet) to 11.6 meters (about 38 feet) below the sea floor. The anchors were installed by a combination of self-weight penetration and differential pressure. Each anchor is fitted with a valve assembly used to remove water from the internal area to drive the anchors into the sea floor under pressure. The mooring lines will be separated from the anchors and the anchors will be decommissioned in place. A rock dump vessel equipped with a fall pipe will be used to permanently cover the anchors with rock berms. A schematic of the rock berm is provided on Figure 3-1. Impact areas and volumes of fill for the anchors and rock berms are detailed in Table 3-2. All the anchors are located in federal waters. FIGURE 3-1 ANCHOR ROCK BERM SCHEMATIC MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 13 TABLE 3-2 ANCHOR AND ROCK BERM DIMENSIONS Anchor Number Anchor Diameter (feet) Anchor Height Above Sea floor (feet) Rock Berm Footprint (square feet) Rock Berm Footprint (acres) Rock Berm Volume (cubic yards) N1 16.4 2.0 7,913 0.18 526 N2 16.4 2.3 8,446 0.19 629 N3 16.4 3.3 10,145 0.23 493 N4 16.4 2.0 7,913 0.18 526 N5 36 2.0 10,551 0.24 629 N6 16.4 2.0 7,913 0.18 494 N7 16.4 3.0 9,561 0.22 594 N8 30 3.0 11,523 0.26 594 S1 30 2.3 10,272 0.24 947 S2 16.4 3.6 10,745 0.25 666 S3 16.4 2.6 8,995 0.21 560 S4 30 2.6 10,889 0.25 1,007 S5 30 2.5 10,578 0.24 977 S6 30 2.0 9,671 0.22 889 S7 16.4 3.3 10,145 0.23 629 S8 16.4 2.0 7,913 0.18 441 TOTAL 153,171 3.52 12,555 Note: It is assumed that the rock berms for each suction anchor will extend 2 meters (about 6.6 feet) above the top of each anchor with a side slope gradient of 1:5. The total may not equal the addends due to rounding. 3.2.1.4 TRANSITION MANIFOLD, PLEMS, AND TIE-IN SPOOLS The DWP includes three manifolds: the transition manifold and the north and south PLEMs. The manifolds are constructed from steel and have raft-type mudmat foundations. The manifolds have 24-inch or 16-inch diameter tie-in spools that connect the manifold to the pipeline. The transition manifold and the south PLEM have flanged connection points for a pig launcher/receiver. Each PLEM and manifold have a skirted gravity base of welded box construction with a skid structure, a connection to the pipeline via a tie-in spool, and an interface with the riser and umbilical from the STL buoy. The transition manifold also has an overtrawlable structure installed to protect it from fishing activity. Additional manifold details are provided in Table 3-3. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 14 TABLE 3-3 MANIFOLD COMPONENTS AND DIMENSIONS Component Description Length (ft) Width (ft) Height (ft) Footprint (ft2) Footprint (acres) Transition manifold Manifold base and pipes 32.8 26.2 9.8 861 0.02 Transition manifold overtrawlable structure Frame 41.0 41.0 11.5 1,682 0.04 Transition manifold tie- in spool 24-inch transition tie-in spool (2 segments) 82.0 4.3 4.3 350 0.01 16-inch transition tie-in spool (2 segments) 55.8 3.3 3.3 183 0.004 North PLEM PLEM base and pipes 39.4 39.4 13.8 1,550 0.04 North PLEM tie-in spool 16-inch transition tie-in spool (2 segments) 83.7 5.2 5.2 439 0.01 South PLEM PLEM base and pipes 39.4 39.4 13.8 1,550 0.04 South PLEM tie-in spool 24-inch transition tie-in spool (2 segments) 59.1 4.6 4.6 271 0.01 49.2 1.3 1.3 65 0.001 PLEM = pipeline end manifold. Note: Width and height dimensions for tie-in spools represent the surface area they cover. Height is measured from the sea floor and includes frames and connections associated with the tie-in spools. The transition manifold, overtrawlable structure, PLEMs, and associated tie-in spools will be removed as described in the previously reviewed Decommissioning Plan. Prior to removal of the manifold, concrete mattresses will be removed and temporarily stored in debris baskets on the sea floor as discussed in Section 3.2.1.6. The connections will be cut or unbolted, as appropriate. The tie-in spools will be further cut if needed, positioned into debris baskets, or otherwise made ready for recovery. At the north manifold tie-in spool, a remotely operated vehicle (ROV) dredge tool or controlled flow excavation (CFE) will be required to remove sediment that has deposited on top of the tie-in spool. A total of about 82 cubic yards of sediment over an area of 1,087 square feet (0.03 acres) would be removed. The sediments would be re-deposited adjacent to the removal area and the impacted area would likely revert to its natural state shortly after disturbance due to seabed currents and wave action (Taormina et al. 2018). The transition manifold, PLEMs, and debris baskets with tie-in spools will be removed to the surface. Figures 3-2, 3-3, and 3-4 show the components that will be removed and abandoned in place at each manifold. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 15 FIGURE 3-2 SOUTH PLEM TIE-IN SPOOL PLEM = pipeline end manifold. FIGURE 3-3 NORTH PLEM TIE-IN SPOOL PLEM = pipeline end manifold. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 16 FIGURE 3 -4 HOT TAP TRANSITION MANIFOLD 3.2.1.5 HOT TAP A SSEMBLY The hot tap assembly connects the pipeline to HubLine and comprises a 30-inch-by-20-inch clamp-on tee with a 20-inch flanged isolation valve and is protected by a structural brace. The tie- in spool will be removed, while the rest of the hot tap assembly, including ball and check valve and support structure, will be left in place as it is not possible to safely remove this assembly from the live HubLine. Divers will install a blind flange to the exposed end where the tie-in spool was removed. Either 1 or 2 of the concrete mattresses will be removed from where the spool meets the assembly and temporarily stored in debris baskets on the sea floor before being replaced back onto the assembly in the previous location. See Figure 3-5 for details of the hot tap assembly tie- in. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 17 FIGURE 3 -5 HOT TAP ASSEMBLY TIE-IN 3.2.1.6 CONCRETE MATTRESSES AND DEBRIS Concrete mattresses were installed over the pipeline where burial was less than 1.5 feet, at the Hibernia crossing, and near the transition manifold and PLEMs and previously planned to be decommissioned in place along with the pipeline. An estimated 44 mattresses are now proposed for removal from near the transition manifold and PLEMs. All remaining concrete mattresses will be decommissioned in place as these likely now serve as beneficial habitat for fish and invertebrates. The concrete mattresses measure 20 feet by 8 feet by 9 inches. Most of the mattresses that will be removed will be near the transition manifold, but the exact number and location will be determined closer to decommissioning. To remove mattresses, a light construction vessel equipped with a ROV and mattress handling frame will move the mattresses to a debris basket temporarily stored on the sea floor. Debris baskets (typically 20 feet x 8 feet x 5.5 feet) will be placed next to the removal location and would be recovered at a later date. It is estimated that each debris basket will hold approximately four mattresses, so up to eleven debris baskets will be placed on the sea floor. These debris baskets may also be used for temporary storage of the concrete mattresses at the hot tap. A ship’s crane will be used to recover the debris baskets. Decommissioning and removal of mattresses is expected to take approximately 10 days resulting in a temporary impact. 3.2.1.7 PROJECT SCHEDULE The first pre-application agency meeting was held in March 2023 and included members of federal and state agencies. Outreach to stakeholders began in spring 2023 and continued into summer 2023. Agency coordination continued through fall 2023 through quarterly interagency meetings. The applicable permits, consultations, and approvals are discussed in detail in Section 3.2.2. Upon receipt of all federal, state, and local authorizations, decommissioning activities are anticipated to begin as early as January 2025. Decommissioning activities could occur over 181 days (approximately 26 weeks), assuming no tasks are conducted concurrently. The schedule for HOT TAP PIPING AND BRACE ASSEMBLY 16” TRANSITION MANIFOLD TIE-IN SPOOL MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION PROJECT DESCRIPTION CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 18 the decommissioning activities will be defined and flexible to accommodate time of year restrictions for sensitive resources. Decommissioning is anticipated to be complete by summer of 2026. 3.2.2 PERMITS, REVIEWS, AND APPROVALS The federal, state, and local permits, reviews, and approvals received and anticipated to be required for decommissioning of the Project are listed in Table 3-4. TABLE 3-4 PERMITS, APPROVALS AND CONSULTATION SCHEDULE Agency Permit/Approval/Consultation Status Federal U.S Army Corps of Engineers Department of the Army Individual Permit for Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act Submitted January 2024 U.S. Environmental Protection Agency Clean Air Act Permit (42 U.S.C. 85) Consultation initiated December 2023; no permit required Section 402 of the Clean Water Act National Pollutant Discharge Elimination System Permit Anticipated submittal November 2024 U.S. Fish and Wildlife Service ESA Section 7 Consultation Consultation to be initiated February 2024 NOAA Fisheries ESA Section 7 Informal Consultation Consultation to be initiated February 2024 Marine Mammal Protection Act Consultation Consultation initiated January 2024; no permit required Magnuson-Stevens Fishery Conservation Management Act Essential Fish Habitat Assessment Consultation to be initiated February 2024 State Executive Office of Energy and Environmental Affairs— Massachusetts Environmental Policy Act Office Certificate from the Secretary of Energy and Environmental Affairs to approve the Notice of Project Change Submitted January 2024 Massachusetts Historical Commission Section 106 of The National Historic Preservation Act of 1966 Consultation Consultation to be initiated February 2024 Massachusetts Board of Underwater Archaeological Resources SUP for the Marine Underwater Archaeology Survey SUP issued September 2023 MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 19 Agency Permit/Approval/Consultation Status Massachusetts Department of Environmental Protection— Northeast Regional Office Individual 401 Water Quality Certification Anticipated submittal March 2024 Massachusetts Office of Coastal Zone Management Federal Coastal Zone Consistency Review Anticipated submittal March 2024 Massachusetts Department of Environmental Protection— Northeast Regional Office Chapter 91 Waterways License and Permit Authorization being determined in consultation with the agency Local Beverly Conservation Commission Order of Conditions and Local Bylaw Authorization Notification submitted January 2024; no further approval needed Manchester-by-the-Sea Conservation Commission Order of Conditions and Local Bylaw Authorization Notification submitted January 2024; confirming if further approval needed Marblehead Conservation Commission Order of Conditions and Local Bylaw Authorization Anticipated submittal March 2024 Salem Conservation Commission Order of Conditions and Local Bylaw Authorization Notification submitted January 2024; confirming if further approval needed ESA = Endangered Species Act; NOAA = National Oceanic and Atmospheric Administration; SUP = special use permit. 3.2.3 ENVIRONMENTAL JUSTICE Any project that is located within a Designated Geographic Area around one or more Environmental Justice (EJ) populations are required to comply with additional requirements in the MEPA regulations. 310 CMR 11.02 defines the Designated Geographic Area with respect to an EJ population as the area within 1 mile of the project , or within 5 miles if the project will exceed the air quality thresholds for stationary sources listed in 310 CMR 11.03(8)(a-b). The Project is 4 miles from the coastline and there are no EJ populations or residential populations within 1 mile of the Project. Although the air modeling conducted for the emissions associated with decommissioning indicate that the thresholds listed in 310 CMR 11.03(8)(a-b) would be exceeded, these exceedances would be temporary, only occurring while the decommissioning activities are underway and a new stationary source is not being constructed. Therefore, the thresholds listed in 310 CMR 11.03(8)(a-b) do not apply. The majority of the emissions will occur from 4 to 12 miles offshore. A Communications Plan is being developed to offset impacts on commercial and recreational fisheries and impacts on these users are anticipated to be minor. 4. SIGNIFICANCE OF CHANGES 310 CMR 11.10(6) provides six factors for the Secretary to consider in determining whether a change might significantly increase environmental consequences: MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 20 1. Expansion of the project. A change in a project is ordinarily insignificant if it results solely in an increase in square footage, linear footage, height, depth, or other relevant measures of the physical dimensions of the project of less than 10% over estimates previously reviewed, provided the increase does not meet or exceed any review thresholds. 2. Generation of further impacts, including an increase in release or emission of pollutants or contaminants during or after completion of the project. A change in a project is ordinarily insignificant if it results solely in an increase in impacts of less than 25% of the level specified in any review threshold, provided that cumulative impacts of the Project do not meet or exceed any review thresholds that were not previously met or exceeded. 3. Change in expected date for commencement of the project, commencement of construction, completion date for the Project, or schedule of work on the project. 4. Change of the project site. 5. New application for a permit or new request for financial assistance or a land transfer. 6. For a project with net benefits to environmental quality and resources or public health, any change that prevents or materially delays realization of such benefits. The Secretary should consider the information below to arrive at the conclusion that the Project changes are insignificant and further MEPA review by a new Environmental Notification Form or supplemental EIR should not be required. Although some of the changes might increase impacts (e.g., anchor rock berms), the overall impact of the decommissioning activities is minor compared to the construction and operations of the Project and would result in some decreases of impacts (e.g., emissions). The temporary and permanent impacts as a result of decommissioning are also minor relative to the construction of the Project and minor consistent with the previously reviewed decommissioning options. The robust alternatives analysis in Appendix B of the Decommissioning Plan (Appendix C) demonstrates that the changes proposed for decommissioning of the Project are in fact environmentally preferable and more technically feasible to accomplish. Mitigation measures would be implemented during decommissioning activities to further reduce environmental impacts, which are consistent with those proposed previously but with a detailed focus on the proposed decommissioning activities. For example, the PMMP, Communications Plan, and SPCC Plan will all be updated to cater to the specific decommissioning activities. See Section 6.2.3 of the Decommissioning Plan (Appendix C) for more information. 4.1 EXPANSION OF THE PROJECT In the most recent Notice of Project Change, the project impacts were decreased due to a reduction in the overall pipeline length, the elimination of anchor sweep over hard bottom habitat, and the elimination of pile driving activities. These changes all occurred within federal waters. The proposed square footage of other wetland alteration was 2,621,774 (60.2 acres) and the gross square footage of the pipeline and manifolds was provided as 687,895 square feet (15.8 acres). The currently proposed decommissioning impacts are as follows: • Proposed square footage of other wetland alteration ° temporary impacts in federal and state waters are 10,253 square feet (0.24 acre) MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 21 ° temporary impacts in state waters are 1,760 square feet (0.04 acres) ° permanent impacts in federal and state waters are 140,238 square feet (3.22 acres ) ° permanent impacts in state waters are -9,189 square feet (-0.21 acres) • Gross square footage of the pipeline and manifolds ° temporary impacts in federal and state waters are 7,153 square feet (0.16 acres) ° temporary impacts in state waters are 1,760 square feet (0.04 acres) ° permanent impacts in federal and state waters are -12,933 square feet (-0.30 acres) ° permanent impacts in state waters are -9,189 square feet (-0.21 acres) These numbers include all proposed decommissioning activities. Gross square footage of the pipeline and manifolds includes the decommissioning activities associated with the pipeline (e.g., potential jack-up rig, rock berms), concrete mattresses and debris baskets, transition manifold (e.g., manifold, overtrawlable structure, tie-in spools), north PLEM dredging, and north and south PLEMs (e.g., manifold, tie-in spools). Decommissioning impacts are quantified in 4-1 and 4 -2. Net changes are provided in the NPC Form. While some DWP components will be removed, reducing the footprint of the Project, the installation of the rock berms on the suction anchors will result in an overall increase to the Project footprint. Abandoning the anchors in place: • is the safest alternative; • avoids the consequences of an expected failure of the reverse installation method; • avoids significant subsea operations and sea floor disturbance associated with the previously proposed cutting alternatives; • results in the least environmental impact and lower vessel emissions; • is the most technically feasible; and • may result in creating beneficial marine habitat in the area. A turbidity and sediment dispersion analysis was conducted for cutting the anchors to 15 feet below the sea floor. The impact of removing the anchors would result in turbidity and sedimentation at a significantly higher magnitude than burial of the anchors with rock berms (see Section 6.2.1 of the Decommissioning Plan, Appendix C). Data from the 2023 surveys show some DWP components being used as beneficial habitat and the relatively smaller impact area would reduce impacts overall on the users of these habitats. The rationale for the selection of this alternative for decommissioning of the anchors is described in the Decommissioning Plan (Appendix C) and Alternatives Assessment (Appendix B of Appendix C). However, as descri bed in the Neptune LNG FEIS and FEIR, “it would be possible to leave some of the facilities’ underwater structure in place to function as an artificial reef.” This option could be incorporated into the Decommissioning Plan with agency agreement. The expanded footprint impacts are located outside of state waters. Temporary and permanent impacts are quantified in Tables 4-1 and 4-2. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 22 TABLE 4-1 TEMPORARY IMPACTS Infrastructure Authority Impact (ft2) Impact Area (acres) Pipeline Jack-up drill rig for flaring a Federal waters 4,306 0.1 Concrete Mattresses and Debris Debris baskets for 44 concrete mattresses and removed components and temporary storage of hot tap concrete mattresses State and Federal waters 1,760 b,c 0.04 b,c North PLEM Dredging Federal waters 1,087 0.03 Risers and Umbilicals Move south PLEM for use as anchor for STL Buoy d Federal waters 1,550 0.04 Move north PLEM for use as anchor for STL buoy d Federal waters 1,550 0.04 Total Temporary Impacts e Decommissioning total 10,253 0.24 State waters f 1,760 c 0.04 c PLEM = pipeline end manifold. a A jack-up rig or a flare barge will be used, the jack-up rig sea floor impact is included as the maximum potential impact. b Calculated using typical debris basket footprint, typically 20 ft x 8 ft x 5.5 ft, for 11 baskets. c The majority of the debris baskets will be needed at the transition manifold with one or two needed at the south PLEM. d The PLEMs will act as temporary anchors for the STL buoys while the risers and umbilicals are removed before being permanently removed. The permanent removal impact from the PLEMs is included in Table 4-2. e Totals may not equal the addends due to rounding. f The impact numbers provided for state waters are presented as the total impact from the debris baskets to provide a maximum impact number because the required number of debris baskets at each location will be determined based on need at the time of decommissioning. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 23 TABLE 4-2 PERMANENT IMPACTS Infrastructure Authority Impact (square feet) Impact Area (acres) Type of Permanent Impact Impact Volume (cubic yards) Pipeline Rock berms over pipeline ends a Federal waters (2 berms) 131.2 0.003 Addition 128 State waters (1 berm) 65.6 0.002 Addition 64 Anchors 16 rock berms over anchors b Federal waters 153,171 3.52 Addition 12,555 Concrete mattresses and debris 44 concrete mattresses c State and Federal waters 7,040 0.16 Removal 195 Transition manifold Transition manifold and overtrawlable structure removal d State waters 1,682 0.04 Removal 715 Tie-in spool removal e,f State waters 533 0.01 Removal 78 North PLEM PLEM base and pipes Federal waters 1,550 0.04 Removal 791 Tie-in spool removal f Federal waters 439 0.01 Removal 85 South PLEM PLEM base and pipes Federal waters 1,550 0.04 Removal 791 Tie-in spool removal f Federal waters 336 0.01 Removal 49 Risers and umbilicals Risers and umbilicals Federal waters NA g NA g Removal NA g Mooring lines Mooring lines Federal waters NA g NA g Removal NA g STL buoys North STL buoy Federal waters NA g NA g Removal NA g South STL buoy Federal waters NA g NA g Removal NA g MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 24 Infrastructure Authority Impact (square feet) Impact Area (acres) Type of Permanent Impact Impact Volume (cubic yards) Total permanent additional impacts h Decommissioning total 153,368 3.52 NA 12,555 State waters 65.6 0.002 NA 64 Total permanent removal impacts h Decommissioning total 13,130 0.30 NA 2,704 State waters i 9,255 0.21 NA 1,052 Note: NA = Not applicable; PLEM = pipeline end manifold; STL = submerged turret loading. a Rock berm footprint calculated using length of 2 feet by width of 32.8 feet. Volume is calculated using a profile height of 4.92 feet and 1:3 side slope gradient. b Anchor impact numbers assume a 2 meters (6.6 feet) rock pile height above each anchor and are calculated based on the heights for each anchor and a side slope gradient of 1:5. c Concrete mattress dimensions are 20 feet by 8 feet by 9 inches. Most of the mattresses that will be removed will be near the transition manifold, but the exact number and location will be determined closer to decommissioning. d The transition manifold is located underneath the overtrawlable structure, which has a larger footprint. The larger footprint of the overtrawlable structure is used for the impact. e Includes the 24-inch and 16-inch transition tie-in spools. f Width and height dimensions for tie-in spools represent the surface area they cover. Height is measured from the sea floor and includes frames and connections associated with the tie-in spools. g Impacts for these components are not provided because they are floating structures. See the Decommissioning Plan (Appendix C) for dimensions and further description. h Totals may not equal the addends due to rounding. i The removal impact numbers provided for state waters include the total impact from the concrete mattresses to provide a maximum impact number because the exact locations where concrete mattresses will be removed will be determined closer to decommissioning. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 25 4.2 GENERATION OF FURTHER IMPACTS Because the previously reviewed Neptune LNG FEIS and FEIR did not state how the purged gas from the pipeline would be treated, the potential environmental impacts from the proposed method (i.e., hot flaring) are discussed in this section to demonstrate that these impacts would not be significant. Multiple alternatives for treatment of the gas were evaluated in the alternatives analysis in Appendix B of the Decommissioning Plan (Appendix C) to determine the preferred method to treat the gas. Hot flaring of the gas is the preferred alternative because the environmental impact will be substantially similar to pushing the gas into HubLine, but Greenhouse Gas (GHG) emissions will be lower than a cold flare. Hot flaring is safer because it will require less dives for shorter durations and will be less technically complex. Potential technical challenges from the previous option include the unconfirmed gas quality, status of the connection to the HubLine, and undetermined commercial issues such as whether or not Algonquin would need to take expensive steps before or after pushing the gas into HubLine that may add significant costs to the decommissioning. Cold flaring and venting of the gas were evaluated but dismissed due to the even higher GHG emissions. Although hot flaring of the gas is less attractive from a societal perspective (no beneficial use of the gas), the value of the gas itself is minimal (less than $100,000). Additional analysis comparing the options can be found in the Decommissioning Plan (Appendix C). Regardless of whether the gas is flared or pushed into HubLine, similar support vessels will be needed, which burn marine diesel oil/marine gas oil resulting in similar criteria pollutant and GHG emissions. See Tables 4-3 and 4-4 for the estimated fuel consumption, duration, and emissions associated with the support vessels. Ultimately, it is reasonable to assume that emissions from the 21.8 MMscf of natural gas currently in the pipeline will be released to the atmosphere either by Neptune via flaring, or the end user of the gas once it is in HubLine. To provide a comprehensive comparison, the criteria pollutant and GHG emissions from the two options at the time of decommissioning are quantified in Tables 4-3 and 4-4, assuming pushing the gas into HubLine is technically feasible and would result in no emissions at that time. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 26 TABLE 4-3 CRITERIA POLLUTANT EMISSIONS Total Fuel Used Duration (days) Emissions (tons) NOx Da Vinci a NOx Wellservicer a VOC TSP CO SO2 Support Vessels 37.6 m3 4.8 2.4 2.5 0.3 0.1 0.3 7.1E-04 Push Gas to HubLine 21.8 MMscf b 0.25 - 0.5 0 c 0 c 0 c 0 c 0 c 0 c Hot Flaring 21.8 MMscf b 0.5 0.8 0.8 0.1 0.02 0.0 1.3E-04 Lowest MEPA Air Review Threshold for New and Existing Stationary Sources d NA NA 25 25 25 15/10 100 40 Source: Decommissioning Plan (Appendix C) CO = carbon monoxide; m3/MMscf = cubic meters/million standard cubic feet; NA = not applicable; NOx = nitric oxide and nitrogen dioxide; SO2 = sulfur dioxide; TSP = total suspended particulate; VOC = volatile organic compounds a NOx emissions calculations are provided for two potential vessels of different ages for comparison purposes. The engines were built to meet older and updated NOx emission standards, and either could potentially be used for any of the work during decommissioning. b Fuel used is the amount of gas currently in the pipeline. c Zero emissions are assumed at the time of push to HubLine. d 310 CMR 11.03(8)(b)(2). MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 27 TABLE 4-4 GHG EMISSIONS Total Fuel Used Duration (days) Emissions (tons) CO2 CH4 N2O CO2e Support Vessels 37.6 4.8 113.0 0.0 0.001 113.0 Push Gas to HubLine 21.8 MMscf a 0.25 - 0.5 0 b 0 b 0 b 0 b Hot Flaring 21.8 MMscf a 0.5 1,282.0 10.9 0.002 1,589.0 Lowest MEPA Air Review Threshold for New and Existing Stationary Sources c NA NA NA NA NA 100,000 Source: Decommissioning Plan (Appendix C) CO2 = carbon dioxide; CO2e = carbon dioxide equivalents; CH4 = methane; m3/MMscf = cubic meters/million standard cubic feet; NA = not applicable; N2O = nitrous oxide; PLEM = pipeline end manifold a Fuel used is the amount of gas currently in the pipeline. b Zero emissions are assumed at the time of push to HubLine. c As defined in 310 CMR 11.03(8)(b)(2). The criteria pollutant and GHG emissions from the proposed flaring of the gas would be below the lowest MEPA review threshold for each criteria as defined in the MEPA regulations (310 CMR 11.03(8)(b)(2). Therefore, the release of emissions during the proposed hot flaring would be considered insignificant. The total proposed Decommissioning Plan emissions only exceed the MEPA NOx review threshold and do not exceed the other criteria pollutant emissions or GHG emissions thresholds [see Tables 6-9 and 6-10 in the Decommissioning Plan (Appendix C)]. These thresholds are meant to evaluate emissions from continuously operated stationary sources, and not from temporary decommissioning activities. Therefore, these thresholds do not apply to this Project, and are only being mentioned for comparison purposes. The Alternatives Analysis (Appendix B to Appendix C) evaluated criteria pollutant and GHG emissions for a range of decommissioning options for other components of the DWP and the proposed decommissioning options result in significantly lower emissions than the previously proposed plan. The largest contributor to NOx emissions is removal of the mooring lines, STL buoys, and PLEMs. These activities were previously proposed and therefore, can be considered no net change from what was previously proposed. The other major change component is installation of rock berms over the anchors instead of the previously proposed plan to remove or cut and remove the anchors. Installation of the rock berms as proposed results in a significant reduction of NOx emissions by 50 to 92 percent, depending on whether an older or newer vessel is used and the extent to which the anchors are removed (see Table 16-37 in Appendix B of Appendix C). Similarly, GHG emissions will be reduced by 40 to 92 percent for the proposed Decommissioning Plan. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 28 The Decommissioning Plan was distributed to the Environmental Protection Agency (EPA) in December 2023 and follow up coordination occurred to determine whether a permit is needed for the proposed decommissioning activities. The EPA has determined that no permit is needed at this time under federal requirements and advised that, likewise, a permit would not be required from the Commonwealth. Neptune will continue to coordinate with the EPA as the Decommissioning Plan review is ongoing. 4.3 SCHEDULE AND NEW PERMITS Other factors for the Secretary to consider include changes to the schedule and the need for new permits; both of which apply but are both reasonable due to the lapse of time since the Decommissioning Plan was previously reviewed. The schedule is being refined and expanded from the brief basic schedule that was previously reviewed; however, the currently proposed schedule will take fisheries concerns and other environmental resource concerns into consideration for the least impact. Also, simply because new permits are required for the decommissioning activities does not mean the impacts or review processes are significant. The list of permits, approvals, and reviews currently anticipated are in Section 3.2.2. The permit issued by the US Army Corps of Engineers for the Project included a standard condition that requires a permittee to obtain a modification of the permit. Because an EIS was required for the original permit, an Individual Permit with a 30- day public notice is anticipated to be required. The impacts also exceed the New England District’s very low thresholds for General Permit coverage; however, that does not mean the decommissioning activities are significant. Simply as a result of the procedural need for an Individual Permit, a Section 401 Water Quality Certificate and Coastal Consistency review are required. Likewise, other federal consultations (e.g., Section 7 Endangered Species Act and Essential Fish Habitat) are required for the same reason. 4.4 UNCHANGED MITIGATION COMMITMENTS A Section 61 Findings Summary was prepared in 2007 when the Waterways License and Section 401 Water Quality Certification were issued. Table 4-5 lists the mitigation measures from those findings. Most of the measures were relevant to construction and operation and have been completed; however, additional measures relevant to decommissioning activities are identified and discussed. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 29 TABLE 4-5 MITIGATION COMMITMENTS EIR Category DEP Permit Impact Mitigation Measures from Section 61 Findings Changes Geology Waterways License Potential changes to the sea floor Selection of Route through substrate. Perform trenching and burial of the gas transmission pipeline using a pipeline plot towed by a derrick/lay barge to minimize impacts to sediments and geologic resources. Use a single pass for the plow for a majority of the pipeline route. The Hub Line tie -in location would be excavated using a diver-assisted jetting to prevent damage to the pipeline and to minimize environmental impacts from sediment re-suspension that would be caused by conventional dredging. For the limited areas where jetting is required to excavate the pipeline trench, backfilling would utilize diver -placed sandbags, concrete mats, or depending on the operational requirements of the site, importation of sand or rock placed by tremie tube. No imported backfill material will be dumped from vessels on the surface. To minimize impacts on the seafloor, the trench will be backfilled to grade with the excavated material. Mitigation measures were completed previously. Impacts on geology are not anticipated. Decommissioning activities will adhere to the PMMP. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 30 EIR Category DEP Permit Impact Mitigation Measures from Section 61 Findings Changes Funding of 2.5 million to support sea floor mapping activities and habitat characterization to be managed by the office of Coastal Zone Management, in consultation with other resource agencies. Implementation of the construction contingency plan and reporting procedures required by all applicable state and federal permits, licenses, and memoranda of understanding. Marine water quality and sediments Waterways License and Water Quality Certification Potential impacts from increases in turbidity, redistribution of contaminated sediments, construction vessels water discharge, hydrocarbon, or discharge of hydrostatic test water. Filtered sea water and an environmentally safe dye for leak detection purposes would be used for the hydrostatic testing. It is estimated that the water would be in the line for fewer than 30 days. Therefore, biocide, oxygen scavengers, and corrosion inhibitors would not be added to the test water, which would avoid discharge of potentially contaminated water. The pipeline hydrostatic test water intake velocity will meet the EPA 316(b) rule criteria of less than 0.5 feet per second. Any scale or dirt from the pipeline after the hydrotest will be removed and stored in a settling tank on board a construction support vessel and then filtered and treated prior to discharge. No discharge of debris, food or untreated sanitary wastes will be allowed into water in the construction area. Mitigation measures were c ompleted previously. Decommissioning vessels would comply with the SPCC Plan (Appendix L of Appendix C ). No discharge of debris, food or untreated sanitary wastes will be allowed into water in the construction area would be allowed during decommissioning. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 31 EIR Category DEP Permit Impact Mitigation Measures from Section 61 Findings Changes To reduce risk of spill impacts, spill prevention techniques and plans (SPCC) will be implemented. Funding of $0.6 million to provide buoys and /or meteorological. Hydrodynamic and/or other instrumentation to significantly enhance the Gulf of Maine Ocean Observing System. Marine Mammals, Plankton, Lobster, Benthic O rganisms, Shellfish, and F infish Waterways License and Water Quality Certification Potential impacts due to vessel strikes, underwater noise, entanglement, alteration of water quality, sea floor habitat alteration, hydrostatic test water intake, and or accidental hydrocarbon spills and releases Construction period limited to May - November. The sequence of work planned to avoid impacts on lobsters. Use of trained/certified marine mammal observers for determining marine mammal presence and avoiding marine mammal strikes. Marine mammal observers will direct a moving vessel to slow idle if a baleen whale is seen within 1 km of the vessel. Stationary vessels need not shut down since they have no chance to strike a whale. To minimize entanglements, the use of equipment that can cause entanglements will be minimized as much as possible, any necessary slack in cables/lines will also be minimized, and knotless non-floating lines will be used. The schedule for the decommissioning activities will be defined and flexible to accommodate time of year restrictions for sensitive resources. Decommissioning activities will adhere to the PMMP, which will comply with the proposed mitigation measures listed which include Noise, avoiding marine mammals, entanglements, and lighting impacts (PMMP, Appendix M of the Decommissioning Plan Appendix C ). See Socioeconomics for additional mitigation measures to offset lobster impacts. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 32 EIR Category DEP Permit Impact Mitigation Measures from Section 61 Findings Changes To minimize underwater noise, when starting up ship power will be increased slowly to allow baleen whales to move away to avoid the vessels. If whales are seen within 1 km, then the vessel will wait until the whale leaves the area, before starting up. To minimize lighting impacts, lighting will be reduced to required wattages only, lights will be directed downward as much as possible, and lights will be extinguished when not in use. Funding of $0.15 million to support research and educational programs of the New England Aquarium. Funding of $1.4 million to conduct surveys and assessments related to fisheries resources to be managed by the Massachusetts Division of Marine Fisheries. Funding of $3.25 million for components of a PAM system to include buoys, instrumentation, and management of the system. Funding of $0.75 million for right whale management and research and development of acoustic technology in Cape Cod Bay, with funds to be managed by the Massachusetts Division of Marine Fisheries. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 33 EIR Category DEP Permit Impact Mitigation Measures from Section 61 Findings Changes Funding of $0.6 million to the New England Aquarium to direct and manage a study of the biological impacts of the exclusion zone around the deepwater port. Cultural Resources Waterways License and Water Quality Certification Potential Impacts on prehistoric/ historic sites Significant potential cultural resource areas were avoided in the definition of the pipeline alignment based on results of field studies (geophysical surveys). A pre-construction debris/cultural resource survey will be performed before conducting construction activities. An unanticipated discoveries plan consistent with the Massachusetts Historical Commission and the Board of Underwater Archaeological Resources guidelines will be implemented if any cultural resources area accidently encountered. Funding of $0.15 million to the Peabody Essex Museum to support activities related to programs to preserve the region’s maritime heritage. Funding of $0.15 million to the Peabody Essex Museum to support activities related to maritime exhibits and heritage. Mitigation measures were c ompleted previously; no c hange proposed . An Unanticipated Discoveries Plan will be prepared in consultation with regulatory agencies in the event of an archaeological discovery. Avoidance and Anchor Handling Plans will be prepared in consultation with regulatory agencies to avoid high probability targets and shipwrecks. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 34 EIR Category DEP Permit Impact Mitigation Measures from Section 61 Findings Changes Socioeconomics Waterways License and Water Quality Certification Potential impacts to commercial fisheries, recreational fisheries, local population, economies, and property values Implementation of the offshore communications plan. Minimize construction clearance zones to the extent possible. Funding of $6.3 million to capitalize a non-profit organization to buy/lease fisheries permits and Days at Sea for the inshore groundfish fleet with funding managed by the Gloucester Fishing Community Preservation Fund. Funding of $1.7 million for potential impacts to commercial lobsterman, including loss of gear. Mitigation measures are c omplete. Additional mitigation measures include: Development of a Communications Plan for engagement with relevant stakeholders. Decommissioning activities will take place outside of lobster season to the extent practicable. Neptune will coordinate with the Massachusetts Lobstermen’s Association to identify the preferred timeframes. Lobster habitat created along abandoned pipeline will continue to benefit the New England lobster fishery in perpetuity. Installation of rock berms over pipeline ends and anchors will increase suitable lobster habitat in otherwise soft bottom substrate. MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION SIGNIFICANCE OF CHANGES CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 35 EIR Category DEP Permit Impact Mitigation Measures from Section 61 Findings Changes Ocean Use, Recreation and Visual Resources Waterways License and Water Quality Certification Potential impacts to coastal uses, recreational activities, visual resources, and the general public interest represented by the public trust doctrine and the Massachusetts Ocean Sanctuaries Act. Mitigation measures described above. Funding of $5.6 million to support infrastructure improvements and transportation to the Boston Harbor Islands. Funding of $0.35 million to maintain and/or construct public access boat ramps. Mitigation measures are c omplete; no change proposed. Source: Executive Office of Environmental Affairs, Massachusetts Department of Environmental Protection 2007. PMMP = Prevention, Monitoring, and Mitigation Plan MASSACHUSETTS ENVIRONMENTAL POLICY ACT NOTICE OF PROJECT CHANGE PROJECT CHANGE DESCRIPTION CIRCULATION LIST CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 Page 36 4.5 CONCLUSION In conclusion, Neptune believes that it is reasonable for the Secretary to determine that no further MEPA analysis is required. Although the total footprint of impact specific to decommissioning would increase compared to the previously reviewed amount, the resulting impact on the environment due to safety, technical, and other factors would be less overall. The implementation of additional mitigation measures would further lessen environmental impacts. 5. CIRCULATION LIST This NPC is being circulated electronically to the entities listed in Appendix D. 6. REFERENCES Executive Office of Environmental Affairs, Massachusetts Department of Environmental Protection. 2007. 401 Water Quality Certification and Section 61 Findings. DEP Transmittal #W090651. Neptune LNG Deepwater Port. June 2007. 73 p Neptune. 2010. Prevention, Monitoring, and Mitigation Plan for the Operations Phase, Neptune Deepwater Port, Massachusetts Bay. Submitted to United States Coast Guard. January 2010. 75 p Taormina, B., J. Bald, A. Want, G. Thouzeau, M. Lejart, N. Desroy, and A. Carlier. 2018. “A Review of Potential Impacts of Submarine Power Cables on the Marine Environment: Knowledge Gaps, Recommendations, and Future Directions.” Renewable and Sustainable Energy Reviews 96: 380–391. USCG and MARAD. 2006. Neptune LNG Deepwater Port License Application Final Environmental Impact Statement and Environmental Impact Report. Volume I. Docket No. USGCS-2004- 17696. March 2006. CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 APPENDIX A MOST RECENT PROJECT CERTIFICATES Mr. Juan Restrepo Vice President of Business Development Suez Energy North America, Inc. 1990 Post Oak Boulevard, Suite 1900 Houston, TX 77066-3831 Subj: U.S. Coast Guard and Maritime Administration Environmental Review and Approval of Neptune Request for Project Change Request Dear Mr: Restrepo On January 22, 2008 Neptune LNG, LLC submitted a proposal for changes to the construction schedule and layout of Neptune LNG Deepwater Port to the Coast Guard and the Maritime Administration (MARAD) titled: Neptune LNG Project Proposed Improvements to Buoy/Pipeline Alignment and Construction Schedule.Your subsequent letter of February 22, 2008 (enclosure 2) requested approval of the proposed changes. Condition 11 Changes to the Deepwater Port in the License issued to Neptune on March 23, 2007 by the Maritime Administration states: “In the event the Licensee proposes to make any substantive change to the Deepwater Port...the Licensee shall submit to the USCG, with copy to MARAD, an Environmental Impact Assessment...The USCG and MARAD, in consultation with other agencies as appropriate, will then decide what level of further environmental review, if any, will be necessary.” After review of this proposal; coordination with appropriate agencies; and review of Neptune’s response to additional questions, the Coast Guard and MARAD have determined that the impacts of the proposed project changes are minor and not significant and are not greater than those impacts assessed in the Final Environmental Impact Statement/Environmental Impact Report (EIS/EIR) of November 2006. In fact, we agree with Neptune that due to reduced pipeline length, improved buoy anchoring locations and array, and splitting the construction schedule over two years, the actual environmental impact of the project will be less than that assessed in the EIS/EIR. As such, we have determined that no other environmental review or supplemental NEPA analysis is necessary. Though the proposal and request for change, as well as this response will be posted on the docket (USCG-2006-22611) we do not feel there is need for additional public notification or comment beyond that already in progress through the NPDES permit and Massachusetts Environmental Policy Act (MEPA) Notice of Project Change process. The proposed changes also fall within the parameters of the other license conditions. Commandant United States Coast Guard 2100 Second Street, S.W. Washington, DC 20593-0001 Staff Symbol: CG-5225 Phone: (202) 372 1440 Fax: (202) 372-1926 Email: Mark.A.Prescott@uscg.mil 16613 March 7, 2008 Subj: Neptune Project Change Proposal 16613 March 7, 2008 2 Be advised that Neptune is responsible for meeting all License conditions that are required prior to commencing and during construction for the construction phase proposed in 2008. These conditions include but are not limited to: 1. Obtain and/or modify (date change) all authorizations, approvals and permits, required for the construction of the deepwater port under Federal, State, and Local law. 2. Pre-construction surveys and contingency plans for the avoidance of geologic hazards, hazardous materials and protection of cultural/archeological resources. 3. Restriction of marine construction activities to between May 1 and November 30 of each year. 4. Construction practices and vessel speed restrictions as noted in the license. 5. Meeting the Pipeline and Hazardous Materials Safety Administration (PHMSA) requirements for the pipeline and flowline portions downstream of the subsea manifolds. 6. Per License Condition 12 and prior to commencing construction, Neptune must prepare a Prevention, Monitoring and Mitigation Program (PMMP) to be approved by the Coast Guard and MARAD after concurrence by applicable agencies. Please note that besides approval of the PMMP, there are monitoring requirements that must be in place before commencing construction. The PMMP shall include how Neptune will comply with all permit and authorization actions and consultation recommendations. It also must include a specific marine mammal section to address the whale monitoring, noise and vessel strike avoidance monitoring buoys and training for construction personnel. We encourage Neptune to work with Excelerate with regard to cost sharing of equipment, monitoring operations, and lessons learned. In addition, due to timing of this 2008 construction schedule, we are recommending a separate PMMP for Construction or possibly even separating Construction 2008 to expedite agency review and concurrence and Coast Guard/MARAD approval. 7. Per License Condition 2.a General Conformity Determination, in the event that NOx emissions are above the applicable General Conformity thresholds, Neptune must offset such emissions by converting Emission Reduction Credits (ERCs). According to the General Conformity emissions analysis (Enclosure 6) provided by Neptune, Neptune must convert ERC’s in its possession to 131 discrete credits prior to construction for the year 2008. The DWP license does not need to be revised as it specifies the requirement to offset in the year of construction but does not specify the year. Public notice is not needed as the total project emissions do not increase. Subj: Neptune Project Change Proposal 16613 March 7, 2008 3 Neptune shall coordinate with U.S. EPA Region 1 Air Quality Division and confirm this conformity determination and that the changes in air quality will be a neutral or positive change and, in addition, confirm Neptune’s analysis that because the 2009 construction emissions are below the threshold, that offsets are not required for the second year. 8. Neptune License conditions do not include all of the detail addressed in the EIS/EIR and consultation recommendations made by resource agencies, however in Condition 11 Changes to the Deepwater Port (also referenced in the first paragraph of this letter), and in Condition 13, which refers to the conditions set forth in the Governor of Massachusetts approval letter, it is expected that construction and operation of the port shall be consistent with the environmental analysis in the EIS/EIR. The following is a list of items from the EIS/EIR for your attention. a.Total Construction Time. Under Condition 8, Port and Pipeline Construction, the License authorized construction between May 1 and November 30 but did not include a total time limit. From resource agency consultations and the EIS/EIR, the construction period was not to exceed 7 months. Though now split between 2008 and 2009, the 7 month total time must still be adhered to, otherwise additional agency consultation may be required. We acknowledge that Neptune has committed to 7 month total construction time within the May to November timeframes of both years. More detail on this is provided in enclosures (1, 4, and 5). b.Commissioning Water Use. Though not directly related to this proposal, resource agencies raised some concern that the amount of water required for commissioning Neptune’s LNG carriers exceeded the estimated water usage assessed in the EIS/EIR. In working with Neptune, our analysis indicates that due to commissioning one vessel in 2009 and the second vessel in 2010 combined with anticipated transit schedules, the actual total water use for port commissioning and subsequent operations for 2009 and 2010 will actually be considerably less than that analyzed in the EIS/EIR. In fact the EIS/EIR annual water use was based on at least a three ship operation and the water use analyzed, with adjustments in operations and commissioning would enable a third ship to be commissioning with two ships already in use. The License incorporates by reference the Application, the EIS/EIR, and recommendations from resource agency consultations. Neptune will be held to those impacts assessed in the EIS/EIR otherwise additional analysis may be required. We appreciate Neptune commitment to stay within the water use parameters established in the EIS/EIR. More detail on water use is provided in enclosure (1). c.Auto Detection Buoys and Autonomous Recording Units (ARUs). License Condition 12,Prevention, Monitoring and Mitigation Program (PMMP) includes, among other requirements an array of 6 auto detections buoys and approximately 19 autonomous recording units to cover construction and port operations. This same condition was included in the Northeast Gateway license to ensure the program would be established even if only one application had been approved. Subj: Neptune Project Change Proposal 16613 March 7, 2008 4 It was the Coast Guard and MARAD’s intent that only one array of 19 ARU’s be employed and shared by both Neptune and Northeast Gateway as the array covers the entire area of both deepwater ports. We also understand from Neptune that NOAA is supporting such an arrangement. As such, it is expected that Neptune will work out appropriate cost sharing arrangements for the operation and maintenance of these ARUs as well as the Auto Detection Buoys placed in the TSS. License Condition 1, requires reasonable efforts between Neptune and Northeast Gateway to coordinate and cost share, among other things, mitigation activities and environmental monitoring and protection. Neptune, Northeast Gateway and NOAA are encouraged to recommend improvements to the system based on new technology and lessons learned. More detail on this is provided in enclosure (1). As mentioned in #6 above, the auto detection buoys and ARU’s are part of the project PMMP which must be approved by MARAD and the Coast Guard following concurrence by appropriate resource agencies. It should also be noted that by Federal Register on February 19, 2008 the National Marine Fisheries Service (NMFS) of the National Oceanic and Atmospheric Administration (NOAA), noticed the proposed incidental harassment authorization (IHA) with comment period ending March 20, 2008. The EPA has published the Draft NPDES permit with comment period from February 26 to March 28, 2008, with a public meeting scheduled on March 27, 2008. The Massachusetts Environmental Policy Act (MEPA) Office has published a Notice of Project Change in the Environmental Monitor with comment period ending March 11, 2008. For the purpose of responding to questions raised by resource agencies involved in helping the Coast Guard and MARAD evaluate the environmental impacts of the proposed changes, we are copying those involved agencies and provide the additional detail in the enclosed attachments. That information discusses the environmental review of the project changes as supplemented by additional information provided by Neptune and verified by Coast Guard and MARAD in coordination with the relevant Federal and State agencies. We have concluded that the impacts from Neptune’s proposed construction changes will not be greater than those assessed in the EIS/EIR. We appreciate the innovation and informational thoroughness of Neptune in this proposal that will reduce environmental impacts from project construction while better achieving project schedule needs. We look forward to continuing this effective relationship throughout project construction and operations. We also wish to thank those agencies involved that, in a short timeframe, contributed to this review with their expertise and, as with Neptune, look forward to continue this working relationship in enabling this project to move forward as proposed and within the established environmental parameters. ENVIRONMENTAL REVIEW Summary of Proposed Changes 1.Schedule Change. The project originally proposed a May 1 through November 30, 2009 construction schedule. The proposed change would have pipeline construction begin in 2008 and port construction finishing in 2009, keeping within the same time of year and with all construction to be completed within a total of seven months. Therefore, there are no additional impacts beyond those identified in the EIS/EIR 2.Move STL Buoy Locations. The Northern Buoy is shifted 928 feet to the northwest along the previously approved pipeline corridor. The Southern Buoy is shifted 1863 feet to the northeast along the previously approved flowline corridor. Since the buoy shift is within the same pipeline/flowline corridors as analyzed in the EIS/EIR, there are no additional impacts beyond those identified in the EIS/EIR. 3.Shift in Pipeline Alignment. The gas transmission pipeline would be about 925 feet shorter based on the Northern Buoy location shift. Therefore, there are no additional impacts beyond those identified in the EIS/EIR and in fact impacts will less due to reducing the pipeline. length. 4.Shift in Flowline Alignment. The flowline (between the buoys) is approximately 509 feet shorter due to buoys shift and is offset approximately 477 feet at the Southern Buoy and 75 feet at the Northern Buoy. This offset is still within the previously approved flowline corridor. There are no additional impacts beyond those identified in the EIS/EIR. 5.Change in STL Buoy Anchoring Array. Due to buoy location change the originally proposed mooring anchoring array has been moved and lengths adjusted with total bottom anchor chain sweep reduced from the original proposal. Impacts have been reduced from those assessed in the EIS/EIR. In our environmental review some additional questions were generated by the Coast Guard and through the coordination with other agencies. Based on a conference call on and email comments several issues and questions were raised on various topics that needed further clarification. The Coast Guard, in coordination with MARAD, and through its own analysis and soliciting additional clarification from Neptune, provides the following information regarding these issues. Summary of Findings to Questions Raised Impact of Shift in STL Buoy Locations (See Enclosure 3) The shift in locations is slight and does not constitute a significant change from initial analysis. In addition, the anchoring array is reduced in aerial coverage reducing seafloor impact and this move is intended to eliminate the need for pile driving anchors which can now be accomplished by suction anchors thus eliminating or significantly reducing noise impact. Subj: Neptune Project Change Proposal 16613 March 7, 2008 2 Impact of 2008/2009 Construction Schedule (See Enclosure 4 and 5) Neptune must not deviate from the May-November time frame that has been previously analyzed. Also, Neptune needs to adhere to the seven months that was analyzed previously when the work was proposed to be done entirely in 2009. As analyzed in the EIS/EIR, construction is restricted to this window to reduce the impacts to northern right whales. Therefore, there are no additional impacts beyond those identified in the EIS/EIR. With the newly proposed work schedule, barring any delays, construction will take approximately 5-6 months over the two construction seasons. The fact that it will occur over two seasons instead of one, is not of any greater concern for issuance of the MMPA authorization. Neptune will commit to the total seven month construction schedule which was previously analyzed in the EIS/EIR and by NOAA in the IHA for the single construction year 2009. In Neptune’s discussions with NOAA, and in a follow-up email to the Coast Guard, NOAA/Protected Resources stated that construction over two years (a total of seven months) does not pose any greater impacts than their previous analysis, and therefore raises no additional concerns for issuance of the MMPA authorization. Neptune will complete construction in seven months, over a two year period. The schedule provided in the Project Change (Enclosure 4) document shows pipeline installation taking place in three to four months in 2008 (July through October) and buoy and mooring installation in two to three months in 2009 (May though July). Neptune provided in its Project Change documentation, a base and contingency construction schedule. Neptune is presently finalizing the pipeline installation contract and plans to start construction in July 2008. Pre-construction monitoring including the buoys program and PMMP preparations are underway to meet this schedule. Agency consultation will soon begin to ensure all agency concerns and comments are addressed. This construction schedule is feasible and offers many benefits to the project and mitigation recipients. Impacts to Commercial Fishing There will be no discernible change to commercial fishing due to the change in buoy locations. The exclusion area dimensions closed for commercial fishing around both buoys, both during construction and operation, have not changed. The buoy closest to Stellwagen Bank National Marine Sanctuary (“SBNMS”) has moved further away, and the other buoy, closer to SBNMS. Both buoys are about 1.5 miles from the Sanctuary. The distribution of construction activities over the two seasons will have no significant impact to the industry. The same construction activities, equipment, and durations that were planned over a one year period will now take place over a two year period. There will be no additional areas closed to fishermen or for longer durations. Neptune must coordinate the scheduling of work to keep closed areas to a minimum, and areas not affected by construction must be available for fishing. In addition, because of these changes, it appears that there will be less construction activity on the water at any one time or season, thus reducing impacts to fishing. Subj: Neptune Project Change Proposal 16613 March 7, 2008 3 Cost-Sharing Pre-Construction Monitoring of Local Acoustic Environment using a passive acoustic array. Neptune met with Excelerate on February 12, 2008 to finalize the negotiation of the cost sharing agreement. Contracts are now being prepared. The Coast Guard will be notified when the contracts have been signed. Build, install and operate six automatic detection buoys in the area around the port prior to start of construction. Neptune has initiated through Excelerate’s agreements with Cornell University and Woods Hole Oceanographic Institute for the fabrication of seven new automatic detection buoys with electronic packages. As required in the License, six buoys will be deployed in both construction seasons when construction is taking place, leaving one for spare. Neptune plans to start consultations with Cornell and NOAA shortly to finalize the scheduling and monitoring plans. The Coast Guard will be notified when these activities occur. Impact of two-year distribution of activities mobilizing and demobilizing buoys. The 19 ARU Acoustic array is established from the construction of Northeast Gateway and we assume will remain the same for Neptune as it covers the entire area of both ports. Unless there have been changes to the program from the Northeast Gateway array, only the 6 auto detection buoys have to be addressed. The time involved for NOAA approval of plans for collection and use of monitoring data and installation of buoys should be minimized as it has already been established for Northeast Gateway. Impacts associated with mobilizing and demobilizing buoys will be minimal for the two construction seasons. Impact on General Conformity Determination (Enclosure 6) Neptune has recalculated the general conformity analysis to reproportion the construction emissions into 2008 and 2009. Operational emissions subject to general conformity would still occur in 2009 and have been retained in the 2009 total. The total NOx emissions remain at 183 tons, and results indicate NOx emissions will be 131 tons in 2008 and 52 tons in 2009. The 52 tons of NOx in 2009 will not need to be offset because total emissions would be below the 100- tpy threshold. The total construction emissions do not change because the same equipment, load factors, and operating times determined for the one year construction schedule are split over two years and equal the previous one year total. Neptune must convert ERC’s in its possession to 131 discrete credits prior to construction for the year 2008. The DWP license does not need to be revised as it specifies the requirement to offset in the year of construction but does not specify the year. Note that the total project emissions have not increased, but now will occur over two years, which may be an environmental benefit to the region. As there has not been an increase in emissions, public notice of this change is not required. Subj: Neptune Project Change Proposal 16613 March 7, 2008 4 Neptune will coordinate with U.S. EPA Region 1 Air Quality Division and confirm that the changes in air quality will be a neutral or positive change and has verified that low sulfur diesel (.05 % S) will be used in construction equipment per License conditions. Neptune will also confirm with EPA that emissions in 2009 will not need to be offset. Public Input and Notice The Coast Guard and MARAD have determined that the impacts of the changes in this proposal are less than those impacts assessed in the EIS/EIR, are minor and not significant, and that no further NEPA analysis or public notice and comment is required. The Coast Guard and MARAD, in working with the Licensee, have coordinated extensively on these minor changes with the affected Federal and Massachusetts agencies and will post this letter, the proposal, and all relevant communications related to those changes on the docket for the Neptune project at www.regulations.gov (USCG-2005-22611). Additional public notification is provided by the NPDES permit process and MEPA’s Notice of Project Change. Assess need for additional sea bottom surveys In preparation for this proposal, Neptune completed additional sea bottom surveys that covered the additional area along the flowline shift near the Southern Buoy and in the new buoy anchoring array locations. This became part of their decision making process that the proposed location shifts did not include archeological/cultural sites or geological hazards and that the bottom locations were actually more suitable for suction anchoring and pipe lay. The Coast Guard has determined that additional surveys are not required Impact on results of Independent Risk Assessment The Coast Guard conducted an independent risk assessment (IRA) to address accidental and intentional events that could result in LNG releases. The report was included in Appendix H of the EIS/EIR. Neptune’s proposal includes shifting the Northern Buoy 928 feet to the northwest and the Southern Buoy 1863 feet to the northeast. The proposed shift in project components increases the distance of the Neptune deepwater port from the vessel traffic in the Boston TSS and from the vessel traffic associated with the Northeast Gateway deepwater port. The change in distance does not result in increased impacts beyond those identified in the EIS/EIR. Though the proposed northerly buoy location shifts the port closer to land, the maximum predicted distance of any impacts associated with a LNG release would still be over 3 miles offshore. Commissioning water use and ichthyoplankton Some agencies voiced concerns that the additional seawater use required for commissioning the LNG carriers proposed by Neptune for the NPDES permit was not assessed in the EIS/EIR and would result in larger impacts to ichthyoplankton than those assessed in the EIS/EIR. Subj: Neptune Project Change Proposal 16613 March 7, 2008 5 Use of seawater during commissioning is not directly impacted by this proposal, nor was it specifically identified in the EIS/EIR. However, because of the timing of commissioning activities and LNG carrier availability, we have determined that the overall total annual water use, including during commissioning activity, will actually be less than the amounts assessed and disclosed in the EIS/EIR for full port operations. Therefore, there are no additional impacts beyond those identified in the EIS/EIR. The EIS/EIR analyzed the impact of water use during full port operations that actually assumed more than two LNG carriers (at least 3) would be available and required to make the 50 deliveries per year. The estimate of 873 million gallons per year (2.39MGD) actually assumed that there would be a ship on one of the buoys at all times with several hours overlap of ships on both buoys. This is only possible with at least three ships due to loading and transit times to and from the deepwater and loading port. In a two ship operation, there will be ships at the port vaporizing gas only approximately 2/3 of the time therefore actual impacts of 578 million gallons will be much less than disclosed in the EIS/EIR. In summary: -The EIS/EIR assessed water use of approximately 873 million gallons annually at the port -1 ship operating would use approximately 289 million gallons annually at the port -1 ship operating 2nd ship commissioning then operating: 840 million gallons annually -2 ships operating: 578 million gallons annually -2 ships operating 3nd ship commissioning then operating: 1128 million gallons annually (NOTE: a less conservative but more accurate estimate: 910 million gallons annually) -3 ships operating would use approximately 867 million gallons annually at the port -Commissioning a ship would require approximately 369 million gallons for 45 days These numbers are conservative (high) as they assume an average 2.39 MGD allowing for time when there are ships on both buoys at the same time. That would only routinely happen if 3 ships are in operation as the estimated time at the port per ship per year is 33% of the time or 121 days. Average ship water use without the overlap is 2.25 MGD or 272 million gallons annually. The 45 days commissioning is also a conservative estimate and is expected to be more in the 10 – 20 day range. 20 days commissioning would require approximately164 million gallons. It is possible for 2 ships to be operating and a third ship be commissioned and begin operations in the same year and remain within the annual water use limits identified in the EIS/EIR with adjustments in operations and commissioning. The calculations supporting these totals are provided for your information at the end of this enclosure. Neptune has committed to stay within the water use impacts identified in the EIS/EIR and would adjust deliveries, operations, and commissioning activities accordingly to do so. Neptune has provided the information requested by EPA for the draft NPDES permit. At present, Neptune has two vessels on order and being built, one for delivery and commissioning in late 2009 and the other for early 2010. As an additional note, Northeast Gateway may not be fully utilizing its port capacity in the early years. From a cumulative water use standpoint the water use for both projects will be far less than that assessed in the EIS/EIR. Subj: Neptune Project Change Proposal 16613 March 7, 2008 6 Supporting information and calculations: Water Use as Identified in EIS/EIR (full port operations)) -Over a vaporization cycle, average intake is 2.25 million gallons per day (MGD); at an intake velocity 0.15ft/sec. This equates to an annual 821 million gallons. -Annual average 2.39MGD based on overlap of two LNGCs moored (9 hrs every 6 days). -Total annual water intake 873 million gallons (2.39MGD x 365days) -Max intake rate at any time during vaporization 6.97 MGD (velocity < 0.47ft/sec). -During normal operations no cooling water would be discharged Estimated Water Use during Commissioning -Each vessel will require approx 20 day commissioning. Worst case 40 days. Permit 45 days -Seawater intake average 5700 gpm (8.2MGD) for 45 days = 369 million gallons per ship -If commissioning complete in the expected 20 days this drops to 164 million gallons Estimated annual time at port and water use per ship -Normal ship rotation assuming Trinidad as LNG supply: -7 day offloading period at the port; 6 day voyage to Trinidad; 1 day loading LNG in Trinidad; 6 day return trip to Boston -Total days at port 7 out of 20 or 128 days per year per ship -Actual estimate from Neptune allowing for gaps in the rotation schedule is 121 days per year -1 ship operation = 1 x 121 days per ship x 2.39 MGD = 289 million gallons per ship 2 and 3 ship operational water use at port -2 ship operation = 2 ships x 121 days per ship x 2.39 MGD = 578 million gallons per year -3 ship operation = 3 ships x 121 days per ship x 2.39 MGD = 867 million gallons per year Water use with single vessel operations and ship commissioning in same year -1 ship operation for 1st year, 2.39 MGD x 121 days = 289 MG -2nd ship commissioning max water use +369 million gallons -2nd ship operational water use max operational time +182 million gallons -Total water use year one 840 million gallons -NOTE: Maximum operational time based on 121 days (available) – 45 days (for commissioning) = 76 days remaining for full operations at 2.39 MGD = 182 million gallons Water use with two vessel operations and third ship commissioning in same year -2 ship operation = 2 ships x 121 days x 2.39 MGD = 578 million gallons per year -3rd ship commissioning max water use +369 million gallons -3rd ship operational water use max operational time +182 million gallons -Total water use year one 1128 million gallons -NOTE: Actual operational water use for two ships would be less as overlap of both ships on the port would be minimal and commissioning time would likely be reduced by the time a 3rd ship is ready (if that happens). A more realistic estimate of total water use requirement would be on the order of 910 million gallons for that year. Neptune has committed to adjust deliveries, operations, and commissioning activities to stay within 873 million gallons per year and be consistent with that analyzed in the EIS/EIR. " " " " " " " " " " " " " " " " " " " " " " " " " " " " " » -25 0ft - 2 0 0 f t - 3 0 0 f t - 2 5 0 f t -200 f t -250 f t -2 5 0 f t -250 f t - 2 5 0 f t -250 f t - 2 0 0 f t -250 f t -250ft -200 f t -2 50 f t - 2 5 0 f t -2 50ft -20 0 f t -2 5 0 f t -250 f t - 2 0 0 f t -250f t -250ft - 2 5 0 f t - 2 5 0 f t -2 00 f t -2 5 0 f t -25 0ft -2 50 f t -2 00 f t 6575 6525 6576 6526 6574 2 4 " E x c e le r a t e 2 2 - J a n - 0 7 N e wFlowline - 5 513.6 f t New B uoy - 8 017.6 7ft Prev ious B u o y -9458.85 f t New Buoy - 7 140.4 8ft P re viousbuoy- 6 631 .89 f t Pre vi ous F low l i ne - 549 2 .21 f t S8 S7 S6 S5 S4 S3 S2 S1 N8 N7 N6 N5 N4 N3 N2 N1 70°34'0"W70°35'0"W70°36'0"W70°37'0"W70°38'0"W70°39'0"W 42°29'0"N 42°28'0"N 42°27'0"N 1,195,000 1,200,000 1,205,000 1,210,000 1,215,000 15 , 4 2 5 , 0 0 0 15 , 4 3 0 , 0 0 0 15 , 4 3 5 , 0 0 0 15 , 4 4 0 , 0 0 0 NEPTUNE PROJECT Revised Infrastructure Layout in Federal Waters Stellwagen Bank Marine Sanctuary Uncontrolled Sketch Scale at Tabloid size: PROJECTION: ZONE: SPHEROID: DATUM: CENTRAL MERIDIAN: GRID UNITS: UTM 19 N GRS 1980 NAD83 69 W US SURVEY FEET GEODETIC INFORMATION VER- SION DATE CREATED BY CHECKED BYDESCRIPTION (C) 2008. SUEZ LNG NA LLC. ALL RIGHTS RESERVED. COPYING THIS DOCUMENT OR ANY PORTION OF IT IS STRICTLY PROHIBITED. µ REFERENCES: 1. BACKGROUND IMAGE : U.S. Geological Survey Data Series 99, Bradford Butman, Page C. Valentine, Tammie J. Middleton and William W. Danforth LEGEND LOCATION MAP: APPROVED BY NOTES: FI L E : G : \ 1 1 1 8 5 6 0 4 - N e p t u n e \ P H A S E I I I \ I N T E C \ 0 6 C H A R T I N G \ U n c o n t r o l l e d _ S k e t c h e s \ 1 1 1 8 5 6 0 4 - 3 0 0 - G I S - S t e l l w a g e n . m x d F e b r u a r y 2 0 0 8 Massachusetts Bay ShipInboundFairway Outbou n dFairway Massachusetts This drawing Buoy Mooring Plan Previous Buoy Mooring Plan ""Excelerate Northeast Gateway Route Spool Piece Riser Manifold Neptune Flowline/Transmission Line Previous Neptune Flowline STATE/FEDERAL WATERS BOUNDARY LEASE BLOCKS (MMS) RESTRICTED AREA North Submerged Turret Loading (STL) Buoy X = 1,206,779.20 ft Y = 15,436,601.29 ft PreviousBuoyLocation Transmission Line Crosses State/Federal Boundary X = 1,203,687.60 ft Y = 15,439,097.19 ft South Submerged Turret Loading (STL) Buoy X = 1,208,247.80 ft Y = 15,425,248.16 ft Previous Buoy Location 0 1,000 2,000 3,000 4,000 5,000500Feet 1 inch equals 2,000 feet 186 3ft 92 8 f t S t e l l w a g e n B a n k N a t i o n a l M a r i n e S a n c t u a r y Neptune LNG Project Figure 3-1 Revised January 2008 Neptune LNG Project Figure 3-2 Revised January 2008 Neptune LNG Project Figure 3-2 Revised January 2008 Vessel Use for 2008/2009 Construction versus Original 2009 Construction 2008 Start-up Base Case The revised 2008 construction start-up used exactly the same items and times as the original schedule, and managed to install all pipeline related work in 2008 with the buoy to be installed in 2009 as originally scheduled. The air emissions totals will remain exactly the same; however will be spread over 2008 and 2009 instead of just being in 2009. The tables below are modified to show the split between 2008 (yellow) and 2009 (turquoise) season for the base case schedules. 2008 Start-up Contingency Case The revised 2008 construction contingency case (base case with weather etc.) start-up used exactly the same items and times as the original contingency (base case with weather etc.) schedule; however, in this case the pipeline work could not be completed in 2008 and some remains in 2009, with the buoy to be installed in 2009 as originally scheduled. The air emissions totals will remain exactly the same; however will be spread over 2008 and 2009 instead of just being in 2009. The tables below are modified to show the split between 2008 (green) and 2009 (purple) season. Table 0-1: Construction Sequence with Durations and Vessel Tasks[1],[4]Duration[3]Pipelay/ Derrick Barge[[5] AHTS1[2]AHTS2[2]DSV1 Supply Crew/ Survey Plow Federal Waters (%) State Waters (%) Debris Survey 8 X 10 90 Postlay Survey 8 X 20 8 As Built Survey 8 X 100 Install DMA/Lay Flowline 6 X X X X X 100 Install DMA/Install Pipeline 22 X X X X X 10 90 Trench 15 X X X X X X 20 80 Backfill 15 X X X X X X 20 80 Install Manifolds/Spool 15 X X X 66 33 Perform Hydrotests 8 X X X X 50 50 Install Anchors/Chains 15 X X X 100 Install Buoys 8 X X X 100 Install Risers 8 X X X 100 Perform Buoy System Test 8 X X X 100 Excavate Hot Tap 8 X X 100 Perform Hot Tap 15 X 100 Install Field Spool 8 X X 100 Concrete Mats Hibernia Cable 8 X X 100 Post Installation Mats 22 X X 100 Total 120 120 120 58 61 104 120 30 78 120 1. Some Activities occur concurrently. 2. AHTS vessels are not required if a DP pipelay, derrick barge is used. 3. Duration is based on a 24-hour day. 4. Based on a 4-month schedule 5. Assume pipelay/derrick barge diving capabilities. Table 0-2: Construction Sequence with Durations and Vessel (including weather contingency) Tasks[1],[4]Duration[3]Pipelay/ Derrick Barge[[5] AHTS1[2]AHTS2[2]DSV1 Supply Crew/ Survey Plow Federal Waters (%) State Waters (%) Debris Survey 12 X 10 90 Postlay Survey 12 X 20 8 As Built Survey 12 X 100 Install DMA/Lay Flowline 9 X X X X X 100 Install DMA/Install Pipeline 33 X X X X X 10 90 Trench 22.5 X X X X X X 20 80 Backfill 22.5 X X X X X X 20 80 Install Manifolds/Spool 22.5 X X X 66 33 Perform Hydrotests 12 X X X X 50 50 Install Anchors/Chains 22.5 X X X 100 Install Buoys 12 X X X 100 Install Risers 12 X X X 100 Perform Buoy System Test 12 X X X 100 Excavate Hot Tap 12 X X 100 Perform Hot Tap 22.5 X 100 Install Field Spool 12 X X 100 Concrete Mats Hibernia Cable 12 X X 100 Post Installation Mats 33 X X 100 Total 180 180 180 86 91 155 180 44 117 180 1. Some Activities occur concurrently. 2. AHTS vessels are not required if a DP pipelay, derrick barge is used. 3. Duration is based on a 24-hour day. 4. Based on a 6-month schedule 5. Assume pipelay/derrick barge diving capabilities 14:2043.TL02 Update of the General Conformity Emission Analysis for Activities in State of Massachusetts Waters and in 800-Meter Zones Around Regasification Buoys Neptune Project Offshore Boston, Massachusetts February 2008 Prepared for: NEPTUNE LNG LLC 1 Liberty Square 10th Floor Boston, MA 02109 Prepared by: 368 Pleasant View Drive Lancaster, New York 14086 Neptune Project © 2008 Suez LNG NA LLC. All rights reserved. Copying this document or any portion of it is strictly prohibited. 14:2043.TL02 1 Update of the General Conformity Emission Analysis for Activities in State of Massachusetts Waters and in 800-Meter Zones Around Regasification Buoys This report update discusses the General Conformity emission changes corresponding to the change in the construction schedule for the Neptune liquefied natural gas (LNG) deepwater port. The Port was originally envisioned to be constructed entirely during 2009 and, therefore, all construction- related emissions would occur in 2009. Port operations would commence during the latter three months of 2009, thus emissions from operational activities that are subject to General Conformity are also included in the 2009 General Conformity emission total. Neptune LNG LLC has decided to start construction of the Neptune Project in 2008, with the expected completion in 2009. Therefore, for the General Conformity applicability determination, the air emissions for the construction phase have been reproportioned to account for construction activities occurring in 2008 and 2009; operational emissions subject to General Conformity would still occur in 2009 and have been retained in the total for 2009. Attachment A at the end of this report provides an updated spreadsheet detailing the emission calculations. Calculations include construction emissions occurring in State of Massachusetts waters, within 800 meters of both buoys, emissions associated with deploying acoustic monitoring buoys, onshore construction emissions from barge loading operations; all emissions are proportioned between 2008 and 2009 based on construction engineering schedule estimates. Previously, when construction would occur entirely in 2009, total 2009 construction emissions were estimated to be 182 tons per year (tpy) of nitrogen oxides (NOX) and 40 tpy of volatile organic compounds (VOC). By adding the total 2008 and total 2009 emissions shown in Tables 1 and 2, respectively, the total construction emissions over the two years remain the same; SRV on buoy emissions are slightly higher based on final Air Permit limits. Activities in 2008 In Table 1, a list of construction activities and the corresponding estimated emissions are given for 2008. Note that 2008 is the construction year in which most activity would occur within State waters. Construction includes onshore activities (two land-based and one floating crane for loading materials onto barges), laying pipe and flow lines, deploying the acoustic buoys, and construction activities within the 800-meter radius of each buoy. Activities in 2009 In Table 2, a similar list of construction activities and the corresponding estimated emissions are given for 2009. 2009 is the remaining construction year during which limited activity would occur within State waters. Construction includes a continuation of the onshore activities described in the 2008 section, deploying the acoustic buoys, and the remaining construction activities within the 800- meter radius of each buoy. Neptune Project © 2008 Suez LNG NA LLC. All rights reserved. Copying this document or any portion of it is strictly prohibited. 14:2043.TL02 2 Table 1 Summary of 2008 Emission Activity – Base Scenario without Weather Contingency Emission Activity Nitrogen Oxides (NOX) (tons per year) Volatile Organic Compounds (VOC) (tons per year) Construction State Waters 109.8 21.0 Construction within 800 meters of both buoys 13.4 2.3 Deploy Acoustic Monitoring Buoys 0.7 0.2 Onshore Construction related emissions 7.4 1.3 SRV Transit State Waters 0.0 0.0 SRV On Buoy 0.0 0.0 Support Vessel Operation in State Waters 0.0 0.0 TOTAL 2008 Emissions 131.3 24.8 Key: SRV = shuttle and regasification vessel. Construction is scheduled to be completed and the Port operational for an estimated three months at the end of 2009. Operational activities with emissions subject to General Conformity include the storage and regasification vessel (SRV) transit within state waters, SRV at the buoy prior to and after regasification has been completed, and support vessel operations in state waters. Table 2 Summary of 2009 Emission Activity – Base Scenario without Weather Contingency Emission Activity Nitrogen Oxides (NOX) (tons per year) Volatile Organic Compounds (VOC) (tons per year) Construction State Waters 8.9 1.7 Construction within 800 meters of both buoys 27.3 4.7 Deploy Acoustic Monitoring Buoys 0.7 0.2 Onshore Construction related emissions 0.8 0.1 SRV Transit State Waters 0.1 0.1 SRV On Buoy 12.3 9.6 Support Vessel Operation in State Waters 1.6 < 0.1 TOTAL 2009 Emissions 51.7 16.5 Key: SRV = shuttle and regasification vessel. Emission Reduction Credits The total NOX emissions in 2008 exceed the General Conformity threshold of 100 tpy as stated in 40 CFR Section 93.153. Neptune LNG LLC will fully offset the NOX emissions generated in 2008 from the Project construction in Massachusetts waters and within 800 meters of both buoys through the conversion of emission credits already in its possession to discrete emission reduction credits that would result in emissions reductions equal to or greater than the projected emissions. The discrete Emission Reduction Credits have been committed to the Project to offset construction emissions, have been certified by the Massachusetts Department of Environmental Protection, and are sufficient to fully offset the estimated 131 tons of construction and operations NOX emissions in 2008. The estimated 52 tons of NOX in 2009 will not need to be offset because the total emissions would be below the 100-tpy threshold. VOC emissions in 2008 and 2009 would be below the 100-tpy threshold and do not require mitigation under General Conformity. Neptune Project © 2008 Suez LNG NA LLC. All rights reserved. Copying this document or any portion of it is strictly prohibited. 14:2043.TL02 Attachment A Emission Calculation Spreadsheet Tables 2008 2008 2009 2009 2010 2010 Emission Activity NOx tpy (a)VOC tpy (a)NOx tpy (b)VOC tpy (b)NOx tpy (c)VOC tpy (c) Construction State Waters 131.3 24.7 37.7 6.7 0.0 0.0 SRV Transit State Waters 0.0 0.0 0.1 0.1 0.5 0.3 SRV On Buoy 0.0 0.0 12.3 9.6 49.0 38.3 Support Vessel Operation in State Waters 0.0 0.0 1.6 0.0 6.2 0.2 TOTAL Emissions 131.3 24.7 51.6 16.4 55.7 38.8 Notes (c) 2010 is first full year of normal operation. No Construction. (b) 2009 is remaining construction year with limited activity in State waters. SRV Transit, SRV on Buoy and Support Vessel occurs for 3 months in 2009 after Construction period has ended. Construction includes onshore (cranes loadingpipe to barge), deploying acoustic buoys and construction activities w/in 800 meter radii of each buoy (a) 2008 is construction year with most activity in State waters. Construction includes onshore (cranes loading pipe to barge), laying pipe and flowlines, deploying acoustic buoys and construction activities w/in 800 meter radii of each buoy. Summary of Emissions for Base Scenario without Weather Contingency 1 of 3 Vessel Activity One-way Distance (mi)(a) RT Distance (mi) RT Time (hours)(b) Number of RTs/yr (c)Hours/yr Number of engines at 100% load Engine Max Rating (Kw each) Annual kW-hr HC+NOx (g/kw- hr) HC+NOx (tpy) NOx only (tpy)(d) VOC only (tpy)(d) Trip from Gloucester Harbor to State Water boundary 8.0 16.0 3.4 64.0 215.6 2 1864 803678 7.2 6.4 6.2 0.2 In Federal Waters (State Water boundary to northern buoy) 1.5 3.0 0.6 64.0 40.4 2 1864 150690 7.2 1.2 1.2 0.0 Total 9.5 19.0 4.0 64.0 256.0 n/a n/a 954368 n/a 7.6 7.4 0.2 Notes: (d) Used method in previous support vessel spreadsheet to break out NOx from HC+NOx. Ratio = 0.9721706 (most of HC+NOx is NOx) Support Vessel Emission Calculation Worksheet (a) Values measured on Figure 5-1 "Proposed Neptune Project and Marine Sanctuaries" map from the Neptune Project Deepwater Port License Application, Environmental Notification Form, September, 2005. (b) Value for RT time in Federal Waters taken from the Neptune Project Deepwater Port License Application, Volume II, Environmental Evaluation, Section 9 – Air Quality (Addendum), April 21, 2006, and proportioned to State Waters based on distance. (c) Values assumed one RT per SRV delivery. 2 of 3 Emissions from Vessel Operation for Construction in State Waters, Construction Within 800 Meters of Both Buoys and SRV Transit Activity (without weather contingency) Total Days % State Days in State Waters Pipelay/Barge State Days Pipelay/Barge Fed Days AHTS1 State Days AHTS1 Fed Days AHTS 2 State Days AHTS 2 Fed Days DSV1 State Days DSV1 Fed Days Supply State Days Supply Fed Days Crew State Days Crew Fed Days Plow State Days Plow Fed Days Debris Survey 8 90% 7.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 7.2 0.8 0.0 0.0 Postlay Survey 8 80% 6.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 6.4 1.6 0.0 0.0 As Built Survey(2009 ops only)8 0% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 8.0 0.0 0.0 Install DMA/Lay Flowline 6 0% 0.0 0.0 6.0 0.0 6.0 0.0 6.0 0.0 0.0 0.0 6.0 0.0 6.0 0.0 0.0 Install DMA/Install pipeline 22 90% 19.8 19.8 2.2 19.8 2.2 19.8 2.2 0.0 0.0 19.8 2.2 19.8 2.2 0.0 0.0 Trench 15 80% 12.0 12.0 3.0 12.0 3.0 12.0 3.0 0.0 0.0 12.0 3.0 12.0 3.0 12.0 3.0 Backfill 15 80% 12.0 12.0 3.0 12.0 3.0 12.0 3.0 0.0 0.0 12.0 3.0 12.0 3.0 12.0 3.0 Install Manifolds/Spools (2009 ops only)15 33% 5.0 5.0 10.1 5.0 10.1 0.0 0.0 0.0 0.0 0.0 0.0 5.0 10.1 0.0 0.0 Perform Hydrotests (2009 ops only)8 50% 4.0 4.0 4.0 4.0 4.0 0.0 0.0 0.0 0.0 4.0 4.0 4.0 4.0 0.0 0.0 Install Anchor/Chains (2009 ops only)15 0% 0.0 0.0 15.0 0.0 15.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 15.0 0.0 0.0 Install Buoys (2009 ops only)8 0% 0.0 0.0 8.0 0.0 8.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 8.0 0.0 0.0 Install Risers (2009 ops only)8 0% 0.0 0.0 8.0 0.0 8.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 8.0 0.0 0.0 Perform Buoy System Test (2009 ops only)8 0% 0.0 0.0 8.0 0.0 8.0 0.0 0.0 0.0 8.0 0.0 0.0 0.0 0.0 0.0 0.0 Excavate Hot Tap 8 100% 8.0 0.0 0.0 0.0 0.0 0.0 0.0 8.0 0.0 8.0 0.0 0.0 0.0 0.0 0.0 Perform Hot Tap 15 100% 15.0 0.0 0.0 0.0 0.0 0.0 0.0 15.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Install Field Spool 8 100% 8.0 8.0 0.0 8.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Concrete Mats Hibernia Cable 8 100% 8.0 0.0 0.0 0.0 0.0 0.0 0.0 8.0 0.0 8.0 0.0 0.0 0.0 0.0 0.0 Post Installation Mats 22 100% 22.0 0.0 0.0 0.0 0.0 0.0 0.0 22.0 0.0 22.0 0.0 0.0 0.0 0.0 0.0 Total Days 2008 118.4 51.8 14.2 51.8 14.2 43.8 14.2 53.0 0.0 81.8 14.2 57.4 16.6 24.0 6.0 Total Days 2009 9.0 9.0 53.1 9.0 53.1 0.0 0.0 0.0 8.0 4.0 4.0 9.0 53.1 0.0 0.0 Total Days both years 127.4 60.8 67.3 60.8 67.3 43.8 14.2 53.0 8.0 85.8 18.2 66.4 69.7 24.0 6.0 Notes: (a) Blue highlighted activities indicate construction occuring only in 2009 NOx VOC Construction Vessel Total tons both years fed and state waters Total tons both years fed and state waters NOx VOC NOx VOC Pipelay/Derrick Barge (incl plow per Intec)47.00 9.00 22.55 4.32 2.66 0.51 AHTS1 61.00 11.00 24.69 4.45 4.27 0.77 AHTS2 30.00 6.00 22.66 4.53 0.00 0.00 DSV 12.00 2.00 10.43 1.74 0.00 0.00 Supply 31.00 6.00 24.38 4.72 1.19 0.23 Crew Survey 12.00 3.00 5.06 1.27 0.79 0.20 Total Construction 193.00 37.00 109.76 21.02 8.91 1.71 SRV Transit State Waters 0.45 0.31 0.00 0.00 0.04 0.03 These are per month emissions only in 2009. In summary sheet, this is *3 to account for 3 months of ops. Note: Data from "Attachment 92-A Emissions on Approach.xls" SRV On Buoy 49.00 38.30 0.00 0.00 4.08 3.19 These are per month emissions only in 2009. In summary sheet, this is *3 to account for 3 months of ops. Note: Data from Final Air Permit Support Vessel Operation 6.20 0.18 0.00 0.00 0.52 0.01 These are per month emissions only in 2009. In summary sheet, this is *3 to account for 3 months of ops. Note: Value from Support Vessel Calculation sheet Construction w/in 800 meters 40.70 7.00 13.43 2.31 27.27 4.69 radii of each buoy Deploy Acoustic buoys 1.40 0.30 0.70 0.15 0.70 0.15 in State waters and 800 meter radii of each buoy Onshore construction related 8.20 1.40 7.38 1.26 0.82 0.14 Total tpy State Waters only 2008 Total tpy State Waters only 2009 3 of 3 CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 APPENDIX B PROJECT FIGURE -6 0 -10 -25 -5 -5 -5 -5 -35 -70 -10 -60 -1 5 -20 -1 0 -80 -10 -5 -25 -30 - 4 5 -5 5 -40 -1 0 -20 -40 - 5 -5 -5 5 -10 -25 -10 -5 5 -30 - 2 5 -5 -25 -30 -6 0 -55 -80 -55 -45 -40 - 1 5 -70 - 1 0 -8 5 -50 -45- 5 0 - 1 5 - 7 5 -35 - 2 0 -60 -20 - 7 5 -6 5 -5 -10 - 5 5 -6 0 -25 - 4 5 - 2 5 -7 5 -40 -15 -5 -45 -20 -50 - 1 0 -50 -70 -2 5 -70 - 6 5 -10 -2 0 -5 - 7 5 -3 5 -40 -45 -3 5 -45 -1 5 -5 -65 -20 -20 -5 - 7 5 - 5 5 -2 0 -65 - 6 0 -2 5 -5 5 -30 -5 -6 0 -15 -60 -4 0 -20 -30 -65 -35 -30 -5 -5 -45 -60 -10 -25 -15 - 1 5 -80 -20 -10 - 3 0 -15 -3 0 -2 5 -7 5 -6 0 -15 -25 -10 -70 -45 -60 - 5 5 - 1 5 -6 5 -25 - 1 0 0 - 5 0 -25 -5 5 -7 0 -50 - 6 0 -75 -5 -30 -15 -60 - 2 5 - 5 5 -5 -25 - 5 -40 -5 -5 -90 -10 -35 -35 -5 - 9 5 - 3 5 - 4 5 - 1 0 -6 0 -40 -55 - 3 0 - 5 0 - 6 5 -5 -6 0 - 9 0 -45 - 1 0 -80 -20 -70 -50 -8 5 -2 0 -5 -15 -50 -45 - 5 -65 -4 5 -25 -1 0 - 3 0 -1 5 -5 -75 -35 GLOUCESTER ROCKPORT MANCHESTER BEVERLY SALEM MARBLEHEAD SWAMPSCOTT LYNN NAHANT MP 0 MP 1 MP 2 MP 3 MP 4 MP 5 MP 6MP 7 MP 8 MP 9 MP 10 MP 11 MP 12 MP 13MP 13.13 Legend Mileposts Anchor Final Position STL Buoy Algonquin Hubline LNG Pipeline Neptune LNG Pipeline Amitié Fiber Optic Cable GTT Cable (Hibernia) State Seaward Boundary (SSB) Bathymetry Town Boundaries Offshore p 0 50½ Miles CHS, Esri, Garmin, NaturalVue, Source: Airbus,USGS,NGA,NASA,CGIAR,NLS,OS,NMA,Geodatastyrelsen,GSA,GSI and the GIS User Community, MassGIS, Esri Canada, Esri, HERE, Garmin, INCREMENT P, USGS, METI/NASA, NGA, EPA, USDA along with The ERM Group Re v i s e d : 0 1 / 1 7 / 2 0 2 4 | S c a l e : 1 : 1 3 5 , 0 3 7 w h e n p r i n t e d a t 8 . 5 ' ' x 1 1 ' ' APRX Path | Layout Name: M:\US\Projects\D-F\Engie\Neptune Decommisioning - MA\MXD\Neptune DWP Decommissioning.aprx | Neptune_DWP_USGS_LocationMap1 CO O R D I N A T E S Y S T E M : W G S 1 9 8 4 W e b M e r c a t o r A u x i l i a r y S p h e r e Map Author: CLAIRE.DICKSON Bathymetry Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, OpenStreetMap contributors, and GIS User Community CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 APPENDIX C DECOMMISSIONING PLAN WITH APPENDICES (see standalone Appendix C files) CLIENT: Neptune LNG LLC PROJECT NO: 0667298 DATE : January 2024 VERSION: 1 APPENDIX D CIRCULATION LIST CIRCULATION LIST FOR NOTICE OF PROJECT CHANGE State Agencies MEPA Office 100 Cambridge Street, Suite 900 Boston, MA 02114 MEPA@mass.gov Tori.Kim@mass.gov Alexander.Strysky@mass.gov Executive Office of Energy and Environmental Affairs Office of Coastal Zone Management 100 Cambridge Street, Suite 900 Boston, MA 02114 todd.callaghan@mass.gov sean.duffey@mass.gov Massachusetts Historical Commission The MA Archives Building 220 Morrissey Boulevard Boston, MA 02125 (hard copy only) Massachusetts Board of Underwater Archaeological Resources 100 Cambridge Street, Suite 900 Boston, MA 02114 david.s.robinson@mass.gov Massachusetts Department of Environmental Protection – Division of Wetlands and Waterways 100 Cambridge Street, Suite 900 Boston, MA 02114 david.w.wong@mass.gov kenneth.alepidis@mass.gov Massachusetts Department of Environmental Protection - Waterways Regulation Program 100 Cambridge Street, Suite 900 Boston, MA 02114 christine.hopps@mass.gov Daniel.padien@mass.gov Ivan.morales@mass.gov Division of Marine Fisheries 30 Emerson Avenue Gloucester, MA 01930 kate.frew@mass.gov mark.rousseau@mass.gov DMF.ENVReview-north@mass.gov Division of Marine Fisheries 836 South Rodney French Boulevard New Bedford, MA 02740 erin.burke@mass.gov Massachusetts Executive Office of Energy and Environmental Affairs Attn: EEA EJ Director 100 Cambridge Street, Suite 900 Boston, MA 02114 MEPA-EJ@mass.gov Massachusetts Department of Energy and Resources Attn: MEPA Coordinator 100 Cambridge Street, Suite 900 Boston, MA 02114 paul.ormond@mass.gov Massachusetts Water Resources Authority Attn: MEPA Coordinator 100 First Avenue Charlestown Navy Yard Boston, MA 02129 Hillary.Monahan@mwra.com Department of Public Utilities 1 South Station, 3rd floor Boston, MA 02110 richard.enright@mass.gov State Agencies Massachusetts Department of Environmental Protection, Northeast Regional Office Attn: MEPA Coordinator 150 Presidential Way Woburn, MA 01801 john.d.viola@mass.gov Massachusetts Department of Environmental Protection, Boston Office Commissioner’s Office 1 Winter Street Boston, MA 02108 helena.boccadoro@mass.gov Federal Agencies National Oceanic and Atmospheric Administration National Ocean Service Office of National Marine Sanctuaries Stellwagen Bank National Marine Sanctuary 175 Edward Foster Road Scituate, MA 02066 alice.stratton@noaa.gov pete.decola@noaa.gov ben.haskell@noaa.gov National Oceanic and Atmospheric Administration Greater Atlantic Regional Fisheries Office Protected Resource Division 55 Great Republic Drive Gloucester, MA 01930 christopher.boelke@noaa.gov samantha.tolken@noaa.gov kaitlyn.shaw@noaa.gov brian.d.hopper@noaa.gov U.S. Environmental Protection Agency Region 1 5 Post Office Square, Suite 100 Boston, MA 02109 Bird.Patrick@epa.gov colarusso.phil@epa.gov U.S. Army Corps of Engineers, New England District Office 696 Virginia Road Concord, MA 07142 Ruthann.A.Brien@usace.army.mil Bureau of Safety and Environmental Enforcement 1201 Elmwood Park Blvd New Orleans, LA 70123 Angie.Gobert@bsee.gov U.S. Department of Transportation Maritime Administration 1200 New Jersey Avenue, SE Washington, DC 20590 brian.barton@dot.gov Bureau of Ocean Energy Management 1201 Elmwood Park Blvd New Orleans, LA 70123 quazi.islam@boem.gov U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 mark.sacchetti@dot.gov United States Coast Guard Office of Operating & Environmental Standards 2703 Martin Luther King Jr. Ave. SE STOP 7509 Washington, D.C. 20593-7509 Brent.C.Yezefski@uscg.mil Local/Other Organizations Beverly Conservation Commission City Hall Department of Planning & Development 191 Cabot Street, 3rd Floor Beverly, MA 01915 conservation@beverlyma.gov Beverly Board of Selectmen City Hall Department of Planning & Development 191 Cabot Street Beverly, MA 01915 Michael P. Cahill, Mayor mayorcahill@beverlyma.gov Beverly Planning Board City Hall 191 Cabot Street Beverly, MA 01915 Darlene Wynne, Director of Planning & Development dwynne@beverlyma.gov Beverly Department/Board of Health City Hall 191 Cabot Street Beverly, MA 01915 Laura Dellechiaie, Director of Health ldellechiaie@beverlyma.gov Manchester-by-the-Sea Conservation Commission 10 Central Street Manchester-by-the-Sea, MA 01944 farrk@manchester.ma.us Manchester-by-the-Sea Board of Selectmen 10 Central Street Manchester-by-the-Sea, MA 01944 Gregory Federspiel, Town Administrator federspielg@manchester.ma.us Manchester-by-the-Sea Planning Board/Department 10 Central Street Manchester-by-the-Sea, MA 01944 Gail Hunter, Administrative Assistant hunterg@manchester.ma.us Manchester-by-the-Sea Department/Board of Health 10 Central Street Manchester-by-the-Sea, MA 01944 Ellen Lufkin, Administrative Assistant lufkine@manchester.ma.us Marblehead Conservation Commission Mary Alley Municipal Building 7 Widger Road Marblehead, MA 01945 quigleyc@marblehead.org conservation@marblehead.org Marblehead Board of Selectmen Abbot Hall 188 Washington Street, Marblehead, MA 01945 Kyle Wiley, Administrative Aide wileyk@marblehead.org Marblehead Planning Board/Department Abbot Hall 188 Washington Street, Marblehead, MA 01945 Rebecca Curran Cutting, Town Planner rebeccac@marblehead.org Marblehead Department/Board of Health Mary Alley Municipal Building Health Department 7 Widger Road Marblehead, MA 01945 pettya@marblehead.org Salem Conservation Commission Salem City Hall 98 Washington Street, 2nd Floor Salem, MA 01970 kkennedy@salem.com Salem Board of Selectmen Salem City Hall 93 Washington Street, Salem, MA 01970 citycouncilors@salem.com thapworth@salem.com Entities that Commented on Previous MEPA Reviews Massachusetts Lobstermen’s Association, Inc. 8 Otis Place Scituate, MA 02066 beth.casoni@lobstermen.com City of Gloucester Attn: Office of the Mayor 9 Dale Ave, Gloucester, MA 01930 mayor@gloucester-ma.gov Safe Waters in Massachusetts Nahant SWIM, Inc. PO Box 57, Nahant, MA 01908 nahantswiminc@gmail.com Massachusetts Marine Trades Association MMTA PO Box 325 Foxboro, MA 02035 Info@boatma.com Conservation Law Foundation 62 Summer St Boston, MA 02110 e-info@clf.org City of Boston Environment Department (formerly the Office of Environmental and Energy Services) 1 City Hall Square Room 709 Boston, MA 02201-2031 environment@boston.gov The Whale Center of New England 24 Harbor Loop, Gloucester, MA 01930 (No longer in existence) New England Energy Alliance (No contact information available) Local/Other Organizations Salem Planning Board/Department Salem City Hall 98 Washington Street, 2nd Floor Salem, MA 01970 Patricia Morsillo pmorsillo@salem.com Salem Department/Board of Health Salem City Hall 98 Washington Street, 3rd Floor Salem, MA 01970 health@salem.com Metropolitan Area Planning Council 60 Temple Place, 6th Floor Boston, MA 02111 mpillsbury@mapc.org afelix@mapc.org