At Least The Website Is Clean

What the railroads don't want you to know about coal dust.
This post is part of the research project: Northwest Coal Exports

Coal dust is a problem for railways. It escapes from rail cars during shipping, creating safety and congestion problems. It’s toxic, unhealthy, and obviously unpopular with nearby communities.

And yet… coal is the single biggest source of revenue for freight railways. So when debate about new export terminals turns to coal dust, what’s a railroad to do? According to BNSF—shipper of Powder River Basin coal to the Northwest—the answer is: scrub your website.

They recently removed some important information about coal dust. Fortunately, I can right-click like nobody’s business. So, for the sake of posterity and public policy alike, I give you a screenshot of the original version of BNSF’s guide for freight customers, “Coal Dust Frequently Asked Questions.”

 

You read that right. BNSF says that “500 pounds to a ton of coal can escape from a single loaded car.” Coal dust accumulates in the ballast between the rails, undermining the track structure and causing derailments. And coal dust deposits sometimes even cause fires.

In addition to what BNSF once acknowledged on its website, the US Department of Transportation classifies coal dust as a “pernicious ballast foulant” that can weaken and destabilize rail tracks. Although there are ways to reduce or eliminate coal dust escaping during transit—such as reducing the amount of coal per car or covering loads with tarps or sprayed-on chemical sealants—the measures are unpopular with coal shippers because they add to the cost of moving coal. It will be interesting to watch how this issue plays out now that BNSF won a ruling from the Surface Transportation Board (STB) that will require coal cars to reduce coal dust escape, perhaps by as much as 85 percent.*

Assuming that the new rules can be enforced, the coal dust problem may be limited to “only” 75 to 300 pounds of coal dust settling on nearby communities. Too bad it’s potentially 300 pounds per rail car, and rail line communities between the Powder River Basin and Washington ports are looking at perhaps 18 trains per day, each of them roughly 125 cars long.

* Technically speaking, BNSF “lost” the case because the STB ruled that BNSF’s tariff on coal shippers was not allowable. STB did, however, also rule that BNSF can require coal shippers to perform measures that significantly reduce the escape of coal dust.

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Comments

  1. don says:

    Did BNSF really scrub their website or did they update the page to inform their customers and reflect the new STB regulations? I found the page, perhaps you should look a little harder:

    http://www.bnsf.com/customers/what-can-i-ship/coal/coal-dust.html

    • Eric de Place says:

      Don,

      I’m aware that the webpage still exists in altered form, but you can color me unconvinced. BNSF removed the specific numbers about coal dust escape; they removed all photos of coal dust blanketing the tracksides in the PRB region; and they removed any mention of the derailments caused by coal dust weakening the tracks. All of that information is helpful context not only for potentially affected communities, but also for shippers using the railway.

  2. don says:

    I’m thinking that the only reason that BNSF put the information on their website in the first place was to convince customers of the reason for the tariff (a rule requiring customers to mitigate loss). You make it out to be some evil, nefarious thing that it was removed. Now that the STB has ruled that BNSF can require mitigation, the specific amounts of loss may not be important from the railroad’s point of view (in that they were trying to justify mitigation measures).

    Have you even tried to look in the STB archives for that information? It should be a matter of public record if the information was used by the railroad in testimony before the board.

    Stop looking for boogey men under every bed and do a little investigation before jumping to conclusions.

  3. Steve Erickson says:

    All right! Lets do the numbers:

    3.0% (maximum proportion of coal that may escape in shipment according to now scrubbed BNSF website)
    85.0% (maximum reduction that MAY be required)
    =0.45% (minimum escape rate)

    Washington: current proposed coal export facility capacity in million tons per year:
    80 [Longview]
    48 [Bellingham]
    5 [Grays Harbor]
    =113 million tons per year
    =226,000,000,000 pounds per year

    x 0.45% (minimum escape rate)
    = 1,017,000,000 [with rounding] pounds per year lost during shipment

    So, each year there may be somewhere in the neighborhood of over 1 billion pounds of coal escaping during shipment.

    Next question: how long is the route? What is the average projected loss per mile of rail line? What is the average loss per mile along major and minor waterways (the Columbia, Puget Sound, etc.)?

    • Kim says:

      Yes numbers! Thank you! Also, the fact that they tried to start building the unloading zone at cherry point without any permits also really makes you wonder what else they are trying to get done without anyone knowing. Transparency anyone? I don’t trust them! They are going about this like the public will have no sway on whether or not the terminal will get built. They haven’t brought anything to the table except for “We are going to build this terminal”

    • Jason Van Orsdol says:

      Western Joint Line Route into major Hubs is appx 1,200 miles.

  4. Kim says:

    with 1 billion pounds of coal dust escaping with maybe half being into our already troubled Puget Sound, would they need a permit to discharge into our waterways? that’s just alot of coal…. and lets not get started on the process of coal refinement- mercury, uranium, thorium, arsenic, and other heavy metals… hmmm health problems anyone?

    • Steve Erickson says:

      No, they would not need, e.g., a National Pollutant Discharge Elimination System (NPDES) permit under the Clean Water Act because its not a point source emission. But this is precisely the sort of cumulative environmental impact that SEPA (State Environmental Policy Act) is intended to address. With this information. it looks to me that not only will people in the immediate vicinity of the projects be able to gain legal standing in any appeals, but also anyone whose travel will be disrupted (including both being forced to wait at crossings and anyone who uses passenger rail), but also anyone who can show a nexus to waterbodies that will likely be polluted.

      About my rough calculations above: keep in mind that that is 1 billion pounds per year, every year. The sheer quantity of the coal being shipped is so huge that it looks to me like there is no realistic way to prevent significant adverse environmental impacts unless there is 100% containment during shipping. Even if emissions were reduced to 1/1000 of what they are now, that’s still around 100,000,000 pounds per year, every year. And 100% containment should do very interesting things to shipping costs.

      The escapement issue is also a very good organizing tool for communities along the way. Farmer, did the thousands of coal trains poison your crops and livestock? Your water supply? Lots of opportunity here for a big coalition.

    • Bill says:

      Kim – what is your source for claiming half-a-billion pounds of coal dust would escape into Puget Sound? You’re citing BNSF studies to get total pounds – but ignoring BNSF studies showing de minimus dust emissions beyond 100 or so miles from the mines, after mines were forced to apply surface treatment and load shaping. Can’t have it both ways.

      Steve – SEPA would certainly apply to actual measurable pollution, and it should, but it doesn’t apply to crossing waits on private rail lines. That would upend 150+ years of case law. While there are some rules about maximum time a given train can block a crossing, no government entity at any level has jurisdiction over the volume of trains a private railroad can run on its private right of way. The FRA regulates rail safety, and the STB oversees railroad/shipper business disputes, but applying environmental rules to rail traffic volume would be as insane as applying it to the # of trucks allowed to transit I-5.

      • Steve Erickson says:

        There is not 150 years of case law for SEPA or NEPA, these laws only dating back to the early 1970s. No case law is “upended” by considering “quality of life” impacts, such as delays caused by train crossings.

        Elements of the environment (WAC 197-11-444) include:
        (2) Built environment
        (a) Environmental health
        (i) Noise
        (ii) Risk of explosion
        (iii) Releases or potential releases to the environment affecting public health, such as toxic or hazardous materials
        (b) Land and shoreline use
        (i) Relationship to existing land use plans and to estimated population
        (ii) Housing
        (iii) Light and glare
        (iv) Aesthetics
        (v) Recreation
        (vi) Historic and cultural preservation
        (vii) Agricultural crops
        (c) Transportation
        (i) Transportation systems
        (ii) Vehicular traffic
        (iii) Waterborne, rail, and air traffic
        (iv) Parking
        (v) Movement/circulation of people or goods
        (vi) Traffic hazards
        (d) Public services and utilities
        (i) Fire
        (ii) Police
        (iii) Schools
        (iv) Parks or other recreational facilities
        (v) Maintenance
        (vi) Communications
        (vii) Water/storm water
        (viii) Sewer/solid waste
        (ix) Other governmental services or utilities

  5. Don S says:

    Eric and Steve,
    And lots of opportunity to needlessly create more fear. Actually, you need to do some more homework on BNSF’s website as suggested by don above. Coal dust is an issue only near the mines. BNSF testing shows that with load shaping and surface treatment that there is no detectable coal dust emitted after a train has traveled the first 120 or so miles of its journey.
    With the coal currently being transported by BNSF to Canada for export (about 1-3 trains per day)there have been no air quality complaints to the Northwest WA clean air agency. I expect you’d find the same results in Seattle and back up the line.
    This is a bogus issue for WA state communities.

    • Todd says:

      Don’s right on track here. The numbers being bandied about sound alarming, but there is no context for them, only assumptions. For example, the assumption that the coal dust is somehow distributed equally along the route, vice most of the loose particles escaping during the early part of the journey from the loading facility near the mine.
      - Being alarmist like this actually WEAKENS any arguments against the Powder River Basin to Cherry Point plan, as it becomes yet another data point of shoddy analysis by the opposition.
      - If you want to oppose this plan, say less, but say what is exactly correct.
      - Also, I noticed that nobody is talking about the coal trains that have been traveling this same BNSF rail route for decades (albeit at far less frequency than proposed). Do we see even a mote of coal dust along the tracks in Edmonds or Everett? Nope.
      - Let’s be more factual in our discussion, by expressing concern for the coal dust IN WYOMING, because that’s where it’s going to be deposited.

      • Eric de Place says:

        Don S and Todd,

        I hope you’re right! But it seems to me like the best way for NW communities to get certainty about this issue — an issue that many people are deeply concerned about — would be to expand the scope of the coal export terminal EIS projects to examine the potential risks of coal dust escape all along Washington’s rail lines, including evaluating dust escape today in windy locations like the Columbia River Gorge and Chuckanut Drive.

        If there’s documented evidence that coal dust only escapes within a short distance of the PRB mines (and only from loaded cars) please share it with me. I would be more than happy to revise or clarify what I’ve written if there is, in fact, good evidence to show that railway coal dust is not problematic.

    • Steve Erickson says:

      Except that today its being reported that Puget Soundkeeper found coal traces along a rail line.
      Why should the coal corporations and their allies (such as BNSF) get special treatment? If I drive my truck down the highway I’m supposed to keep the load covered so NOTHING escapes. The volume of coal that is proposed to be moved through Washington is so huge that there needs to be zero tolerance for any loss.
      As for complaints to NW Clean Air Agency, we’re not talking about plumes blowing off the trains. Just a slow steady loss that will continue until the mines are played out. Or the Chinese get off coal. Either way, the cumulative emissions are huge. As I calculated using BNSF’s own figures, even if the current rate of loss in shipping is reduced as proposed, that’s still over 1,000,000 pounds per year. Every year. Even if the Bellingham export facility is considered in isolation (which SEPA says you’re not supposed to do), the emissions will be around 400,000,000 pounds per year.

      • Steve Erickson says:

        I see that I ave a typo in this line:
        As I calculated using BNSF’s own figures, even if the current rate of loss in shipping is reduced as proposed, that’s still over 1,000,000 pounds per year.

        I dropped three zeros. The number should be 1,000,000,000. That’s 1 billion.

      • Bill says:

        Coal traces found near rail lines? Stop the presses!

        Coal has been shipped along these lines since the late 1800′s. It was even mined for 100+ years around Newcastle, Black Diamond and Roslyn. I would be amazed if coal traces were NOT found.

        The important question is whether current coal trains, using current surface treatments and load shaping, are emitting environmentally significant amounts of coal or coal dust. BNSF says it’s minimal much beyond the mines. That claim should be tested.

        I agree with your comment about “covering the load”. That’s been BNSF’s position in their years of court fights with mine owners, they are hardly “allies” on this issue (and an Arkansas utility just sued BNSF again).

        However, your zero-tolerance position is ludicrous, unless you intend to apply it to emissions from ALL forms of transportation, including highways, airlines, ships etc. Be consistent.

  6. Paula says:

    My hometown, Seward Alaska, has the distinction of being the terminus for the Usibelli Coal trains. these trains haul coal from interior Alaska (Healy) to Seward to load onto ships via conveyor. Coal is headed to Chile and China. If a bit windy, they have to shut down the conveyor because it blankets Seward with coal dust. Oh well, not many people there, so not much complaining going on. Apparently it is CLOSER for Chile to import Alaska coal, than to source coal from Australia. Now the big planners are considering developing a large coal deposit across Cook Inlet..using a conveyor to get coal to tidewater. How about the salmon in the rivers that will be destroyed.

  7. marilee dea says:

    As a nurse practitioner and an urban organic farmer situated less than a 1/2 mile from the BNSF tracks, I have concerns and questions about what is in the coal dust besides asthma irritating, fine particle, coal. Is the mercury, arsenic, lead frequently mentioned with coal, found in the coal dust or is limited to extraction, refinement or burning phase of coal production and use?

  8. Donald Steinke says:

    Eric,
    Laura Stevens and I met with a long time rail worker who claims that most of the fugitive coal comes out the bottom of the trains. He said no one bothers to repair the seals. No one has mentioned that.

    On the other hand, if that were true, then why would bnsf force shippers to apply surfactant?

    You mentioned that the trains don’t need an NPDES permit because they are not point sources of water pollution. It just so happens that one section of the Clean Water Act DOES regulate non-point sources, such as neighborhood storm drains.

    Does anyone know who regulates the fugitive coal that sifts out the bottom of the rail cars onto the tracks and is then part of runoff into salmon-bearing streams?

  9. pat says:

    hmm didn’t know about the garbage making up the dust I have to go
    over to the tracks at the near the inlet here where a train load of
    coal passes by a small neighborhood park used by moms with their
    babies here in Anchorage Alaska. hmm 500 lb’s a car think i’ll walk
    over to the EPA and ask them for any reserch papers conserning coal
    dust lost. maybe thats why it doesn’t matter which salmom you eat..
    the amount of mercury between wild and farmed are about the same.
    I quit eating tuna and salmom hahaaha

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