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

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Comment From: Teresa Allen

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

Comment From: Deborah Parker

2/27/23 @ 11:04 PM

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:

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: Tristan Weiss

2/27/23 @ 11:02 PM

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 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: Deborah Kaye

2/27/23 @ 10:57 PM

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:

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: Dagmar Fabian

2/27/23 @ 10:54 PM

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:

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: Lise Grace

2/27/23 @ 10:49 PM

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:

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: Lynne Pendleton

2/27/23 @ 10:43 PM

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:

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: David Laws

2/27/23 @ 10:39 PM

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:

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: Eleanor Hines

2/27/23 @ 10:35 PM

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:

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: Faye Bartlett

2/27/23 @ 10:29 PM

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:

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: Lynn Billington

2/27/23 @ 10:24 PM

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:

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. I worked at an oil refinery and for a government agency. I know we need more safeguards to make oil transfer safer. Thanks for your consideration as a Professional Engineer with a Master Degree.

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Comment From: Dean Wight

2/27/23 @ 10:10 PM

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:

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: Glen Anderson

2/27/23 @ 10:07 PM

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:

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: Wesley Banks

2/27/23 @ 10:02 PM

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:

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: Rhonda Barrett

2/27/23 @ 10:01 PM

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:

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: Charlie Maliszewski

2/27/23 @ 10:00 PM

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:

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: Tika Bordelon

2/27/23 @ 9:59 PM

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:

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: Amy Mower

2/27/23 @ 9:57 PM

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:

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: Valerie Day

2/27/23 @ 9:51 PM

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:

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: Scott Dawson

2/27/23 @ 9:39 PM

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:

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: Valerie Rose

2/27/23 @ 9:38 PM

For the sake of the whales! 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, ...↓

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:

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: Dirk Vermeeren

2/27/23 @ 9:35 PM

As a retired oil industry professional and having managed the Chevron Pt Wells Refinery at Richmond Beach I fully support requiring additional seismic protection measures, retrofits for oil storage tanks and transfer pipelines, updating decommissioni...↓

Your leadership in the process with interested stakeholders to amend regulations is timely. Reducing threats to our Salish Sea and specifically southern resident killer whales by improving the safety of oil transportation, facility oil handling standards and vessel oil transfer advance notices and containment requirements to implement ESHB 1578.

However, this rulemaking should also:

To address a forecasted Cascadia Rising I suggest requiring all new and existing containment structures (that prevent spilled oil from reaching the waters of the state) to withstand seismic forces:

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: Leslie Brinson

2/27/23 @ 9:32 PM

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:

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: Betty Barats

2/27/23 @ 9:27 PM

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:

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: Sonja Hinz

2/27/23 @ 9:27 PM

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:

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: Dorothy Neill

2/27/23 @ 9:19 PM

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:

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: Elena Rumiantseva

2/27/23 @ 9:17 PM

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:

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 Bailey

2/27/23 @ 9:16 PM

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:

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: Tina McKim

2/27/23 @ 9:13 PM

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:

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: Rick Romito

2/27/23 @ 9:10 PM

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:

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: Lynn Rosenblum

2/27/23 @ 9:09 PM

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:

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: Jeff Daffron

2/27/23 @ 9:05 PM

Please implement ESHB 1578, Reducing threats to southern resident killer whales by improving the safety of oil transportation.

I support requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines, new ...↓

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:

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: Janis Olson

2/27/23 @ 9:05 PM

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:

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: Erik LaRue

2/27/23 @ 9:04 PM

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:

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 Hamill

2/27/23 @ 9:01 PM

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:

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: Friedrich Ulrich

2/27/23 @ 9:00 PM

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:

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: Nick Barcott

2/27/23 @ 8:58 PM

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:

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 Bartlett

2/27/23 @ 8:57 PM

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:

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: Andrew Davis

2/27/23 @ 8:44 PM

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:

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: Kirsti Charlton

2/27/23 @ 8:42 PM

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:

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: Barry Meyers

2/27/23 @ 8:42 PM

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:

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: Margarette Grant

2/27/23 @ 8:41 PM

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:

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: Glenn Wilson

2/27/23 @ 8:41 PM

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:

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: Lyle Anderson

2/27/23 @ 8:40 PM

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:

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: Andrew Reding

2/27/23 @ 8:37 PM

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:

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: Jennifer Campbell

2/27/23 @ 8:33 PM

This couldnt be any more important. Every preventative action we take protects our unique & beautiful waterways.

Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vess...↓

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:

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: Jeremy Harrison-Smith

2/27/23 @ 8:33 PM

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:

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 White

2/27/23 @ 8:30 PM

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:

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 Lamb

2/27/23 @ 8:29 PM

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:

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: Sarah Bauman

2/27/23 @ 8:28 PM

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:

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: Norm Conrad

2/27/23 @ 8:27 PM

Get ready; the next two paragraphs may take a while to digest.

Thank you for leading the process with interested stakeholders to amend regulations over facility oil handling standards and vessel oil transfer advance notice and containment requirements...↓

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:

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: Tom M

2/27/23 @ 8:27 PM

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:

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: Christopher Loar

2/27/23 @ 8:26 PM

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:

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: Morgan Kay

2/27/23 @ 8:24 PM

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:

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: Belinda Hovde-Klingman

2/27/23 @ 8:17 PM

As a former WQ Inspector with Ecology's NWRO (1991-2003), I strongly support these efforts.

Thank you for leading a process with interested stakeholders to amend regulations associated with facility oil handling standards and vessel oil transfer advan...↓

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:

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: Susie Edwards

2/27/23 @ 8:15 PM

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:

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: Alissa Vanlandingham

2/27/23 @ 8:12 PM

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:

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: Mary Holder

2/27/23 @ 8:12 PM

I live in Skagit County and am concerned about that vessel oil transfers at our two refineries can cause irreparable harm to the Orca whales, fish and birds that depend on the Salish Sea for their continued survival. I thank you for leading a proce...↓

Specifically, 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:

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: Joanne Allison

2/27/23 @ 8:11 PM

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:

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: Cheryn Zimmer

2/27/23 @ 8:11 PM

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:

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: David Scheer

2/27/23 @ 8:10 PM

Thank you sovery much for 'leading' a process with interested stakeholders to AMEND regulations associated with facility oil handling standards and vessel oil transfer advance notice ...PLUS containment requirements to implement ESHB 1578...which wou...↓

I VERY STRONGLY SUPPORT requiring additional seismic protection measures and retrofits for oil storage tanks and transfer pipelines...PLUS new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines...PLUS additional advance notice of oil transfers....AND disclosure of the type, origin and characteristics of the crude oil being transferred! Get all of these done, would you?!?

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!

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!

And...THANK YOU SO MUCH for your efforts to improve the safety of oil transportation in Washington State (!!)

No attachments

Comment From: Steve Garey

2/27/23 @ 8:06 PM

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:

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: Ursula Mass

2/27/23 @ 8:05 PM

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:

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 Kemp

2/27/23 @ 8:04 PM

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:

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: Eileen Kiera

2/27/23 @ 8:03 PM

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:

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: Jay Kosa

2/27/23 @ 5:15 PM

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:

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: Genevieve Shank

2/27/23 @ 5:01 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.

No attachments

Comment From: HF Sinclair Puget Sound Refini... (Gautam Kini)

2/27/23 @ 4:07 PM

Attachments:

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Comment From: Paul Manz

2/25/23 @ 8:45 AM

For the interdependent health of our communities and our environment, I strongly urge you to make decisions to reasonably keep oil transportation as safe as possible. This is especially important to consider in an area predisposed to earthquakes with...↓

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Comment From: David Turnoy

2/24/23 @ 9:22 PM

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;

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: Miriam Margulies

2/24/23 @ 7:01 PM

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 Hampel

2/24/23 @ 12:09 PM

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;

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: John Tester

2/16/23 @ 6:34 AM

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Comment From: Anonymous Anonymous

2/16/23 @ 6:28 AM

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Comment From: San Juan Preservation Trust (Dean Dougherty)

2/16/23 @ 1:00 AM

Well, thank you. Again this is Dean Dougherty. I'm with the San Juan Preservation Trust and Brittany has my contact information. But I will email it to you just to confirm that. First of all, I wanted to thank everyone at Ecology for going through th...↓is process and I understand that you know your efforts are to protect the waters of Washington State and we appreciate that. I wanted to, so I wanted to start by saying, you know, when we kicked off this meeting it was, it was mentioned that the reason that this is all happening is because of the passage of EHH, ESHB 1578, reducing the threats to Southern resident killer whales by improving the safety of oil transportation. Now I'm going to limit my comments just about the vessel transfer rule and I'm not really seeing how the proposed rule changes are reducing the threats for oil spills. My preference would be to see two changes: First, for all oil transfers to be pre-boomed when it is safe and effective to do so, and secondly, to restrict all transfers to daylight hours. I understand that there are constraints to accomplish those changes, but even if they're not possible I would like for you to explore ways to move closer to that ideal. Ecology is required to scale requirements to risk. When the rules were written, the cutoff between Rate A and B transfers was set at 500 gallons per minute, and those levels may have been appropriate at the time, but at least for Vendovi Island much has changed since the rules were written. When the rules were written, the number of Rate B oil transfers were two in 2014 and they've increased to 15, the high point in 2020. And also 13 in 2021. And the volume of Rate B oil transfers was only 82,000 gallons in 2014 but they've risen to over 700,000 gallons in 2020. Well that 500 gallon per minute cutoff may have been defensible if you're talking about less than a 100,000 gallons, it gets less defensible when you approach a million gallons of oil being transferred near the shores of the nature preserves at Vendovi and Jack Island. So in conclusion, I'm just, I just like to say, I don't think that we are accomplishing reducing threats to killer whales unless the rules either reduce oil transfers at night or make sure that a higher percentage of oil transfers are pre-boomed. Thank you.

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Comment From: Washington Conservation Action (Rein Attemann)

2/14/23 @ 1:00 AM

Thank you Fran. For the record, Rein Attemann, Washington Conservation Action. I would like to start off by thanking Ecology staff for leading a process with all these interested stakeholders to amend regulations associated with the facility oil hand...↓ling standards and the vessel oil transfer advance notice and containment requirements. And we support the requirements for 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, and additional advance notice of oil transfer, and some of the other amendments that have been made and Brittany alluded to earlier. However, this rulemaking, we believe, should also include some additional measures like requiring all secondary containment structures to withstand seismic forces. I think, Lovel’s comments or questions in the Q&A need to be addressed more clearly because W, the WAC 173-180-320(8)(b) states that secondary containment systems must be designed to withstand seismic forces. And we know that spills from storage tanks and pipelines are likely to occur in major earthquakes, making secondary containment all more important to contain that spilled oil. And given that earthquakes will happen, secondary containment systems are not required to be updated and maintained to withstand seismic forces do not comply with the definition of secondary containment in WAC 173-180-025, which says that secondary containment means containment systems would prevent the discharge of oil from reaching waters of the State. And just a reminder that Rcw 90.56.005(2) concludes that the primary objective of the State and Ecology is to achieve a zero spill strategy to prevent any oil or hazardous substances from entering waters of the state. So the draft rule should be revised to require all Class 1 facility’s secondary containment systems to be updated and maintained to withstand seismic forces. And also, second big loophole that we see is the need to require all oil transfer operations to be pre-boomed when safe and effective to do so and this rulemaking should eliminate the Rate B loophole that allows oil transfers at 500 gallons per minute or less to occur without pre-booming. We feel that the oil spill risk associated with the rate B oil transfer warrants protective and preventative measures which are more cost effective now, then, the damages and costs occured from an oil spill in the future. So thank you for all your efforts and the opportunity to provide public comment, and we'll be submitting some written comments by the fifth of March. Thank you.

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Comment From: San Juan Preservation Trust (Elaina Thompson)

2/14/23 @ 1:00 AM

Hello, my name is Elaina Thompson and I am the Vendovi Island caretaker for the San Juan Preservation Trust. If you hear my daughter in the background, I apologize, she is with me in this meeting. So I'm the caretaker, and I've been asked to repres...↓

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Comment From: John Tester

2/09/23 @ 3:24 PM

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Comment From: John Tester

2/09/23 @ 3:22 PM

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Comment From: John Tester

2/09/23 @ 3:15 PM

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Comment From: Anonymous Anonymous

2/09/23 @ 3:12 PM

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Comment From: Anonymous Anonymous

2/07/23 @ 3:36 PM

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Comment From: Joseph DeBin

1/29/23 @ 4:54 PM

Please take action to prevent future disasters.

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;

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: LeeAnn Chastain

1/29/23 @ 11:21 AM

Washington must pass more effective measures to regulate oil transfers from vessels in our coastal waters. I support advance notification of such transfers but also the requirement of pre-booming to mitigate any potential oil spill. The oil and gas i...↓

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Comment From: Victoria Miller

1/29/23 @ 11:20 AM

Americans have never paid the true cost of oil and gas production and transportation in this country. Keeping our waterways safe (clean) is a common sense priority, and if the cost per gallon of fuel is slightly increased by doing so, we are willing ...↓

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Comment From: Barbara Keller

1/29/23 @ 7:16 AM

I want to thank you for finally taking on this important and timely update. There is probably no one other more dangerous threat to our waters than an uncontained oil spill. While I have personally taken training in oil spill response, the one real...↓

I want you to know of my support for 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 and all other, though less dramatic species, 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 - it's not like we don't have earthquakes!

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. (But, hey, maybe they should not be done under those conditions at all!)

Thank you for your consideration.

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Comment From: David Turnoy

1/27/23 @ 6:12 PM

I want to second the comments of Janet Alderton:

I am very concerned about the negative impacts of fossil fuels that are spilled on our lands and into

our waters. Spilled oils can spread rapidly unless they are contained by barriers, such as booms that...↓

are put in place before oil is transferred. I oppose the 500 gallon per minute threshold for the

pre-booming requirement. There should be no threshold. When oil will be transferred in marine

waters, there must be pre-booming.

I also support the new decommissioning requirements for out of service oil storage tanks and oil

transfer pipelines as well as requirements for additional seismic protection measures for oil storage

tanks and transfer pipelines to help prevent oil spills during earthquakes.

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: Mary Ferm

1/27/23 @ 2:56 PM

As the granddaughter of marine biologists who worked at Friday Harbor labs, and then retired on San Juan Island, I am very concerned about the dangers presented by outdated oil spill containment systems for ships passing around the San Juans. We als...↓

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;

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: Janet Alderton

1/27/23 @ 2:03 PM

I am very concerned about the negative impacts of fossil fuels that are spilled on our lands and into our waters. Spilled oils can spread rapidly unless they are contained by barriers, such as booms that are put in place before oil is transferred. I ...↓

I also support the new decommissioning requirements for out of service oil storage tanks and oil transfer pipelines as well as requirements for additional seismic protection measures for oil storage tanks and transfer pipelines to help prevent oil spills during earthquakes.

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;

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: Alice Swan

1/27/23 @ 1:46 PM

This is critically important.

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;

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: Susan Hampel

1/27/23 @ 1:37 PM

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;

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: Susan Kimball

1/27/23 @ 11:25 AM

I definitely support tighter regulation of oil transfers and oil spill prevention.

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Comment From: Elise Cope

1/26/23 @ 3:12 PM

To implement ESHB 1578, Reducing threats to southern resident killer whales by improving the safety of oil transportation, this rulemaking 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; and, 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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