Submission Number: MBTL-NEPA-DEIS-0003010
Received: 11/29/2016 4:51:15 PM
Commenter: Michael Riordan
Organization: Friends of the San Juans
Agency: The U.S. Army Corps of Engineers, Seattle District (Corps)
Initiative: Millennium Bulk-Terminals Longview NEPA DEIS
MBTL-NEPA-DEIS-0003010-112706.pdf Size = 2908 KB
MBTL-NEPA-DEIS-0003010-112707.pdf Size = 161 KB
MBTL-NEPA-DEIS-0003010-112708.pdf Size = 592 KB
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Dear Officials of the Army Corps of Engineers,
The attached documents constitute my complete comment on the Draft NEPA Environmental Impact Statement (DEIS) on the proposed Millennium Bulk Terminals—Longview (MBTL) project, which was released for public comment on September 30, 2016. There are three documents attached as PDF files:
A. RiordanCommentNEPADEIS.pdf, my official comment on the NEPA DEIS
B. RiordanCommentSEPADEIS.pdf, my official comment on the SEPA DEIS submitted in June
C. AirQualityAppendices.pdf, which describe the fugitive-dust emissions rate calculations by URS Corporation, which are discussed in items A and B above.
Let me briefly summarize here my principal comments on and analysis of the NEPA DEIS:
1. Like the SEPA DEIS, the NEPA DEIS dramatically underestimates the fugitive coal dust that would be released from the MBTL project because of the use of optimistic, unjustified assumptions about possible dust-control efficiencies and crucial input parameters such as coal silt content in the calculations of fugitive dust emissions rates from various terminal operations.
2. The NEPA DEIS ignored or omitted the substantial fugitive coal-dust contributions that would occur due to bulldozing of coal storage piles and due to vehicles traveling roads on the terminal site.
3. Because of the above problems, the fugitive coal-dust emissions rates from the individual terminal operations that were addressed in the NEPA DEIS are low by factors of 2 to 7.
4. Because of the above problems, the total fugitive coal-dust emissions rate is low by a factor of 2.4 to 4.3 (11.05 tons per year versus 26.7 to 46.3 tons/year; this discrepancy will be even higher if the fugitive coal-dust contributions from #2 above are included.
5. Similar underestimates will occur in the emissions of PM10 and PM2.5 coal-dust particulates because similar assumptions are made (and oversights occur) in estimating these emissions rates as the NEPA DEIS presented for estimating total suspended particulates.
6. The output values of from AERMOD simulations of the dispersal of coal-dust PM10 and PM2.5 particulates are likely to be low by similar multiplicative factors as in #4 above because of the low, incorrect values of the input fugitive coal-dust emissions rates.
7. By comparisons with operations at other, similar coal terminals shipping Powder River Basin coal, I estimate that the total fugitive coal-dust emissions will be at least 47 tons/year.
8. The DEIS estimates of fugitive coal dust entering the Columbia River are low by a factor of at least 10. I estimate that the likely values of the coal-dust deposition rate close to the piers range from 14 to 21 grams per square meter per year, versus the maximum value of 1.45 given in the DEIS.
9. The DEIS analysis of coal dust behavior after reaching the waters of the Columbia River is incorrect because a light portion consisting of smaller particles will float, forming unsightly floating mats, while a heavy portion consisting of larger particles will sink to the river bottom downstream of the terminal, fouling it and adversely affecting benthic habitats there.
For details of these arguments and analyses, please consult the documents cited above.
Michael Riordan, Ph.D.