Even before amendments come in about its environmental impacts, the last of six coal terminals proposed for the Pacific Northwest is on the ropes, having been denied a crucial sublease by the Washington Department of Natural Resources. And the coal dust it would release into the surroundings may be the final nail in its coffin.
First proposed in 2012 at a projected cost of $680 million, the Millennium Bulk Terminal on the Columbia River in Longview, Washington, was designed to ship up to 48 million tons (44 million metric tons) of coal annually. As expected, terminal advocates touted the family-wage jobs it would bring to the area, while ignoring or dismissing adverse impacts such as climate change, train noise, traffic blockages, and coal dust. “If complaints continue about dust, we will know it’s a device just to deceive,” said Millennium executive Bill Chapman. “Facts do matter.”
As a Ph.D. physicist and science historian, I agree. Facts indeed matter. And when it comes to estimating fugitive coal dust—that which escapes from trains and port operations into the surroundings—I could not find very many of them when I looked deeply into the draft Environmental Impact Statement (DEIS) for the project, which is supposed to provide detailed factual information about its environmental risks. There was unsupported conjecture aplenty, but few well-founded facts.
As I explained at length in my formal comments on the DEIS, the official analysis seriously underestimates releases of fugitive coal dust from the Longview facility by a factor of between 2.4 and 4.2. Releases from individual operations within the terminal—for example, from coal-pile wind erosion—are low-balled by factors of up to 7. And some dust-generating processes, such as bulldozing the storage piles and trucks driving on terminal roads, are completely ignored, so the underestimates must be even worse.
I had to dig deeply to get at the underlying “facts,” which were not easily accessible. The crucial calculations of fugitive coal dust emissions rates, performed by subcontractor URS Corporation, curiously cannot be located on the project’s official web site; only a summary of these calculations can be found there. For the details, I had to specifically request other documents from the Washington Department of Ecology, including several appendices in which these calculations were finally presented.
How did the environmental analysis end up with such large underestimates of fugitive coal dust? For one, the authors used unwarranted and optimistic physical parameters in their emissions calculations. Compounding this problem, they applied unjustified and unreasonably high efficiencies for dust-control measures (such as watering the coal piles). For example, URS Corporation used the lowest possible value, 2.2 percent, for the coal silt content in estimating fugitive dust from wind erosion of the storage piles rather than the US Environmental Protection Agency’s standard value of 8.6 percent for western surface coal, thereby underestimating the dust loss by a factor of 3.9. And the authors then applied a high efficiency factor of 95 percent for watering the coal piles without sufficiently justifying their use of such an optimistic number. Taken together, these unwarranted and unsupported assumptions yielded coal dust estimates that are probably low by nearly an order of magnitude.
Apparently no one involved actually checked these estimates by comparing them with operating experience at other coal terminals. There were trains loaded with Powder River Basin coal rumbling past Longview almost daily, for example, but nobody seemed to have thought to obtain a few samples of this coal and actually measure the silt content. Instead, URS Corporation engineers cherry-picked the smallest value they could find in tables published by EPA and used that number in their calculations. Good, professional engineers and scientists establish facts by comparing tentative hypotheses and calculations with real, measured data. This was not done for the Longview terminal’s fugitive coal dust estimates.
Also improperly treated in the Longview DEIS was the loss of coal and the fugitive coal dust generated during the ship-loading process. This has proved to be one of the largest sources of coal dust at other terminals I have examined, such as those in Delta and Prince Rupert, British Columbia; Duluth, Minnesota; and Seward, Alaska. As much as half the total coal losses from these terminals occur during ship loading, and almost all of those losses end up in the waters below, either drifting away with the currents or sinking to the bottom and contaminating it.
The URS Corporation calculations lumped the ship-loading losses together with other losses from the entire coal conveyor system (which transfers coal from storage piles to the ship holds) and obtained total emissions of only 5.25 tons per year, again assuming a high 95 percent efficiency factor. But when I calculated just the ship-loading losses using reasonable values for wind speeds, coal moisture content, and dust-suppression efficiency, I obtained 5.9 tons per year for that operation alone. And essentially all of that coal would drop directly into the Columbia River.
A good example of what happens during ship loading can be found at the Westshore Terminals in Delta, BC, on the Salish Sea just north of the border. That port can load up to 33 million metric tons annually, so it’s roughly equivalent in coal-loading volume to the proposed Longview terminal. And it uses similar loading technologies, with the ship-loading tube extending well down into the carrier holds to try to minimize escaping dust. But a comprehensive 2006 examination of the coal losses at Westshore revealed coal accumulations on the sea floor near the piers that exceeded 10 percent of the natural sediments found there, and the dominant portion of that coal came in grains too large to have drifted very far.
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A revealing photograph of a bulk carrier being loaded at Westshore shows what actually happens during the ship-loading process. Winds blowing over the holds suck coal dust up and out of them due to the famous Bernoulli effect, which physicists and aeronautical engineers all recognize. Some of this dust is then deposited on the deck while the rest drops directly into the waters below, drifting away on the currents. Lummi Nation fishers working south of the terminal have witnessed and photographed this process, too.
Take a closer look at this photograph, particularly at the small pile of coal in the foreground. This is coal lost due to human error when the operator moves the ship-loader from one hold to the next, as is done many, many times during loading to keep the vessel balanced. It is coarse-grained coal just like that found on the sea floor adjacent to the terminal’s piers.
In the Longview terminal’s fugitive-dust analysis, the DEIS authors made no serious attempt to account for coal-spillage losses due to human error. From what I can tell, in fact, the URS Corporation engineers included only wind-driven dust with tiny grain sizes less than 10 micrometers. Such a glaring omission leads to another gross underestimate of the coal losses, particularly those that would occur at the piers and fall directly into the Columbia River, sinking to the bottom and contaminating nearby shorelines.
All told, including realistic wind-driven losses plus those arising from operator error, I estimate that between 10 and 15 tons of coal would enter the Columbia annually—the equivalent of a full dump truck load—if the terminal were to operate at its peak capacity of 48 million tons per year. Although that corresponds to only about a tenth of a teaspoonful per ton of coal loaded, it really adds up when loading so many millions of tons annually. And that doesn’t include losses from other kinds of mishaps, such as a carrier collision with the pier or conveyor system, as happened at Westshore in December 2012.
In general, based on actual operating experience at other comparable coal terminals like Westshore, we should expect the Longview facility to release between 6 and 10 tons of coal for every million tons loaded. That’s less than a measly 0.001 percent. But if we apply those figures to the maximum Longview capacity, we obtain overall coal losses of 290 to 480 tons per year. Even if we optimistically assume that the Longview terminal’s coal-loading efficiency could somehow be improved so much that losses of only 0.0001 percent occur, or less than half a teaspoonful per ton, that still adds up to 48 tons per year. That’s more than four times as much as the 11 tons that was estimated in the draft EIS for the Millennium Bulk Terminal—and at least a quarter of that would end up in the Columbia River.
Yes, indeed, facts do matter. But there is little reason to believe that the public has been given real facts—grounded in solid evidence based on observation and measurements—about how much coal dust the Longview terminal would actually release. To the contrary, an honest, detailed examination reveals that the Longview terminal is likely to be a major source of air and water pollution to the surrounding community and especially to the Columbia River. These are the facts we should be heeding, not the “alternative facts” peddled by Bill Chapman and the coal export industry.
Michael Riordan is the author or coauthor of five books, including The Solar Home Book, The Hunting of the Quark, and most recently Tunnel Visions. He writes about science, technology and public policy from his home on Orcas Island, Washington.