Friday, August 3, 2012

Coal: Terminal Design & Operations Recommendations

This NRDC website describes a number of recommended design, operation and policy recommendations for Container Port and Terminal facilities, based on major pollution problems identified in 2004 as needing major improvement.

Most of these recommendations apply to existing Container Port & Terminal facilities as needed modifications; but in the case of new facilities, they should be used as part of the design & operation criteria.

While the proposed GPT is not presently foreseen as a Container Port, but instead a Bulk Terminal for coal, these recommendations would seem to be even more important because of the toxic and friable nature of the coal - which contributes to airborne dust and water-borne pollution.

What a rare opportunity to use state-of-the-art technology and best management practices to begin with rather than waiting for predictable problems to occur!

That kind of prudence is called the Precautionary Principle, first espoused by Benjamin Franklin who famously said that 'a stitch in time saves nine'.

So, in that spirit, why not adopt these prudent recommendations at the very start of any new terminal at Cherry Point?
After all, that would allow both advocates and opponents more confidence and certainty in what is actually being proposed as well as what adaptions will be incorporated into the design and operations as up-front mitigation for known concerns.

Here is a summary of recommendations:
The fact-finding for this report revealed untenable situations in many communities near ports: freeways and neighborhood streets overloaded with trucks, homes coated with soot, soaring asthma rates, containers stacked high enough to create significant neighborhood blight, piles of dredged sludge forming toxic islands, and prime marine animal habitats gouged by channeling. The following are recommendations to port operators and policymakers on how to clean up port operations. The recommendations, and the problems they seek to address, are described in greater detail throughout the report.

Recommendations for Ports

Ports must commit to protect local communities and the environment, not only during expansions but also during regular operations. Following are suggested measures used by select ports worldwide to successfully decrease impacts on local communities and ecosystems. These measures should be employed at all container ports to clean up their operations, and local activists should be aware of these options to advocate for their implementation. Ports should consider the negotiation of new or modified leases as an important opportunity to require a combination of the mitigation measures, such as the use of cleaner fuels and equipment.

Marine vessels
  • Clean up harbor craft, such as tugboats, through engine repower and retrofit programs.

  • Limit idling of oceangoing vessels and tugboats by providing electric power at docks and requiring ships and tugboats to "plug in" to shoreside power while at berth.

  • Require ships, including oceangoing vessels, to use the cleanest grade of diesel fuel possible, with a sulfur content of 15 to 2,000 parts per million.

  • Where possible, create incentives for, or otherwise promote the use of, emission controls on oceangoing vessels.
Cargo-handling equipment
  • Retire equipment that is ten or more years old and replace it with the cleanest available equipment and fuel choices, preferably alternative fuels.

  • Retrofit existing equipment less than ten years old to run on the best available control technology, including diesel particulate filters (DPFs) with lean NOx catalysts (LNCs) and, if not feasible, with diesel oxidation catalysts (DOCs).

  • Switch to cleaner diesel fuels, such as low-sulfur fuel with sulfur content less than 15 parts per million and diesel emulsions.
On-road trucks
  • Create incentive programs that encourage fleet modernization, the retirement of older trucks, and their replacement with modern lower-emitting trucks.

  • Offer incentives for the installation of pollution controls, including DPFs with LNCs or, if not feasible, with DOCs.

  • Make cleaner fuels, such as diesel emulsions or low-sulfur diesel, available to off-site trucks.

  • Minimize truck idling by enforcing idling limits or by installing idle shutoff controls.
  • Repower or replace all switching locomotives that do not meet the Environmental Protection Agency (EPA) Tier 0 Standards with electric-hybrid or alternative-fuel engines.

  • Install engine emissions controls where possible.

  • Require automatic engine shutoff controls to minimize unnecessary idling.

  • Commit to using cleaner fuels, such as on-road grade diesel.
Stormwater management
  • Take principal responsibility, as the general permittee, for preparing a stormwater pollution prevention plan for all terminals.

  • Provide guidance to all port tenants for development of model stormwater programs, oversight and inspections of individual terminals to confirm implementation of an acceptable program, and education and training of terminal staff.

  • Carefully document and analyze potential water pollution problems, water quality monitoring, and best management practices for the prevention, control, and treatment of stormwater runoff. Other measures recommended include water quality programs; traffic mitigation; land use, light, and noise abatement; improved aesthetics; and other terminal design features.
Recommendations for Policymakers

In addition to the mitigation measures ports should implement on their own, a number of policy and regulatory actions are needed to protect human health and the environment from the large, industrial, and high-polluting operations at marine ports. Ordinarily, such activities would be subject to stringent regulation, but oversight of ports falls between the regulatory cracks, defeated by confusion over jurisdictional authority and the ongoing efforts of a strong industry lobby. While a patchwork of international, federal, state, and local rules apply to various pollution sources at ports, most are weak and poorly enforced.

Marine vessels
  • The U.S. government should officially ratify MARPOL Annexes IV and VI (an international treaty that prevents sewage pollution and sets emissions standards for ships) and the Antifouling Systems Convention, which bans toxic chemical coatings on ship hulls.

  • The EPA should expedite efforts to establish the entire East, West, and Gulf coasts as control zones subject to stricter emission standards under MARPOL VI.

  • The EPA should implement a graduated harbor fee system similar to a program in Sweden that requires more polluting ships to pay higher fees upon entering a port.

  • The EPA should expedite implementation of stricter emission standards for all marine vessels within two years.

  • States and regional authorities should create financial incentives for the cleanup and replacement of older marine vessels.

  • States and regional authorities should require ships to plug in to shoreside power while docked.

  • States should require that ships use low-sulfur diesel while in coastal waters and at berth (until electric power is made available). In the absence of state action, regional authorities should require this.

  • Regional authorities should monitor and enforce ship speed limits.
On-road and nonroad vehicles
  • The EPA must follow through with full implementation of its 2007 emissions standards for on-road, heavy-duty trucks; its 2008 emissions standards for nonroad vehicles and equipment; and the related lower sulfur diesel requirements.

  • The EPA should adopt a series of diesel retrofit rules, similar to those proposed in the California risk reduction program, to establish a cleanup schedule for existing polluting diesel engines. In the absence of federal action, states or local authorities should adopt these programs.

  • The EPA should set uniform federal idling limits for all diesel engines. In the absence of federal action, states or local authorities should require idling limits.

  • States should provide incentive programs to reduce pollution from heavy-duty diesel engines, similar to programs such as California's Carl Moyer and Gateway Cities; in the absence of state action, regional authorities should sponsor such programs.

  • Regional authorities should adopt fleet rules to clean up and require new, cleaner purchases of all heavy-duty engines, similar to those in place in the Los Angeles area.
Inland cargo transport
  • The EPA and individual states should consider fees on each container entering a port to provide funding for mitigation of the environmental impacts of moving those containers.

  • The U.S. government should adopt and support a sustainable transportation system program, similar to the European Union program, facilitating the shift of cargo transport from more polluting modes (such as trucking) to cleaner locomotive and barge transport.
  • The EPA should implement stricter emission standards for locomotives within one year.

  • States and regional authorities should also create financial incentives for the cleanup and replacement of older locomotives.

  • States should negotiate memorandums of understanding that create incentives for cleaner locomotives. In the absence of state action, regional authorities should pursue this.
Land use
  • Regional authorities should improve efforts to protect marine habitats from further infill due to port developments.

  • Regional authorities should work together with local communities and marine terminals to improve efficiency and land use and to minimize impacts of terminals on local communities.
Community relations
  • Neighboring states should work together in coastal alliances to protect their marine natural resources and to share information on programs and technologies, and they should work together to jointly shoulder the neglected responsibility to neighboring communities and their surrounding environment.
  • The EPA should issue effluent guidelines to require a general baseline level of pollutant reduction for port facilities, or for those pollutants typically found in port runoff.

  • States should ensure that anti-degradation provisions of federal and state law are fully implemented in stormwater permits.

  • States should give special attention to the development of total maximum daily loads (TMDLs) for impaired waters around many ports.

  • Local governments should prioritize port facilities when designing inspection protocols in conjunction with local regulatory programs and implementation of municipal stormwater permits.
Oil spills
  • Congress should pass the Stop Oil Spills Act (H.R. 880) to accelerate the phase-in of double-hulled tankers in U.S. waters by 2007.

  • Regional authorities should require ports to take steps to ensure that oil pollution does not become part of runoff and that portwide oil-recycling programs are in place.
Ballast water
  • The U.S. Coast Guard should finalize mandatory national ballast water regulations as quickly as possible, or no later than the expected summer 2004 completion date.

  • States should adopt ballast water regulations, similar to those in place in California and Washington, that ensure a 200-mile buffer from the U.S. coast.
Waste discharge
  • The EPA must consider more stringent requirements on the dumping of wastes containing oxygen-depleting nitrogen and phosphorous, as well as persistent toxic compounds that continue to threaten marine life.

Based on our previous survey of 10 of the largest container ports in the United States, not nearly enough is being done to alleviate the severe impacts of the highly polluting shipping industry despite real and significant environmental and health impacts associated with marine port operations. Ports should take internal measures to reduce pollution caused by port activities. Likewise, regulatory agencies at the federal, state, and local level must provide long overdue safeguards. Further, if port expansions are to continue, all projects must be mitigated to the maximum extent possible, efficiency must be improved, and current operations should be cleaned up.