Oregon LNG Terminal and Oregon Pipeline Project FERC Review Resource Report 9, Air and Noise Quality

y Comment/Response Matrix Section 9.0 Page 9-1 Question/Comment/Additional Information Needed Provide a copy of the Air Contaminant Discharge Permit Application. Response The Air Contaminant Discharge Permit Application is provided in Appendix 9C. The application is in draft format pending inclusion of final data from the Oregon Department of Environmental Quality. Data are anticipated in May 2008. Air Quality Control Regions are indicated in Sections 9.1.2.1 and 9.1.2.2. Specific Oregon Ambient Air Quality Standards for sulfur dioxide are provided in Table 9.1-1. Construction emissions are provided in Tables 9.1-2 and 9.1-3.

9.1.2.1 9.1.2.1 9.1.3.1

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Indicate which Air Quality Control Region (AQCR) the project falls within. Provide specific Oregon Ambient Air Quality Standards for sulfur dioxide. Include a table(s) that shows construction emissions of NOx, CO, SO2, VOC, PM10, and PM2.5, CO2 as well as HAPs by year for the LNG terminal and Comrpessor Station. Provide detailed emissions calculations documenting the methodology, emission factors, operating rates, and schedule used to develop the emission rates. The table(s) should include emissions from mobile sources such as delivery vehicles and commuter traffic as well as construction equipment such as earthmoving equipment, marine dredges and barges, welders, etc. The table(s) should also include fugitive emissions from land disturbance and surface preparation (blasting and surface coating) activities. Quantify the amount of ethane and methane that would be released during a blowdown event, estimate the frequency and estimate the total carbon dioxide equivalents of methane released in tons per year. It is stated that three natural gas-fired supplemental heaters with a total rating of 140 MMBtu/hr would be

9.1.3.2

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9.1.3.2

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Ethane and methane emission estimates have been added to Table 9.1-4. The total carbon dioxide equivalent of methane has been added to the text. An estimated frequency of blowdown events of once every five years is stated in Section 9.1.3.2. Additional details regarding physical bottlenecks have been added to Section 9.1.3.2.

Oregon LNG Terminal and Oregon Pipeline Project FERC Review Resource Report 9, Air and Noise Quality Comment/Response Matrix Section Page Question/Comment/Additional Information Needed used at the Terminal. The supporting emission calculations indicate that each supplemental heater are rated at 60 MMBtu/hr for a total of 180 MMBtu/hr. Provide additional details regarding physical bottlenecks that would prevent operations in excess of 140 MMBtu/hr or recalculate emissions based on maximum capacity operations of 180 MMBtu/hr. Section 9.1.3.2 includes a statement that emissions from a flare or venting are estimated to be zero. Please clarify whether or not a flare would be constructed as part of the Terminal, and if so, what would the capacity of the flare be. Response

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The construction of the flare has been made more explicit in Section 9.1.3.2. The capacity of the flare has been added. The Terminal is designed such that no venting of boiloff gas (BOG) will occur during normal operation. The Terminal is equipped with a Flare Stack, L210, which would be used to safely flare boiloff gas during abnormal scenarios only. The bounding abnormal scenario for boiloff gas venting occurs during transfer of LNG from a carrier at or near maximum saturated condition and at or near maximum unloading rates, discharging into on-shore LNG tanks that are operating near maximum operating pressure. Any loss of vapor handling or LNG sendout could result in the LNG tanks approaching maximum allowable operating pressure, necessitating venting of the boiloff gas. Such an event would very quickly result in the reduction or cessation of LNG transfer, thus should venting occur it will be very short lived. The gas venting rate under this scenario is calculated to be a maximum

Oregon LNG Terminal and Oregon Pipeline Project FERC Review Resource Report 9, Air and Noise Quality Comment/Response Matrix Section Page Question/Comment/Additional Information Needed Response of 79,000 pounds per hour of boiloff gas. The flare is therefore designed to handle this bounding capacity.

9.1.3.2

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Provide the following for LNG vessels while at the unloading berth: a. Please confirm whether the LNG vessels generate their own electrical power or use shoreside power. b. If the LNG vessel will generate their own electrical power, will the LNG vessels burn natural gas, diesel or bunker fuel? c. If natural gas will be used, provide the source (ship boiloff, vapor return from terminal, on-ship vaporization, etc.). d. If natural gas will be used, how will the company ensure that there is a sufficient supply for the LNG vessels resident time at berth? e. Clarify the type of fuels used by support vessels. f. Will LNG vessels use boil-off gas prior to, and after berthing? If alternative fuels will be used, update the emission data to reflect this. In addition, what management controls will be in place to assure that boil off gas is used prior to berthing and during unloading of the steam turbine ships. a. Vessels generate their own power. b. Conventional LNG vessels are powered by boilers burning BOG and/or fuel oil while at berth. The use of fuel oil was used in the calculations. c. Boiloff is the most likely source of the natural gas when used. On-ship vaporization may be used. Vapor return will not be used. d. An adequate supply of fuel is the vessel Captains responsibility. e. Support vessels will generally use diesel fuel. f. Again, conventional LNG vessels are powered by boilers burning BOG and/or fuel oil while at berth. Alternative fuels will not be used.

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Quantify marine-related emission impacts to air quality in the region; discuss the feasibility of emission controls;

Emission impacts and the feasibility of emission controls are presented in Section 9.1.3.3. Compliance with

Oregon LNG Terminal and Oregon Pipeline Project FERC Review Resource Report 9, Air and Noise Quality Comment/Response Matrix Section Page Question/Comment/Additional Information Needed and demonstrate compliance with associated regulations. Please detail the sources of the emission estimates, whether from manufacturer derived estimates, EPA AP-42 tables or other models. For both the LNG Terminal and Marine emissions, demonstrate that these emissions would not significantly impact air quality in the following class I areas: Mt. Rainer National Park in Washington, Goat Rocks Wilderness in Washington, Mt. Adams Wilderness in Washington, Mt Hood Wilderness in Oregon, and Mt. Jefferson Wilderness in Oregon. Include all correspondence with the Federal Land Manager and the Pacific Northwest Region USDA Forest Service regarding air quality. Based on the information presented in DRAFT RR9, the proposed facility is incorrectly classified as a 100 tpy major source threshold source under PSD rules. The incorrect classification is based on the fact that the Terminal would consist of fossil-fuel fired boilers. The 100 tpy source category under PSD applies to fossil-fuel fired boilers with a combined rating of 250 MMBtu/hr or more. Data in DRAFT RR9 indicates a total combined rating of 140 MMBtu/hr. However, with regard to PSD applicability, please clarify the inclusion (or portion thereof) of vessel emissions when berthed at port. Based on U.S. EPA guidance, emissions from vessels berthed at port that directly serve the purposes of the Terminal must be included in the PSD applicability analysis. The distinction of whether or not this only includes emissions directly Response associated regulations and air quality impacts are presented in Section 9.1.3.5 and are detailed in a new appendix to the resource report, Appendix 9B.

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The boilers at the Terminal, as noted, will have a total combined heat input rating of 140 MMBtu/hr. As such the facility will have a 250 ton per year PSD threshold. This has been corrected in the text in Section 9.1.3.5. With regard to the LNGC operations, the emissions associated with vessels when berthed at port have been included in the summary of Terminal emissions. Emissions associated with LNGC unloading and tug emissions associated with the vessel when docked have been included. These emissions have also been included in the dispersion modeling analysis. Emissions associated with marine transport of the vessels while having been estimated have not been included in Terminal operations and modeled as Terminal sources. The heat rating of the docked LNGCs boilers have not

Oregon LNG Terminal and Oregon Pipeline Project FERC Review Resource Report 9, Air and Noise Quality Comment/Response Matrix Section Page Question/Comment/Additional Information Needed related to pumping LNG to the storage tanks, or also includes idling/hotelling emissions should also consider the fact that U.S. Coast Guard regulations require the LNGCs to be operationally ready due to the type of port. Furthermore, the inclusion of LNGC emissions may impact the combined fossil fuel-fired boiler capacity of the Terminal, thus changing the maximum potential emissions in comparison to PSD major source applicability levels. Should the conclusion result in PSD applicability, an analysis should address ambient impacts of secondary emission sources. References: January 8, 1990 letter to Mr. Ken Waid, Waid and Associates from John Calcagni, Director, Air Quality Management Division. October 28, 2003 letter to Mr. Michael Cathey, El Paso Energy Bridge Gulf of Mexico, LLC from Charles J. Sheehan, EPA Region 6, Regional Counsel 9.2.2.2 9.2.2.2 9-18 9-18 Clarify how OAR 340-035-035(5) is applicable to the proposed project. Indicate if there are any quiet areas as defined by OAR 340-035-015(50) in the project area. Noise from sources identified in OAR 340-035-035(5) is not regulated or limited. There are no quiet areas within the Project vicinity. The only quiet area in the state of Oregon is The Grotto, The National Sanctuary of Our Sorrowful Mother staffed by the Order of Servants of Mary. The Grotto is Response been included in the summation of heat input associated with the Terminal for purposes of determining PSD applicability. Oregon LNG will have no direct control over the size of the boilers and the LNGC will be at the site for only short periods of time. As such, while the LNGC emissions will be considered part of the Terminal operations, the boilers will not be considered part of the Terminal boilers for purposes of PSD threshold determination.

Oregon LNG Terminal and Oregon Pipeline Project FERC Review Resource Report 9, Air and Noise Quality Comment/Response Matrix Section 9.2.2.3 9.2.3 9.2.4.1 9.2.4.1 Page 9-18 9-19 9-26 9-28 Question/Comment/Additional Information Needed Specifically state the cities and counties that were researched and found not to have noise regulations. Briefly describe major or potential sources of noise near the noise monitoring sites. Describe the model/formulas used to calculate the noise levels presented in Table 9.2-6. For each HDD location provide the following:(a)identify the nearest NSAs (b)the estimated number of days for drilling or re-completion work that would be required for each well, and whether drilling would be done 24 hours per day;(c)the distance (feet) and direction of the NSAs;(d) the existing Ldn at the NSA(s) and the proposed Ldn at the NSA(s) during and after project well drilling at the well drilling locations; and (e)a description of any noise mitigation that would be implement during and after well drilling activity to reduce noise to 55 dBA Ldn at the NSAs near each HDD location. Describe the model/formulas used to calculate the noise contour levels presented in Figure 9.2-5. Provide a discussion on predicted noise levels associated with all pile driving operations (pier, seawall, berthing area, LNG tanks, etc), including: a. a detailed assessment of the projected pile driving noise and vibration at the nearest NSA as well as potential impacts on NSAs and other structures within 2 miles of the pile driving site; b. the distance (feet) and direction of each NSA and the identified structures from the pile driving Response located on NE 85th and Sandy Boulevard in Portland, Oregon. Stated in Section 9.2.2.3. Added to Table 9.2-4 and to Appendices 9E and 9F. Description is provided in Appendix 9E, Section 9.3.1, Predicted Construction Noise Levels. Provided in the attachment to Appendix 9E.

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Provided in Appendix 9F. a and b. The nearest NSAs to the general LNG Terminal location are the same as the nearest NSAs to the pile driving locations. No additional NSAs would be affected by the pile driving locations. c. The number of days and the duration are addressed in the main text in Section 9.2.4.1. Impacts to and mitigation of aquatic environment are addressed in Resource Report 3.

Oregon LNG Terminal and Oregon Pipeline Project FERC Review Resource Report 9, Air and Noise Quality Comment/Response Matrix Section Page Question/Comment/Additional Information Needed site if they are different from those already provided for the general LNG terminal location or if any additional NSAs would be affected from the pile driving locations; c. the estimated number of days that pile driving activities would take place and whether pile driving would be conducted 24 hours per day; d. the existing day-night equivalent sound level (Ldn) at any additional NSAs identified in response to b and the proposed Ldn at the identified NSAs (including those initially identified for the terminal) and structures during pile driving activities; and e. evaluate and quantify sound pressure levels in the aquatic environment from pile driving (in dB re: 1Pa) to a distance of 1/2 mile, identify aquatic species affected and discuss impacts to the species; and f. provide a description of any mitigation measures that would be implemented during pile driving activities to reduce noise and/or vibration perceived at the identified NSAs, Quiet Area, structures, and on the marine/aquatic environment. Confirm that the project would not involve other aboveground facilities (e.g., pressure reduction valves) that could be a source of operational noise. If other sources of noise are associated with potation of the project, provide the location of the facilities and the Response d, e, f. Provided in Appendix 9F.

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There will be pressure-reducing valve stations at the terminus of the lateral pipeline and mainline pipeline at Molalla. Distances to nearest NSAs as well as estimates of existing noise levels are provided in Appendix 9E. The closest NSA to the terminus of the lateral pipeline is

Oregon LNG Terminal and Oregon Pipeline Project FERC Review Resource Report 9, Air and Noise Quality Comment/Response Matrix Section Page Question/Comment/Additional Information Needed distance and direction to the nearest NSA. Additionally, provide an estimate of the existing noise levels at these NSAs. Response over 1 mile away while the closest NSA to the terminus of the main pipeline in Molalla is approximately 400 feet away. Given the rural nature of both these areas, the existing levels are anticipated to be similar to those presented for Monitoring Location 5. Mitigation measures such as acoustical lagging, low noise trim, barriers, enclosures or undergrounding will be incorporated during the final design process to ensure the resulting levels from these pressure reducing valves comply with both Oregons and FERCs noise requirements. Analysis is provided in Appendix 9F. Tugboats and LNG carrier ships are expected to result in sound levels of 64 and 61 dBA, respectively, at a distance of 300 feet (FEED Expansion, 2005 and Bradwood Landing DEIS, 2007). The proposed dock is approximately 6,500 feet from the closest NSAs. Geometric spreading would provide a 27 dBA reduction and atmospheric attenuation would result in an additional 9 dBA reduction. This would result in levels of less than 30 dBA at the closest NSAs to the Terminal and are therefore not expected to be a significant source of operational noise. Oregon LNG anticipates working with vendors to ensure the Terminal complies with the applicable noise limits. Mitigation measures employed may include silencers, barriers, and enclosures. Potential emissions for the emergency generator and the fire pump engines have been recalculated based on 500 hours per year.

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Provide additional information and analysis of noise from the LNG carrier ships and tugboats that would be introduced with proposed docking and unloading operations.

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Describe mitigation measures that Oregon LNG would implement to minimize noise associated with operation of the Terminal. Provide clarification as to why the potential to emit for the emergency electrical generator is not based on the U.S. EPA guideline of 500 hours per year or recalculate potential emissions based on 500 hours per year.

App 9A

Oregon LNG Terminal and Oregon Pipeline Project FERC Review Resource Report 9, Air and Noise Quality Comment/Response Matrix Section App 9B Page 4 Question/Comment/Additional Information Needed Provide a refined air dispersion analysis for the LNG faciltyfor both Class II and Class I areas. Oregon LNG landing should coordinate with the Oregon DEQ Air Quality Division and the Federal Land Managers for Class I areas within 150 km to develop a protocol acceptable to all agencies. a. Impacts should be evaluated at the Class I areas and near and far field areas for stationary sources and mobile emissions (LNG Ship, support vessels, etc.) originating within the moored safety zone. Specifically, model emissions for stationary sources, stationary combined with hotelling, and stationary combined with offloading and mobile sources within the moored safety zone. b. Results from this modeling should be compared to significant impact levels (SILs) as well as added to the background levels and compared to the NAAQS (Class I, II areas). In addition, please include a Class I visibility and deposition analysis for Class I areas within 150 km Provide an analysis of the predicted extent of fog associated with the ambient air vaporizers by season. If appropriate, update the visual impact assessment to include consideration of fog, including revised photo simulations. Also, please note any other potential impacts associated with fog (e.g., traffic impacts). Response Appendix 9B is now Appendix 9C. The USDA Forest Service and the National Park Service are the Federal Land Managers for the Class I areas within 150 km of the site. Based on guidance from the USDA Forest Service, an evaluation of Air Quality Related Values has been conducted based on a similar analysis done for a nearby major source. This shows small and acceptable impacts to visibility and sulfate and nitrate deposition in the Class I Areas. Emissions from all sources, Terminal, unloading, and marine, associated with Oregon LNG have been included. An analysis has also been conducted for the nearby Class II areas and compared to the ambient air quality standards.

Analysis has been added to Appendix 9D, the Terminal water vapor plume study. A summary is provided in Section 9.1.3.4