Copy of an email posted on the Observer sight. Best Ive seen yet. Quite thorough with cited references: Dear Mr. Simpson, I, together with my two brothers and one sister, are co-owners of a fourth-generation family home located on North 6th Street in the historic district of Fernandina Beach, FL. I am writing to formally protest any proposed changes to air quality permits for the Port of Fernandina operations, and specifically regarding the subject permit 0890440-001-AC for Kinder-Morgan, that would allow increases in gaseous and particulate emissions from this site. My understanding is that Kinder-Morgan is proposing to transport large quantities of pulverized coal through the Port of Fernandina using marine vessels for incoming product, with railroad and trucking to be used for subsequent distribution out of the port. I understand that Kinder-Morgan is also proposing the possible use of marine barges for bulk storage of coal inventory. I further understand that Kinder-Morgan has estimated they may transport 500,000 tons per year through the port, but that this is not specified to be a “not-to-exceed” amount and hence could be higher. As you are undoubtedly aware, the movement of bulk quantities of pulverized coal is inherently environmentally dirty due to the incidental release of particulates, especially with open-air transfer operations involving clamshell loaders, open conveyor belts and open storage as would be utilized at the port. Such operations also increase the release of gaseous products from the coal, in particular methane and hydrogen sulfide. Because of the above, I want to register the following specific items of concern for you and FDEP consideration regarding the subject permit: 1) The handling and transport of raw pulverized coal results in a certain proportion of that coal fracturing into fine dust and becoming airborne. Coal dust can become airborne in particle sizes smaller than 500 microns, with the fraction smaller than 10 microns (PM10) being particularly important, as particles in this size range can be inhaled into the respiratory alveoli of humans and wildlife. Respirable coal dust can exacerbate asthma and COPD, and cause chronic bronchitis even in non-smokers at rates which approximate heavy smokers [Marine et al, 1988)]. Coal dust in all size fractions contains varying amounts of heavy metal contaminants such as mercury, arsenic, beryllium, cadmium, chromium, nickel, and selenium and lead [sourcewatch.org, 2014] . . . the degree to which this heavy metal contamination can lead to a substantial health impact has not yet been established, in the form of a formal assessment by the US Department of Health, but is a particular on-going safety concern. 2) Terminal processing, storage and shipping of coal, such as is proposed for the Port of Fernandina, can lead to high “fugitive” (escaping) emissions, approximating those of an open pit coal mine [Ghose and Majee, 2007]. In this study of airborne monitoring around an open pit mine in India, and in the attendant transport corridor, PM10 episodically approached levels that would be considered in violation of OSHA standards in the United States, and the residential areas up to 2.5 km (1.6 miles) away from the mine boundary showed PM10 above baseline for the region. A 1993 study on a West Virginia rail line, transporting bituminous coal, showed loss of coal dust of up to a pound of coal per mile per car [Simpson Weather Associates, 1993]. This loss occurs throughout the entire transport, as the mechanical fracturing of the coal continuously produces fugitive dust as the coal settles. There are even substantial coal dust emissions on the return trip, as the “empty” cars actually contain a significant quantity of fine particles known as “carry back” [Cornell Hatch, 2008]. 3) As indicated above, numerous studies show that the largest concentration of coal dust is released near a loading/trans-shipping terminal site and within the first few miles along the transport route(s) leaving that site. Considering the possibility of strong sustained winds that may occur during operations, the adverse impact zone from a site of the size proposed by the subject permit will realistically extend at least two miles in all directions. The following environmentally-sensitive and/or historically significant areas are all within two miles of the Port of Fernandina: Florida Intercostal Waterway (immediately adjacent W), City of Fernandina Beach Historic District (0.3 miles SSE), City of Fernandina Beach downtown district and waterfront (0.5 miles SSE to SSW), Egan’s Creek watershed and wildlife estuary (1.0 mile NNE to 1.2 miles NE), Ft. Clinch State Park (1.3 miles NE), and marsh areas, estuaries and uplands on the western side of the Intercostal Waterway (“Little Tiger Island” beginning 0.3 miles WNW and others). Amelia Island’s public beaches are just 2 miles to the east, Tiger Island nature preserve-Florida DEP/Parks and Recreation 2.2 miles NW, and Cumberland Island National Seashore-Georgia just 2.6 miles north, of the port. 4) Apart from the respirable fraction, fugitive coal dust emissions are an undeniable and costly nuisance pollutant to businesses and residences near a coal terminal and along a transportation railway or roadway, with substantial adverse economic impact simply due to the need for frequent cleaning of buildings, streets and signs [Cope et. al., 1994]. Such coal dust emissions are sure to have severe negative consequences within the Fernandina Beach historic district, where many Victorian-style homes retain their classic pure white external paint and many homes as well as churches incorporate beautiful stained glass windows. Likewise, coal dust settling on boats berthed at the city docks is sure to be unwelcome. Moreover, within the City of Fernandina, there are private residences within 0.2 miles SE of the port and the historic community of Old Towne (Fernandina) is just 0.8 miles NNE. 5) Beyond the impact zone surrounding the Port of Fernandina, there are environmentally sensitive marshlands, watersheds and forested areas along the transport pathways that would be used for rail and truck distribution of the coal through and off Amelia Island . . . all of these would be impacted by fugitive coal dust emissions. Frequent rainstorms, characteristic of this region of the country, will guarantee that coal particulates are transported into land surface waters as well as marine waters. 6) With the above-noted significant health and environmental concerns, I would think that an Environmental Assessment and attendant Environmental Impact Statement, both specific to the subject permit, would be required but I do not believe such as been performed or made public. If necessary, I hereby formally request such. Of special concern regarding the subject permit, exactly how much coal dust is Kinder-Morgan requesting it be allowed to release into the environment each year of operation? 7) My understanding of this matter is that the Kinder-Morgan permit proposal to FDEP was little publicized in the City of Fernandina or within Nassau County, and that the public comment period regarding this permit ends on September 9 at 5 pm. Therefore, I do not believe that there has been sufficient time for a full, open and transparent discussion on this important matter that may—if the requested permit is granted—have lasting, adverse and severe impacts on the health, economy and environment of those in the affected areas. Of particular wildlife concern, the marshlands and estuaries along the Intercostal waterway bordering Amelia Island are recognized as critical areas for shrimp egg, larva and post-larval life stages and I question if the impact of coal dust on this aquatic species or on filter feeders such as oysters (common in the area) has been addressed anywhere. In summary, I request that the subject permit not be granted at this time. As a minimum, I request that the public comment period be extended by an additional 60 days so that this critical matter can be subjected to full discussion from concerned residents and community leaders in the potentially affected areas, which should include those along the proposed rail and road distribution routes within Nassau county. Sincerely, s/ Gordon A. Dressler 310-560-1797 (cell) List of References: - Marine WM, Gurr D, Jacobsen M 1988. Clinically important respiratory effects of dust exposure and smoking in British coal miners. Am Rev Resp Dis. 137:106-112. - sourcewatch.org/index.php/Heavy_metals_and_coal, accessed Sept 8, 2014. Coal Ash and List of Heavy Metals in Coal - Ghose MK, Majee SR. 2007. Characteristics of hazardous airborne dust around an Indian surface coal mining area. Environmental Monitoring and Assessment 130:17- 25. - Simpson Weather Associates 1993. Norfolk southern rail emission study: consulting report prepared for Norfolk Southern Corporation. Charlottesville, VA - Connell Hatch and Co. Final Report & Queensland Government Environmental Protection Agency Report. 2008. Environmental evaluation of fugitive coal dust emissions from coal trains Goonyella, Blackwater, and Moura coal rail systems, Queensland rail limited. - Cope D, Wituschek W, Poon D et al. 1994. Report on the emission and control of fugitive coal dust from coal trains. Regional Program Report 86 – 11. Environmental Protection Service, Pacific Region British Columbia Canada.
Posted on: Wed, 10 Sep 2014 09:35:54 +0000
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