Malibu Surfside NewsStory Home Page
LNG Firm Wants Coast Guard Concerns Applied to Competitor
• NorthernStar Move Could Be Sign that Offshore Development Options in Southern California Are Dwindling
BY HANS LAETZ
In what may be a case of “corporate tit-for-tat,” the company asking to build one offshore liquefied natural gas terminal near Ventura has demanded that another, competing LNG terminal closer to the Malibu coast address a long list of environmental concerns—concerns originally proposed by the government for the first plant.
Officials for the Woodside Natural Gas LNG terminal, proposed for 21 miles off Malibu’s Point Dume, said they “find it odd” that their competitor filed the letter in the official comment file for Woodside’s proposed OceanWay gas terminal.
The Ventura applicant, NorthernStar Energy, was hit with a list of 396 environmental questions by the U.S. Coast Guard last month, ranging from how LNG tankers will avoid killing whales to whether the Clearwater Port project is needed in the first place.
That list, first revealed in the Malibu Surfside News last week, could delay the NorthernStar terminal for many months, officials said, as they strive to conduct research and compile answers to the 396 items.
Now, NorthernStar has taken the same government list and demands that its competitor meet the same 396 standards.
“It’s just a matter of basic fairness, just to ensure parity,” said NorthernStar vice president Joe Desmond. “We are concerned that different regulatory agencies may apply different criteria to two projects that are very similar.”
Although the Coast Guard is handling both projects, its local partner in Ventura is the California State Lands Commission, which has already addressed LNG issues in its rejection of the BHP Billiton LNG terminal in Malibu. The local partner for the Woodside request off Malibu, is the City of Los Angeles—which has no LNG experience.
Woodside vice president Laura Doll said her company expected some questions to be raised about its proposal, but “we just really didn’t expect it to come from an LNG company.”
Doll said the Woodside’s OceanWay proposal was designed over several years to answer the questions posed in the NorthernStar letter. “We honestly haven’t seen anything filed in the comments yet that would make us think we left something out,” she said.
The Woodside plant in Santa Monica Bay is somewhat different from NorthernStar’s oil rig repurposing project, as Woodside would employ two regasification ships that would alternate cruising out beyond the Channel Islands to accept transfers of LNG cargoes on the high seas from trans-pacific carriers.
At any given time, one of the two carriers would be anchored halfway between Point Dume and Catalina Island, unloading its cargo.
The other ship would be in the designated transfer areas, and the U.S. Navy has voiced opposition that the transfer process would interfere with naval exercises, including live firing of missiles in the Navy’s Point Mugu Sea Range. Several retired admirals have publicly opposed the concept.
Last week, the Navy formally dropped its objections and said it could live with LNG carriers in its missile test range so long as Woodside acknowledged that the Navy has first dibs on the waters, and that the company would schedule its ship movements around Navy exercises.
In other news, last week the Santa Monica City Council formally went on record opposing the Woodside proposal. City council members said the placement of two two-foot-diameter gas pipelines in Santa Monica Bay would be detrimental to marine life.
Los Angeles City Councilmember Bill Rosendahl also came out swinging against the LNG terminal in Santa Monica Bay. He said the terminal and its gas pipeline across Los Angeles International Airport would make LAX a vulnerable terrorism target, and the LNG regasification ships would be targets like the U.S.S. Cole.
Rosendahl also said the project would adversely affect LAX runway relocations, would make extension of the Green Line difficult, and would disrupt environmentally sensitive sand dunes at Dockweiler Beach.
Rosendahl is chair of the LA Airports board, and chair of the L.A. council’s public works committee, both of which have veto over the proposal. The natural gas pipelines would cross his district as they come ashore at LAX and head east.
And the Los Angeles Unified School District said it wants Woodside to explain what safety precautions would be taken at 21 locations where proposed high-pressure, 24-inch gas pipelines would pass within 1500 feet of public schools in Westchester, Watts, South Gate and Cudahy.
Environmental laws provide special protections to low income areas in the interest of economic justice, and community organizers on L.A.’s south side have yet to be heard on this issue.
Impetus to build LNG terminals in the coastal waters of California may be affected by two proposals to build new natural gas pipelines into the west from new gas fields in Utah and Wyoming.
Both the Kern River and Spectra gas pipeline companies filed legal notice last week that they plan to add California-bound gas capacity if customers can be found.
If both of these pipelines are built, their capacity would approximately equal the LNG capacity proposed by the Woodside and NorthernStar projects combined.
And finally, a San Diego company that will start up its new LNG import terminal at Ensenada, Mexico announced Thursday it will build a $150 million addition to treat its LNG imports to remove the “hot gas” threat. Sempra officials said they would treat LNG cargoes with nitrogen to lower their burning temperature, thus dramatically decreasing the amount of air pollution that will be caused by burning the natural gas.
Although California regulators have approved the socalled hot gas for use here, smog agencies have filed suits to overturn that because of the large amounts of smog that would be generated.
Neither of the two offshore LNG terminals have plans to limit or treat imports to bring them in line with lower-burning standards.
Friday, November 09, 2007
Thursday, November 08, 2007
LNG: "Sell It To Us, Lease It To Us Or Lose It To Us!"
Government Abetting Private Property Takings To The Benefit Of Private Industry?
"Sell it to us, lease it to us or lose it to us"
That was the choice Roger Thompson was faced with regarding his family's 132 year ownership of their property in Clatskanie and which just happend to be in the path of Spiro Vassilopoulos's(sp?) proposed "Port Westward LNG Transfer/Storage facility and ironically, in full support and abetted by "The Port of St. Helens".
Fate, Kharma, Destiny intervened in favor of the Thompsn's on that when PWLNG could not muster investors.
Now, with Oregon LNG and its V.P., former employee of now defunct and broke Calpine Energy Group and ex-Enron Clone, Peter Hansen at the helm a bunch of property owners could quite possibly be besieged with likely the same choices and arm twisting, once again abetted by Government as well to the benefit of this one "Private Corporation" bent on selling Natural Gas to California?
Hell! and this is on record, California's Lt. Governor, in a recent speech and I'm paraphrasing, said "California doesn't need to worry about extensive LNG development and speculation because we will get all the, LNG derived, Natural Gas we need from Oregon".
So now, all you property owners in the path of this, in my view, insurrection should be prepared for a, what is it 30" - 36" diammeter pipe, loaded with flowing Natural Gas through your property, whether you want it to or not then be prepared to lose a 125' - 150' wide right of way swathe across your property. Can you live with that?
How long you think it will take to get a good night's sleep?
For us on the coast down here, we'll just be living with the fact that in each one of these LNG Storage Tanks there's 7.6 Million Cubic Feet of boiling Liquefied Natural Gas at -260 degrees just waiting for an opportunity to escape, vaporize and blow a mile, mile and a half in any direction of us off the face of the earth while leaving many more brutally scarred and in terrible misery for the rest of their lives, should they survive but hey! that's just "Fear Mongering" on my part.
Who could have ever believed that someone could actually cammandeer a couple of passenger aircraft and fly them into "The World Trade Center Buildings" and cause them to collapse?
Who could have actually believed that someone could actually maneuver a passenger aircraft through all the security of the mightiest military in the world, to some, and crash it into the base of all that power, "The Pentagon"?
Can you imagine how ludicrous that concept would have registered?
"Sell it to us, lease it to us or lose it to us"
That was the choice Roger Thompson was faced with regarding his family's 132 year ownership of their property in Clatskanie and which just happend to be in the path of Spiro Vassilopoulos's(sp?) proposed "Port Westward LNG Transfer/Storage facility and ironically, in full support and abetted by "The Port of St. Helens".
Fate, Kharma, Destiny intervened in favor of the Thompsn's on that when PWLNG could not muster investors.
Now, with Oregon LNG and its V.P., former employee of now defunct and broke Calpine Energy Group and ex-Enron Clone, Peter Hansen at the helm a bunch of property owners could quite possibly be besieged with likely the same choices and arm twisting, once again abetted by Government as well to the benefit of this one "Private Corporation" bent on selling Natural Gas to California?
Hell! and this is on record, California's Lt. Governor, in a recent speech and I'm paraphrasing, said "California doesn't need to worry about extensive LNG development and speculation because we will get all the, LNG derived, Natural Gas we need from Oregon".
So now, all you property owners in the path of this, in my view, insurrection should be prepared for a, what is it 30" - 36" diammeter pipe, loaded with flowing Natural Gas through your property, whether you want it to or not then be prepared to lose a 125' - 150' wide right of way swathe across your property. Can you live with that?
How long you think it will take to get a good night's sleep?
For us on the coast down here, we'll just be living with the fact that in each one of these LNG Storage Tanks there's 7.6 Million Cubic Feet of boiling Liquefied Natural Gas at -260 degrees just waiting for an opportunity to escape, vaporize and blow a mile, mile and a half in any direction of us off the face of the earth while leaving many more brutally scarred and in terrible misery for the rest of their lives, should they survive but hey! that's just "Fear Mongering" on my part.
Who could have ever believed that someone could actually cammandeer a couple of passenger aircraft and fly them into "The World Trade Center Buildings" and cause them to collapse?
Who could have actually believed that someone could actually maneuver a passenger aircraft through all the security of the mightiest military in the world, to some, and crash it into the base of all that power, "The Pentagon"?
Can you imagine how ludicrous that concept would have registered?
Tuesday, November 06, 2007
LNG: Those Tankers And Bad Siting Are Really A Problem
Fall River / Somerset LNGWhy Take The Risk?
An official from Weaver’s Cove recently told the Fall River City Council that the opponents of siting an LNG facility in a heavily populated area lack the facts concerning LNG. This was far from the truth. The members of the Coalition for the Responsible Siting of LNG Facilities have been researching the issue for many months and have discovered that scientific experts, fire officials, public officials have not only spoken against the siting of LNG facilities in populated areas but they have scientific information to back up their opinion.
Professor James Fay of the Massachusetts Institute of Technology created a report on the possible hazards from LNG. In regards to what could happen along the Fall River / Somerset waterfront he said, “A tanker spill fire at any location along this route would have serious consequences for persons and property on the shore adjacent to the stricken vessel.” Moreover Professor Fay stated that, “The magnitude of the resulting liquid cargo pool fires are unprecedented in scale. There is no possibility of ameliorating the fire’s effects, much less extinguishing it, during the short time (several minutes) of burnout.
”Professor Jerry Havens of the University of Arkansas who said, “In my judgment, a large pool fire – on water, and therefore uncontained – is of the highest concern.” “Most predictions suggest that even the largest LNG tankers (typically more than 900 feet in length) might be completely enveloped in a pool fire following a complete spill of a single 6.5 million gallon tank. This raises questions about the vulnerability of the ship and the potential for additional releases. A typical LNG tanker contains as many as five tanks with a combined capacity of 33 million gallons.” In addition Professor Havens has said that safety zones based on the limited, 10-minute spill could not protect the public from the kind of fire that would result from an LNG tanker accident. He also said that the “Hazard Exclusion Zones” might need to extend a mile or more from the LNG terminal.
William Lehr, author of the National Oceanic and Atmospheric Administration (NOAA) report due out shortly said, “The maximum emissive power of an LNG pool fire is several times more than we would expect from a regular oil fire. A common danger level for thermal radiation flux in an area of public assembly is 5 kilowatts per square meter. A person exposed to this level would feel considerable pain in a few seconds. A very large unconfined LNG pool fire could possibly produce thermal radiation effects at this level or above for more than a kilometer away from the center of the fire.”When we worry that a mishap or an attack on the LNG tanker could take place we are told that the Coast Guard will handle security.
Here is what Rear Admiral Kevin Eldridge, commander of the U.S. Coast Guard’s 11th District off California had to say when he was asked about the possibility of an attack on U.S. shores. He said, “It’s likely enough for us to put a lot of effort into planning for it. Frankly, if we have a vessel in our port that has a problem, it’s too late.
”William Pope, U.S. State Department Deputy Coordinator for Counter-Terrorism said recently, “We have every reason to believe they (terrorists) will also be attracted to one of the softest targets of all, commercial shipping.
”In a recent article from an Australian newspaper, Alexey Muraviev of Curtin University of Technology in Perth, told a maritime security conference that intelligence experts believed ships were far more vulnerable to an al-Qaeda attack than commercial airlines. Targets could include cruise ships, oil supertankers, LNG-carriers and chemical tankers.
In addition Senator Elizabeth Dole had this to say about the U.S. Coast Guard having the responsibility of protecting LNG tankers. She said, “We need to give our Coast Guard more resources right now, not the added responsibility of overseeing tankers bringing dangerous LNG into our ports.”The federal government back in 1979 already knew of the dangers relating to LNG even before there was talk about terrorism.
In 1979 the U.S. General Accounting Office (GAO), which acts as the investigative arm of Congress, researched the LNG issue. GAO Director J. Dexter Peach testified before the Senate and said, “We believe remote siting is the primary factor in safety.
”In addition to Mr. Peach speaking before the Senate Massachusetts Congressman Ed Markey said recently, “When Congress passed my LNG safety bill back in 1979, it directed the Department of Transportation (DOT) to prescribe standards for the siting of new LNG facilities that were supposed to consider the need to encourage remote siting.”While many have realized that LNG is extremely dangerous the Federal Energy Regulatory Commission (FERC), the agency in charge of making a decision on the Weaver’s Cove facility, have been touting a report known as the “Quest Study” as evidence that we have little to fear from an LNG spill.
The problem is that the lead scientist on the Quest Study of LNG fires, John Cornwell, said that he did not think the study’s computations were appropriate for many of the things they are being used for.
In addition an article written in the “Mobile Register” said, “Most published scientific studies, including a soon-to-be-released analysis by the National Oceanic and Atmospheric Administration, produce estimates of a potential LNG tanker fire that are five to six times larger than the Quest estimate.
”Furthermore the Federal Energy Regulatory Commission is headed by Patrick Henry Wood III. Mr. Wood’s agency will be making the decision on whether or not Weaver’s Cove can construct an LNG facility in Fall River.
It is interesting to note the Weaver’s Cove has hired the law firm of Baker & Botts out of Texas to represent them. The Chairman of FERC, Mr. Wood, was employed by Baker & Botts in the past.
Other LNG Sites:There are many other companies looking to place LNG sites throughout the U.S. but they are taking a different approach, unlike Weaver’s Cove.Billiton LNG International, a large energy firm from Australia would like to locate a LNG facility in California. Stephen Billiot, the V.P. had this to say: “We understand California’s concern for its coastline and it communities. Although LNG’s excellent safety record is well documented, we are siting this much needed LNG facility far offshore and away from populated centers to ensure the highest level of protection for the California coast and public safety.
”Cameron Parish La., Cheniere Energy is being supported by the citizens to locate a LNG facility there. The company points out that they have 600 acres for a buffer zone.
Sabine Texas, Golden Pass LNG project being sponsored by Exxon / Mobil. The company is highlighting the fact that they have over 500 acres for a buffer zone.The lack of buffer zones has brought out many communities to be against these dangerous LNG proposals.
Fall River Ma., Mobile Alabama, Harpswell Maine, Vallejo Calif, and other communities in California, the country of Mexico stopped Marathon Oil from building an LNG facility near a city in that country by taking the land over and nationalizing it.
In R.I. a bill has been filed by State Representative Raymond Gallison to ban LNG tankers from using the Sakonnet River or from going under the Mount Hope Bridge.On February 3, 2004, United States Senator John Kerry and others sent a letter to Tom Ridge saying that every time an LNG tanker comes into Boston that the Federal Govt. needs to raise the threat level in Boston to HIGH! Is that what we want in the Fall River area?
September 9, 2003 Congressional Research Service Report“Because LNG infrastructure is highly visible and easily identified, it can be vulnerable to terrorist attack.”Boston Deputy Fire Chief Joseph Fleming presented a report to the Commonwealth. The report contained information from the National Fire Prevention Association handbook: “Contact between water and pooled LNG should be avoided to prevent increased vaporization, unless vapor can be controlled” What will the fire boats that Weaver’s Cove said they would provide do to a LNG fire? According to a fire expert the Weaver’s Cove fire tugs would make the fire even worse!
The Fall River City Council has gone on record 7 to 2 opposing the facility. State Representatives David Sullivan and Mike Rodrigues have gone on record opposing any facility near populated areas.As anyone can plainly see the Coalition for the Responsible Siting of LNG Facilities has gathered information from far and wide. We do know the facts. It is foolish to site a dangerous facility in a heavily populated area. Why take the risk?
An official from Weaver’s Cove recently told the Fall River City Council that the opponents of siting an LNG facility in a heavily populated area lack the facts concerning LNG. This was far from the truth. The members of the Coalition for the Responsible Siting of LNG Facilities have been researching the issue for many months and have discovered that scientific experts, fire officials, public officials have not only spoken against the siting of LNG facilities in populated areas but they have scientific information to back up their opinion.
Professor James Fay of the Massachusetts Institute of Technology created a report on the possible hazards from LNG. In regards to what could happen along the Fall River / Somerset waterfront he said, “A tanker spill fire at any location along this route would have serious consequences for persons and property on the shore adjacent to the stricken vessel.” Moreover Professor Fay stated that, “The magnitude of the resulting liquid cargo pool fires are unprecedented in scale. There is no possibility of ameliorating the fire’s effects, much less extinguishing it, during the short time (several minutes) of burnout.
”Professor Jerry Havens of the University of Arkansas who said, “In my judgment, a large pool fire – on water, and therefore uncontained – is of the highest concern.” “Most predictions suggest that even the largest LNG tankers (typically more than 900 feet in length) might be completely enveloped in a pool fire following a complete spill of a single 6.5 million gallon tank. This raises questions about the vulnerability of the ship and the potential for additional releases. A typical LNG tanker contains as many as five tanks with a combined capacity of 33 million gallons.” In addition Professor Havens has said that safety zones based on the limited, 10-minute spill could not protect the public from the kind of fire that would result from an LNG tanker accident. He also said that the “Hazard Exclusion Zones” might need to extend a mile or more from the LNG terminal.
William Lehr, author of the National Oceanic and Atmospheric Administration (NOAA) report due out shortly said, “The maximum emissive power of an LNG pool fire is several times more than we would expect from a regular oil fire. A common danger level for thermal radiation flux in an area of public assembly is 5 kilowatts per square meter. A person exposed to this level would feel considerable pain in a few seconds. A very large unconfined LNG pool fire could possibly produce thermal radiation effects at this level or above for more than a kilometer away from the center of the fire.”When we worry that a mishap or an attack on the LNG tanker could take place we are told that the Coast Guard will handle security.
Here is what Rear Admiral Kevin Eldridge, commander of the U.S. Coast Guard’s 11th District off California had to say when he was asked about the possibility of an attack on U.S. shores. He said, “It’s likely enough for us to put a lot of effort into planning for it. Frankly, if we have a vessel in our port that has a problem, it’s too late.
”William Pope, U.S. State Department Deputy Coordinator for Counter-Terrorism said recently, “We have every reason to believe they (terrorists) will also be attracted to one of the softest targets of all, commercial shipping.
”In a recent article from an Australian newspaper, Alexey Muraviev of Curtin University of Technology in Perth, told a maritime security conference that intelligence experts believed ships were far more vulnerable to an al-Qaeda attack than commercial airlines. Targets could include cruise ships, oil supertankers, LNG-carriers and chemical tankers.
In addition Senator Elizabeth Dole had this to say about the U.S. Coast Guard having the responsibility of protecting LNG tankers. She said, “We need to give our Coast Guard more resources right now, not the added responsibility of overseeing tankers bringing dangerous LNG into our ports.”The federal government back in 1979 already knew of the dangers relating to LNG even before there was talk about terrorism.
In 1979 the U.S. General Accounting Office (GAO), which acts as the investigative arm of Congress, researched the LNG issue. GAO Director J. Dexter Peach testified before the Senate and said, “We believe remote siting is the primary factor in safety.
”In addition to Mr. Peach speaking before the Senate Massachusetts Congressman Ed Markey said recently, “When Congress passed my LNG safety bill back in 1979, it directed the Department of Transportation (DOT) to prescribe standards for the siting of new LNG facilities that were supposed to consider the need to encourage remote siting.”While many have realized that LNG is extremely dangerous the Federal Energy Regulatory Commission (FERC), the agency in charge of making a decision on the Weaver’s Cove facility, have been touting a report known as the “Quest Study” as evidence that we have little to fear from an LNG spill.
The problem is that the lead scientist on the Quest Study of LNG fires, John Cornwell, said that he did not think the study’s computations were appropriate for many of the things they are being used for.
In addition an article written in the “Mobile Register” said, “Most published scientific studies, including a soon-to-be-released analysis by the National Oceanic and Atmospheric Administration, produce estimates of a potential LNG tanker fire that are five to six times larger than the Quest estimate.
”Furthermore the Federal Energy Regulatory Commission is headed by Patrick Henry Wood III. Mr. Wood’s agency will be making the decision on whether or not Weaver’s Cove can construct an LNG facility in Fall River.
It is interesting to note the Weaver’s Cove has hired the law firm of Baker & Botts out of Texas to represent them. The Chairman of FERC, Mr. Wood, was employed by Baker & Botts in the past.
Other LNG Sites:There are many other companies looking to place LNG sites throughout the U.S. but they are taking a different approach, unlike Weaver’s Cove.Billiton LNG International, a large energy firm from Australia would like to locate a LNG facility in California. Stephen Billiot, the V.P. had this to say: “We understand California’s concern for its coastline and it communities. Although LNG’s excellent safety record is well documented, we are siting this much needed LNG facility far offshore and away from populated centers to ensure the highest level of protection for the California coast and public safety.
”Cameron Parish La., Cheniere Energy is being supported by the citizens to locate a LNG facility there. The company points out that they have 600 acres for a buffer zone.
Sabine Texas, Golden Pass LNG project being sponsored by Exxon / Mobil. The company is highlighting the fact that they have over 500 acres for a buffer zone.The lack of buffer zones has brought out many communities to be against these dangerous LNG proposals.
Fall River Ma., Mobile Alabama, Harpswell Maine, Vallejo Calif, and other communities in California, the country of Mexico stopped Marathon Oil from building an LNG facility near a city in that country by taking the land over and nationalizing it.
In R.I. a bill has been filed by State Representative Raymond Gallison to ban LNG tankers from using the Sakonnet River or from going under the Mount Hope Bridge.On February 3, 2004, United States Senator John Kerry and others sent a letter to Tom Ridge saying that every time an LNG tanker comes into Boston that the Federal Govt. needs to raise the threat level in Boston to HIGH! Is that what we want in the Fall River area?
September 9, 2003 Congressional Research Service Report“Because LNG infrastructure is highly visible and easily identified, it can be vulnerable to terrorist attack.”Boston Deputy Fire Chief Joseph Fleming presented a report to the Commonwealth. The report contained information from the National Fire Prevention Association handbook: “Contact between water and pooled LNG should be avoided to prevent increased vaporization, unless vapor can be controlled” What will the fire boats that Weaver’s Cove said they would provide do to a LNG fire? According to a fire expert the Weaver’s Cove fire tugs would make the fire even worse!
The Fall River City Council has gone on record 7 to 2 opposing the facility. State Representatives David Sullivan and Mike Rodrigues have gone on record opposing any facility near populated areas.As anyone can plainly see the Coalition for the Responsible Siting of LNG Facilities has gathered information from far and wide. We do know the facts. It is foolish to site a dangerous facility in a heavily populated area. Why take the risk?
Monday, November 05, 2007
Bradwood: Way Too Many Unanswered Questions...Read This Thing!!!
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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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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