AES Sparrows Point LNG, LLC and

AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number DR3 1 Global: General Comments AES Sparrows Point LNG, LLC’s Responses: (a) In many instances, the response “This has been clarified in the September 27, 2006 filing of Resource Report 1” (or similar language) can get confusing for long sections. In future submittals of responses to our comments on draft resource reports, please change the title of the “Responses Located in Resource Report Number” column to “How addressed”; this column should contain how AES has addressed or is addressing the comment (as AES has done in many instances.) The final column, “Responses Located in Section Number,” should direct the reader to the exact location where any modification was made. (b) List of References i. ii. List References alphabetically Provide a URL for each reference that you are aware is available on the web/Internet. If not available on the web/Internet, include each reference any contact information contained in the reference regarding where to obtain the document (e.g., typically on the back side of the title page in standard, published book format; or often a contact person or This change has been made. URLs have been provided for the appropriate References. Reference availability information has been provided where not 1.11 1.11 This Response Matrix and remaining other pending Response Matrices have been reformatted accordingly for future submittals. Page 1of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number office is listed in gray literature). obvious within the reference citation DR3 2 DR1 #9 (c) Address the power plant entirely within Section 1.10. (If you feel a Section 1.3.3.4 is needed, just mention it there in one or two sentences and cross-reference Section 1.10.) 1.3.1 & DR1 #9: In Section 1.3.1 of RR 1, you state that the “LNG Terminal will be located on an approximately 60-acre parcel within the existing Sparrows Point Industrial Complex located in Baltimore County, Maryland, with approximately 30 acres of upland area and the remainder of the site a near shore riparian rights area.” Provide a preliminary plot plan to show the relationship of the proposed facilities to the upland versus the near shore riparian rights area. Confirm that the 5.5 acres of uplands dedicated to the “Dredged Material Recycling Facility,” referenced in Section 1.5.3.1, is included in this 30-acre upland area.  Define “riparian rights area” (or cross-reference to where it is explained) including what entity has designated it as such and any restrictions on use of that area. The power plant discussion has been moved to Section 1.10. 1.10 Defined riparian rights area as designated and in relation to permits. No restrictions of area 1.3.1 Page 2of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number identified. DR3 3 1.3.3.1: (a) Section 1.3.3.1, third paragraph: Revise the Appendix designation (e.g., Appendix 1D, not Appendix D) using the Resource Report number in front of the appendix letter would be consistent with the Table of Contents, and with the other Resource Report designations of appendices, and would eliminate potential confusion over which appendix to which you refer. (b) Part B, second paragraph states: “The turning basin and approach channel will provide an access point for approaching LNG ships (from the existing Brewerton Channel to the southeast).” Should this be “to the southwest?” (c) Part B, second paragraph: In the third sentence, “slow speed” leaves room for interpretation: Would the following be accurate? “The speed of the incoming LNG ship will be gradually reduced during its transit of the Brewerton Channel until, by the time it reaches the entrance of the approach channel to the LNG Terminal, it will have been slowed sufficiently to operate safely in the waters adjacent to the terminal.” Please clarify. Pipeline Description Appendix designations have been corrected. 1.3.3.1 The text has been corrected to indicate “southwest.” Te text has been modified with this suggested language. 1.3.3.1 1.3.3.1 Page 3of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number DR3 4 DR1 #22 1.3.2.6 & DR1 #22: In Section 1.3.2.6, Mid-Atlantic Express describes conceptual plans for placement of mainline valves. Milepost locations for the valves will be required for the application. Concern with valve placement distance and protection of the public has been raised during scoping. MidAtlantic Express should comment on the criteria to determine distance between valves to protect the public (i.e., to minimize gas release in an accident), in addition to the requirements of 49 CFR Part 192. Valve locations should be indicated by milepost (text or table) and presented on the alignment sheets. Valve locations are now referenced on the Alignment Sheets and in the text. Figure 1.3-3 (Sheets 1-10) and Section 1.3.3.3.A DR3 5 DR1 # 24 Table 1.4.1 & DR1 #24: Aboveground Facilities. Use the column headers “Land Disturbed During Construction” instead of “Temporary” and “Land Required for Operation” instead of “Permanent.” Clarify the footnote to this table that “an additional 30 acres of the site are near shore riparian rights area.” Does this mean that the 30 acres of near shore riparian rights area will not be impacted by construction or operation of the LNG terminal? The referenced footnote has not been clarified. The table footnotes have now been clarified. Table 1.4.1 DR3 6 DR1 #25 Table 1.4-2 & DR1 #25: Pipeline Facilities. See comments above for Table 1.4-1. Note that the text in section 1.4.1.2, beginning with “Temporary Page 4of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number construction land requirements for the pipeline …” does not match the table. The text states that the 896 acres of temporary impact includes the anticipated access roads, yards and CROW, whereas Table 1.4-2 implies that the access roads, yards and office/trailers are in addition to the 896 acres of pipeline facilities. Please clarify. The same comment applies for the apparent discrepancy in the “permanent” column of the table compared to the language of the text. Add a “Total” row at the bottom of the table. Make any additional changes to minimize apparent contradictions and confusing text (e.g., the text states that the temporary acreage includes access roads, however the acreage for permanent access roads is “TBD”; the temporary acreage is stated to include the access roads, yet the permanent acreage does not include them, thus making the acreages not comparable; and the acreage totals in the text do not match those in the table. Construction Procedures 1.5.2.4 & DR1 #30: In section 1.5.2.4, there is a description of potentially using processed dredged material to backfill behind the new shoreline bulkheading. Public comments have been made asking if it is acceptable to fill the area behind the bulkhead with dredged material which potentially could be contaminated. A total row has been added at the bottom. The notes associated with the table have been clarified. Table 1.4.1.2 Table 1.4.1.2 DR3 7 DR1 #30 Page 5of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number Address the following: a. Give the criteria and sampling procedures that would be used to ensure that any bulkhead fill material will be free of contaminants. Discuss the stability of the processed dredge material and indicate how AES would ensure that leachate of potential contaminants within the processed dredged material would not lead to pollution of the harbor. Section 1.5.1.1.D: (a) AES states that “Fill to bring the site to grade will be obtained from the processed dredge material (PDM), pending determination of engineering and environmental properties and matching of the schedule between the dredge operations to initial construction of the LNG Terminal.” Where will AES acquire fill material if the engineering and environmental properties (e.g., chemical composition and potential contamination) are not suitable? (b) When will AES perform its additional sampling and characterization of the sediment in the proposed dredge area? The text has been revised to indicate commercial sources will be utilized if needed. The text has been revised with date if necessary. Currently no additional sampling is planned unless 1.5.1.1.D 1.5.1.1.D Page 6of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number required by US COE permit conditions. The text has been revised to clarify. DR3 8 1.5.1.2: Section 1.5.1.2.A, third paragraph: The first sentence of this paragraph conveys the impression that the BWI dredging permit may apply to the Sparrows Point LNG terminal project. Would the following statement more accurately describe the situation: “Some of the same dredge areas required for the LNG Terminal are also subject to approvals under the BWI Permit…” 1.5.1.2 & DR1 #35: Provide further clarification of how decanted or processed water (from dewatering the dredge material) will be tested for contaminants and provide more details for complying with existing water quality criteria. In the event of non-compliance with existing standards, describe the procedures for disposal of contaminated water. This can be discussed in draft RR2.  AES’s revised RR1 does not describe the procedures for disposal of contaminated decanted or processed water in the event of noncompliance with existing standards. 1.5.1.2.A DR3 9 DR1 #35 The text has been revised to address contingencies of disposal of contaminated water, if needed. 1.5.1.2 DR3 10 DR1 #37 1.5.1.2 & DR1 #37: In the description of the dredged material recycling facility, AES states that the facility will occupy approximately 5.5 acres of upland terrain within the facility boundaries. You also state that an additional 20 acre site will Page 7of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number be used as a “temporary Processed Dredged Material (PDM) storage area.” In Appendix 1.C Dredging Plan, Figure 1C-2 (stamped CEII), the locations of two 20-acre PDM storage areas are shown on the map. Are these two alternative locations, or is there a need for two 20-acre PDM storage areas? Figure 1.3-2a indicates that the Dredged Material Recycling Facility and PDM storage area would occupy one 15-acre site. Are the two PDM storage area sites shown on Figure 1C-2 still valid alternative sites for this Facility? If so, the other sites should be addressed (i.e., described and compared to the proposed site) in RR10. DR3 11 1.5.1.2:  Section 1.5.1.3.H.5: The appropriate sheets of Figure 1.3-6 – or the appropriate case on Sheet 4 of Figure 1.3-6 – should be cross referenced throughout this section. The text and figures have been revised to clarify and reflect current proposed configuration. 1.5.1.2.A and Figures 1C-1, 1C-2, 1C-3. Figure 1.3-6 has been superceded by Resource Report 2 - Appendix 2B BMP and site specific crossing drawings. References to appropriate drawings have been inserted in text accordingly. 1.5.1.3.H.5 DR3 12 DR1 #43 Figures and Appendices Figure 1.3-5 & DR1 #43: Address the following issues concerning figures: Page 8of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number a. Figure 1.3-5 is confusing. There is no description for the difference in Type I construction and Type II construction. Also these dimensions of a 100-foot-wide construction ROW do not appear to match the text (Section 1.3.2.5) which describes the typical construction ROW as 75 feet. Explain the discrepancy. Additionally, the terms “Lateral Loop” or “Lateral Replacement” should not be used in Figure 1.3-5 (Sheet 2). For Figure 1.3-5, Sheets 3 – 6, please provide title – and explanation in the figure, if necessary – that indicates the circumstances being illustrated, i.e., not "Proposed Pipeline Typical Construction ROW" for all of these. Also, currently Sheet 6 shows a CROW of 75 feet even with topsoil segregation; this does not correspond to text which indicates 75 feet only in areas with no topsoil segregation. Also, Sheets 3 – 6 seem to indicate topsoil segregation everywhere. This does not match the text. Please clarify. Figure 1.3-6 Sheet 4, note for Case D: Define “ARN.” This was a typo in the Draft figure; in addition, the figure has been superceded Appendix 2B. b.  Page 9of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number with Figure 3 in Appendix 2B, “Best Management Practices” Figure set. DR3 13 DR1 #44 Appendix 1C & DR1 #44: For Appendix 1.C, Dredging Management Plan, provide the following information: a. comments on the draft Dredging Management Plan from consultation with the appropriate permitting agencies (including the COE, U.S. Environmental Protection Agency, National Marine Fisheries Service, Maryland Department of Natural Resources);  These comments are not in the September 26, 2006 version of Appendix 1C. Correspondence to date on the Dredge Management Plan has now been incorporated in Appendix 1C. Appendix 1C DR3 14 DR2 #2 1.6 & DR2 #2: AES does not refer to some of the major issues raised during the scoping process, e.g. terrorism and security, safety, tanker routing and operational concerns, proximity of infrastructure, thermal exclusion zone, and vapor cloud analysis. The Guidance Manual at p 3-2 asks for “existing Page 10of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number conditions or resources that may be directly or indirectly affected by the project or that may affect the project.” The public will use RR 1 as an overview and should at least be directed to where the information can be found on potential impacts.  Add a note to the first paragraph of Section 1.6 directing to the location of the Waterway Suitability Assessments. Reference note added. 1.6 DR3 15 DR2 #3 DR2 #3: Provide a table of the construction techniques to be used by milepost. Account for special construction techniques to be used for difficult terrain, residential areas, and agricultural (cropland) areas. Cross-reference drawings of typical construction profiles for each construction technique.  A table of proposed construction methods for wetland crossings has not been provided. This information has been added to Table 2.5-1 and cross referenced in Section 1.5 1.5 Table 2.5-1 DR3 16 DR2 #5 Specific Comments DR2 #5: When will a decision on the power plant be made and what are the factors or criteria for making the decision?  Decision-making criteria are not provided. Additional input regarding decision making criteria for 1.10 Page 11of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number Power Plant has been incorporated. DR3 17 DR2 #8 DR2 #8: Quantify in miles the use of existing right-of-way. Provide a table of collocation by milepost.  Neither a table nor any other quantification has been provided. (The bullet list in the third paragraph of Section 1.3.2 does not provide the requested information; the distances in that bullet list are not restricted to portions of the proposed Mid-Atlantic Express route colocated with or parallel to existing right-of-ways.) A new table containing requested data has been included. Table 1.3-1 DR2 1 Global: Though not a filing requirement, it would be easier to review the resource reports (RR) against FERC’s Environmental Report Guidance Manual if it followed the Guideline’s title and numbering scheme starting at page 3-6, ie. 1.1 Proposed Facilities; 1.1.1 Purpose and Need, etc. Account for all of the minimum requirements by either explaining why the information was not included or saying exactly when it will be filed (See FERC Guidance Manual p 3-3). DR2 2 Global: AES does not refer to some of the major issues raised during the scoping process, e.g. terrorism and security, safety, tanker routing and operational concerns, proximity of infrastructure, thermal exclusion zone, and Due to the extent of the effort to renumber Resource Reports, Figures, Tables, Maps, Data requests and responses filed to date, AES has considered this recommendation and decided not to update the numbering in RR1 to follow the numbering in the FERC Guidance. In addition, the FERC Guidance is limited to pipelines; the numbering in the drafts is more workable for addressing both the LNG Terminal and the Pipeline. This issue has been clarified 1.6 in the September 27, 2006 submission of Resource Page 12of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number vapor cloud analysis. The Guidance Manual at p 3-2 asks for “existing conditions or resources that may be directly or indirectly affected by the project or that may affect the project.” The public will use RR 1 as an overview and should at least be directed to where the information can be found on potential impacts. DR2 3 Global: Provide a table of the construction techniques to be used by milepost. Account for special construction techniques to be used for difficult terrain, residential areas, and agricultural (cropland) areas. Cross-reference drawings of typical construction profiles for each construction technique. Report 1, 11 and 13 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 1.3.4 Appendix 1A Resource Report 2 – Sections 2.4.8, 2.5.2, Tables 2.4-1 and 2.51 Appendix 2B BMPs DR2 4 Global: As the project becomes more defined, provide tables indicating: 1) Road and railroad crossing by milepost. 2) Foreign pipeline crossings by milepost. 3) Access roads, location, length and area. This issue has been clarified in the September 27, 2006 submission of Resource Report 1 1.4.1.1, 1.4.1.2 Tables 1.4-1 and 1.42 Appendix 1A Page 13of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number Resource Report 8 – Sections 8.3.2, 8.3.3, 8.3.4 and 8.3.5 Tables 8.3.2-1, 8.3.22, 8.3.3-1, 8.3.4-1, 8.3.5-1 DR2 5 Specific Comments 1.3: When will a decision on the power plant be made and what are the factors or criteria for making the decision? This issue has been clarified in the September 27, 2006 submission of Resource Report 1 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 This issue has been clarified in the September 27, 2006 submission of Resource 1.3.3.4 DR2 6 1.3: Provide information on customers or delivery volumes for the pipeline (FERC Guidance Manual p 3-6). Provide information on where the LNG is coming from or the status of the Section 3 import license. 1.3: What is the status of the interconnect agreements with the other pipelines? 1.2.2 and 1.3.1 DR2 7 1.3.3.3 DR2 8 1.3.1: Quantify in miles the use of existing right-of-way. Provide a table of colocation by milepost. 1.3.2 Page 14of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number DR2 9 1.3.1: - Quantify the positive impacts to communities and landowners (or if this is presented in Resource Report 8, cross-reference this resource report). - Explain why no increase in pipe capacity would be needed to increase sendout. - Provide length, beam and draft of the LNG tankers and contrast to current ship traffic using the existing channels to Sparrows Point and to Baltimore Harbor. 1.3.2: When will the final dredging plan be filed? Report 1 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 and in Resource Report 8 filed September 14, 2006 An updated dredging plan was submitted as Appendix 1C of the September 27, 2006 filing of Resource Report 1. To the extent the plan changes further, AES will also submit the plan with the formal filing of RR1 currently anticipated in the January 2007 AES will submit the final construction procedures in with the formal filing of RR1 currently anticipated in the January 2007 1.3.2 , 1.3.3.3.a and 10.3.2 - Appendix 1D DR2 10 Appendix 1C DR2 11 1.5: When will final construction procedures by milepost be filed? Appendix 1AAlignment Sheets; Tables 2.4-1, 2.5-1 and 7.4-2. Page 15of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number DR2 12 1.5.3.1: Who are the prospective customers for the recycled dredged material? This issue has been clarified in the September 27, 2006 submission of Resource Report 1 AES has updated this information in the September 27, 2006 filing of Resource Report 1 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 1.5.1.2.A DR2 13 1.9: The 1.3 mile proximity of residents has changed since the proposed pier location moved north (closer). What is the new distance to the closest residence? 1.10: The Four-factor test analysis should be provided for the non-jurisdictional facility. (See FERC Guidance Manual, p 3-23) 1.3.3.1 DR2 14 1.3.3.4 DR1 1 Address the following general issues: b. The maps need to be at a more legible scale. Final pipeline alignment sheets for the application will need to meet FERC Guidance Manual requirements (i.e. scale no smaller than 1:6,000, or 1 inch = 500 feet). Provide a Word document version of future Resource Reports to FERC staff. b. Appendix 1A, Alignment Sheets are at a scale of 1:6000 Submissions are currently being provided to the FERC in both b. Appendix 1A c. c. c. Previous draft revision provided. Page 16of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number Word and PDF formats d. d. Spell out acronyms first time they are used in the text [e.g. Baltimore Gas & Electric (BG&E)] and Texas Eastern Transmission Corporation should be abbreviated as TETCO. Use “alternative routes” not “alternate routes.” e. Text is has been updated per comment in all Resource Reports The language “alternative routes” has been used in RR-10 (Alternatives) submitted to the FERC, and is updated in the version of RR1 submitted September 27, 2006 AES is utilizing “mllw” throughout d. Globally e. e. Globally f. Use a standard reference throughout document for water depth (such as below mean sea level [msl] or below mean lower low f. f. Globally Page 17of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number water [mllw]). each resource report this language has been utilized in the September 27, 2006 update of Resource Report 1 Statements are derived from EIA 2005 This issues has been clarified in the September 27, 2006 filing of Resource Report 1 The market area has been clarified in the September 27, 2006 filing of Resource Report 1 1.2.1 DR1 2 DR1 3 Purpose and Need Are the bullets regarding underlying conditions in the U.S. gas market, on pages 1 and 2 of Resource Report (RR) 1, statements from EIA (2005), or are there other sources for these statements AES states that the project will provide “the market with a new supply of reliable, competitively priced LNG.” Can AES state the competitiveness of the gas to the wholesale or retail market? The purpose of the proposed Sparrows Point Project (as stated in the alternatives section) is to "introduce a new incremental supply of natural gas into the MidAtlantic Region and Baltimore area markets to help serve the growing demand for energy in those markets in a safe, reliable and economic manner." The use of "Mid-Atlantic Region" to set boundaries on the scope of the alternatives analysis is understandable, but should be further described (i.e., the U.S. census defines this region as New York, New Jersey, and Pennsylvania). Section 1.2.2 of RR 1 mentions that “In addition to serving the Mid-Atlantic 1.2.2 DR1 4 1.2.2 DR1 5 The market area has been 1.2.2; Page 18of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number market, the Sparrows Point Project will also serve sections of the south Atlantic market, specifically focusing on the Maryland, Virginia, and Washington D.C. markets.” Provide a clearer Purpose and Need statement in Section 1.2 to address all markets that the project is intended to serve and the relative amount of the gas that would be delivered to each market Why is the Baltimore area the only area specifically listed in the project purpose? This could be viewed as skewing the alternatives analysis toward the Baltimore area, whereas no regional areas (e.g., Wilmington, DE; Philadelphia, PA) in the Mid-Atlantic Region are listed. Is this because a greater percentage of the gas will serve the Baltimore area? Provide further documentation/justification concerning the reason for including Baltimore in the purpose and need statement. clarified in Resource Report 1 and Resource Report 10 Covered in general throughout RR10 10.3, 10.4 and 10.6; and Appendix 10A 1.2.2 DR1 6 The market area has been clarified in the September 27, 2006 filing of Resource Report 1 DR1 7 DR1 8 Project Description In the opening paragraph of the Project Description, give a citation to the U.S. Department of Transportation (USDOT), FERC and U. S. Coast Guard standards and requirements, or cross-reference where these standards, requirements and codes will be cited. The statement that “Mid-Atlantic Express LLC has selected a route that maximizes the use of existing utility and highway rights-of-way, thereby minimizing potential impacts to individual landowners…” is not necessarily correct for the congested portions of the route. Modify, qualify, or support the This has been clarified in the September 27, 2006 filing of Resource Report 1 This statement has been clarified in the September 27, 2006 filing of Resource Report 1 1.3 1.3 Page 19of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number DR1 9 statement. In Section 1.3.1 of RR 1, you state that the “LNG Terminal will be located on an approximately 60-acre parcel within the existing Sparrows Point Industrial Complex located in Baltimore County, Maryland, with approximately 30 acres of upland area and the remainder of the site a near shore riparian rights area.” Provide a preliminary plot plan to show the relationship of the proposed facilities to the upland versus the near shore riparian rights area. Confirm that the 5.5 acres of uplands dedicated to the “Dredged Material Recycling Facility,” referenced in Section 1.5.3.1, is included in this 30-acre upland area. In Section 1.3.1 of RR 1, regarding discussions with BG&E, by the time of the filing of the application this fall, will Mid-Atlantic Express know if the agreement with BG&E will allow true “co-location” of a portion of the right-ofway (ROW), thus narrowing the construction ROW, or will the ROWs merely abut each other? A modified and updated property general arrangement was submitted with a RR-1 update of 18 August 2006 and is also addressed in the September 27, 2006 update of RR-1 Discussions remain ongoing, ROW information updated (with information available to date) in the final submission of Resource Report 1 in January 2007 This has been addressed in RR-10 submitted to the FERC, and is addressed in RR-1 updated version submitted September 27, 2006 This issue has been clarified 1.3.2 Figure 1.3-2 Sheet 6, and new Figure 1.32a 1.5.1.2 DR1 10 1.3.2 DR1 11 In Section 1.3.1 of RR 1, general discussions of criteria for your alternatives analysis are appropriate, in a summary format, but discussions of “desirability” of one route versus another should be left to Resource Report 10. 1.3.2 DR1 12 In the criteria for route selection, the example of “short-term disruptions due to 1.3.2 Page 20of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number construction activities” would appear to be a way of minimizing negative impacts not a positive impact as implied. DR1 13 Section 1.3.2.1 is titled “LNG Terminal Marine Facility” but the section discusses both the water-based facilities such as the berths and trestle, and the land-based facilities such as the process equipment, the boil of gas (BOG) compression system, and the storage tanks. If AES intends to distinguish between the “marine facilities” and “the LNG Terminal” as a whole, please provide a description of the terms early in this section. Section 1.3.2.1 mentions that LNG tankers would “leave in ballast condition.” Volumes of ballast water withdrawn and impacts associated with water withdrawals should be discussed in the appropriate future Resource Reports, such as water resources and fisheries. Section 1.3.2 discusses the need for installation of steel pipe piles and section 1.5.3.3 discusses the need for steel sheet pile for the construction of the LNG Terminal. Discuss the installation impacts associated with the various pile driving techniques (vibratory or impact pile driving hammer) and methods to minimize impacts (such as curtains, monitoring and scare charges) in the appropriate future Resource Reports, including geology and soils, marine mammals, fisheries and essential fish habitat, and noise. in the September 27, 2006 submission of Resource Report 1 This issued was resolved in the August 18, 2006 update of Resource Report 1 1.3.3.1 DR1 14 Addressed in September 5, 2006 submission of Resource Report 2 To be covered in Resource Reports: Water, Wetland and Wildlife Impacts have been assessed in the September 5, 2006 submission of Resource Reports 2 and 3 Impacts to Geologic and Soil Resources have been assessed in Resource 2.4.9.2 DR1 15 Water Impacts 2.4.8.2 Wetland Impacts 2.5.2 Fisheries Impacts 3.3.3 Vegetation Impacts 3.4.3 Page 21of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number Reports 6 and 7 submitted on September 8, 2006. Land Use Impacts have been assessed in Resource Report 8 Noise impacts have been evaluated in RR-9 Section 9.4.4.1, submitted on 23 August 2006 Wildlife Impacts 3.5.3 Endangered and Threatened Species Impacts 3.6.2 Geologic Hazards 6.6 Avoidance and Minimization Procedures 6.7 Soil Construction and Operation Impacts 7.4 Residential and Commercial Area Impact ad Mitigation 8.4.4 Public Land, Recreation or Other Designated Area Impact and Mitigation 8.5.6 Visual Resources 8.6 Page 22of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number Noise Impacts 9.4.4.1 System Design Resource Report 13 Appendix M.2, Document 06909DS-200-204 Air Emissions 9.3.2.2.D and Appendix 9A Firewater System 13.17 Firewater Intake Structure 2.4.9.2 DR1 16 Section 1.3.2.2 LNG Receiving, C. Boil Off Gas Compressor indicates three reciprocating type boil off gas compressors. Include a detailed description (manufacturer, horsepower, model, etc,) of each of the three reciprocating type boil off gas compressors (as well as any other compressors and air emission sources anticipated for the entire project), including air emissions anticipated and a noise analysis for Resource Report 9. DR1 17 In Section 1.3.2 add a subsection discussing safety and firefighting systems. For the firefighting system, describe the source of the firewater, and any backup system. If any of these systems would depend upon marine water for a water source, describe the intake system. This issue has been clarified in the September 27, 2006 submission of Resource Report 1, although system design is discussed in Resource Report 13 and air emissions and noise have been discussed in RR-9 Section 9.3.2.2.D and Appendix 9A This issue has been clarified in the September 27, 2006 submission of Resource Report 1 Safety and Firefighting systems are discussed in Resource Report 13 submitted on September 1, 2006 and the fire water intake is discussed in Resource Report 2 Page 23of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number submitted on September 5, 2006. This issue has been updated in the September 27, 2006 submission of Resource Report 1 This issue has been clarified in the September 27, 2006 submission of Resource Report 1; additionally, systems are discussed in Resource Report 13 submitted on September 1, 2006 This issue has been clarified in the September 25, 2006 submission of Resource Report 1, the September 1, 2006 submission of Resource Reports 2 and 3, the September 8, 2006 DR1 18 DR1 19 Section 1.3.2.1 indicates that the “final geometry and layout of the approach channel and turning basin is determined through fast-time and real-time simulations studies.” Indicate when these studies and the final design for the channel and turning basin would be completed. Section 1.3.2.4 E. LNG Regasification references the use of vertical shell and tube heat exchangers for regasification. Indicate whether this system is still proposed and whether any outside water would be needed for the glycol water solution. 1.3.3.1 HP LNG Vaporization 13.5.48.6 HP LNG Vaporizer system 13.5.48.7 Cooling Water 13.5.37 DR1 20 Pipeline Description In Section 1.3.2.5, please correct your use of the terms Construction Right of Way (CROW), temporary, and Permanent Right-of-Way (PROW) and the acreages associated with those terms. For example, in at least some cases, you use “CROW” for what is actually the temporary ROW. Please make sure your terminology regarding this is consistent throughout the ER, and that your acreages (e.g., in Tables 1.4-1 and 1.4-2) correctly reflect the terminology you use. FERC requires tables on work space to tabulate “Land Affected During 1.3.3.3 Table 1.4-1 Table 1.4-2 As well as throughout Resource Reports 2 through 13 Page 24of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number Construction (acres)” and “Land Affected During Operation (acres)” as such: a. The construction acreage is all-inclusive. The CROW for the pipeline should consist of the PROW plus temporary ROW. Any additional temporary work spaces outside the typical construction ROW configuration, pipe storage yards, contractor yards and access roads should each be listed separately under construction impacts for the project. The operations acreage (for the pipeline) is only the permanent ROW and any mainline valves that are integrated into the PROW. Aboveground facility operations (i.e. meter stations and mainline valves) should each be accounted for separately under operation impacts for the entire project. submission of Resource Reports 6 and 7, and the September 13 submission of Resource Report 8. b. DR1 21 In Section 1.3.2.5, the paragraph which begins “Pipeline facilities will be installed within a 50-foot-wide permanent easement …” is confusing. The description should progress from the most likely (or typical) construction 75foot-wide CROW, with reference to a figure, to exceptions or specific construction ROWs in special circumstances (such as a 100-foot-wide CROW in agricultural areas), each referring to a figure to illustrate the exception. Include in the descriptions and figures any estimated permanent and/or construction This issue has been clarified in the September 27, 2006 submission of Resource Report 1 And the September 1, the 2006 submission of Resource Reports 2 and 3, 1.3.3.3 Table 1.4-1 Table 1.4-2 As well as throughout Resource Reports 2 through 13 Page 25of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number ROW overlap with existing ROWs. the September 8, 2006 submission of Resource Reports 6 and 7, and the September 13 submission of Resource Report 8. This issue has been clarified in the September 27, 2006 submission of Resource Report 1 DR1 22 DR1 23 In Section 1.3.2.6, Mid-Atlantic Express describes conceptual plans for placement of mainline valves. Milepost locations for the valves will be required for the application. Concern with valve placement distance and protection of the public has been raised during scoping. Mid-Atlantic Express should comment on the criteria to determine distance between valves to protect the public (i.e., to minimize gas release in an accident), in addition to the requirements of 49 CFR Part 192 Interconnect Facilities. The description of these facilities references interconnects to BG&E. These BG&E locations are not on the project maps. Provide maps showing the BG&E interconnect Table 1.4.1 Aboveground Facilities. Use the column headers “Land Disturbed During Construction” instead of “Temporary” and “Land Required for Operation” instead of “Permanent.” Clarify the footnote to this table that “an additional 30 acres of the site are near shore riparian rights area.” Does this mean that the 30 acres of near shore riparian rights area will not be impacted by construction or operation of the LNG terminal? Table 1.4-2 Pipeline Facilities. See comments above for Table 1.4-1. Note 1.3.3.3.A Table 1.4-1 DR1 24 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 1.3.3.3.A Table 1.4-1 DR1 25 This issue has been clarified Table 1.4.2 Page 26of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number that the text in section 1.4.1.2, beginning with “Temporary construction land requirements for the pipeline …” does not match the table. The text states that the 896 acres of temporary impact includes the anticipated access roads, yards and CROW, whereas Table 1.4-2 implies that the access roads, yards and office/trailers are in addition to the 896 acres of pipeline facilities. Please clarify. The same comment applies for the apparent discrepancy in the “permanent” column of the table compared to the language of the text. Construction Procedures In Section 1.5, AES states that it may request variances to the FERC Plan and Procedures in the future. The potential date for such variance request was given as “about September of 2006.” Clarify if this variance request will be in the next Draft of RR 1, or in the application filing RR 1 proposed for November. In either case, the request for variances should include a justification of why each variance is being requested. If the variances include changes in construction or permanent ROW dimensions, please provide an engineering analysis (with drawings or figures) of why different ROW dimensions are being requested. Regarding construction mitigation procedures, we recommend that typical mitigation procedures be summarized in RR 1. However, specific or detailed measures, plans, procedures, drawings and specifications should be included in the appropriate Resource Reports (2 – 13) and incorporated into RR 1 by crossreference. Section 1.5.1 indicates that there would be “follow-up inspections of all in the September 27, 2006 submission of Resource Report 1 DR1 26 This issue has been clarified in the September 27, 2006 submission of Resource Report 1, and with the submission of Resource Report 2 on September 5, 2006 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 and in Resource Reports 2 through 13 filed to date. Pending submission of 1.5 Appendix 2A to Resource Report 2 DR1 27 1.5 DR1 28 Appendix 2A to Page 27of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number disturbed areas after the first and second growing seasons to determine the success of revegetation.” Confirm that per FERC’s Procedures, Mid-Atlantic Express would monitor and record the success of wetland revegetation annually for the first 3 years after construction or until wetland revegetation is successful. September 27, 2006 update of Resource Report 1, AES’ Environmental Construction Plan was included with the submission of Resource Report 2 on September 5, 2006 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 Resource Report 2 DR1 29 In section 1.5.2.4, there is a reference to Figure 1.3-2 which is stamped CEII. It would be helpful to have a similar figure that could be released to the public to show the future bulkhead and the existing finger slips that will be demolished. 1.5.2.4: In section 1.5.2.4, there is a description of potentially using processed dredged material to backfill behind the new shoreline bulkheading. Public comments have been made asking if it is acceptable to fill the area behind the bulkhead with dredged material which potentially could be contaminated. Address the following: a. Give the criteria and sampling procedures that would be used to ensure that any bulkhead fill material will be free of contaminants. Figure 1.3-2a DR1 30 1.5.1.1.D Discuss the stability of the processed dredge material and indicate how AES would ensure that leachate of potential contaminants within the processed Page 28of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number DR1 31 dredged material would not lead to pollution of the harbor. 1.5.2.9: Section 1.5.2.9 Stormwater Management system. Will there be conceptual or preliminary drawings of the stormwater collection/treatment system in future drafts of RR 1 or 13? Please verify the schedule of when these details are forthcoming. This issue has been clarified in the September 27, 2006 submission of Resource Report 1, and shown in detail in RR-13, submitted on September 1, 2006. This issue has been clarified in the September 27, 2006 submission of Resource Report 1, additionally included in the September 5, 2006 submission of Resource Report 2 Stormwater 13.7.6 Resource Report 13 Appendix U.5 and U.6 DR1 32 DR1 33 1.5.3: Section 1.5.3 LNG Terminal Offshore Construction. In the subsection on Dredging, AES states that “the area to be used for LNG vessel approach and maneuvering has been dredged in the past and maintains a permit issued by the US Corps of Engineers (COE) and Water Quality Certification from the State of Maryland to perform dredging using hydraulic or mechanical techniques.” This statement is at odds with numerous public comments that the area proposed to be dredged has not been actively dredged for a relatively long time. Please explain this apparent discrepancy. Specifically, provide the current dredge permit number and permitted authority to which you refer. Provide a summary of the dredging history of this area, as available through COE files, or other historical resources. 1.5.3.1: Similarly in section 1.5.3.1, AES states that “dredging is allowed under existing permit for maintenance and waterfront operations to a depth of -39 ft across approximately the same area as would be developed for the Sparrows Point LNG terminal project.” Clarify if you are referring to the BWI Sparrows Point LLC permit issued in May of 2005. If this is the case, provide a drawing Marine Dredging 2.4.8 Contaminated Sediment 2.4.3 This issue has been clarified in the September 27, 2006 submission of Resource Report 1, additionally included in the September 1.5.1.2.A Marine Dredging 2.4.8 Page 29of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number overlaying the dimensions of the BWI Sparrows Point LLC project with your projected project area to be dredged. In the event that the BWI Sparrows Point LLC project is implemented before AES Sparrows Point LNG facility, estimate the additional volume of the dredging material that would be necessary to complete the AES channel and turning basin design. If this depends upon bathymetric data that has not yet been collected, provide a schedule as to when this task can be completed. 1.5.1.2: Regarding the discussion on the dredged material recycling facility, there are several quantities cited (10,000 cubic yard per day facility; dredging production of 12,000 cubic yards per day, and dredged material transport of 5,000 cubic yards per day) that do not appear to match. Provide clarification. If the difference is the amount of water processed per day, provide this clarification. 1.5.1.2: Provide further clarification of how decanted or processed water (from dewatering the dredged material) will be tested for contaminants and provide more details for complying with existing water quality criteria. In the event of non-compliance with existing standards, describe the procedures for disposal of contaminated water. This can be discussed in draft RR 2 1.5.1.2: In the appropriate Resource Report, provide more information on the daily tonnage and traffic of vehicles hauling processed dredged material out of Sparrows Point. How does this relate to current traffic in and out of the existing port facilities? 1.5.1.2: In the description of the dredged material recycling facility, AES states 5, 2006 submission of Resource Report 2 DR1 34 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 1.5.1.2.A – Dredging Operations DR1 35 DR1 36 DR1 37 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 and the September 1, 2006 submission of RR-2 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 They are alternate sites, as 1.5.1.2.A – Dredging Operations; Appendix 1C; and 2.4.8 1.5.1.2.A – Dredging Operations 1.5.1.2.A – Dredging Page 30of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number that the facility will occupy approximately 5.5 acres of upland terrain within the facility boundaries. You also state that an additional 20 acre site will be used as a “temporary Processed Dredged Material (PDM) storage area.” In Appendix 1.C Dredging Plan, Figure 1C-2 (stamped CEII), the locations of two 20-acre PDM storage areas are shown on the map. Are these two alternative locations, or is there a need for two 20-acre PDM storage areas? 1.5.1.2: Because of the issues raised during the scoping process concerning the placement of dredged material storage (temporary or permanent), it would be useful to have a figure available to the public that shows the approximate location of these PDM storage areas. Please provide a location map, without CEII information, that can be used to show the potential PDM storage areas, in relation to the proposed LNG terminal site. 1.5.3.1: Under Section 1.5.3.1, under Dredging Operations, AES states that dredging “will be conducted utilizing a mechanical (clamshell) dredge, or if conditions warrant, with an environmental bucket or suitable alternative as requires by permit.” Due to considerable public concern regarding sediment contaminants, provide AES’s criteria under which environmental bucket dredging would be the dredging method of choice. Describe, citing the literature, what the likely efficiencies are (i.e., reduction of water contamination, or reduction of loss of dredged material) that have been measured using environmental buckets, compared with more typical clamshell dredge buckets. If available, cite any project experience (not just yours, but anyone’s) with using environmental buckets in contaminated sediment settings. [NOTE: This clarified with submission of September 25, 2006 update of RR-1 Operations; Appendix 1C; and Figure 1.3-2a DR1 38 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 1.5.1.2.A – Dredging Operations; Appendix 1C; and Figure 1.3-2a 1.5.1.2.A – Dredging Operations; Appendix 1C;and Section 2.4.8 DR1 39 This issue has been clarified in the September 25, 2006 submission of Resource Report 1 and the September 1, 2006 submission of RR-2 Page 31of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number description and analysis can be provided in the Dredging Management Plan or Resource Report 2 as part of the analysis of dredging impacts on water quality. 1.5.3.1: In section 1.5.3.1, the paragraph discussing “Other potential options for management of dredged material,” AES mentions “off-site disposal, open ocean disposal at approved off-shore locations, and upland fill sites.” then states that these alternatives are not as viable as the proposed recycling alternative. In RR 10, AES should provide more information and an alternatives analysis comparing the recycling alternative to these other disposal methods and provide details of each alternative and how the proposed method is better than the others. 1.5.4.4: Under section 1.5.4.4, in the subsection on Nondestructive Examination, Inspection and Weld Repair, verify that the welds are 100% inspected by non-destructive examination (NDE) (e.g.. x-ray examination or ultrasonic examination). There has been concern at public meetings that a lower percentage of welds (less than 100%) might be inspected for the pipeline 1.10: Section 1.10 Non-jurisdictional facilities indicates that AES is investigating the possibility of building a “300 MW” combined cycle cogeneration facility adjacent to the LNG terminal site and additional information would be provided within 90 days of the initial Resource Report 1 filing, relative to the power plant facility and its anticipated effects on project layout and schedule. Additional information should include a detailed description (manufacturer, horsepower, model, etc,) of the gas turbine and steam DR1 40 This has been addressed in RR-10 submitted 14 August 2006 10.5.2 DR1 41 DR1 42 They will be 100% inspected and This issue has been clarified in the September 25, 2006 submission of Resource Report 1 Comment addressed in RR9, and will is clarified in the September 25, 2006 submission of Resource Report 1 1.5.1.3.D.3 9.3.2.4; 9.3.3; Appendix 9A; 9.4.4.3; 1.10 Page 32of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number turbine, including air emissions anticipated and a noise analysis for Resource Report 9. Also identify any permits/authorizations that would be needed for construction or operation of the power plant, including a timeline for applying for these approvals. Figures and Appendices 1.3.5: Address the following issues concerning figures: a. Figure 1.3-5 is confusing. There is no description for the difference in Type I construction and Type II construction. Also these dimensions of a 100-foot-wide construction ROW do not appear to match the text (Section 1.3.2.5) which describes the typical construction ROW as 75 feet. Explain the discrepancy. Additionally, the terms “Lateral Loop” or “Lateral Replacement” should not be used in Figure 1.3-5 (Sheet 2). For Figure 1.3-5, Sheets 3 – 6, please provide title – and explanation in the figure, if necessary – that indicates the circumstances being illustrated, i.e., not "Proposed Pipeline Typical Construction ROW" for all of these. Also, currently Sheet 6 shows a CROW of 75 feet even with topsoil segregation; this does not correspond to text which indicates 75 feet only in areas with no topsoil segregation. Also, Sheets DR1 43 This issue has been clarified in the September 27, 2006 submission of Resource Report 1 Figure 1.3-5 and 1.36 have been superceded by BMP Figures #2 (2a-2d) and #3 b. Page 33of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number 3 – 6 seem to indicate topsoil segregation everywhere. This does not match the text. Please clarify. DR1 44 Appendix 1.C: For Appendix 1.C, Dredging Management Plan, provide the following information: a. comments on the draft Dredging Management Plan from consultation with the appropriate permitting agencies (including the COE, U.S. Environmental Protection Agency, National Marine Fisheries Service, Maryland Department of Natural Resources); a list of any permits/authorizations that would be needed for the dredging operations and the operation of the recycling facility, including a timeline for applying for these approvals; and specific details on each alternative dredging method and dredged material disposal as discussed above in questions 39 and 40. This issue has been clarified in the September 27, 2006 submission of Resource Report 1 Appendix 1C b. c. Page 34of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1. AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Environmental Resource Report 1 and Summary of Alternatives dated 24 July 2006 (DR1) with additional comments received on September 14, 2006 (DR2), November 28, 2006 (DR3) and MD DNR PPRP comments dated 16 October 2006 (PPRP DR1) Data Item or Responses Request Comment How Comment Was Located in No. No. Section: Comment Addressed Section Number PPRP DR1 1 The report indicated that the water would come from either potable municipal supply or the Patapsco River. A withdraw from the river would be subject to an appropriations permit from the Maryland Department of the Environment (MDE). No water is required for the proposed 300 MW power plant. Should the applicant pursue the Power Plant option, this unique design element will be addressed as part of the Certificate of Public Convenience and Necessity (CPCN) as required by the Maryland Public Service Commission. The potential sources of water for the LNG tank and pipeline hydrostatic testing has been included. No water is planned for the potential Power Plant option. Resource Report 2 2.4.5.2 (tanks) 2.4.5.1 (pipeline) PPRP DR1 2 2.4.9.3 Page 35of 35 The Maryland Department of Natural Resources (MD DNR) Power Plant Research Program (PPRP) list of data requests came in letter dated 16 October 2006, from review of Resource Reports 1-13. The list provided within this matrix comprises the PPRP comments on Resource Report 1.