Stockpiles of coal and petroleum coke await loading onto vessels at Levin-Richmond Terminal, as photographed by a San Francisco Baykeeper pollution patrol in 2013.

For decades, residents of the Bay Area who live near industrial areas and transportation corridors have battled particulate matter, the microscopic grains of dust and soot that can lodge deep in the body and trigger asthma and other ailments. In this fight, regulators have primarily focused on reducing residents’ exposure to particulate matter from diesel engines, especially in areas like ports, where trucks, trains, and ships can all burn diesel fuel. More recently, however, attention has turned to another port-related form of particulate air pollution: dust from storing and shipping coal and petroleum coke at terminals in the East Bay.

As the country switches away from coal-fired power, coal producers in states such as Utah and Wyoming have found markets in Asia, but they need larger terminals at West Coast ports to transfer their coal from trains to ships. They’ve looked to the Bay Area to meet this need, but have encountered resistance, and not just because of the impact on local air quality — environmental activists argue that exporting such a carbon-intensive fuel undermines efforts to reduce climate change. Communities have rallied to protest a proposed terminal in Oakland, coal and petroleum coke shipping in Richmond, and a possible terminal in Vallejo.

In 2013, the City of Oakland signed an agreement granting a developer the right to build a bulk commodity terminal near the foot of the Bay Bridge. After learning of the developer’s plans to ship coal — a commodity not mentioned in the agreement — the city banned coal shipments in 2016, claiming they endangered public health and safety. But this past May, a district court judge ruled that the city had broken its agreement with the developer by applying the ban to the terminal without adequately proving the hazards. The city appealed the case, and has now declared that the development agreement has been terminated, with more court battles ahead.

Meanwhile, the privately-owned Levin-Richmond Terminal substantially increased shipments of coal between 2016, when the Oakland ban was passed, and 2017. Last May, local CBS television news affiliate KPIX 5 reported compelling evidence that coal is being diverted to Levin that would otherwise have gone to Oakland.

Levin-Richmond Terminal also handles other bulk commodities, one of which is petroleum coke, or petcoke. Petcoke is created by burning off residual hydrocarbons and other impurities from the tar-like material left after refining petroleum into other usable products. Like coal, petcoke is stored outdoors in piles, and can give off dust particles with the potential to impact surrounding neighborhoods. A recent literature review by the National Institutes of Health concluded that “the main threat to urban populations in the vicinity of petcoke piles is most likely fugitive dust emissions in the form of fine particulate matter.”

In addition to air pollution, coal and petcoke dust can affect waterways around terminals. That’s been a problem here — in 2014, the environmental advocacy nonprofit San Francisco Baykeeper successfully sued Levin-Richmond Terminal to impose greater controls on dust blown into the water and carried in stormwater discharged to the Bay.

Dust produced while storing and handling coal and petcoke can be controlled, but regulatory approaches vary. In August, the Bay Area Air Quality Management District amended its particulate matter regulations to address fugitive dust from sources that include bulk storage. With adjustments to Rule 6-1, the agency set specific standards requiring facility operators to prevent dust from going offsite. Many of the rule’s recommended measures are already in use at Levin-Richmond Terminal: wind barriers, covers for conveyors, spray misting or watering piles of material, and suspending operations during periods of high winds.

Rule 6-1 is a “performance-based” regulation; its success is measured by whether the facility successfully meets the standards for limiting dust emissions. Guy Gimlen, principal air quality engineer at the Air District, explained in an email that “most facilities behave responsibly if they know what the requirements are … we tried to make these performance-based requirements clear and practical — something the average worker could relate to: i.e. no visible dust across the property boundary; and no dust with greater than 10 percent opacity (barely visible) greater than 5 feet wide, tall, or deep for more than 3 minutes in any hour. For the worker, if they can see any dust, they should take notice. If the dust forms a cloud (plume) larger than 5 feet they should take corrective action.” The new rule will take effect in July 2019.

The Air District also requires that any new facilities include “best available control technology.” Gimlen cited the Carbon Inc. facility at the Koch Marine Terminal in Pittsburg, which handles petcoke from two refineries. Gimlen said the facility uses “enclosures around storage and handling operations, [and] induced draft fans drawing air through the enclosures and then filtering the discharge of the fans through a baghouse.”

Frank Gordon was on the Pittsburg Planning Commission when the terminal was proposed, and recalled, “The project proponent at the time was told that if they expected to get approved they needed to show the public that they were willing to be a good neighbor and present a state-of-the-art facility.” Gordon reported that in addition to facility enclosures, the covered trucks bringing petcoke to the facility travel at night; by avoiding highway congestion, the trucks spend less time on the road, reducing diesel exhaust pollution.

Best available control technology specifications based on regulations in Southern California were incorporated into a proposed amendment of Richmond’s Nuisance Ordinance aimed at dust from bulk storage such as that at Levin-Richmond Terminal. In May, Richmond Mayor Tom Butt wrote on his personal website that “it is clear that coal dust is escaping from the property into at least 4th Street, because Levin machine and hand sweeps it constantly to keep it under control.” Members of the group No Coal in Richmond note that it’s impossible to enforce opacity standards if loading is done at night.

The draft ordinance is on hold while Levin works with the city and the Air District on a study to provide additional input to the city decision process. Air District officials reported that Levin has been cited only once since 2000, and suggested that street dust may be coming from the tires of trucks leaving the facility. This “track-out” is also regulated under the agency’s new Rule 6-6, and street sweeping is an acceptable control for track-out dust. The terminal will be required to comply with the Air District’s Rule 6-1 and 6-6 regardless of the outcome of the city ordinance.

Gimlen pointed out that “the concern that is left unaddressed is the coal dust that can get carried out of the top of rail cars.” Dust from trains may have a greater impact than storage and shipping at terminals; while air quality regulations govern terminals, federally regulated railroads don’t have the same restrictions.

The local short-line railroad that moves coal from the Richmond railyard to Levin is operated by the terminal. It travels at low speeds and uses new clean diesel engines. Beyond Richmond, both shippers and railroads have incentives to reduce the coal dust from trains. Burlington Northern Santa Fe Railroad studied the loss of dust from coal cars — because the dust disrupts the integrity of railbeds, leading to derailments — and then pressured shippers to take steps to reduce dust loss by shaping and sealing loads with surfactants. This has decreased dust by up to 85 percent according to some estimates, and most dust is lost close to the original loading point. The harder coal from Utah coming to the Bay Area creates less dust than other types, and car covers were proposed for the Oakland terminal as additional protection, although many experts maintain that coal cars cannot be covered because of potentially explosive dust buildup, and no covers have been commercially tested.

In any case, groups that oppose coal in their communities will continue to work on reducing local impacts from shipments. According to Margaret Rossoff, an activist with No Coal in Oakland, her group plans to begin monthly coordination meetings with No Coal in Richmond and No Coal in Vallejo beginning in December. Richmond is also one of the communities chosen to develop an air monitoring plan under 2017’s Assembly Bill 617 (C. Garcia), and coal and petcoke dust monitoring may become part of that plan.

Leslie Stewart covers air quality and energy for the Monitor.