Letter to FERC.

As the engineering and other mitigated issues change faster than it can be printed (bait and switch), the following letter was submitted to the FERC.

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

888 First Street, NE. Room 1A

Washington, DC. 20426

Ref. Docket No. CP06-365-000 et al.

Dear Ms. Bose:

Thank you for the opportunity to submit my comments and concerns related to the proposed Bradwood LNG facility.

As the permit process continues and following the filing of the Draft Emergency Response Plan (ERP), several issues surfaced pertaining to Wahkiakum County, WA.

and Puget Island in particular.

Puget Island is the closest community to the proposed facility and adjacent to the LNG carrier turning basin (less than 0.5 mile) as is the County’s shoreline to the LNG carrier transit route. But after review of the Draft ERP the only mentioning of our community is related to evacuation as for Tsunami’s. Aural warnings by means of siren and reverse 911 calls.

In the Emergency Management Plan (EMP) Annexes is mention of Puget Island pages 6D 9.1.4. and 7D 4.2.4. Related to aural warnings and evacuation.

Much more will be required to bolster the County’s infrastructure for the protection and safety of our citizens, the elderly and our properties.

In the ERP Appendix 4,  First Aid Response Organizational Chart shows ship support  with only two (2) tug boats. As per USCG Water Suitability Report (WSR), three (3) tug boats are required during dockside transfer of LNG. (While unloading, all three tugs will remain on standby to assist with emergency departure procedures.)

Three tug boats are A-1 equipped with high volume 5000gpm fire fighting pumps for a total capacity of more than 15,000gpm, will the pump intake be screened for protection of these pumps and accidental ingesting of marine live? (NOAA Fisheries)

In order to comply with 49 CFR 193.2057 and 49 CFR 193.2059 NorthernStar has to submit weather related data pertaining to Temperature, Relative Humidity, and Wind Speed, my question is: why is FERC requesting weather data from the past  three (3) years from Oregon LNG^[1] , but NorthernStar would be able to submit only one (1) year of data, due to their local weather station was only in operation for one year.

Unless NorthernStar submitted data from the Astoria, OR. weather station, which data should be unacceptable.

I have an electronic weather station (Davis Vantage PRO with a Weatherlink Data loader) installed for the past eight years and the results are quite different from the Astoria station due to location and terrain.

Due to the close proximity of Puget Island and the prevailing weather conditions, I’m asking the FERC to calculate the exact 49 CFR 193.2057 Thermal radiation protection zone and 49 CFR 193.2059 Flammable vapor-gas dispersion protection zone.

As these zones are calculated from the LNG storage container and LNG transfer systems, the ships transfer system will be outside the containment area.

These zones have to be owned or be in control of the facility operator, would normal river traffic be allowed through  these zones?

In summary, FERC has to hold the applicant(s) to the highest standards possible to meet NEPA, which should include “need” and “alternatives” and address the safety and security for the citizens of Wahkiakum County, WA.

The draft ERP and EMP are grossly inadequate in reference to Wahkiakum County and should not be addressed as a surrounding counties² due in part to the above mentioned criteria.

All cost of the necessary equipment, personnel, training, etc. should be borne by the applicant(s) as they are outside of our taxing district. 

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^[1]  20080402-3019 FERC PDF dated 04/02/2008

²  Cover letter page 1, dated 02/25/08 Bradwood Landing, LLC