A letter from the state Utilities and Transportation Commission to the Department of Ecology outlines a plethora of railroad safety concerns the commission has about the crude-by-rail storage facilities proposed for the Port of Grays Harbor.
The letter, dated Nov. 30, came on the final day of the Department of Ecology’s public comment period following the release of the draft environmental impact statements for the projects. The statements outlined potential environmental and economic impacts of two crude-oil-storage facilities proposed for Westway Terminals and Imperium Renewables’s properties at the port.
Imperium’s facility was purchased this summer by Iowa-based Renewable Energy Group.
The commission’s letter breaks down its safety concerns by category, including bridges, public and private railroad crossings, signage along the track, issues with sections of the track itself, and switching operations. The letter also outlines recommendations for the Department of Ecology to address the various concerns.
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The commission’s first section of concern centers on the load capacity of the 52 bridges along the Puget Sound & Pacific rail line between Centralia and the port. The draft statements from Ecology, the commission’s letter says, do not address this concern thoroughly enough.
“The draft statements of both Westway and Imperium project proposals provide very brief and general descriptions of the 52 bridges on this line, and equally brief reference to a future maintenance project to upgrade three steel bridges,” the letter says. “This lack of detail is insufficient to determine whether the infrastructure can safely accommodate the increased loads envisioned in the proposed projects.”
The commission’s recommendations include demonstrating that a qualified inspector verify the bridges’ load capacities and makes the inspection reports. The commission also calls for inspections to occur annually and describe which bridges are due for upgrades.
The letter also calls into question the safety of public and private crossings along the line, adding that the draft statements do not make mention of many of the private crossings in the Federal Railroad Administration’s crossing inventory. Seventeen public crossings the commission has identified as “at risk” — crossings “that require further study and field analysis” before taking on rail cars carrying crude oil — were omitted from the draft statements, the letter says.
Of the 17 at-risk public crossings listed in the letter, 16 are in Grays Harbor County.
“The draft statements must address more fully how the companies intend to address safety at these crossings,” the letter says.
The letter recommends Puget Sound & Pacific be required to provide a list of private crossings along the line and conduct on-site diagnostic reviews of those 17 crossings.
The letter also points to issues with the track itself, particularly to a 1,000-foot section about 4 miles west of Montesano, where three trains derailed in 2014 “due to poor soil conditions,” the letter says. The speed limit along that section of the line has since been brought down from 25 mph to 10 mph.
The letter recommends that Ecology “require PS&P to address the underlying soil issues before it transports volatile Bakken crude oil, regardless of the speed at which the trains travel.”
The letter also criticized how the statement addressed blocked crossings. Though the letter says the commission has no jurisdiction over blocked public grade crossings, it said it “has significant concerns about blocked crossings from the cumulative effect of both the Westway and Imperium proposals.”
The commission aimed some of its most critical language at the issue of the railroad’s switching operations — the switching of rail cars from one line to another. The switching operations planned for crude-oil cars along the line, according to the letter, would “occupy public crossings longer than other feasible switching movements.”
In its letter, the commission adds, “Choosing to inconvenience businesses and citizens and create unnecessary safety problems related to blocked public crossings because it is more ‘time-efficient and cost-efficient’ to the railroad is not acceptable.”
The final recommendation suggests the state require Puget Sound & Pacific to be financially responsible for a potential oil spill.
Comments on the draft statements still are being sorted by ICF International, the consultant the state used to conduct the environmental impact statements, Department of Ecology spokesman Chase Gallagher said. The number of comments from private individuals, organizations and local, state and federal agencies, Gallagher said, approaches 100,000.
The final environmental impact statements are expected to be released next year.