Submission Number: MBTL-EIS-0002087
Received: 11/15/2013 1:56:20 PM
Commenter: Sanford Olson
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
Surfactants are ubiquitous in the world of modern chemistry; and many consumer and agricultural products use surfactants that are considered "nontoxic" and "biodegradable." But when some of these surfactants contaminate low-oxygen environments, such as fresh water or marine sediments, the biodegradation of the surfactant is incomplete. The resulting compounds can be endocrine disruptors that interfere with the development of fish and amphibians.
BNSF in an understandable effort to suppress fugitive coal dust from open cars during rail transit is proposing to apply dust control agents such as MinTopper S+0150 to the loaded rail cars at the mines. The routes these coal carrying trains travel are over and alongside many rivers, streams and wetlands. While this surfactant may have low toxicity in short term laboratory tests, partially biodegraded surfactants can be endocrine disruptors particularly in fish and amphibian reproduction. Not that long ago, surfactants were considered innocuous until field tests of sewage effluents unexpectedly uncovered their reproductively disruptive breakdown products.
Partial non-ionic surfactant biodegradation in low-oxygen environments such as fresh water sediments (rivers, stream shores, and wetlands) can result in the production of nonylphenol. Alkyl phenols have been documented to have endocrine disrupting effects in fresh water organisms at concentrations as low as 20 micrograms per liter and are known to persist in these environments and thus enter the food chain.
The MinTech technical data sheet says that their product is “practically nontoxic.” This means that test organism mortality is not high when exposed to the product over 48 to 96 hours. Even if MinTopper S+0150 does not contain a non-ionic surfactant related to nonylphenol, multi-year field tests are necessary to understand the true environmental impacts of this and other dust suppression surfactants and their degradation products. Brief lab tests of 48 to 96 hours are inadequate, as toxic synergies may exist between product components or the degradation products of MinTopper S+0150.
Please study the effects of the surfactant products used to reduce fugitive coal dust on the development of fish and amphibians. Given the potential escape of dust during the rail transport (BNSF has admitted to as much as 650 pounds of coal dust per car per trip) and ship loading of millions of tons of coal, please study the cumulative effects of coal dust and the surfactant over the estimated lifetime of coal transport to and at the Millennium Bulk Terminal, including accidental spillage of coal and any surfactant product into riparian systems and waterways.