Submission Number: MBTL-SEPA-DEIS-0002490 

Received: 6/10/2016 2:38:48 PM
Commenter: Nancy Crumpacker
Organization: 
State: Oregon

Agency: Cowlitz County and the Washington Department of Ecology
Initiative: Millennium Bulk-Terminals Longview SEPA DEIS
Attachments: No Attachments
Submission Text
I am an oncologist from Portland. I urge you to select the "No Action Alternative" in the EIS as presented on your website as of June 10, 2016, because it does not contain a Health Impact Statement (HIA). Is this HIA limited as your website (http://www.millenniumbulkeiswa.gov/health-impact-assessment.html) stated on 6/10/2016: The assessment will focus on neighborhoods near the proposed project, and community facilities along the BNSF rail line in Cowlitz County? How can the remainder of the citizens of Washington who live along the train tracks be ignored? Diesel exhaust particulate matter causes asthma, heart disease, lung disease, and cancers of the digestive tract, breast and lung. It causes brain development disorders in children. Exposure in pregnant females is associated with lung and heart disorders in their offspring. Diesel exhaust in the gaseous phase contains benzene, formaldehyde, acrolein, 1,3-butadiene, formaldehyde and polycyclic aromatic hydrocarbons-all carcinogens. Coal dust inhalation causes chronic obstructive lung disease, pneumoconiosis and diminished lung function. Coal dust contains the neurotoxins mercury and lead; and the carcinogens arsenic and polycyclic aromatic hydrocarbons. Lead ingestion can cause anemia, hypertension, and chronic kidney disease. A comprehensive HIA should address the potential human health impacts and mitigation strategies along the entire length of the statewide train corridor (in Washington and Oregon) in addition to those at the project site. It should address the potential health impacts and mitigation strategies along the Washington/Oregon shipping lanes. What will be the coal dust and diesel particulate matter (PM2.5 and PM 10) exposure to people living at 50 ft, 100 ft, 200 ft, 500 ft, 1000 ft from the tracks when a coal train passes-on a daily and annual basis? How will wind and rain runoff affect exposures? What will be the coal dust and diesel particulate matter (PM2.5 and PM 10) exposure to people living at 50 ft, 100 ft, 200 ft, 500 ft, 1000 ft from the Columbia River in Longview and along the river from Longview to the mouth of the Columbia River as coal-laden ships pass-on a daily and annual basis? How will wind and rain runoff affect exposures? To address the full range of health impacts, experts need to know the chemical composition of the Powder River Basin coal and the Uinta Basin coal. What are the expected medical care costs to the state when vulnerable populations use state funds to treat their cancers and lung/heart diseases-short-term and long-term? What is the cost to local and state tax payers who fund education for those suffering neurologic development disorders like ADHD, autism spectrum disorder and lowered IQ? What is the cost to local and state tax payers who fund the judicial system to deal with the increase in delinquent behavior of lead-exposed youth? What is the cost to the state in lost production of public and private employees? How will these figures change over the next 20 and 30 years? What mechanisms will be put in place to monitor the impacts on health of exposed citizens and the efficacy of mitigation methods? Modeling should use either the California Office of Environmental Health Hazard Assessment tools and modeling protocol or the EPA Air Toxics Community Multiscale Air Quality Model to predict multiple pollutant effects on the affected communities. The modeling protocol should be approved by the Washington Department of Ecology and the EPA. The modeling should be performed by consultants familiar with the models and with interpreting the results. In the absence of a comprehensive health impact assessment, I urge you to select the "No action alternative".