Rulemaking Comment Period for Chapter 173-180 WAC and Chapter 173-184 WAC

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Comment From: Jude Green

3/06/23 @ 12:52 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: U.S. Navy, Manchester Fuel Dep... (Michael Hardiman)

3/05/23 @ 9:01 PM
Chapter 173-180 WAC incorporates by reference 40 CFR 112, Federal Oil Pollution Prevention regulations. Federal facilities in Washington State are regulated by the Environmental Protection Agency (EPA) with the rules contained in 40 CFR 112. To our k...↓
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Comment From: Friends of the San Juans (Lovel Pratt)

3/05/23 @ 11:27 AM
The Western States Petroleum Association's comments include the report from Turner, Mason & Company (February 16, 2023) ECONOMIC IMPACT ASSESSMENT OF WASHINGTON STATE PROPOSED AMENDMENT TO WAC CHAPTER 173-180, 184, which states (on page 4):
"The exist...↓
the first implementation of WAC 173-180-330 in 1994."
"Some API STD 650 tanks could require significant modifications or even a rebuild to
meet the more demanding loads accounted for in Annex E."
The MEMBER FACILITY STATISTICS, Storage Tank � Construction Year / Design Standard (page 16) states that of the 283 storage tanks (out of 291) with a known year of construction that would potentially be impacted by a change in the rules, 60% are more than 63 years old and 69% are more than 53 years old.
Ecology should answer these questions: What is the life span of a storage tank? At what age should storage tanks be required to be rebuilt or replaced? How many Class 1 facility storage tanks exceed that age?
To comply with the legislature's direction and to meet existing state requirements, this rule should require the rebuild/replacement of storage tanks that have exceeded their safe usage. All storage tanks should be required to meet API Standard 650 (2020) seismic design requirements, including Annex E and section E.7.3 Piping Flexibility. Also, at the very least, the 10-year compliance schedule should be the effective date of WAC 173-180-080, and not the effective date of this rule.
No attachments

Comment From: Friends of the San Juans (Lovel Pratt)

3/04/23 @ 6:59 PM
Attachments:

Comment From: WSPA (Jim Verburg)

3/04/23 @ 3:34 PM
Attachments:

Comment From: 15 non-governmental organizati... (Lovel Pratt)

3/04/23 @ 12:25 PM
Attached are comments from Friends of the San Juans, Washington Conservation Action, Puget Soundkeeper, San Juan Preservation Trust, RE Sources, Communities for a Healthy Bay, Seattle Aquarium, Earth Ministry/Washington Interfaith Power & Light, Citi...↓
Attachments:

Comment From: Amber Larsen

3/04/23 @ 9:44 AM
Attachments:

Comment From: Roundtable Engineering Solutio... (KahKan Chan)

3/03/23 @ 10:31 PM
Attachments:

Comment From: Dana Crediford

3/03/23 @ 6:33 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Janet Alderton

3/03/23 @ 6:12 PM
Rulemaking Comment Period for Chapter 173-180 WAC and Chapter 173-184 WAC

I'm grateful for the excellent job Governor Inslee does to protect the environment of Washington state. I also very much appreciate the work done by the Washington Dept. of Ecol...↓

I am writing to urge Ecology to protect the Salish Sea by tightening the rules to improve the safety of oil transfer operations in remote anchorages. I have deep concerns over the damage that oil spills do to the marine waters of the San Juan Archipelago, which is a nursery for juvenile salmon.

Many oil transfer operations occur over water in remote anchorage areas. I live on Orcas Island, not far from Vendovi Island. The Vendovi Island Preserve is one of the wildest private islands in the San Juan archipelago. It was a priority for permanent conservation for many years leading up to its protection in perpetuity by the San Juan Preservation Trust in 2010.

There are five anchorage areas near Vendovi Island that are also in proximity to the federally protected San Juan Islands National Monument, San Juan Islands National Wildlife Refuge, and the Padilla Bay National Estuarine Research Reserve.

No oil transfer operations occurred before 2014 in the Vendovi anchorages. But the total volume of oil transfer operations there has increased from 82,500 gallons in 2014 to 18,236,304 gallons in 2021. The Rate B oil transfer operations that were not pre-boomed increased from two in 2014 to a high of 15 in 2020, and 13 in 2021. The volume of oil transferred close to the Vendovi Island Preserve rose from 82,500 gallons in 2014 to 705,567 gallons in 2020.

These oil transfers pose a huge risk because they are in relatively remote areas and lack the spill response resources immediately available like those at terminals and refineries. If an oil spill occurs in a remote anchorage area, it takes time for oil spill response resources to arrive from other locations.

Specifically, I urge the Washington Department of Ecology to take the following actions:

1. Reduce the threats to southern resident killer whales by requiring all oil transfer operation to be PRE-BOOMED when safe and effective to do so.

2. Eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

3. With a major earthquake in Washington state a real possibility, require all secondary containment structures that prevent spilled oil from reach waters of the state to withstand seismic forces.

4. Restrict all oil transfer operations to daylight hours.

These actions by Ecology would improve the regulations that went into effect in 2007 in response to the 2003 Foss Barge Point Wells oil spill involving about 5,000 gallons of heavy fuel oil spilled in an oil transfer operation.

Serious damage to about 400 acres of the Suquamish Indian Reservation's prime cultural and environmental lands, including saltwater marsh, old growth timber, beaches, and clam beds. That spill occurred WITHOUT pre-booming and in the middle of the night.

It's extremely important for Ecology to tighten these oil transfer and oil containment regulations so that we reduce the likelihood of such a disaster.

Thank you for considering my views.

Sincerely,

Janet Alderton
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Comment From: Dana Crediford

3/03/23 @ 4:55 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Washington Conservation Action (Rein Attemann)

3/03/23 @ 1:38 PM
Please find attached 698 public comments from supporters and members of Washington Conservation Action. We expect that each letter to Ecology in this PDF document will be regarded as an individual, unique public comment letter.
With regards.
Attachments:

Comment From: Kristin Edmark

3/03/23 @ 9:56 AM
Please update the rules regarding spill prevention, preparedness and preparedness to better protect our major Washington waterways which are now being used for increased shipping. I support the draft rule's new decommissioning requirements for out of...↓

Please also revise the draft to address:
• Include secondary containment systems, including those before 1994, which can withstand seismic forces in addition to additional seismic protection measures for oil storage tanks and transfer pipelines to help prevent oil spills during earthquakes.
• Eliminate the Rate B loophole and instead require operations to be pre-boomed. Please analyze the safety of any operations which cannot be pre-boomed and restrict those operations to daylight hours.

Thank you for addressing this issue which is so important to the health of wildlife and people of Washington. Thank you for addressing the strengthening of prevention because clean-up, at best, cannot avoid huge destruction in most cases.

Respectfully submitted, Kristin Edmark. MPH RD
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Comment From: Kathryn Alexander

3/02/23 @ 5:32 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: US Oil & Refining Co (Daniel Bourne)

3/02/23 @ 3:18 PM
Attachments:

Comment From: Randy Guthrie

3/02/23 @ 3:14 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Daniel Perl

3/02/23 @ 11:09 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Shellee Nunley

3/02/23 @ 9:33 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Stephanie Trasoff

3/01/23 @ 11:05 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Jonathan Lane

3/01/23 @ 9:06 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Elizabeth Michaelson

3/01/23 @ 7:23 PM
Pre booming seems like an obvious and basic precaution to me! Once we loose our pristine water and its fragile ecosystems, how will we ever retrieve it?
Attachments:

Comment From: Larry Mahlis

3/01/23 @ 6:46 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Pamela Large

3/01/23 @ 5:43 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Rowena Donelson

3/01/23 @ 5:27 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Matthew Stuckey

3/01/23 @ 4:45 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: John Graber

3/01/23 @ 4:26 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

We need to make our water cleaner, not worse.

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Jamie Donaldson

3/01/23 @ 2:10 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: R. Larson

3/01/23 @ 1:38 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Kathryn Beck

3/01/23 @ 1:01 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Jamie Donaldson

3/01/23 @ 12:18 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Susan Pevonak

3/01/23 @ 9:36 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
The Salish Sea is truly a jewel on this planet and why we all live here. Please help protect this ecosystem in which we all rely.
No attachments

Comment From: Lisa Lawrence

3/01/23 @ 6:13 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, improving oil transportation...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out-of-service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:
● Require all secondary containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces;
● Require all oil transfer operations to be pre-boomed (when safe and effective to do so.) This rulemaking should eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.
● Restrict all oil transfer operations to daylight hours, and at the very least, restrict all oil transfer operations to daylight hours if it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Aaron Vahid

3/01/23 @ 1:00 AM
Attachments:

Comment From: Sean Edmison

3/01/23 @ 12:31 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

I urge you to make sure the final rule is as strong as possible, that it holds the oil industry accountable for the risks their operations pose to all of us. In particular, the rule needs to include the following provisions:
Require that any and all containment structures to prevent spilled oil from reaching our waters be designed to withstand seismic forces, and the large-scale earthquake that is overdue to our region;
Require all oil transfer operations to be pre-boomed wherever it is safe and effective to do so, and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.
Restrict all oil transfer operations to daylight hours, or at the very least, restrict all oil transfer operations to daylight hours when its not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington.
No attachments

Comment From: Shaun Hubbard

3/01/23 @ 12:00 AM
Attachments:

Comment From: Paula Rotondi

2/28/23 @ 11:52 PM
I'm a resident of Whatcom County who has walked the Cherry Point beach many times, taken tours of the BP refinery, spent days in a small sailboat in the the Salish sea - oftentimes within sight of BP's and Conoco Phillips' piers and ships. The glarin...↓

Please require additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

I ask that the new rules:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

BP and Conoco Phillips have been making record profits and the cost of these new requirements is a small amount in comparison. I still hope these corporations will consider it their responsibility to take steps to prevent their operations from destroying our shared natural treasures upon which we and all after us depend.

Thank you for leading this process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements per ESHB 1578. Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Heather Merchant

2/28/23 @ 10:05 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Rondi Nordal

2/28/23 @ 9:28 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Julia Spencer

2/28/23 @ 7:51 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: jim lombard

2/28/23 @ 7:30 PM
This legislation should make it mandatory for transfers to be scheduled so the can be monitored, and it is a must that there be pre-booming in understanding the damage done in any spill to the Salish Sea.
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Comment From: Barbara Keller

2/28/23 @ 7:24 PM
I have long been studying the, what I believe to be, impossibility of cleaning up a spill in our San Juan Islands, given the currents, tides and intricate coastlines. And I certainly don't see us giving up fossil fuels any time soon, no matter the s...↓

I support the new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, requiring additional seismic protection measures for oil storage tanks and transfer pipelines to help prevent oil spills during earthquakes, and updating the requirements to mitigate the impacts of spills from oil transfer operations.

To implement ESHB 1578, Reducing threats to southern resident killer whales by improving the safety of oil transportation, this rule should also:

1) Require all secondary containment structures (that prevent spilled oil from reaching waters of the state) to withstand seismic forces;

2) Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming;

3) Restrict all oil transfer operations to daylight hours or, at the very least, restrict all oil transfer operations to daylight hours when it's not safe and effective to pre-boom.
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Comment From: Daniel Ritchie

2/28/23 @ 6:41 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Mary Mooney

2/28/23 @ 5:51 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Lorraine Johnson

2/28/23 @ 5:15 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Rhiannon Le Fay

2/28/23 @ 5:01 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: jon Howe

2/28/23 @ 5:00 PM
Pre-booming for commercial oil transfers should not have a minimum. Have you seen the way oil spreads on the surface?! A minimum is like asking "how much damage is too much" when any amount of damage is too much.
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Comment From: Jeanne Ripp

2/28/23 @ 4:55 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Richard Lyles

2/28/23 @ 4:43 PM
Thanks so much for considering my comments on Chapter 173-180 WAC, Facility Oil Handling Standards and Chapter 173-184 WAC, Vessel Oil Transfer Advance Notice and Containment Requirements.

As a resident of the San Juan Islands, I am deeply concerned a...↓

Decommissioning requirements for out-of-service oil storage tanks and oil transfer pipelines must include additional seismic protection measures for oil storage tanks and transfer pipelines to help prevent oil spills during earthquakes. Importantly, I also ask that you update the requirements to mitigate the impacts of spills from oil transfer operations.

To implement ESHB 1578, Reducing threats to southern resident killer whales by improving the safety of oil transportation, this rule must also:

1) Require all secondary containment structures (that prevent spilled oil from reaching waters of the state) to withstand seismic forces;

2) Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming;

3) Restrict all oil transfer operations to daylight hours or, at the very least, restrict all oil transfer operations to daylight hours when it's not safe and effective to pre-boom.

Respectfully,

R. Brent Lyles
Friday Harbor, Washington
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Comment From: Kathleen Capson

2/28/23 @ 4:38 PM
My husband and I have read the information associated with this issue and agree with all points presented in our commentary. We would like to add that we live a few blocks from the railroad tracks in Blaine and that the action requested in the follow...↓

A few years ago Blaine's fire chief resigned because he said that a rail accident (such as the one which just occurred in East Palestine, Ohio) WILL eventually occur on the tracks in Blaine, and that he had insufficient equipment to fight such an occurance, and therefore he was compelled to save his professional reputation, resign as Blaine's fire chief, and move on to a different community. Which he did. We are pointing this out at this time to bring attention to the fact that regulations to prevent any problems with Whatcom County's and Washington's oil refining industry ultimately ensure the health and safety of everyone. Implementing not only the measures proposed here, but also a broad array of regulations and safeguards, will keep Whatcom County's refinery operations safe, will keep Whatcom County's and WA State's economy strong, will ensure a thriving maritime industry, will protect critical shoreline habitat, and will keep residents safe from problematic oil transfer operations, as well as rail disasters. This is the chief concern of my husband and myself as residents (since 1990) of Whatcom County and Washington Sate.

Thank you for leading a process to amend regulations associated with (a) facility oil handling standards, (b) vessel oil transfer advance notice and (c) containment requirements to IMPLEMENT ESHB 1578, thereby reducing threats to our shorelines, our maritime industry, human health and safety, and the state mandated protection of southern resident Orca whales by taking all necessary measures to oversee and improve the safety of oil transportation.

We unequivocally support: (1) requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, (2) new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, (3) additional advance notice of oil transfers, and (4) disclosure of the type, origin and characteristics of the crude oil being transferred.

IN ADDITION, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to WITHSTAND SEISMIC FORCES and,

Require all oil transfer operations to be PRE-BOOMED (when safe) and,

ELIMINATE THE RATE B LOOPHOLE that allows oil transfers at 500 gallons per minute or less to occur without pre-booming and,

RESTRICT ALL OIL TRANSFER OPERATIONS TO DAYLIGHT HOURS, particularly at times when it is not safe and effective to pre-boom.

Your efforts to IMPROVE ALL ASPECTES CONCERNING THE SAFETY OF ALL OIL TRANSPORTATION in Washington State are CRITICAL, especially for the Lummi Nation, Blaine's oyster beds, Blaine and Bellingham's seafood industry, the existance our our Orca population, the safety of all marine creatures and their habitat, the economy of our region, and many other aspects of this issue too numerous to mention here. Thank you for your service and for DOING THE RIGHT THING to safeguard our precious enviornment.

Kathleen and Zdenek Capson
2/28/2023
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Comment From: Laurence Brown

2/28/23 @ 4:29 PM
Thank you for reviewing regulations for facility oil handling and transfer per ESHB 1578, to reduce threats to southern resident Orca.

I support requiring more safety-increasing seismic protection measures and retrofits for oil storage tanks and trans...↓

In particular, this should include:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the coastal environment of Washington State.
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Comment From: Alice Swan

2/28/23 @ 4:22 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Chris Wolfe

2/28/23 @ 4:19 PM
I support the new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, requiring additional seismic protection measures for oil storage tanks and transfer pipelines to help prevent oil spills during earthquake...↓

To implement ESHB 1578, Reducing threats to southern resident killer whales by improving the safety of oil transportation, this rule should also:

1) Require all secondary containment structures (that prevent spilled oil from reaching waters of the state) to withstand seismic forces;

2) Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming;

3) Restrict all oil transfer operations to daylight hours or, at the very least, restrict all oil transfer operations to daylight hours when it's not safe and effective to pre-boom.
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Comment From: Julie Whitacre

2/28/23 @ 3:06 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Susan Albert

2/28/23 @ 2:59 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: James Hansen

2/28/23 @ 2:34 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Virginia Davis

2/28/23 @ 2:08 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

* Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces.

* Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

* Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Krista Hammer

2/28/23 @ 1:50 PM
I live on the water at Birch Bay and also boat frequently in the Salish Sea. This ecosystem is so fragile, and our Orca whales are at great risk from oil spills. It would be devastating for the whales, our regional tourism, fisheries. Please do every...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Andronetta Douglass

2/28/23 @ 1:12 PM
Bellingham citizens have great concerns about safe train transport of flammable products. We have had a pipeline explosion, a train crash with a fire and a smokestack fire at BP oil refinery. Thank you for leading a process with interested stakeholde...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Martha Hall

2/28/23 @ 12:33 PM
I support closing loopholes in the existing rulemaking and added further protections as recommended because I live in Anacortes and I see the threats posed by our two refineries everyday. I know these refineries and the tanker traffic they generate c...↓

I Also look out from our house and shoreline and see the tankers anchored off Guemes Island waiting to load and unload crude and refined oil and oil products. I see tankers being loaded and unloaded at the refinery docks. All of this loading and unloading is going on next to Padilla Bay which has the second largest eelgrass beds on our west coast, second only to one in Alaska. An oil spill in any of these places would be a disaster for Padilla Bay and all of the marine resources found there, fish, birds, shellfish. I also know the extreme currents we have in these same areas around Fidalgo and Guemes Islands and the mainland. We could sail in our sailboat for hours headed towards Anacortes in Guemes Channel and never make much headway because of the strong current. We watch the current from this current from the windows of our house as the ferry fights to cross the channel. I've also spent time on the beaches of Guemes Island and seen the fierce winds and waves on a north or northeast wind.
This was the wrong place to build refineries and the wrong place to be transferring oil and oil products. We can't seem to get rid of these refineries, but we can at least protect our orcas and other marine resources that can be destroyed by these refineries.

The WA Department of Ecology's draft rule closes a major loophole that exists in current booming requirements. Until this is addressed, oil spills during oil transfers are dangerous.
For these orcas, this loophole could be a matter of life and death. The current requirements for advance notice of oil transfer operations helps with the regulation of these. Pre-booming oil transfers is extremely important. These rules need to address transfers of less than 500 gallons per minute as well as those over 500 gallons per minute. Those under 500 per minute could turn out to be just as deadly.

New decommissioning requirements are also needed for out-of-service oil storage tanks and o8il transfers. More protections are needed to prevent oil spills during earthquakes which we should expect and plan for. Seismic updates for all transfer pipelines and storage tanks are needed including secondary containment systems. Most of the refinery and bulk oil handling facilities in our state were built before 1994. This means they pose a serious threat. We have too many aging facilities who can and do pollute Puget Sound. More and better requirements are needed to make these safer.

I hope the Department of Ecology will do whatever is possible to add further protections like those in this proposal. Our state is spending millions and millions of dollars to try to save our resident orcas because Washingtonians care about these orcas. Ecology must be part of this effort.

There is a good chance that these orcas will disappear from our waters in our lifetimes IF we do not do everything possible to reduce the many threats they face every day they spend time in Puget Sound. We have done a very poor job of keeping our waters clean and healthy in the past. We need to do much better in the future. This draft rule may be the one thing that saves orcas in case of an accident during an oil tranfer operation or an earthquake.

Thank you for this opportunity to comment,
Martha Hall
Anacortes, WA 98221
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Comment From: Simon Bakke

2/28/23 @ 12:13 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Jann Eberharter

2/28/23 @ 11:44 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Shannon Wright

2/28/23 @ 11:30 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Jane Palajac

2/28/23 @ 10:55 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Debra Goldman

2/28/23 @ 10:35 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Dorothy Jordan

2/28/23 @ 10:31 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I strongly support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Denise Weeks

2/28/23 @ 10:31 AM
As a Whatcom County resident who spends a lot of time paddling a kayak in our bay, I want to thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer adv...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Laura Sheehan

2/28/23 @ 10:11 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:
Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces;
● Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.
● Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Stephen Wilson

2/28/23 @ 8:35 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Kimberly Tisovec

2/28/23 @ 7:35 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Eric Hirst

2/28/23 @ 7:00 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Candice Trusty

2/28/23 @ 6:36 AM
Our state needs to do all it can to protect water quality within Puget Sound. Please consider amending regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements.

I support requiring...↓

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts.
No attachments

Comment From: Deborah Stewart

2/28/23 @ 6:25 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Angi Cunningham-Armstrong

2/28/23 @ 6:13 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Carl Golden

2/28/23 @ 6:00 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Andria Bensuaski

2/28/23 @ 4:21 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Jean Mendoza

2/28/23 @ 1:35 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Wanda Cucinotta

2/28/23 @ 1:18 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Robert Mitchell

2/28/23 @ 12:54 AM
I am writing to express my support for the regulations that have been developed to implement ESHB 1578, Reducing threats to southern resident killer whales by improving the safety of oil transportation. I appreciate the effort that has gone into this...↓

I would like to request that the rulemaking also includes the following measures to further enhance the safety of oil transportation in Washington State:

* Requiring all new and existing containment structures to withstand seismic forces to prevent spilled oil from reaching the waters of the state.

* Requiring all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminating the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

* Restricting all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

These measures are necessary to ensure that the safety of our environment and communities is not compromised during oil transportation operations. By implementing these measures, we can reduce the risk of oil spills and protect our natural resources.

Once again, thank you for your efforts to improve the safety of oil transportation in Washington State.

Sincerely,

Robert Mitchell
Olympia, Wa
No attachments

Comment From: Elizabeth Lengel

2/28/23 @ 12:38 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Donita Reams

2/28/23 @ 12:37 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Janet Lehwalder

2/28/23 @ 12:27 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Kimberly Carlton

2/28/23 @ 12:24 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Corbin Ball

2/28/23 @ 12:01 AM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Gail warren

2/27/23 @ 11:56 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Lori Erbs

2/27/23 @ 11:49 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Sasha Savoian

2/27/23 @ 11:44 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Paul Bakke

2/27/23 @ 11:44 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Gloria McClintock

2/27/23 @ 11:41 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Wendy Eakle

2/27/23 @ 11:34 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Tracy Ouellette

2/27/23 @ 11:33 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Stan Parker

2/27/23 @ 11:30 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Meryle Korn

2/27/23 @ 11:29 PM
Thank you for offering a process wherein interested stakeholders can comment on amending regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing ...↓

I strongly support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Barbara Davidson

2/27/23 @ 11:28 PM
Go well. Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats t...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Marguerite Rietz

2/27/23 @ 11:27 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Jillian Froebe

2/27/23 @ 11:26 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: jan gordon

2/27/23 @ 11:25 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Celeste Monke

2/27/23 @ 11:24 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: Margaret Woll

2/27/23 @ 11:24 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
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Comment From: Darcy Carlson

2/27/23 @ 11:13 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

Comment From: james hipp

2/27/23 @ 11:10 PM
Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advance notice and containment requirements to implement ESHB 1578, Reducing threats to southern...↓

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines, additional advance notice of oil transfers, and disclosure of the type, origin and characteristics of the crude oil being transferred.

However, this rulemaking should also:

Require all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

Require all oil transfer operations to be pre-boomed (when safe and effective to do so) and eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming.

Restrict all oil transfer operations to daylight hours, particularly when it's not safe and effective to pre-boom.

Thank you for your efforts to improve the safety of oil transportation in Washington State.
No attachments

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