Citizens for a Clean Harbor

Oil terminals proposed for Grays Harbor would have significant adverse impacts

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The actions proposed by Westway and Imperium will have unavoidable and significant adverse impacts                                                                                   by Don Steinke

Dear Ecology and City of Hoquiam:

Nowhere in your DEIS do you mention that people are likely to burn or die.

Your Draft Environmental Impact Statement glosses over the impacts, particularly in the extended rail study area. Our communities have names and there will be property damage, burns, loss of life, and oil in the river.

The probability of this happening in any one town on any one day may be “low” as you say, but in 20 years, significant property damage, loss of life, burns and oil in the river is almost guaranteed to happen and will be unavoidable.

You computed the probability of harm for the last 59 miles of the route and we want you to compute that probability for the entire route. A million people who live, work, and drive near the tracks are at risk. Having 2 drunk drivers on the road doesn’t mean it is OK to have three.

We disagree with your use of the word “low” in this statement.

“Although the likelihood of a large spill, fire, or explosion is low, the potential for significant adverse impacts on the environment and human health in the case of such an incident is high.”

Using the FRA rate of 0.8 non-yard accidents per million miles, we conclude there will be 22 non-yard accidents involving full oil trains and 22 more involving empty oil train in twenty years for the combined Westway and Imperium proposals.

Either replace the word “low” with the word “high” or ask your consultants to do the math for the entire route.

In your EIS please describe how oil trains will affects the health safety and welfare of other communities including members of the Columbia River Inter-Tribal Fish Commission, the Washougal School District and the Federally protected National Scenic Columbia River Gorge and Recreation Area.

Questionable assumptions in the DEISs

1. You assume that historical risk assessment for crude oil applies to Bakken Crude. You wrote “Long-term historical data may show that most spills do not result in fires or explosions” . . . but . . . the oil being transported now is much more prone to ignite. There have been 14 spills resulting from derailments since 2013, and all but two of them have ignited.
2. You assume that if one tank car spills from a derailment, the subsequent fire doesn’t cause other tank cars to spill.
3. You assume empty tank car derailments don’t cause fire, but the fire chief in Ellensburg says otherwise.
4. You assume sparks are almost absent at 25 mph.
5. You assume the impacts to property values of an oil train, is the same as the impacts to property value of a general freight train.
6. You assume spills can be cleaned up, but according to the Marine and Rail Transportation Study, at best only 14% of the oil is recovered in a spill.
7. You assume tank car caps are on tight and there are no vapor releases during transport, but Oregon State Rail Inspector reports hearing hissing.
8. You say “Heavier oils . . . do not generate many flammable vapors”, but the oil train fires in Timmens and Gogama Ontario in winter involved Tar Sands Crude.
9. In the event of an accident, you assume the responsible parties will be able to pay for damages and do so in a timely manner.
10. You assume the vapor combustion units are reliable, but they have been known to fail. You assume that better control technology doesn’t exist.
11. You assume sea-level will stop rising at the end of the century, but NASA studies conclude the loss of sheet ice will continue for centuries.
12. You assume that oil production in Alaska and from OPEC might decline in amounts equivalent to the amounts proposed for Grays Harbor. We have no guarantees of that and OPEC appears unwilling to give up market share.
13. In your economic summary, you make a chart of economic benefits and costs assuming there would be NO job losses and no accidents, You didn’t include the harm to jobs in the fishing industry. You didn’t include the decay that will set in, as businesses and people move away.
14. You assumed that mud-flows from Mt. St. Helens eruptions would never wipe out the tracks.

Impacts Not addressed or Not adequately addressed
1. Why Bakken Crude is more prone to ignite than motor oil.
2. Speeds above which tank cars can rupture.
3. Harm to endangered species
4. Sole-source aquifers in Vancouver and Spokane
5. Who pays for site-cleanup in the event of a bankruptcy?
6. Way-side detectors in the study area.
7. Inspectors not allowed to use infrared cameras to detect vapor leaks.
8. Statewide economic impacts
9. Statewide traffic impacts.
10. First responder delays statewide.
11. School bus delays statewide.
12. Secondary containment common to all tanks at the terminal. Fire from a leak in one tank could weaken other tanks sitting in the same pool, causing the oil to exceed capacity of the secondary containment.
13. Rail inspection failures
14. Equipment inspection failures
15. Adequacy of Financial Responsibility
16. The Economic Impact Analysis Planning model used by ECONorthwest in relation to the fact that oil trains are prone to catch fire.
17. Crew size on trains.
18. The human element, fatigue, long hours
19. Lessons learned from the recent whistleblower victory in court.
20. The cost of providing adequate staff, and equipment for emergency preparedness.
21. America’s largest landslide area, in the Columbia River Gorge.
22. The Coast Guard has not updated its regulations regarding loading marine vessels as asked by Congress five years ago.
23. Under-regulated barges.
24. The speed of the train that spilled into the James river was 24 mph
25. The four ruptures of the newer safer CPC 1232s
26. Failure of track inspection equipment leading to explosion of LPG train in Gainford Alberta in Oct 2013.
27. The need for the 25 mph speed limit on the PS&P line.
28. The impact of greenhouse gases on snow pack and our economy.
29. We are in an oil glut. You ignore the impact that increased supply of oil will have on consumer interest in fuel efficient cars. You suggest that maybe production in North Dakota might replace production from OPEC or Alaska, but there are no guarantees of that.
30. Have producers in Alaska or in OPEC agreed to reduce production if we increase ours? By flooding the market with oil, greenhouse gas emissions will increase.
31. We have no hope of stopping climate change if we continue to build new fossil fuel infrastructure. We need to transition away from fossil fuels, not strengthen our dependence on them. Once a facility is built, investors such as pension funds will demand a return on investment for the rest of the century.


Public hearings October 1 and October 8

Comments will be taken at each hearing between 1:30 pm – 4:30 pm
and also that evening 6:00 pm – 9:00 pm

Oct. 8 at the D&R Theater in Aberdeen

Rally @ 5:00pm       Wear RED
205 I Street, between Heron and Wishkah

If you can’t make Aberdeen, please attend:

October 1 in Elma
Satsop Industrial Park – Flextech Bldg. (Bldg. 100) 150 Technology Way

Public comments can be made in person at these hearings, by mail, or by email to the Ecology website.

IMPORTANT NOTE email Subject Line to Ecology and City of Hoquiam needs to be: “Westway and Imperium crude oil-by-rail terminal EISs”

Claudia Woodward-Rice • September 30, 2015

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