Excessive Emissions Predicted at BNSF’s Proposed Gardner IMF

The US Environmental Protection Agency has predicted that fine particle emissions will exceed the national air quality standard at BNSF’s proposed intermodal facility just southwest of Gardner, Kansas in the KC metro area.  BNSF, one of the largest railroads in the US, is proposing to move its train/truck intermodal transportation center from Argentine in Kansas City, KS to this new site and more than double its size.  The facility, along with a huge complex of warehouses (Logistics Park) proposed by another company, will cover more than a square mile and host 2000 to 4000 diesel-fueled tractor-trailers per day.

BNSF will need to relocate a nearby stream and thus must obtain a permit from the US Army Corp. of Engineers (USACE).  The USACE released its Environmental Assessment on July 10 for public comment.  USACE proposes to approve the project despite air quality modeling data from USEPA that predicts that emissions of very fine particles (PM2.5) will cause an exceedance of the 24 hour and annual national ambient air quality standard (NAAQS) all along 191st street which will feed traffic to the facility.  It is well established that PM 2.5 are dangerous to human health.  Fine particles can access airways deep in the lung and even enter the bloodstream.

The applicant has challenged the EPA’s data, but has agreed to set up an air monitoring station at the site and to mitigate emissions if the NAAQS is exceeded after the facility begins operations.  However, my analysis has turned up some deficiencies in the applicant’s own analysis.  For example BNSF did not take into account emissions from I-35 which runs only ½ mile to the southwest and is upwind of the site.  In fact EPA, who used in their analysis only the sources designated by BNSF, showed NAAQS exceedances right next to I-35 at 191st Street.

The promise to monitor and mitigate is quite vague.  Computer modeling aside, common sense  dictates that such a huge facility with so many diesel trucks and locomotives deserves closer scrutiny.  USACE should proceed to commission a full health risk assessment and require a detailed, multi-point monitoring and mitigation plan before the project is approved.  Then they should subject that plan to additional public comment.

By Craig Volland, Chair, Air Quality Committee


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