Submission Number: MBTL-EIS-0000660 

Received: 10/10/2013 3:26:56 PM
Commenter: Lynne Oulman
Organization: 
State: Washington

Agency: Cowlitz County, the Washington Department of Ecology, and the U.S. Army Corps of Engineers
Initiative: Millennium Bulk-Terminals Longview EIS
Attachments: No Attachments
Submission Text
Dear Co-Leads, The Pacific Northwest is home, and I fear for its well-being: water, air, organisms, and people. I am writing to you today to ask you to study the impact of the coal dust & residue that will attend your coal transport plans. No amount of covering or coating will stop all leaking and leaching. This is a foreseeable, significant, adverse impact. There is no sure-fire way to keep coal from leaking and blowing. The coal residue will end up in the Columbia River, and spread out from there. This coal residue will eventually kill all living organisms. Wherever coal is, it contains mercury, lead, arsenic, cadmium, selenium, etc. Poisoning might not happen in a flash, but heavy metals cumulatively will wreak havoc on the water, sea-life, and then us. Ingestion of salmon, etc., will simply transmit back to us, what we have dumped on them. With enough coal dust in and on the water, it will not take long until dead zones appear. There is quite a lot of science out there to explain acidification of the water. Existing dead zones should already alarm everyone because they are the canary in the cage. Please study the impact that any coal residue will have on the local environment, and take into consideration the effects of coal dust in transit all the way from Powder River! Thank you very much for your integrity and attention. 1) Health Risk Study for the Burlington Northern/Santa Fe Railroad Spokane Railyard” http://www.coaltrainfacts.org/docs/BNSF-Spokane-Railyard-Health-Study.pdf 2) Coal Dust and Residue http://www.coaltrainfacts.org/key-facts#air “BNSF has indicated that each coal car loses 500 lbs to a ton of coal dust en route; 80 near shore acres at the GPT terminal site would be covered in open heaps of coal. Newspaper photos of coal dust over two relatively small British Columbia coal ports, one at Westshore and one at Ridley would seem to indicate that dust management, as currently practiced, is not effective. While coal dust is a reported nuisance in coal port communities, the health effects of pulverized coal released into the air have not yet, to our knowledge, been systematically studied. Coal dust inhalation in closed situations is, of course, a different matter, although instructive in the kind of governmental oversight and corporate compliance that is necessary to keep people safe: NPR and the Center for Public Integrity recently reported the resurgence of black lung disease in American miners is due to “weak regulation and industry deception.” It is worth considering that our air is directly affected by what happens in Asia, the market to which GPT would ship coal. The Jaffe Group has proven that mercury emitted by coal combustion in Asia crosses over the Pacific Ocean and pollutes our Northwest water supplies; mercury is implicated in a number of health problems, especially those involving the brain and nervous system. The New York Times has written that sulphur dioxide, which can cause respiratory disorders, likewise blows back to us from Asia. Noted meteorologist and UW atmospheric scientist Cliff Mass has shown that the haze over much of the Pacific Northwest coastline in early summer 2012 was smoke from massive Asian wildfires. What burns in Asia does not stay in Asia: we all breathe the same air. …. Coal dust is notoriously difficult to control. BNSF estimates that each uncovered car loses between 500 pounds and a ton of coal dust en route. It is unknown how much coal dust will be released into the air, onto the land, and into the water from the from the 80-100+ acres of open, continuously turned-over, coal heaps in storage at the terminal site. There are concerns about train derailments, the effects of dust on human health, local clean water supplies, and on the marine environment. The methods of containing coal dust, especially in adverse weather conditions (wind, rain) are unproven, and it is uncertain which party would pay for dust mitigation measures. Because most coal trains are uncovered, they produce significant amounts of coal dust in the course of transporting the coal from one place to another. According to BNSF research, 500 pounds to a ton of of coal can escape a single loaded car. Coal dust is regarded as a nuisance, as the dust can damage the ballast and, the railway claims, cause derailments. BNSF asks that shippers pay for dust mitigation; shippers typically balk at paying. The Puget Sound coast line is notoriously rainy and windy; it is unclear as to how effective surfactants might be at containing the pulverized coal in adverse weather. There seem to be no guarantees that dust would successfully be controlled en route from the mines to the port. Dust is also generated at the terminal site, as bulldozers continually shift and rotate the ground-up coal. Constant turnover is required to both keep the coal in one area, and also to prevent spontaneous combustion. Wind and moisture can agitate the combustive properties of coal. The potential adverse effects of coal dust on adjacent sites was a factor in the Port of Vancouver rejecting a proposal to export coal from a new export site there. The dust is notoriously difficult to control, and has proven to be a concern for residents close to Westshore, the coal port in BC. The coal at the proposed GPT terminal will be stored in open heaps on 80-105 acres located in proximity to the Cherry Point Aquatic Reserve. Cherry Point can be buffeted by high winds, winter conditions often see wind gusts in the 60-70 knot range. It seems likely that the wind will agitate the heaped, pulverized coal. The leaching of toxic heavy metals from coal ash into water supplies is a proven problem. Exposure to arsenic, cadmium, barium, chromium, selenium, lead and mercury can cause any number of health problems, including cancers and neurological diseases. It is unknown if and to what extent these heavy metals might leach out from the coal and/or fugitive coal dust, from the train cars and at the terminal storage site, into local water supplies and into the marine environment. There are potential implications for the safety of the water we drink and the seafood we eat.” 3) Diesel Emissions – not just trains http://www.epa.gov/oms/oceanvessels.htm “Large ships such as container ships, tankers, bulk carriers, cruise ships, and Lakers are significant contributors to air pollution in many of our nation’s cities and ports.”