Public Hearing: Northwest Clean Air Agency

by Sandra Spargo Saturday, October 11, 2014 1:39 PM

Draft Permit for Potential Emissions of

Bakken Crude Oil Volatile Organic Compounds

Thursday, Oct. 16, 6 p.m. to 9 p.m. (or to when the last person speaks)

Anacortes Public Library

1220 10th Avenue, Anacortes

Shell proposed rail terminal

Proposed Shell Crude-by-Rail East Gate rail terminal area on March Point, Anacortes

Encompassed by Highway 20, Fidalgo Bay and Padilla Bay

Shell Puget Sound Refinery (PSR) must meet the requirements of over 15 permits to ensure that its proposed crude-by-rail terminal will be built.


The Northwest Clean Air Agency (NWCAA) of Mount Vernon will hold a public hearing on Oct. 16 regarding one of these permits, whose project is described as follows:

Project description:  Shell Puget Sound Refinery (PSR) proposes to construct a crude oil unloading system with the capacity to unload up to 102 railcars per day. Upon the train’s arrival at the Crude-by-Rail East Gate station, PSR would connect hoses to the bottom of each railcar, allowing crude oil to drain into a large collection pipe. PSR would pump crude oil to existing tanks. The collection pipe and railcar overhead vents are designed as a closed vapor control system.  Volatile organic compounds (ozone precursors) could total 0.9 tons a year. Potential sources of VOCs would be leaks from unloading equipment such as pumps, valves, and flanges and leaks from oily wastewater systems. (Courtesy of Protect Skagit.)

Shell Notice of Construction, G. Criteria Air Pollutant2 Emissions, Page 3, demonstrates the technicality of this proposed permit. Therefore, if you would not rather address technicalities, Protect Skagit generously wrote the following talking points for those who wish to speak at the public hearing.  A second option is to speak that you support the testimony already given. A third option is to come and occupy a seat of concern.

Northwest Clean Air Agency draft construction permit for the construction and operation of a terminal for unloading crude oil delivered by rail.

1) Since the Skagit County Planning and Development Services ruling on a Mitigated Determination of Non-Significance (MDNS) for environmental harm from this project is under appeal, why not wait to decide on this permit until after that appeal? The appeal could result in a ruling that an Environmental Impact Statement is needed for this project so why rule on this permit in advance of the MDNS hearing? NWCAA should not issue an approval for construction until the appeal has been resolved.

2) The Project summary language for the permit should specifically reference just Bakken crude oil from North Dakota, and Niobrara crude oil primarily from Colorado and Wyoming. The current language is too vague, saying the unloading facility is for receiving light crude oil which could include diluted bitumen from Canadian tar sands.

3) An Environmental Impact Statement (EIS) is needed since Bakken and Niobrara crude oil is chemically and physically different from crude oils currently being refined. There may be increases or changes in emissions, fouling of equipment, and upsets in the refining process that are currently unknown. It is too soon to tell if these problems are occurring at other refineries like Tesoro that already bring in Bakken. Therefore, an EIS must be conducted on this and all other potential cumulative impacts from the transport and refining of Bakken and Niobrara crude at the Shell refinery.

4) Governor Insleeʼs recent draft oil transportation study specifically recommends on page 67: “Modify definition of ʻfacilityʼ to include moving trains carrying oil” for purposes of oil spill prevention and response. Accordingly, the NWCAA should study rail diesel particulates and the possible release of toxic emissions from crude oil tank cars from trains traveling to and from the Shell refinery, and while idling there. The results of this study should be included in a full EIS prior to either the approval or denial of this permit to determine the full health impacts from air emissions resulting from the proposed project. The study results should also be sent to the Environmental Protection Agency, WA State Dept. of Ecology, and the Governor’s office to determine whether changes to the regulations of air emissions from crude oil transport are needed.

5) The state threshold for greenhouse gas emissions (GHG) of 10,000 metric tons per year is exceeded by the Shell project, according to Earthjustice and others who have filed the appeal on the MDNS. The NWCAA has a responsibility to determine all GHG emissions and not issue the permit as currently drafted for construction of this facility if the GHG emissions are shown in the appeal to exceed the state threshold for GHG emissions.

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