PUBLIC SAFETY ASSESSMENT1.0IntroductionPBS&J has been contracted by Clatsop County, Oregon, to conduct a public safety assessment for the proposed Bradwood Landing LLC/NorthernStar Natural Gas LNG project. The major component of the public safety assessment was to analyze and evaluate the Water Safety Report (WSR) (See Appendix A)and the draft Emergency Response Plan (ERP). The WSR deals with matters related to the transport ofLNG on the Columbia River. --------------------------------------------------------------------------------
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PUBLIC SAFETY ASSESSMENT2.2National Incident Management System Compliance The procedures documented in NIMS must be incorporated into all Emergency Operations Plans(EOPs). NIMS was created so first responders from various jurisdictions and disciplines can work together in a variety of emergency response scenarios. NIMS concepts and procedures establish a unified approach to incident management; standard command and management structures; andemphasize preparedness, mutual aid, and resource management. To establish compliance withNIMS procedures, all levels of government, private sector organizations, and nongovernmentalagencies must be prepared to prevent, protect against, respond to, and recover from a wide spectrum of major events that exceed the capabilities of any single entity. These hazard responses require a unified and coordinated national approach to planning and domestic incident management. To address this need, Homeland Security Presidential Directive 5: Management of DomesticIncidents (HSPD-5) and Homeland Security Presidential Directive 8: National Preparedness (HSPD-8) establish the following national initiatives that serve to establish a common approachto preparedness and response. a) HSPD-5 identifies steps for improved coordination in response to incidents. It requires the Department of Homeland Security (DHS) to coordinate with other Federal departments and agencies and State, local, and tribal governments to establish a National Response Plan (NRP) and a National Incident Management System. b) HSPD-8 describes the way Federal departments and agencies will prepare forincidents. It requires DHS to coordinate with other Federal departments and agencies and State, local, and tribal governments to develop a National Preparedness Goal. 3.0Methodology After completing scope items 1–2, the draft Emergency Response Plan for the Bradwood LandingLLC/NorthernStar Natural Gas LNG Facility (February 2007), was reviewed to identify “gaps” betweenthe requirements for a FERC- and NIMS-compliant ERP and the draft ERP. This effort is referred to as a “gap analysis.” Specifically, PBS&J staff with expertise in emergency management, emergency response,emergency planning, disaster recovery, public safety, hazardous materials, navigation, security, and geological hazards conducted the gap analysis. PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT2
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PUBLIC SAFETY ASSESSMENTThe following tasks were conducted: 1. Met with Clatsop County Manager Scott Derickson to review the terms and objectives of this project. 2. Developed an understanding of and fluency with relevant regulatory and agency guidance andadopted standards, including (but not limited to): Title 33 CFR 127, Title 49 CFR 193, NVIC 05-05, NVIC 09-02, NVIC 11-02, and National Fire Protection Association Standard 59a, FERC Draft Guidance for Emergency Response Plans (Revision 4, September 2006) and the ClatsopCounty Emergency Management Plan. 3. Analyzed and evaluated the FERC project description and WSA/WSR and the draft ERP. 4. Visited the proposed LNG site and populated areas along the Columbia River navigation channel between the Columbia River Bar and the site, and interviewed key Clatsop County staff (including first responders), as well as Bradwood Landing, LLC staff, and consultants to answer questions about the scope of the project. 5. Evaluated and confirmed that existing assets and personnel related to or having responsibility forthe LNG project security, safety, and navigation (plus the incremental assets mandated by WSR)are or are not sufficient to provide adequate mitigation and response capabilities related to the risk probability introduced by the LNG operation. 6. Determined whether additional safety and security resources or measures would be required inaddition to those defined by the Coast Guard in the WSR, identified these resources and measures, and provided rationale for such additional requirements. 7. Provided a written report to Clatsop County regarding the above issues (by July 31, 2007), and agreed to participate in a follow-up conference to discuss the results of the report. A gap analysis of the draft ERP has been conducted to determine whether the draft ERP met FERC requirements and was NIMS-compliant. Additionally, the analysis was performed to determine whetherthe draft ERP is operationally feasible based upon response guidance, response plans, and response principles developed by the National Fire Protection Association(NFPA), Environmental Protection PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT3
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PUBLIC SAFETY ASSESSMENTAgency, (EPA), etc., as well as professional emergency management judgment and experience. The PBS&J emergency management planners have more than 73 combined years of experience in emergencyplanning, preparedness, response, and recovery. Gaps were expected, because the ERP is a draft. The gap analysis was consolidated and discussed with the Clatsop County Community Development Director, County Manager, county first responders and Bradwood Landing LLC/NorthernStar Natural Gas staff. PBS&J personnel met with local, county, State, and Bradwood Landing LLC/NorthernStar Natural Gas staff on July 9 and July 11, 2007, in Clatsop County (See Appendix B: Gap Analysis Discussion Meeting Attendees). In addition, data collection for the draft ERP review was received during several meetings (See Appendix C: ERP Data Collection Meeting Attendees). Several meetings took place during the review process. A site visit to the proposed Terminal was hosted by Bradwood Landing LLC and included a question-and-answer session. Clatsop County hosted a group meeting with a cross section of local emergency response stakeholders, emergency medical services, the Oregon Department of Energy, and the WahkiakumCounty Sheriff’s office. Following the group meeting, PBS&J conducted additional individual meetings with local emergency response stakeholders, emergency medical services, and the Wahkiakum County Sheriff’s office. Lastly, PBS&J attended a County Emergency Managers meeting held in Seaside, Oregon, and conducted a group interview session. 4.0Gap Analysis The findings of the gap analysis are presented from two perspectives—a county perspective and an ERP-execution perspective, as follows: 4.1Gaps in the Draft ERP that Impact the Local Counties a) Not all county and local agencies that might provide support or respond to an event onsite are listed on the draft ERP Distribution List. As a significant component of the LNG certification process, an ERP is under Sensitive Security Information (SSI)rules until the ERP is published. The following organizations are not included in thedraft Distribution List: 1. Columbia Memorial Hospital (Astoria, Ore.) PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT4
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PUBLIC SAFETY ASSESSMENT2. Seaside Providence Hospital (Seaside, Ore.) 3. St. John Medical Center (Longview, Wash.) 4. Medix Ambulance Service (Astoria, Ore.) 5. Clakestine Rural Fire Department (Clakestine, Ore.) b) Wahkiakum, Columbia, Pacific, and Cowlitz Counties are directly downwind (east ofthe Terminal). According to the Oregon Climate Service, the downwind determination is based on the westerly prevailing wind patterns throughout the year. The downwind counties could be within the potential plume, should a release occur.(A plume is a visible or measurable discharge of a contaminant from a given point oforigin. A plume is visible in the air, such as a plume of smoke.) The area downwind is that area that could be dangerous for those exposed to leaking fumes. However,Wahkiakum, Columbia, Pacific, and Cowlitz Counties are not listed in the draft ERP. c) Currently, the draft ERP has no interoperable communications plan and the draft ERP does not provide for redundant communications to report an onsite incident, emergency, or disaster. The only method of communicating an emergency is via the landline, by calling 911. There is currently no cell phone coverage available at the proposed LNG Terminal site. d) The draft ERP does not provide for alternate methods of evacuation for employees, and visitors. Currently, the draft ERP utilizes vehicles to evacuate personnel heading north on Clifton Road, before proceeding east or west on Highway 30. Tugboatscould be used, but only when they are available. e) The draft ERP does not clearly specify what sequence of siren blasts identifies apossible danger, as opposed to an actual incident, emergency, or disaster. f) The draft ERP does not provide a means of onsite sheltering in place for employeesand visitors who are not able to evacuate if an emergency develops at the Terminal. PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT5
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PUBLIC SAFETY ASSESSMENTg) The Emergency training, drills, and exercises contained in Annex F of the draft ERP does not include joint training with local responders. h) The planned exercises are not planned for multi-agency response in concert with Bradwood Landing LLC/NorthernStar Natural Gas. Currently, the planned exercises are only for Bradwood Landing LLC/NorthernStar Natural Gas personnel. 4.2Gaps in the Draft ERP that Impact the Execution of the Plan a) The draft ERP is in the National Response Plan (NRP). This format is widely used atthe Federal level to respond to disasters involving the Department of Homeland Security (DHS) or Federal Emergency Management Agency (FEMA), and is not used the local county level. Local first responders are used following the Clatsop County Comprehensive Emergency Management Plan (CEMP) format. The current version of the ERP is difficult to read and understand. b) The three zones of potential hazard do not coincide with the USDOT Emergency Response Guidebook (Guide 115). c) The exposure amounts of LNG (as shown in Section 4.7.4 of the draft ERP) are different from those used by first responders. The draft ERP does not explain themethodology used to calculate the exposure limits (e.g., Agency for Toxic Substances and Disease Registry (ATSDR) toxicological profile; risk analysis; Occupational Safety and Health Administration (OSHA) Permissible Exposure Limits (PELs); National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limits (NIOSH RELs); NIOSH Immediate Dangerous to Life and Health values (NIOSH IDLHs); and American Conference of Governmental Industrial Hygienists (ACGIH®) Threshold Limit Values (TLVs®)). d) There should be one Incident Command System (ICS) organizational chart in the ERP, as opposed to multiple organization charts. e) The draft ERP should contain ICS terms, but not terms specific to Bradwood Landing LLC/NorthernStar Natural Gas. PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT6
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PUBLIC SAFETY ASSESSMENTf) The annexes should provide more detail or specificity for particular sections notfound in the draft ERP. The annexes should not be the basis for the ERP. g) The ERP should demonstrate a clear understanding of the emergency response cycle. As an ERP, it should cover preparedness as it relates to the response portion of the plan, but not necessarily discuss recovery and mitigation efforts. h) All emergency responses should tie back to the basic response conditions: incident, emergency, and disaster (per Section 4.7.3 of the draft ERP). i) Triggers need to be developed that clearly delineate what will cause the ERP to be activated. j) The draft ERP is not NIMS-compliant. k) The draft ERP does not mention having an Emergency Medical Technician (EMT) with an ambulance onsite. l) The draft ERP does not mention having a Trauma Tent/Building onsite. m) The draft ERP does not mention having fire suppression equipment onsite. n) The draft ERP does not mention having a helispot (helipad) identified for life-flight operations. o) The ERP does not define roles, responsibilities, and jurisdictions for fire responsethroughout the entire vessel berthing and LNG off-loading process at the Terminal. 5.0Preliminary Recommendations In reviewing the ERP, PBS&J determined that the Bradwood Landing LLC/NorthernStar Natural Gas draft ERP fulfills some of the requirements from the FERC ERP guidance. However, the current draftERP would be difficult to read or execute because it is confusing and not concise. Information in the draft ERP is redundant (i.e., located in multiple sections and annexes). Information about the three non-PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT7
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PUBLIC SAFETY ASSESSMENTresponse phases of emergency management (i.e., preparedness, mitigation, and recovery) are included in the draft ERP, but this extra information makes it difficult to find the response procedures quickly. The following preliminary recommendations by PBS&J are provided to improve emergency response operations: 5.1Recommendations to Improve ERP Execution a) The ERP should be written in a format that is used and understood by local first responders. The plan should be consistent and follow a logical response format. PBS&J recommends that the ERP be reformatted to place all like information into one section. The following is a recommended ERP format: 1. The table of contents should be located at the beginning of the ERP. Currently, it is located on page 28 (xxviii). 2. Chapter 1 should outline the purpose, scope, authorities, and references for the implementation, development methodology, and planning assumptions of the ERP. 3. Chapter 2 should identify the hazards (i.e., triggers) that may require ERP implementation, site description, organization, and critical emergencypreparedness and response procedures. 4. Chapter 3 should discuss the concept of operations for an ERP event, preparedness actions, general responsibilities, and evacuation measures. 5. Chapter 4 should explain (in detail) the communication plan, notificationprocedures, and interoperable communications. 6. Chapter 5 should cover the ERP training and exercise plan, which includes drills, functional exercises, tabletop exercises, and full-scale exercises. 7. Chapter 6 should provide ERP maintenance procedures. PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT8
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PUBLIC SAFETY ASSESSMENTb) Make the ERP NIMS-compliant by following the proposed chapter outline andcontent discussed above. c) The ERP should have one standard organization chart that is NIMS- and ICS-compliant for use throughout the plan. The organization chart should have titles, names and phone numbers, and be updated as those names and contact data change. d) The Concept of Operations section should have a Notification flowchart. e) Standard NIMS and ICS terms should be incorporated into the plan. f) Ideally, the ERP should be 40 to 50 pages long, and should not exceed 100 pages.This proposed length will enhance the ability of Terminal staff and emergencyresponders to quickly and easily find information and implement the plan during anemergency. g) The ERP should reference or explain in greater detail how hazard zones weredeveloped and provide a crosswalk that explains the differences from USDOTEmergency Response Guidebook (Guide 115). h) The ERP should explain in detail the derivation of the different exposure limits (i.e., Agency for Toxic Substances and Disease Registry (ATSDR) toxicological profile; risk analysis; Occupational Safety and Health Administration (OSHA) Permissible Exposure Limits (PELs); National Institute for Occupational Safety and Health(NIOSH) Recommended Exposure Limits (NIOSH RELs); NIOSH Immediate Dangerous to Life and Health values (NIOSH IDLHs); and American Conference ofGovernmental Industrial Hygienists (ACGIH®) Threshold Limit Values (TLVs®),etc.) and how they are used to determine the different zones. i) Re-evaluate the need for all of the annexes. If annexes are needed, then they should provide additional information not found in the base ERP. Annexes should be nomore than 1 to 2 pages long and describe in detail the concept of operations for thatannex. Annexes should have checklists. The ERP includes the base plan, annexes, PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT9
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PUBLIC SAFETY ASSESSMENTand appendices. If annexes are needed, they should provide additional informationthat is not included in the body of the document. j) Bradwood Landing LLC/NorthernStar Natural Gas must: (1) identify all categories of events reasonably likely to occur; (2) classify each potential event as “incident,” “emergency,” or “disaster;” (3) describe what measures will be taken by Bradwood Landing to deal with them; and (4) describe what actions would be required of other emergency services. k) The ERP should discuss the triggers identified in the Clatsop County CEMP and identify other site-specific triggers. l) The ERP should plan for the worst events, even if the probability of their occurrence seems low. Clatsop County residents need to be assured that appropriate measurescan and will be taken to deal with catastrophic events (such as a major explosion) ifthere is credible evidence that such an event could occur. m) The signature page of the ERP should include the Clatsop County Administrator,Clatsop County Emergency Manager, Clatsop County Sheriff, Astoria Police Chief, Astoria Fire Chief, Knappa Fire Chief, County EMS, and all others who will support the ERP. n) Wahkiakum, Columbia, Pacific, and Cowlitz Counties need to be added to the ERP in all places where Clatsop County is listed. o) The ERP should list alternative communication procedures, (e.g, satellite phones,800-MHz or VHF radios with repeaters) that can reach first responders. p) The ERP should have an alternate evacuation plan for employees and visitors. Thealternate evacuation method should consider evacuation of people upwind, via the Columbia River. q) The ERP should have a system of siren blasts with voice announcements that clearlylet anyone onsite know whether there is a potential problem or an actual emergency.PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT10
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PUBLIC SAFETY ASSESSMENTIf there is an actual emergency, the warning system should indicate whether an employee or visitor should evacuate or shelter in-place. Bradwood Landing LLC/NorthernStar should contact chemical plants and other industrial plants that may have the same type of hazards, in order to review their warning systems.. r) The functional (or full-scale) exercises should be evaluated by a third party observer that is not Clatsop County, Bradwood Landing LLC/NorthernStar Natural Gas, or the developer of the ERP. The third-party observer will ensure the exercises meet the stated objectives, and will develop corrective actions if it is found that the objectives have not been met. The corrective actions developed by the third-party observer should detail outstanding issues, deficiencies and/or gaps, then conduct briefings about these for local officials from the affected counties and Bradwood Landing LLC/NorthernStar Natural Gas personnel. s) A third party should conduct a review of the ERP annually to ensure all corrective actions have been captured in the ERP. 5.2Recommendations for Bradwood Landing LLC/NorthernStar Natural Gas to Provide Financial and Equipment Support for Clatsop, Wahkiakum, Columbia,Pacific, and Cowlitz Counties (Cost Share: Bradwood 100 percent and Counties 0percent) a) Due to the long response times for first responders, Bradwood LandingLLC/NorthernStar Natural Gas should hire a full time EMT with an ambulance and have it stationed onsite. This will be accomplished by having a full-time staff member that is cross-trained and certified as an EMT. Bradwood should also have a medical/trauma clinic onsite with a registered nurse (RN) or physician’s assistant(PA) to treat minor injuries and care for an injured employee until they can be safely transported to appropriate medical facilities. The EMT and RN or PA must meet allcertification and licensing requirements of the State of Oregon. b) Bradwood Landing LLC/NorthernStar Natural Gas should construct two helispot(helipad) (one at the terminal and one at the intersection of Highway 30 and Clifton PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT11
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PUBLIC SAFETY ASSESSMENTRoad) to accommodate life-flight helicopters for transport of seriously injured peopleto trauma centers. c) Bradwood Landing LLC/NorthernStar Natural Gas should have two to four trained firefighters onsite to operate fire equipment (brush truck and a dry chemical trailer) and respond to fires or other emergencies (e.g., confined space, HazMat, etc.). This will be accomplished by having full-time staff members that are cross-trained and certified as firefighters. The firefighters must meet all meet all certification and licensing requirements of the NFPA and the State of Oregon. d) The Bradwood Landing LLC/NorthernStar Natural Gas should install a Reverse 911 system in Clatsop, Wahkiakum, Columbia, Pacific, and Cowlitz Counties to communicate an emergency onsite. Bradwood Landing LLC/NorthernStar Natural Gas should be a designated user of the Reverse 911 system. In addition, Clatsop, Wahkiakum, Columbia, Pacific, and Cowlitz Counties should work with Bradwood Landing LLC/NorthernStar Natural Gas to develop a site-specific call-down list for site emergencies. e) Bradwood Landing LLC/NorthernStar Natural Gas should purchase and maintain a mobile command center that includes the following components and requirements: 1. Satellite phones; 2. Eight to ten 800-MHz multi-channel radios or VHF radios for first responders to use onsite during an event;3. A base station (VHF or 800-MHz radios) with repeaters to communicate withthe handheld radios referenced in Point 2 (above); and,4. The mobile command vehicle should be stationed onsite, remainoperationally ready, and should be used to run the incident. f) Bradwood Landing LLC/NorthernStar Natural Gas should purchase an all-weather boat capable of holding 7 to 14 people. This boat is in addition to the three tugs PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT12
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PUBLIC SAFETY ASSESSMENTrequired for operations. The boat should be permanently stored onsite. The tugs are only onsite when they are bringing an LNG vessel to the Terminal.g) Bradwood Landing LLC/NorthernStar Natural Gas should construct a reverse-pressurized, self-contained (separate power, communication lines and Heating Ventilation and Cooling (HVAC)) facility that is upwind of the prevailing winds. The facility should be used to allow employees or visitors to shelter in-place if a gas release occurs onsite. h) Bradwood Landing LLC/NorthernStar Natural Gas should provide joint emergencytraining for local first responders and Bradwood Landing, LLC staff on ERP implementation, LNG hazards and protocols. Bradwood Landing LLC/NorthernStar Natural Gas should also provide funding to pay for first responders’ time during the training session. Clatsop, Wahkiakum, Columbia, Pacific, and Cowlitz Counties and the surrounding fire districts have limited budgets to meet the current required training. As such, they will not have sufficient funds to pay for any additional training that is required by the Terminal. i) Bradwood Landing LLC/NorthernStar Natural Gas should develop multi-agencytabletop exercise(s) to flush out issues that could occur when responding to anincident, emergency, or disaster onsite. Bradwood Landing LLC/NorthernStar Natural Gas should provide funding to pay for first responders’ time during the tabletop exercise. j) Bradwood Landing LLC/NorthernStar Natural Gas should develop and conduct anannual functional exercise with all of the first responders. The objective of the exercise would be to test and validate all of the response procedures for an emergency onsite and to provide continuity for changes in staff and the communication of new standards, technology, and procedures. Bradwood Landing LLC/NorthernStar Natural Gas should provide funding to pay for first responders’ time during the functional exercise. PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT13
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PUBLIC SAFETY ASSESSMENTk) The resource list previously provided by Clatsop County emergency responders (titled, “Discussion of Resources of Existing LNG Receiving Facilities as Relates to Clatsop County Joint Report of November 2006”) should be cross-referenced with PBS&J’s recommendations in this report to avoid duplication of services and equipment. PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT14
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PUBLIC SAFETY ASSESSMENTAppendix A – Water Safety Report On February 28, 2007, the USCG completed a review of the WSA for Bradwood Landing LNG Terminal project submitted by NorthernStar Natural Gas, LLC, in May of 2006. The following items are a list of specific mitigation measures that must be put into place to responsibly manage the safety and security risks of this project. Navigational Measures: Safety/Security Zone • A moving safety/security zone of 500 yards around the vessel, but ending at the shoreline. No vessel may enter the zone without USCG permission. • Escort resources will be used to contact and control vessel movements in order that the LNG Carrier is protected. • A moored LNG vessel at the facility shall have a 200-yard security zone around the vessel. • A 50-yard security zone around the LNG facility shall be observed when there is not a vessel at the dock. Escort resources (three 60-ton pull tugs) are addressed on page 10 of the ERP. The ERP does not specifically address the security and safety zones. The Declaration of Security is mentioned on page 6E. A moored vessel will be located approximately 350 yards from the west of the Columbia River Channel. I see no issues for the County. Bradwood Landing would provide and operate the tug boats. Vessel Traffic Management • A Transit Management Plan will be developed in coordination with the River Pilots, Bar Pilots, Escort Tug Operators, Security Assets and the USCG, prior to the first transit. • A Vessel Transit Management Plan must be approved by the COTP at least 30 days prior to the first arrival. The issue is not addressed in the ERP. The County would likely need to attend the meetings. Vessel Traffic Information System/Vessel Traffic System • The current Vessel Traffic Information System on the Columbia River is limited to AIS receivers and a handful of cameras. In order to ensure vessel safety and security, this capability will need to be augmented with a robust camera system capable of monitoring the entire transit route. Due to weather concerns, these cameras must be equipped with PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT15
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PUBLIC SAFETY ASSESSMENTdetectors capable of monitoring vessel traffic in wind, rain, and fog conditions common on the river. In addition, this capability may need to be augmented in the future with additional command and control capability and the establishment of a full Columbia River VTS. This issue is not addressed in the ERP. The issue of who would pay for and operate it has not been addressed. This could be an issue for the County or the State. Tug Escorts and Docking Assist • Each LNG Carrier must be escorted by two tugs; at least one of which must be a tractor tug, which join the vessel as soon as it is safe to do so. The primary tug will be tethered at the direction of the pilot. A third tug will be required to assist with turning and mooring. • All three tugs will be at least 60-ton Astern Bollard Pull or larger and equipped with Class 1 firefighting equipment. Vessels will be limited to transiting during periods of 25 knots of wind or less. Extreme wind or weather conditions may require a third tug to escort the LNG vessel. While unloading, all three tugs will remain on standby to assist with emergency departure procedures. Annex E – Emergency LNG Carrier Departure and Unexpected Disconnects does mention the use of Tug Boats and pilots in an emergency (page 7E). The Annex, however, does not specifically state that all three tugs will remain on standby to assist with emergency departures. The ERP does not address vessels being limited to transiting during periods of 25 knots of wind or less or that a third tug would have to be used during extreme wind or weather conditions. The ERP does address having three 60-ton tugs available for escorting operations. I do not see these issues affecting the County. Navigational Aids LNG Carrier Familiarization Training for Pilots and Tug Operators Dynamic Under-keel Clearance System • An immersion study of deep draft LNG vessels transiting the bar during summer and winter conditions is required within the first 12 months. Not sure who would be responsible for these items. They are not addressed in the ERP. Safety Measures Vessel and Facility Inspections • LNG tankers and facility subject to annual inspection by the USCG. PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT16
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PUBLIC SAFETY ASSESSMENT• LNG vessels and facilities are typically required to undergo a pre-arrival inspection, and transfer monitoring. The USCG states that they would need an additional USCG Facility and Vessel Inspectors. I believe the USCG request for an additional facility asks a bit much. Under MTSA, regulated facilities and vessels undergo annual compliance audits. I am not sure why the USCG would need to inspect every LNG vessel and LNG facility before each arrival. I can see doing so on the first few deliveries. I can’t see the USCG conducting such inspections (123 LNG vessels and the same facility 123 times per year). The USCG used the phrase “typically required to conduct pre-arrival inspections.” I am not sure what the USCG means by “typically.”Shore-side Fire Fighting • Firefighting capability is extremely limited along the entire transit route. Shore-side firefighting resources and training need to be augmented in order to provide basic protection services to the facility, as well as the communities along the transit route. The ERP discusses onsite firefighting equipment and detectors 6H, 6I, 6J, 6K, 6L, 6M, 6N, 6O, 6P. Facility and Offsite Fire Plan is shown on page 4. The tug boats will also have firefighting capability. The ERP does not discuss firefighting for other communities. The County could be impacted by sharing costs associated with developing adequate emergency response capability. Prior to the approval of the Emergency Response Plan, adequate cost-sharing arrangements for project-related training, equipment, maintenance, and staffing will need to be addressed for all of the communities impacted by the project. In-transit Firefighting • Significant resource and jurisdictional issues exist in any marine fire incident on an underway vessel in the Columbia River. Current planning and preparedness efforts focus on a shore-based response to a vessel moored at the facility. The USCG will require a concrete plan for managing underway firefighting, including provisionsfor command and control of tactical firefighting decisions, as well as financial arrangements for provisions of mutual aid and the identification of suitable locations for conducting firefighting operations that are critical to ensuring the safety of the port and securing the waterway. These costs could greatly impact the County. The assets and resources to meet the issues described above are currently not available. The ERP primary discusses onsite fires and offsite fires (outside the fence) in the Facility and Offsite Fire Plan Section. In-transit firefighting is not addressed. PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT17
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PUBLIC SAFETY ASSESSMENTPublic Notification System and Procedures • Adequate means to notify the public along the transit route (including ongoing public education campaigns, emergency notification systems, and adequate drills and training) are required. Education programs must be tailored to meet the various needs of all river users, including commercial and recreational boaters, local businesses, local residents, and tourists. Annex A – Warning and Notifications (page 5A) seem to focus on facility-based emergencies. It does not appear to consider in-transit emergencies. The ERP does not address tailored educational programs to meet the various needs of all river users, including commercial and recreational boaters, local businesses, local residents, and tourists. Current public notification capabilities vary greatly, and as part of the ERP process, a comprehensive notification system (including the deployment of associated equipment and training) will need to be developed. Bradwood Landing, in its Warning and Notifications Annex, depends heavily on the Reverse 911 systems. The local counties may have to come up with the resources to update their 911 systems. Gas-detection Capability • Emergency response personnel (both police and fire) require appropriate gas-detection equipment, maintenance, and training. This issue is not addressed in the ERP. The County could be stuck with the cost. Communication System and Protocols • Inter-agency communication poses a significant obstacle to joint operations. Deployment of a Regional Communication Plan and associated equipment is required to ensure that the facility, associated command centers, emergency responders, USCG, tug operators, escort vessels, and pilots communicate in an effective manner. The system must provide for monitoring and communicating on both secure and unsecure channels, as well as sending and receiving both speech and data. Interoperability of communication systems does not currently exist in the area. There are significant costs involved in building the system that USCG describes. The ERP’s Annex B – Communications does not address the USCG concerns regarding inter-agency communications. Significant cost to the community to up-build an inter-agency communication system. PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT18
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PUBLIC SAFETY ASSESSMENTSecurity Measures Security Boardings, Waterway Monitoring, Shoreline Patrols, and Vessel Escorts • Extensive security measures will be required to provide adequate protection for LNG vessel while transiting the Columbia River and being moored at the facility. This information is SSI. The local counties could have significant short- and long-term law enforcement and security costs associated with this project. Additional Measures While a Cruise Ship is in Port • While cruise ships are moored or anchored at the Port of Astoria, cruse ships will also be required to have separate waterside security, during the LNG Transit. The USCG and local law enforcement would have to be sufficient to provide adequate and independent security for both vessels. These services would add significant costs to the County. This is not addressed in the ERP. According to the USCG, in the absence of the measures described by the USCG, the Columbia River would be considered unsuitable for the LNG marine traffic associated with the Bradwood LNG terminal. PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT19
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PUBLIC SAFETY ASSESSMENTAppendix B – Gap Analysis Discussion Meeting Attendees Name AgencyPaul Olheiser Knappa Fire District Lenard Hansen Astoria Fire Department Ed Wegner Clatsop County, Public Works and Community Development Scott DericksonClatsop County, Manager Deanna HenryOregon Dept of EnergyMitch Rohse Land Use Consultant Kurt AmundsonPBS&J Garry Coppedge Bradwood Landing, LLC David Glessner Bradwood Landing, LLC Michelle Rudd Bradwood Landing, LLC Michael Sparks Bradwood Landing, LLC PROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT20
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PUBLIC SAFETY ASSESSMENTAppendix C – ERP Data Collection Meeting Attendees Name AgencyDeanna HenryOregon Department of EnergyChristine LolichColumbia Memorial Hospital Rich MaysCity of Cannon Beach Gene Halliburton City of Cannon Beach Duane MullinsMedix Ambulance Paul Olheiser Knappa Fire District Mike Jackson Astoria Fire Department Lenard Hansen Astoria Fire Department Dan BardsleyWahkiakum County Sheriff’s Office Duane Stanton Oregon State Police Richard Long Clatskanie Rural Fire District Ted Ames Warrenton Fire Department Rob Deu Pree Astoria Police Department Paul Benoit City of Astoria, City Manager Gene Strong Clatsop County, Emergency MgrEd Wegner Clatsop County, Public Works/CDScott DericksonClatsop County, Manager Mitch Rohse Land Use Consultant Kurt AmundsonPBS&J Neil Daniell PBS&J Saundra Hinsley PBS&J Kari Sutton PBS&J Ed Hauer Clatsop County, EMA Bill Davidson AFD/CERT Dorthy Davidson AFD/CERT Bob Maxfield Warrenton Police Department Jeff Holwege Seaside (Providence Seaside Hospital volunteer) Paulina CockrumProvidence Seaside Hospital Brad Guileff Providence Seaside Hospital Lt. Mark Heussner Group AIRSTA/Astoria Lt. Bryan Burkhalter Group AIRSTA/Astoria Cal Brady9-4-9 / AM 840 Cleve Roper Cannon Beach RFPD Hal Nauman Clatsop County Health and Human Services Deb Treusdale City of Seaside / Tsunami Professor Tom Bergin Clatsop County Sheriff’s Department Margo Lalich RN MPH Clatsop County Public Health Patrick CorcoranOregon State University Clatsop County Extension Tad Pedersen Office of the State Fire Marshal Ron Tyson Olney Walluski Fire and RescuePROPOSED BRADWOOD LANDING LLC/NORTHERNSTAR NATURAL GAS LNG PROJECT21
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