George Exum's Letter to Oregon DOE

Catherine Van Horn, Senior Analyst
Oregon Dept of Energy
625 Marion St. NE
Salem, OR 97301-3737

Dear Catherine,

    Following are some of my concerns regarding the siting of an LNG receiving and re-gasification facility at Bradwood Landing.

1.    Safety Concerns regarding LNG tanker transit from the Columbia River Bar to Bradwood Landing.  The vessel transit through the Astoria waterfront includes transiting in the ship channel that has numerous businesses that border on the existing ship channel.  These businesses include hotels, restaurants, shops, fish marketers, marine suppliers, and the Columbia River Maritime Museum.  Even if the exclusion zones were reduced, the LNG vessels would be transiting very close to vibrant and successful businesses.  How will Northern Star and the various regulatory agencies address the vessel transit in such close proximity to the business community located on the Astoria waterfront?

    The transit from Altoona, WA to Skamokawa, WA includes a very narrow ship channel.  Please refer to Department of Commerce, NOAA, Chart # 18523; mile markers from river mile 25 to river mile 33.  In this section of the river transit, the Washington side of the river is steep rocky cliffs covered by heavy forest.  From the Columbia River bar to Skamokawa is very foggy with limited visibility for many months of the year.  This section of the river with its weather conditions, rocky and remoteness present a difficult and sometimes dangerous passage.  The shoreline because of its remoteness and topography would be difficult to patrol and monitor in the unlikely, according to Northern Star, event of intervention by a terrorist group.  Also with the rocky nature of the shoreline, a vessel in transit has limited maneuverability if a problem arises.

    I have been involved with the maritime industry for over thirty five (35) years. During that time period, I have earned a USCG Chief Engineer’s License for Unlimited Horsepower for Steam and Motor Vessels.  I have sailed as a Chief Engineer for Sealand Services Inc. on container ships. I currently perform ISM (International Safety Management) audits for Horizon Lines and perform vibration analysis on engine room machinery and infrared analysis on electrical equipment for merchant ships worldwide.  During my years of sailing in the engine rooms of tankers, freighters, container ships, and passenger ships, I have witnessed many incidents both serious and near misses.  This includes the loss of the main propulsion system electrical power system, and the steering system.  There were also occurrences of ship pilot or bridge personnel or equipment error.   So human or mechanical malfunction could happen at any time during a very narrow and dangerous passage of the Columbia River bar or river passage.

    The Columbia River and Bar pilot do an excellent job of navigating ships across a treacherous river bar crossing and up a sometimes foggy, windy, and busy (commercial and recreational) river.  But every year ships go aground while transiting the Columbia River.  Please check for these occurrences in the USCG, MTSB, and newspaper records. In fact, I know of at least two incidents that occurred at the entrance of Clifton Channel when a vessel failed to make the turn entering the Puget Island Range.  One of the ships grounded in the sand not too far where Northern Star is planning their LNG unloading dock.  With incidents like this, how can commercial traffic be allowed while an LNG tanker is unloading?

2.    The Department of Homeland Security has stated that LNG facilities and LNG ships are possible terrorist targets.   How will Northern Star ensure security for ships transiting the thirty five (35) miles of rocky-forested shoreline and the numerous marshy river islands?  WHO WILL PAY FOR THIS SECURITY EFFORT?  Who will be the security agency that coordinates a bi-state security situation? The majority of the lower river islands are part of two National Wildlife Refuges.  Who will have the responsibility for security issues on the federal lands in the river?  The security and safety issues of LNG tanker transit up the Columbia River seem to be an important negative aspect regarding the construction of an LNG processing facility this far up the Columbia River.

3.    In December 2004, the Sandia Report (Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas Spill Over Water) was released to the public.  How will Northern Star handle the safety zones as indicated in the Scandia report regarding accidental spills or possible intentional cause of release during LNG tanker transit to the Bradwood Landing and at the storage and re-gasification site?  The locations of concern that need to be addressed include Astoria, Skamokawa, Lewis & Clark NWR, Julia butler Hansen NWR, and Puget Island.

4.    In the past a number of organizations and agencies have performed water quality and bottom sediment testing on the Columbia River and its tributaries. Among these testing agencies was the Army Corps of Engineers, CREST, and the Lower Columbia River Bi-State Program.  The testing has found accumulations of PCBs, dioxins, furans, pesticides, metals, and bacteria.  The entrance to Clifton Channel and the channel itself have not been dredged.

It is a natural settling spot due to the up river bend and the hydrological flow of the main ship channel.  Northern Star plans to dredge the entrance of Clifton Channel and Clifton Channel itself to allow for the construction of a dock for the docking of LNG tankers.  Will Northern Star be required to extensively test the bottom sediment for contaminants prior to dredging operations?  Will the results of this sampling be included in the EIS?  If contaminants are found, how will the dredge spoils be disposed of?  If disposed on land, how will the dispersion of contaminants via wind be addressed?  How will the turbidity of the water during dredging affect migratory fish?  Dredging the entrance of the Clifton Channel and parts of the channel itself will dramatically affect the hydrology of both the main river ship channel. Clifton channel, and the shorelines of both the Oregon shore and the adjacent islands.  Will Northern Star present evidence that their dredging operations will not adversely affect the hydrology and shorelines of the Clifton Channel and downstream channels?  How will the change in hydrology affect local fish populations and migratory fish?  I feel it is important that Northern Star present conclusive evidence that their dredging and daily operation will not be detrimental to endangered and threatened fish populations.

5.    There are two geologic and seismic issues that need to be seriously addressed by Northern Star in its application. The first issue is the geologic stability of the hill that is located up river and adjacent to the proposed facility.  In 1965, a section of the cliff of this hill dislodged and fell into the Columbia.  This was not caused by a seismic event.  This slide created a wave that caused extensive property damage and loss of life on Puget Island.  How will Northern Star address this issue?  I assume they will be able to provide scientific evidence regarding the geologic stability of the hillside adjacent to their facility?  I assume State and Federal scientists will provide additional analysis regarding hillside stability in the EIS.   What is the hillside stability in the event of a large magnitude seismic event? 

    Extensive research regarding large magnitude earthquakes caused by the Cascadia Subduction Fault have been performed and published by the US Geologic Society and the University of Washington.  The last large magnitude (magnitude 9) occurred in this area in 1700.  When seismologists discuss future events caused by the Cascadian Fault, they don’t discuss “if”, they discuss “when”.  The consensus is that we are overdue for a large magnitude event.  In the published literature about past seismic events, it has been noted that sandy soils liquefied.  The proposed site is on a sandy dredge spoil site.

    How will Northern Star address tank and facility building, tank and pipeline rupture, and dock stability during a large magnitude earthquake on a site situated on sandy soil?  An aside to this issue is how will they plan for a tsunami wave generated by an offshore seismic event?   During my seagoing career, I was an engineer on the SS Avila that was docked in Port San Luis, CA during a seismic event offshore.  Fortunately, the vessel had just docked and our tanker discharge hoses were not connected.  The resultant wave, not a tsunami, caused all our lines that were attached to the dock to part and the ship was adrift.   How will Northern Star address ship and discharge hose safety during a seismic or tsunami event?

6.    The islands off the proposed Bradwood Landing LNG facility are part of the National Wildlife Refuge System.  They are home to a threatened species, the Columbia White Tailed Deer.  They are also home to many migratory bird species.  Northern Star should be required to provide scientific evidence that the noise and massive site lighting requirements during construction and operation will not affect wildlife species on adjacent federally protected property.  How will the lighting and noise affect migratory fish?  Is this a sensible industrial project to be located next to a National Wildlife Refuge?

7.    What will be the affect on recreational fishing and boating in the areas near the Bradwood Landing site?  Currently the Clifton Channel is widely used by recreational boaters and occasionally used by tugboats while transiting the Oregon side of the river.  This area is also actively sport fished especially for Spring Chinook.  Clifton Channel and the adjacent islands are active kayak and boat camping areas.  Due to NWR camping restrictions and island topography, the sandy area across from the Bradwood Landing is the most used location used for camping by kayakers and boaters,  According to the navigational chart, it is approximately 1600 feet from Bradwood Landing to this beach.  Will Northern Star address the recreational us of the adjacent island in their proposal?  How will recreational use of the river, channel, and adjacent islands be impacted by an LNG facility?

8.    There has been much discussion regarding exclusion (safety and security) zones around LNG ships and facilities at many of the meetings that have occurred locally.  Northern Star representatives have promised the upriver ports and businesses that they will not be impacted by the LNG operation.  Northern Star has promised commercial fisherman that they will only be minimally impacted; whatever that means. I don’t know what they have promised recreational fisherman and boater groups but I am sure they promised something.  Seems like they have made promises to everyone including state, county and local government on both sides of the river, school districts, and local landowners.  It also seems that if you have a concern then Northern Star has a promise.  I sure would like to see all the promises in their application for siting. How can Northern Star request that exclusion zones be reduced from what is the standard in other areas of the United States?  Do the businesses, property, and lives of people of the Lower Columbia River need less protection than is given to the residents of Boston, MA?  What will be the exclusion zones around LNG facilities and ships during a heightened national terrorist alert?  What will be the impact on commercial river traffic, businesses, and personal property during a heightened security alert?  Who will pay for the interruption to commerce and personal life of such a disruption around and LNG site?  What is Northern Star’s liability in such a situation?

9.    Is there a need for this plant?  Is the gas to be imported to this facility for consumption in the Pacific Northwest?  Sempra Energy, a leading US company in the LNG and natural gas field, has recently completed an assessment of what it believes the US will need in terms of LNG import facilities.  Darcel Hulse, president of Sempra, said that aside from the four existing facilities, the market could use another four terminals. In the foreseeable future, Hulse believes that the market could sustain an additional three or possibly four facilities.  This would bring us to a total of eleven or twelve LNG terminals.  The US has four existing terminals and another four that have been approved or are well along in the certification process. With near term market space for three or four terminals and approximately fifty (50) proposed and potential sites under consideration by state and federal agencies, the competition will be fierce for each site.  This is the modern day gold rush with incredible financial reward at the end of the rainbow.

    Additional LNG terminals will not necessarily create lower natural gas prices.  According to the Wall Street Journal on May 13, 2005, the Gas Exporting Countries Forum met in Trinidad to discuss taking toward creating an “energy cartel” that could police pricing.  They plan to build and share a global supply and demand model to be used to negotiate future contracts and potentially prevent too much gas from hitting the markets.

    Over twenty years ago, Washington State embarked on a massive nuclear energy plant-building program based on future energy needs as projected by future growth and need models.  It turned into a financial fiasco.  Could this be Round 2 but with a different energy component?

10.    At a number of local meetings Northern Star representatives mentioned that bringing LNG from Alaska was their first choice.  Unfortunately they did not inform the public that there was no US flagged and US crewed LNG tankers and according to the Jones Act all cargoes being transported between US ports have to be on US flagged and crewed vessels.  Northern Star has no plans to build US ships to carry their cargo.   There are currently no LNG tankers under construction in US shipyard and no contracts pending.  Why would Northern Star representatives claim that they would be importing Alaskan LNG?

    Since they are energy professionals they were surely aware of the Jones Act!

    I guess we will just be importing more foreign energy.   This fact interests me because many years ago a natural gas pipeline was approved to move natural gas from Alaska to join up with Canadian pipelines that transit to the US.  No US energy companies have stepped forward to accomplish this project.  I guess the financial reward is not as great as importing LNG from foreign countries.  Logic seems to say that if the federal government, which is attempting to control energy siting and distribution, should make bringing natural gas from Alaska a priority before importing LNG from foreign sources.

11.    In conclusion, is Bradwood Landing a sensible site to build an LNG terminal?   Are not coastal sites or offshore sites like the recently approved offshore terminal at Rosarito Beach, Baja more sensible?  Is it in the public interest and safety to bring LNG tankers thirty-five plus miles up a narrow ship channel to unload at a facility adjacent to a national wildlife refuge?

    I have other areas of concern among them the financial and expertise  resources of Northern Star, international manning and training on LNG tankers, and LNG terminal and ship safety concerns.  I wanted to keep my comments brief for this initial correspondence.  This seems the start of a lengthy process and I intend to stay involved and concerned throughout.

Thank you for your consideration of my comments and looking forward to the answers to the questions.

Sincerely,
George Exum