# Movement of Plastic-baled Garbage and Regulated (Domestic) Garbage from Hawaii to Landfills in Oregon, Idaho, and Washington.

Final Biological Assessment, February 20082 

## Table of Contents

I. Introduction and Background on Proposed Action 3

II. Listed Species and Program Assessments 28

Appendix A. Compliance Agreements 85

Appendix B. Marine Mammal Protection Act 1 50

Appendix C. Risk of Introduction of Pests to the Continental United States via Municipal

Solid Waste from Hawaii. 15 9

Appendix D. Risk of Introduction of Pests to Washington State via Municipal Solid Waste

from Hawaii 205

Appendix E. Risk of Introduction of Pests to Oregon via Municipal Solid Waste from

Hawaii. 2 14

Appendix F. Risk of Introduction of Pests to Idaho via Municipal Solid Waste

from Hawaii. 2 333 

## I. Introduction and Background on Proposed Action

This biological assessment (BA) has been prepared by the United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS) to evaluate the potential effects on federally-listed threatened and endangered species and designated critical habitat from the movement of baled garbage and regulated (domestic) garbage (GRG) from the State of Hawaii for disposal at landfills in Or egon, Idaho, and Washington. Specifically, garbage is defined as urban (commercial and residential) solid waste from municipalities in Hawaii, excluding incinerator ash and collections of agricultural waste and yard waste. Regulated (domestic) garbage refers to articles generated in Hawaii that are restricted from movement to the continental United States under various quarantine regulations established to prevent the spread of plant pests (including insects, disease, and weeds) into areas where the pests are not prevalent. Together, these comprise garbage and regulated (domestic) garbage, referred to as GRG in this BA. The movement of GRG would be approved by APHIS after compliance agreements between APHIS, the State of Washi ngton, Idaho, or Oregon, the State of Hawaii, and specific applicants are agreed upon and signed in accordance with APHIS regulations (7 Code of Federal Regulations (CFR) § 330.400). The regulati ons allow GRG from Hawaii to be moved to the continental United States if it is compressed, packaged, shipped, and disposed of in a manner that the APHIS Administrator determines is adequate to prevent the introduction or dissemination of plant pests, and if it is moved in compliance with all applicable laws for environmental protection.

Proposed Action: Baled GRG will be transported on barges pulled by tugboat from Hawaii to the mainland where the barges will enter the Columbia River and continue up the river to specified ports on the river. The baled waste will be transloaded from the barge to an asphalt or concrete staging area then will be loaded onto trucks or rail cars and transported to specified, approved landfills in Washington, Oregon, and Idaho (see figure 1 for potential landfills). APHIS may authorize this activity under compliance agreement with applicants that have requested APHIS approval.4 Figure 1. Potential landfills in Oregon, Washington, and Idaho to receive baled GRG from

Hawaii.

Duration of the proposed action: APHIS expects that the proposed actions will continue for the foreseeable future, as long as the destination landfills maintain required permits to continue functioning and there is capacity in the landfills to accept waste. For example, the Regional Disposal Company (owner and operator of the Roosevelt Regional Landfill in Washington) has an agreement with Klickitat County, Wash ington to operate the landfill until 2041. The Columbia Ridge Landfill in Gilliam County, Oregon, has an estimated remaining service life (permitted site capacity) of approximately 50 years.

At this time, no applicant has specified a timeframe for the proposed action; however, compliance agreements between APHIS, PPQ and the waste management companies are renewed every 3 years. If there are changes to be made to the agreement, those are included at that time if they are agreed upon by both the companies and PPQ (and PPQ would also need to make sure any changes meet PPQ regulations, etc.,). If the effects of the proposed action change in a manner or to an extent not previously considered APHIS will re-initiate consultation

at that time.5 Previous Actions and History of Consultation: Currently, there are two companies that have been approved to move GRG from Honolulu, Hawaii to Roosevelt Regional Landfill in Klickitat County, Washington – Hawaii Waste Systems (HWS) and Pacific Rim Environmental Resources, Inc. (PRER). Each applicant has signed two compliance agreements, one for the handling of GRG at its point of origin and one for handling it at its destination (see appendix A for examples of compliance agreements). These compliance agreements detail conditions and provisions for the movement and transport of bales and the actions to be taken in the event of a breach in the bale wrapping or a spill. While the compliance agreements for HWS and PRER are not identical, they are substantially similar in all aspects affecting pest risk. That is, the compliance agreements are constructed to reduce pest risk to the lowest level possible. Key items that will be included in the compliance agreements are reduction of agricultural waste and yard waste, compression and baling standards to ensure compact and air-tight baling, handling procedures, spill response procedures, and final landfill disposal standards. Although compliance agreements are in place, no baled GRG has yet been barged to the Roosevelt Regional Landfill by either company to date.

APHIS previously consulted with the U.S. Fish and Wildlife Service (FWS) once and the National Marine Fisheries Service (NMFS) tw ice on specific parts of this action. APHIS prepared a BA regarding the proposed rule (now final regulation 7 Code of Federal regulations Section 330.402 and 403) that governs the interstate movement of baled GRG from Hawaii to the continental United States. On September 11, 2006, APHIS received a concurrence letter from NMFS indicating that the administrative amendments of the proposed rule were not likely to adversely affect several whale and sea turtle species. The concurrence was based on the understanding that all site-specific compliance agreements associated with the actual movements of baled GRG from Hawaii would undergo individual section 7 consultations at the time they were proposed. APHIS then submitted a BA to both FWS and NMFS that analyzed a specific proposal to approve the barging and trucking of baled waste from Oahu to the Roosevelt Regional Landfill in Klickitat County, Washington, by two waste management companies, HWS and PRER. APHIS received concurrence from both agencies (letters dated December 15, 2006 (FWS) (USFWS Reference: 13260-2007-I-0023) and December 18, 2006 (NMFS)) on that proposed action and compliance agreements were finalized for both companies. Now, additional companies are proposing to transport GRG via barge from Hawaii to landfills in Washington and other states, including Oregon and Idaho and more companies may request approval from APHIS for such activity. Also, HWS and PRER have submitted amendments to their initial requests. APHIS believes that the reinitiation of section 7 consultation with each slight adjustment of each proposal would be burdens ome to both APHIS, FWS, and NMFS and may appear as “piecemealing” the consultation. APHIS believes that all current and future proposals

for movement of baled GRG can be considered and addressed in one consultation if a “worst case scenerio” approach is used in considering effects of the action on federally listed species and critical habitat. Therefore, this BA will consider the movement of a maximum amount of baled GRG by any company from the State of Hawaii to any qualified landfill in Washington, Oregon, or Idaho under compliance agreement from APHIS. The standards required for the original applicants (HWS and PRER) in regards to baling, handling, spill response, and disposal would apply to any company that requests to barge GRG from Hawaii to Washington, Oregon, or Idaho. APHIS will keep track of each proposal/approval to ensure that the amounts of GRG, or barge, rail, or truck traffic considered in this BA are not exceeded. APHIS will re-initiate6 consultation with FWS and NMFS if a proposal would cause exceedance of the amounts of GRG exported from Hawaii, number of barge trips, or amount of rail or truck traffic that were

considered in this document. APHIS will also re-initiate consultation if new effects not considered in this BA are discoverered or if new species are listed or critical habitat is designated that could be affected by this action.

Action Area: The action area for this project encompasses the ocean route from Hawaii to the mainland, the barge-navigable portion of the Columbia River, and rail and truck routes in Oregon, Washington, and Idaho.



### Hawaii

Description: The State of Hawaii is one of the smaller states with only 10,941 square miles of territory spread over six larger tropical islands and a number of smaller ones. It is also physically separated from the mainland of the United States by 2,300 miles of Pacific Ocean. Its tropical nature and isolated location have provi ded Hawaii with many unique attributes, as well as some unique challenges. The nearshore environments around the islands of the Hawaiian archipelago include a large array of marine animals, corals and plants, some of which are endemic and found nowhere else. This area includes the Hawaiian Islands Humpback Whale National Marine Sanctuary, which is comprised of five separate areas abutting six of the major islands of the State of Hawaii (figure 2). A primary attraction of this marine sanctuary is the large congregation of humpback whales that winter in the area. Beyond the nearshore environments surrounding Hawaii is open ocean i nhabited by resident and migratory pelagic fish, birds, sea turtles, and marine mammals. See appendix B for a list of marine mammals of Hawaii, Washington, and Oregon protected under the Marine Mammal Protection Act.Appendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 7 CPHST. 2006b. The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal

Solid Waste from Hawaii. Center for Plant H ealth Science and Technology (CPHST), Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. 8 pp. Federal Motor Carrier Safety Administration. 2007. Crash Statistics. Federa l Motor Carrier Safety Administration (FMCSA), U.S. Department of Transportation. Last accessed July 06, http://ai.fmcsa.dot.gov/CrashProf ile/StateCrashProfileMain.asp. Hazardous Materials Information System. 2007a. Hazardou s Materials Safety: Serious incidents. Office of Hazardous Materials Safety, U.S. Department of Transportation. Last accessed July 26, 2007, http://hazmat.dot.gov/pubs/inc/ data/tenyr_orig_serious.pdf. Hazardous Materials Information Syst em. 2007b. Hazardous Materials Safety : Total incidents. Office of Hazardous Materials Safety, U.S. Department of Transportation. Last accessed July 26, 2007, http://hazmat.dot.gov/pubs/inc/data/tenyr.pdf. Office of Safety Analysis. 2001. Railroad Safety Statistics: Final Report 2000. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 150 pp. Office of Safety Analysis. 2003. Railroad Safety Statistics: Final Report 2001. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 158 pp. Office of Safety Analysis. 2004. Railroad Safety Statistics: Final Report 2002. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 150 pp. Office of Safety Analysis. 2005a. Railroad Safety Statistics: Final Report 2003. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 159 pp. Office of Safety Analysis. 2005b. Railroad Safety Statistics: Final Report 2004. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 161 pp. Office of Safety Analysis. 2006a. Railroad Safety Statistics: Final Report 2005. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 150 pp. Office of Safety Analysis. 2006b. Thr ee-year accident rate trends. Office of Safe ty Analysis, Federal Railroad Administration. Last accessed July 27, http://safetydata.fra.dot. gov/OfficeofSafety/Query/Defa ult.asp?page=inctally2.asp. Office of Safety Analysis. 2007. 3.07 A ccidents By State/Railroad. Offi ce of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation. Last accessed July 3, 2007, http://safetydata.fra.dot. gov/OfficeofSafety/Query/defa ult.asp?page=incabbr.asp. U.S. Army Corps of Engineers. 2003. Waterborne Commerce of the United States: Calendar Year 2001, Part 5. Corps of Engineers, United St ates Army, Washington, D.C. 98 pp. U.S. Army Corps of Engineers. 2006a. Waterbor ne Commerce of the United States, Calendar Year 2005: Part 4–Waterways and Harbors; Pacific Co ast, Alaska and Hawaii. Institute for Water Resources, U.S. Army Corps of Engineers, Washington, D.C. 207 pp. U.S. Army Corps of Engineers. 2006b. Waterborne Commerce of the United States, Calendar Year

2005: Part 5–National Summaries. Institute for Wa ter Resources, U.S. Army Corps of Engineers, Washington, D.C. 99 pp.8 MSW that is disposed of at the Waimanalo Gulch municipal landfill has primarily been collected by private waste haulers and commercial self-haulers. For the most part, it includes waste generated at businesses, institutions, multi-family residences, and condominiums. Waste collected from single-family households and some apartments and commercial facilities is collected by County Refuse Division trucks and is sent to the incinerator along with some of the MSW from private waste haulers. The waste stream that is deposited at Waimanalo Gulch consists of the following types of materials (R.M. Towhill Corp., 1999):

Paper...................................................................8.9% Including:

Cardboard............5.2% Low grade paper....2.2%

Plastics.................................................................5.0% Including: Film plastics.....2.5% Rigid plastic....1.4%

Metal...................................................................12.3%

Glass.....................................................................0.5% Other inorganics ......................................................20.0% Including: Gypsum wallboard....7.0% Asphalt roofing........1.4% Asphalt paving.........1.9%

Concrete................2.9%

Sand/soil/dirt..........4.0%

Other wastes...........................................................6.4% Including:

Furniture/mattresses.....5.1% Appliances.................1.0%

Yard Waste..............................................................6.0%

Wood .....................................................................31.2% Including:

Treated wood.......13.9%

Pallets/crates..........7.6%

Untreated lumber....5.8% Untreated plywood...2.6% Stumps.................1.3% Other organics...............................................................9.6% Including: Carpet................4.5%

Food.................1.6%

There are other sources of GRG in Hawaii besides that destined for Waimanalo Gulch municipal landfill. However, any alternative sources of GRG (i.e., Hilo or other cities or islands of Hawaii) must meet the APHIS requirement of APHIS regul ations pertaining to the regulation of garbage generated in Hawaii (7 CFR part 330.402 and 403). Specifically, garbage is defined as urban9 (commercial and residential) solid waste from municipalities in Hawaii, excluding incinerator ash and collections of agricultural waste and yard waste. Regulated (domestic) garbage refers to articles generated in Hawaii that are restricted from movement to the continental United States under various quarantine regulations established to prevent the spread of plant pests (including insects, disease, and weeds) into areas where the pests are not prevalent. Together, these comprise garbage and regulated (domestic) garbage, referred to as GRG in this BA.



### Description of APHIS Risk Assessments, Regulations, and Other Aspects of the Proposed Action

Potential for Escape of Plant Pests: The opportunity for GRG to carry plant pests has been a major concern for APHIS and is the primary reason that APHIS has regulatory interest in Hawaiian GRG that may be transported to the continental United States. The opportunity for such pests to be introduced into an environment where they are not normally found and where they could potentially do environmental harm is of concern. The compression, baling, and wrapping process that is required for all GRG to be shipped to the continental United States is designed to reduce the potential for impact to an insignificant risk. By prohibiting agricultural and yard waste (other than incidental amounts (<3%) that may be present in GRG despite reasonable efforts to maintain source separation), much of the risk of pest presence in the GRG is eliminated, resulting in an insignificant risk of pest introduction and establishment in the continental United States. A review of the composition of the GRG from Oahu that could potentially be shipped to the mainland United States indicates that the greatest potential for pest presence would be in any yard waste, stumps, sand/soil/dirt, and food that could be in the GRG.

The USDA, Center for Plant Health Science and Technology (CPHST) developed several risk assessments (attached as appendices C-F in this document) that evaluate the effectiveness of the compressing and packing technology for processing GRG to keep plant pests from entering and successfully establishing in the States of Washington, Oregon, and Idaho, and in the continental

United States. 2 This is because injurious plant pests (quarantine pests) exist in Hawaii that are not currently present or widely distributed within and throughout the continental United States. Under the circumstances, it was necessary to determine the risk and likelihood of introduction and establishment of these pests in the continental United States, and whether there would be potential economic and environmental impacts. APHIS analyzed the plant pest risk of introduction and subsequent establishment of plant pests from properly compressed, baled, and wrapped Hawaiian GRG and found that risk to be insignificant (see appendices C-F).

This risk is considered insignificant for the following reasons: Any pests that remain in the GRG (e.g., in the incidental amounts (<3%) of yard and agricultural waste and soil with weed seeds and food) would be subjected to the compressi on, baling, and wrapping processes. Compression, baling, and wrapping of GRG results in crushing and oxygen deprivation of pests. When bales

2 Risks to animal health have not been considered in the c ontext of the risk assessment process because there are currently no known exotic animal diseases in Hawaii that woul d pose a threat of entry into the continental United States, including the State of Washington.10 are wrapped to the point of being airtight, as re quired, internal temperatures begin to rise and conditions inside the bale become anoxic within several days, thus depriving pests of oxygen. Wrapped bales sit in a staging area for 5 days prior to loading them onto a barge for transport to the continental United States. This allows time for anoxic conditions to develop within the bales. When coupled with the time required to barge the bales to the destination landfill, it is clear that any pests that have survived the packaging process will have been exposed to anoxic

conditions for between two and three weeks. On ce arriving at the landfill destination, the bales will be transloaded to an asphalt or concrete staging area. Bales may remain at the staging area for a few weeks before being transloaded to trucks or rail cars and sent to the landfill. Once placed in the landfill, they will be covered with si x inches of dirt on that same day and will be buried by 7 feet of material within a short time of their arrival.

As long as bales are not punctured, any pests that do survive the trip to to the landfill (most likely weed seeds and pathogens on rotting food) cannot escape the bale and are buried at the landfill, thus posing no risk to the environment. If bales are punctured or torn open during handling, they will either be re-wrapped or patched, depending upon the severity of the puncture, according to the detailed requirements outlined in the compliance agreements to restore their airtight condition. Because of the insignificant risk of plant pest escape and establishment in the continental United States, there will be no effect on listed species or critical habitat from the introduction of non-indigenous plant pests.

Potential for Escape of “Hitchhiking” Pests: The Pest Risk Assessments, prepared by APHIS, indicate that overall, the transportation of urban solid waste from Hawaii in plastic-wrapped, airtight bales poses a low risk of pest establishment; and that the greatest risk is from hitchhikers. Thus, the PRA specific for the movement to Oregon recommends that the bales be certified mollusk-free by the company. The PRA specific for the movement to Idaho also recommends inspection and certification. Included in all Compliance Agreements will be a requirement that the company provide inspection at each transloading location as well as the final offloading point. The companies are required by the compliance agreement to ship bales that do not carry hitchhikers. There is no specific method required by APHIS to achieve this standardbesides inspection, although other methods may be used as well. If a mollusk is found on a pallet a or bale at any of these inspection points on the mainland, the company is required under the Compliance Agreement, to separate it on a solid, flat, impervious surface made of asphalt or concrete, circle the bale with salt, and contact local PPQ immediately so that proper action can be taken to mitigate any potential pest risk. The Compliance Agreements also require that the staging area for bales in Hawaii as well as on the mainland be a solid, flat, impervious surface made of asphalt or concrete.

Before handling and transport of Hawaiian GRG bales, company employees are required to be trained in various procedures for complying with the agreement, including training on Hawaiian plant pests. If a company is found to be in vi olation of any part of the Compliance Agreement, then the Compliance Agreement may be cancelled in accordance with 7 Code of Federal Regulations 330.403(d).11 Hawaii side generic compliance agreement: COMPANY will ensure that the Staging Area be kept clean and free of loose garbage and soil. The Staging Area shall be clearly marked and physically separated from the Transport Area. Operational procedures pertinent to the Staging and Transport areas shall be posted in a location visible to all COMPANY personnel and authorized representatives.

COMPANY shall develop and enforce plans for pe st exclusion and eradication programs to control pests that may be attracted to the bales in the staging and loading area (i.e. rodents, birds, mollusks, etc.) These plans shall be submitted for approval by USDA, APHIS, PPQ in Honolulu,

Hawaii.

COMPANY personnel or their authorized representative shall conduct an inspection of each bale upon placement onto the barge. Bales shall be inspected for any punctures, ruptures, or tears and external contaminants (i.e. soil, garbage, mollusks) upon placement onto the barge. The date and identification of the personnel responsible for the inspection and authorization for forward

movement shall be indicated in the bale manifest.

Mainland side generic compliance agreement:

The staging and transport area shall be kept clean and free of loose garbage and soil. The areas will be controlled for birds, rodents, mollusks, and any other pests that may be attracted to the

bales.

All Garbage and Regulated (domestic) Garbage must be protected from birds, rodents, and mollusks during staging and transport. The bales of Garbage and Regulated (domestic) Garbage will be isolated from close proximity to exposed fresh fruits, plants, or other activities which may attract hitchhiking plant pest. Barriers will be erected if this occurs due to unusual and unavoidable circumstances if the operations cannot be moved.

If bales are palletized, each pallet will be inspected thoroughly to ensure no hitchhiking mollusks. Pallets found to contain hitchhiking mollusks will be separated immediately. The infested pallets will be safeguarded within a circle of salt on a level, solid, and impervious surface of asphalt or cement, and local PPQ will be notified promptly.

PPQ does conduct compliance checks, and with most new operations, those checks are more heavy and frequent at the beginning of the progr am. This provides opportunity to address any concerns and ensure that the company is meeting the standards set in the Compliance Agreement. If the company is operating according to the Compliance Agreement, then PPQ compliance checks become less frequent. The frequency of those checks will be determined byPPQ locally.

See appendices C-F for APHIS risk assessments re garding transport of GRG from Hawaii to the continental United States, and specifically, Washington, Oregon, and Idaho.12 APHIS Regulations Pertaining to the Regulation of Garbage Generated in Hawaii:

Sec. 330.402 Garbage generated in Hawaii

(a) Applicability. This section applies to garbage generated in households, commercial establishments, institutions, and businesses prior to interstate movement from Hawaii, and includes used paper, discarded cans and bottles, and food scraps. Such garbage includes, and is commonly known as, municipal solid waste. (1) Industrial process wastes, mining wastes, sewage sludge, incinerator ash, or other wastes from Hawaii that the Administrator determines do not pose risks of introducing animal or plant pests or diseases into the continental United States are not regulated under

this section. (2) The interstate movement from Hawaii to the continental United States of agricultural wastes and yard waste (other than incidental amounts (less than 3 percent) that may be present in municipal solid waste despite reasonable efforts to maintain source separation) is prohibited. (3) Garbage generated onboard any means of conveyance during interstate movement from Hawaii is regulated under Sec. 330.401. (b) Restrictions on interstate movement of garbage. The interstate movement of garbage generated in Hawaii to the continental United States is regulated as provided in this section. (1) The garbage must be processed, packaged, safeguarded, and disposed of using a methodology that the Administrator has determined is adequate to prevent the introduction or dissemination of plant pests into noninfested areas of the United States. (2) The garbage must be moved under a compliance agreement in accordance with Sec. 330.403. APHIS will only enter into a compliance agreement when the Administrator is satisfied that the Agency has first satisfied all its obligations under the National Environmental Policy Act and all applicable Federal and State statutes to fully assess the impacts associated with the movement of garbage under the compliance agreement. (3) All such garbage moved interstate from Hawaii to any of the continental United States must be moved in compliance with all applicable laws for environmental protection.

Sec. 330.403 Compliance agreement and cancellation.

(a) Any person engaged in the business of handling or disposing of garbage in accordance with this subpart must first enter into a complia nce agreement with the Animal and Plant Health Inspection Service (APHIS). Compliance agreement forms (PPQ Form 519) are available without charge from local USDA/APHIS/Plant Protection and Quarantine offices, which are listed in telephone directories. (b) A person who enters into a compliance agreement, and employees or agents of that person, must comply with the following conditions and any supplemental conditions which are listed in the compliance agreement, as deemed by the Administrator to be necessary to prevent the dissemination into or within the United States of plant pests and livestock or poultry diseases: (1) Comply with all applicable provisions of this subpart; (2) Allow inspectors access to all records maintained by the person regarding handling or disposal of garbage, and to all areas where handling or disposal of garbage occurs; (3)(i) If the garbage is regulated under Sec. 330.401, remove garbage from a means of conveyance only in tight, covered, leak-proof receptacles;13 (ii) If the garbage is regulated under Sec. 330.402, transport garbage interstate in packaging approved by the Administrator; (4) Move the garbage only to a facility approved by the Administrator; and (5) At the approved facility, dispose of the garbage in a manner approved by the Administrator and described in the compliance agreement. (c) Approval for a compliance agreement may be denied at any time if the Administrator determines that the applicant has not met or is unable to meet the requirements set forth in this subpart. Prior to denying any application for a compliance agreement, APHIS will provide notice to the applicant thereof, and will provide the applicant with an opportunity to demonstrate or achieve compliance with requirements. (d) Any compliance agreement may be canceled, either orally or in writing, by an inspector whenever the inspector finds that the person who has entered into the compliance agreement has failed to comply with this subpart. If the cancellation is oral, the cancellation and the reasons for the cancellation will be confirmed in writing as promptly as circumstances allow. Any person whose compliance agreement has been canceled may appeal the decision, in writing, within 10 days after receiving written notification of the cance llation. The appeal must state all of the facts and reasons upon which the person relies to show that the compliance agreement was wrongfully canceled. As promptly as circumstances allow, the Administrator will grant or deny the appeal, in writing, stating the reasons for the decision. A hearing will be held to resolve any conflict as to any material fact. Rules of practice concerning a hearing will be adopted by the Administrator. This administrative remedy must be exhausted before a person can file suit in court challenging the cancellation of a compliance agreement. (e) Where a compliance agreement is denied or canceled, the person who entered into or applied for the compliance agreement may be prohibited, at the discretion of the Administrator, from handling or disposing of regulated garbage.

GRG Baling Process: In Hawaii (all islands), trucks collect waste and take it to a sorting facility. GRG for baling and transportation to the mainland United States is prohibited from containing more than incidental amounts (less than 3%) of agricultural and yard wastes. From the sorting area it is moved to a compression baler where it is unloaded and fed into the baler for compression, baling, and wrapping. GRG is compressed to 1,000 kilograms per cubic meter. All bales of GRG are wrapped with a minimum of four layers of low density impermeable plastic film to provide an airtight and leak-proof encl osure. Wrapped bales weigh between 1.7 to 4 tons. From the compression baler bales are then sent to a staging area until they are loaded onto a barge for the trip to the mainland.

Barge and tug description: The applicants use barges that range in length from 400 to 450 feet long and between 80 and 100 feet wide. Barges are powered by tugs that are 3,000 to 4,000 horsepower and range in length from 90 to 130 feet. The average towing speed across the ocean is 6 to 9 knots and the maximum tow speed is 11.6 knots. Barges will transport approximately 5000-9000 tons of GRG per barge. Bales will be secured to barges by straps or other methods to prevent loss of bales during ocean crossing and river transport.

Barges carry no fuel or oil. Tugs carry between 100,000 and 200,000 gallons of fuel and 500 gallons of oil. No fuel or oil will be discharged during the voyage; an appropriate quantity of fuel will be loaded in Hawaii such that the remaining fuel is sufficient for the trip up the14 Columbia River but not so excessive that a discharge is required to make draft for passage though the locks.

Ocean routes of travel: The applicants have indicated that the tug/barge route that will be traveled (in a westbound context) is such that the barge will travel up the Columbia River and out into the Pacific Ocean approximately 25 mile s, where it will turn south. They will travel south parallel to the coast until near Eureka, California. There, they will make the turn west for Hawaii in a fairly straight southwesterly line. There could be some variation in the route taken however. The full route from Hawaii to the Columbia River is roughly 2,500 miles. See figure 3 for a general map of the barge/tug route.

Figure 3. General route map for barging GRG from Hawaii across the Pacific Ocean to the

mouth of the Columbia River.

Ballast Water: The tugs have internal ballast tanks to provide trim and stability for the ocean crossing. The tugs draw water from the ocean as required to meet trim and stability requirements. Tug ballast water is drawn from the sea and discharged at sea.

Barges are ballasted only during the loading and unloading phase alongside the dock. As barge cargo is unloaded, the stability of the barge shifts, requiring the barge to ballast for trim and stability. Similarly, as the barge is loaded, the center of gravity shifts requiring the barge to ballast to accommodate the weight change. All water taken on to ballast barges for loading or15 unloading is released into the same water body that it was taken from. No ballast water is carried in the barge ballast tanks for the voyage across the ocean. Thus, there will be no effect on any listed species or critical habitat as a result of ballast water discharge.

Hull Fouling: Both barges and tugs use the industry standard ablative coating system to prevent hull fouling. The ablative coating provides a slick surface to which fouling organisms cannot adhere. Currently, barges and tugs are using IntercleneTM, formula BRA 572, from International Paint. However, the specific anti-fouling coating used could vary in the future. Underwater moving equipment is further protected with sacr ificial zinc anodes. However, APHIS has no authority to regulate hull fouling prevention.

Based on information received from Dan Brown, U. S. Fish and Wildlife Service, Pacific Region, Ecological Services, many of these treatments may result in copper leaching. Dissolved copper is known to cause olfactory impairments in salmonids. Copper can disrupt and damage the olfactory system of salmonids and cause a decreased capacity to detect important chemical cues in the environment, including but not limited to the location of prey, predator avoidance and locating natal streams. This sense of smell is critical for salmonids to complete to their complex life history behaviors including homing, foraging, and predator avoidance. Thus, there is potential for these sublethal impacts on the olfactory function to reduce individual salmon chances of survival and reproduction. To address the potential for effects of copper leachate from aquatic vessels , APHIS has prepared a risk assessment on the potential risk of copper exposure to salmonids in the Columbia River fr om barges containing baled GRG from Hawaii. This assessment is included in the “Fish Species That Occur in the Columbia River That Could be Affected by Transport of GRG by Barge” section.

Estimate of Barge Trips Across Ocean: A total of 980,000 tons of GRG annually has been requested by applicants for transport to landfills in Washington, Idaho, and Oregon by the companies that have requested APHIS permission for this action and additional companies could request APHIS permission to transport more to the mainland United States. In the 2005 calendar year, 1,425,752 tons of municipal solid waste were di sposed of in the State of Hawaii, either by landfilling or incineration (OSWM, 2006). However, the State of Hawaii has indicated that it will only allow 300,000 tons of GRG to be exported off-island, regardless of what applicants have proposed. Thus, if a barge carries 5,000 tons of GRG, this would result in approximately 60 barge trips per year, slighly more than 1 per week. In this BA, APHIS will assume that there will be 100 barge trips of GRG from Hawaii per year across the Pacific Ocean to the mainland United States as a worst case scenerio, equaling 500,000 tons of GRG. However, an important aspect of the proposed action is that these tugs and barges traveled to Hawaii loaded with construction or other materials and would be returning to the mainland United States empty regardless of whether this proposed action is approved by APHIS. It is not cost-effective to send empty barges to Hawaii simply for the purpose of picking up baled GRG to return to the mainland. Thus, no net increase in barge traffic across the Pacific Ocean is expected from this action. Nonetheless, the potential effects of barge travel to listed and other marine species are discussed below, in section III, and in appendix B.16 Potential Effects from Ocean Tug/Barge Travel: The potential direct and indirect effects from the ocean travel include striking marine animals by barge/tug combination, increased marine debris, and disturbance of species.

Columbia River Travel: The Columbia and Snake Rivers carry 50 million tons of cargo per year to and from the Pacific Ocean along a 465-mile waterway. A series of eight locks facilitates the passage of ships from the ocean to as far inland as Lewiston, Idaho. These locks are part of the same projects and reservoirs that produce hydropower and help control flooding. From the ocean to Portland, Oregon and Vancouver, Washington, dredging assures that a 40-foot-deep open river channel remains open year-long for ocean-going vessels. This 106-mile segment then connects with a 359-mile segment that extends to Lewiston, Idaho. Within this second segment, a 14-foot-deep channel for barges and other craft is kept open. To maintain this channel depth,

maximum and minimum reservoir elevations are set. These elevations are determined within the context of meeting needs for electrical generation, flood control, and the release of water to help fish passage. In addition to its importance for shipping, the Columbia River is known for its fishery resources. Historically, it contained huge salmonid stocks that supported the indigenous peoples of the area. Over the years, treaties have recognized and maintained the importance of Indian fishing and hunting rights. While greatly reduced from historic levels, salmon and other fish stocks remain an important resource in the Columbia River.

Potential Effects from Columbia River Tug/Barge Travel: A direct effect of the proposed action could be an increase in barge traffic on the Columbia River. A U.S. Army Corps of Engineers (2004) study indicated that the net vol ume of tonnage for the Columbia Basin was 54,390,000 (short) tons of freight (all commodities), with over 1,113,000 tons going between Vancouver and The Dalles and 2,231,000 tons moving above The Dalles. Assuming an average of 5,000 tons per barge load, there are approximately 10,000 barge trips per year on the Columbia. If 100 additional barge trips per year are added, the anticipated increase in barge traffic (approximately 100 trips per year) would represent approximately 1 percent of all barge traffic on the Columbia. This represents a minimal increase in barge traffic on the Columbia River.

Household chemical waste comprises only 0.3% of Hawaiian solid municipal waste (R.M. Towhill Corp., 1999). Before baling, this waste will be sorted to eliminate yard waste, recyclables, and hazardous chemical waste. Although there is a possibility that some household chemical waste could make its way into a bale, an accident would have to occur for a bale to fall into the water. The bale would also have to break open. The rate of barge accidents is low, as will be discussed later in this BA. Because the potential quantity of household chemical wastes being present in the bales is very low, combined with the low probability of a bale-rupturing barge accident, it is very unlikely that there would be an effect on water quality in the mainstem Columbia River. Therefore, the potential impacts on water quality are not considered further.

Another direct effect of the proposed action could be a decrease in water quality from fuel or oil leaks from the tug. A catastrophic spill of fuel or oil is extremely unlikely and would be considered under an emergency consultation with the Services. However, routine leakage of

small amounts of fuel or oil in the Columbia River is considered in this assessment. Effects of the fuel could directly poison fish species in th e Columbia River or indirectly affect them by17 poisoning invertebrate or prey species. Oil and petroleum products vary considerably in their toxicity, and the sensitivity of fish to petroleu m varies among species. The sublethal effects of oil on fish include changes in heart and respiratory rates, gill hyperplasia, enlarged liver, reduced growth, fin erosion, impaired endocrine system, and a variety of biochemical, blood, and cellular changes, and behavioral responses (from page B-32: Biological Opinion, May 9, 2003, U.S. Fish and Wildlife Service, Montana Ecological Services Field Office).

A risk assessment discussing these effects are included in the assessment for Columbia River fish in section II of this document. This assessment has indicated that the risk to species in the Columbia River as a result of fuel or oil leaks would be extremely small.

Transportation by Rail and Truck: Flat-bed semi-tractor trailer trucks or other truck types may be used to transport baled GRG from barge offloading sites to landfills. In certain cases, rail cars will be used to transport baled GRG to landfills. Both of these transportation options

would increase truck or rail traffic in Washington, Oregon, or Idaho, depending on the

destination landfill.

For example, at the Columbia Ridge Landfill in Oregon, 600 to 750 trucks per month are currently received. A proposed option of unloadi ng barges near Boardman, OR and transporting baled GRG by truck to the Columbia Ridge Landfill would add 125 to 200 additional trucks per month to that landfill. The Columbia Ridge Landfill currently receives approximately 5 unit trains per week with each train containing 60 to 65 railcars (1,200 to 1,400 railcars and 60,000 to 80,000 tons per month). A proposal to unload barg es in the Portland, Oregon area and transport GRG by rail to Columbia Ridge Landfill, would add an additional 100 to 150 additional railcars each month to the incoming rail traffic at that landfill.

As of 2001, there were 2,387 route miles of ra ilroad in Oregon (ODT, 2001) (figure 4). Currently, the Union Pacific’s east-west line in Oregon that runs along the south bank of the Columbia River and the I-84 corridor into Idaho is proposed for transport of GRG from Portland to a landfill in Gilliam County, Oregon.18 Figure 4. Freight railroads in Oregon (ODT, 2001).

Idaho is served by two Class I Railroads (carriers having revenues in excess of $250 million annually), the Burlington Northern and the Union P acific. In addition, service is provided by six regional or local railroads. Together, they comprise a 1,940-mile state rail system (ITD, 1996) (figure 5).19 Figure 5. Railroads in Idaho (ITD, 1996).

Washington State is served by two Class I railroads, two regional railroads, and 16 active short lines and switching railroads (WSTC, 2006) (figure 6). In total, there are 3,628 miles of rails operated in the state (WSTC, 2006).20 Figure 6. Washington State Rail System (WSDOT, 2007).

Potential Effects From Rail and Truck Transportation: Increased rail and truck traffic as GRG bales are transported from unloading sites on the Columbia River to landfills will occur. This traffic increase could increase the likelihood that certain listed species could be struck by trucks or trains. Collisions between wildlife and vehicles result in the loss of wildlife, vehicle damage, and, occasionally, human injuries or fatalities. Between 1986 and 2005 in Yoho National Park in Canada, park staff have reco rded over 500 wildlife-vehicle collisions involving large animals. Most victims of highway strikes are large ungulates (deer, elk, and moose), but wolves, coyotes and black bears are also commonly hit. The impact of highway strikes on small mammal, bird, and amphibian populations is unknown, as these collisions are rarely reported.

The following quoted information is from: The relationship between rare carnivores and highways, an update for year 2000. Bill Ruediger, Endangered Species Program Leader, USDA Forest Service, Northern Region, Missoula, Montana

“Carnivores are particularly susceptible to highw ay mortality because of their large home ranges, low biological productivity and the enormous si zed areas required to sustain populations and individuals. Due to the long life spans (over 30 years for grizzly bear), carnivores can continue existing as individuals-without persisting as populations. As mentioned previously, human21 caused mortality has been a contributing factor for many species. Examples of direct mortality on wolves are num erous. In Banff National Park during 1996, there were 11 wolf mortalities caused by collisions with cars, trucks and trains. This was the equivalent of the entire known wolf reproduction for the park and surrounding area. When wolves recolonized NW Montana, two alpha male wolves were killed on I-90 (Bangs, personal communication). The reintroduced wolves as of 2000 are doing well in both Yellowstone National Park and Central Idaho. Vehicle collisions with wolves have become a regular occurrence for these populations. In Weaver's (personal communication) wolf study in Jasper National Park and Paquet's in Banff National Park, highway and railroad mortality averaged 1-2 per pack per year.

Grizzly bear are rarely killed on highways. However, documented fatal collisions have occurred on Highways 93 and 2 in Montana and the Tr ans-Canada Highway before fencing was employed. The rare occurrences of grizzly mortality are likely due to their general avoidance of highways and their low population numbers and densities.”

“Lynx highway mortalities have recently been observed in Colorado, where 10% of the known mortality of a reintroduced population has been vehicle collisions. Clevenger has also seen lynx carcasses on the Trans-Canada Highway. Sixteen of 83 lynx translocated lynx were killed on highways in New York (Brocke et al. 1991).”

“Information from Florida on black bear road k ills suggests that while vehicle use of highways in the study area increased by 100% (to 24,000 vehicle trips per day), black bear road kills went from less than five to over 90 in the same period (Gilbert & Wooding, 1996).”

Grizzly bears have been struck and killed by tr ains; trains between West and East Glacier, Montana killed 13 grizzly bears during the period 1992-2002 (Waller et al. 2005). Railways are another source of human-induced wildlife mortality in Yoho National Park. The Canada Pacific (CP) rail line through Yoho was opened in 1885; today approximately 35 trains travel through the park each day. Since 1986, over 55 animals have been reported killed on the CP rail line, including 25 elk, 11 black bears and 6 wolves. In Banff National Park in Canada, significant amounts of spilled grain have been observed between the rails over the past several years from 6,000 CP hopper cars suspected of leaking grain between the prairies and west coast terminals. Grizzly bears, black bears, wolves, coyotes, elk and deer have been struck and killed as they forage for grain or use the right-of-way for easy passage.

Estimate of Rail Traffic Increase: Using an estimate of 500,000 tons of GRG from Hawaii per year, a bale weight of 1.7 tons, and a trans port weight of 112 tons per railcar (based on information submitted by Idaho Waste Systems), a total of about 4,465 railcars would be added to rail transport per year, assuming that all of the GRG is transported by railcar to landfills. In Oregon alone, 63.5 million tons of cargo were tran sported by rail to, from, within, and through the state in 1999 (Oregon Rail Plan, 2001). This would translate into 566,965 railcars per year. Based on this figure, transport of GRG by rail would result in a less than 1 percent increase in number of railcars per year in Oregon. In 1998, 85 million tons of freight were moved by rail to, from, and within Washington (USDOT, 2002a). This translates to 758,929 railcars. Based on this figure, transport of GRG by rail would also result in a less than 1 percent increase in number22 of railcars per year in Washington. For Idaho, 18 million tons of freight were moved by rail to, from, and within the state (USDOT, 2002b). This translates into 160,715 railcars. Based on this figure, transport of GRG by rail would result in a 3 percent increase in number of railcars per year in Idaho. These estimates of rail increase are very conservative and assume that all of the GRG from Hawaii would be transported by rail, a scenerio that is unlikely.

Estimate of Truck Traffic Increase: Using an estimate of 500,000 tons of GRG from Hawaii per year, a bale weight of 1.7 tons, and a tran sport weight of 34 tons per truck (based on information submitted by applicants in WA), a total of 14,706 trips would be added to truck transport per year, assuming that all of the GRG is transported by truck to landfills. In 1998, 220 million tons of freight were transported by highway in Oregon (USDOT, 2002c) (approximately 6,470,588 truckloads), 307 million tons in Washington (USDOT, 2002a) (approximately 9,029,411 truckloads), and 95 million tons in Idaho (USDOT, 2002b) (approximately 2,794,117 truckloads). This results in a 0.2, 0.1, and 0.5 per cent increase of truck/highway freight traffic in Oregon, Washington, and Idaho, respectively. These estimates of truck traffic increase are very conservative and assume that all of the GRG from Hawaii would be transported by truck, a scenerio that is unlikely.

Potenial Effects from Barge, Train, Tr uck, and Bale Transferring Accidents: Short of capsizing (which would be considered a catastrophic event and would be cause to initiate emergency consultation with NMFS and/or FWS), there is little risk of environmental impact from the transport of baled GRG from Hawaii to the mainland United States. Places where there is potential for impact to occur are wherever bales are moved from one staging area or mode of transportation to another. The transfer points include: (1) the staging area in Hawaii where baled GRG is moved, handled, and loaded onto barges, (2) the staging area where bales are transloaded from the barges and loaded onto railcars or trucks; and (3) the final destination where bales are unloaded from rail cars or trucks and placed into the landfill.

At each of the bale transfer points identified above, there is a small potential for dropping a bale into the water or compromising the integrity of one or more bales of GRG that could result in spillage of the contents on the ground or into the water. Information provided by one of the applicants indicates that when bales were droppe d from heights ranging from 7.5 feet to 12 feet, the bales did not rupture, but remained intact. Ra ther than bales rupturing, it is more likely that equipment operators who are handling bales could accidentally puncture bales. Even though puncturing may occur, material compressed to the extent the baled GRG will be (estimated at 1000 kilograms per cubic meter) is likely to be resistant to movement of material out of the bale. In addition, the likelihood of pest species escaping, while not zero, is very low because of the low likelihood of host material being present and of pests surviving the compression and packaging process and any anoxic conditions experienced until the time of the puncture. Even if material did exit the bale upon puncture, in most cases the spilled GRG would be quickly retrieved and the bale patched or repackaged according to the requirements of the compliance agreement. If this were to happen over water, it would be more difficult to retrieve the spilled

GRG.

Physical risks that must be considered in such a situation include a physical disruption of the environment caused by the broken bales and the physical retrieval of their strewn contents.23 Physical removal of GRG that has been spilled on land will be relatively easy to retrieve. Most, if not all, of the land that will be used during the transfer of bales will be commercial or industrial in nature and not suitable habitat for wildlife. Therefore any cleanup activities are unlikely to have an environmental effect. GRG that is spilled into waterways will be more difficult to retrieve, and some may not be retrievable, resulting in an incremental but permanent degradation of the natural aquatic environment. Since hazardous wastes are not permitted in the bales, any negative impacts will be restricted to physical ones and no chemical pollution is likely

to result from the GRG itself.

Bales of GRG could potentially fall from the barge, either in the ocean or in the Columbia River. Bales of GRG will sink to the bottom because of their significant relative density. Bales may remain intact or could break open, depending on conditions. U.S. Army Corps of Engineers (2002, 2003) gave a mean accident rate for barges of 28.3 per billion ton-miles. Of those, only 4

of the 167 accidents on the Columbia River invol ved freight barges (Marine Safety Offices, 2006). The mean fraction of accidents that might cause bales to rupture was 0.11, estimated from the number of accidents involving hazardous materials which resulted in spills from 1990 to 1997 (see appendix C for APHIS risk assessment). However, applicants must submit spill response plans should bales fall into the water.

The APHIS risk assessments (appendices D-F) an alyzed the potential for bale-rupturing accidents based on specific proposals submitted by applicants. Although none of the risk assessmentsanalyzed the transport of 500,000 tons of GRG, they demonstrate the low probability of balerupturing accidents for barge, truck, and rail transport. This information is summarized in the

below.

• The APHIS risk assessment for Washington State (see appendix D) estimated the annual likelihood of a bale-rupturing accident was 0.03 percent for trucks and 0.37 percent for barges. Mean years to the first bale-rupturing accident for trucks was estimated at 3,333, and that for barges was 130 (USDA, APHIS, 2006). APHIS found a 95 percent chance that the first truck accident would occur only after 171 years, or after 7 years for barge transport. The risk of catastrophic rupture of bales while in transport by truck or barge to Roosevelt landfill is very low (USDA, APHIS, 2006). These risk figures were based on the proposed transport of 300,000 tons of GRG per year.

• The APHIS risk assessment for Gilliam County, Oregon (see appendix E) estimated that for the proposal to offload the baled GRG at the Port of Arlington and truck it to Columbia Ridge Landfill, the risk of a bale-rupturing accident for trucks was 0.045 percent and for barges was 0.41 percent. Mean years to the first bale-rupturing accident for trucks was 2,222, and that for barges was 246. For the alternate route where GRG is off-loaded near Ranier, Oregon and is transported by rail to the Columbia Ridge Landfill, the risk of any bale-rupturing accident by train was 0.002 percent, while that for barges was 0.77 percent. Mean years to the first bale-rupturing accident for trains was 50,000 and for barges, was 130. There wa a 95 percent chance that the first train accident would occur only after 921 years, or after 554 years for barge transport. These risk figures were based on the proposed transport of 120,000 tons of GRG per year. For both options, the risk of catastrophic rupture of bales is low, less than 1 percent.24 • The APHIS risk assessment for Elmore County, Idaho (see appendix F) estimated that for a proposal to barge bales 60 miles up the Columbia River and off-load them onto railcars at Rainier, OR, the mean annual probability of a bale-rupturing accident by barge was 0.07 percent, and for trains 0.26 percent. Mean years to the first bale-rupturing barge accident was 645 years, with only a 5 percent chance of happening within 34 years. Mean years to the first bale-rupturing rail accident was estimated to be 1,429 years, with only a 5 percent chance of that accident happening within 74 years. These probabilities are based on a figure of 360,000 tons transported annually.

Potential Effects from Interrelated Actions: An interrelated action of the proposed action is that barges that transport bales of GRG from Hawaii to the mainland will come from the mainland to Hawaii loaded with materials that are not regulated by APHIS. This could include construction materials or any other product that is transported to Hawaii via barge, and rather than these barges returning to the mainland empty, bales of GRG will be transported to the mainland. APHIS has no knowledge of what these materials are because they are unregulated by this agency. Barges transporting materials from the mainland will depart to Hawaii regardless of whether APHIS approves the movement of GRG bales. It is difficult to predict the effects of these interrelated, yet unknown actions.

Potential Effects from Interdependent Actions: There are no known interdependent actions that will result from approval or implementation of this proposal.

Potential Cumulative Effects: Private and state activities, including barging and transport of materials in the Columbia River, movement of fr eight by truck or rail, and disposal of MSW in landfills occur on a regular basis throughout Or egon, Idaho, and Washington. APHIS does not anticipate any cumulative effects as a result of the proposed action because the increase in barge, rail, and truck transport as a result of this action is not significant. In addition, because the likelihood of bale rupturing accidents via barging, rail transport, and trucking is low, increased pollution/trash in the Columbia River or plant pest release is not expected as a result of this action (USDA, APHIS, 2006, 2007 (see appendices C-F)).

In Hawaii, there are many shipping and boating activities that occur. Some of these include:

Hawaii Superferry is a privately owned inter-island ferry system, that utilizes a 350 foot-long, four-story high-speed catamaran to carry passengers, vehicles and freight between Oahu, Maui and Kauai. These ships will carry upwards of 850 passengers and 280 vehicles each. They will cruise at speeds of up to 45 mph, greatly endangering humpback whales and all marine life in their path. Currently, service to Maui has been suspended until December 1, 2007. An environmental assessment is in preparation by the State of Hawaii to consider the potential for increased traffic around ports, the potential spread of invasive species, and collisions with humpback whales, among other things. The state legislature passed a measure that was signed by the governor on November 6, 2007 that allows the ferry to operate conditionally while an

environmental assessment is conducted.25 Cruises between the United States mainland and Hawaii are growing in popularity each year. Norwegian/NCL America offers the most Hawaii cruises. Other cruise lines with Hawaii itineraries include Carnival, Celebrity, Holland America, Princess, and Royal Caribbean. These ships offer weekly itineraries visiting ports on the major Hawaiian Islands: Oahu (Honolulu port), Maui (Kahului or Lahaina), Kauai (Lihue), and the Big Island (Hilo and Kailua-Kona). In the first 9 months of 2007, there were 52 cruise ship arrivals in Hawaii compared to 45 in the same period in 2006(Wienert, 2007).

According to a Department of Transportation Freight Management and Operations report, 14 million tons of freight was shipped to, from, and within Hawaii by water in 1998 (USDOT, 2002d). The report predicts 20 million tons for 2010 and 24 million tons by 2020 (USDOT, 2002d). See figure 7 for a Department of Transpor tation map of domestic water flows to Hawaii, and table 1 for the top 5 commodities shipped to, from and within Hawaii.

Figure 7. Domestic Water Flows To, From, and Within Hawaii by Water: 1998 (tons) (USDOT, 2002d)26 Table 1. Top Five Commodities Shipped To, From, and Within Hawaii (USDOT, 2002d)

Tons (millions) Value (billions $) Commodity

1998 2020 Commodity

1998 2020

Crude Petroleum/Natural Gas 12 15 Transportation Equipment 11 21

Nonmetallic Minerals 7 9 Electrical Equipment 7 37

Waste/Scrap Materials 4 9 Machinery 7 39

Petroleum/Coal Products 3 6 Mail/Contract Traffic [ a ] 5 25

Farm Products 3 3 Crude Petroleum/Natural Gas 1 2

a U.S. mail or other small packages.

There is increased potential for collisions with listed marine species and other protected marine

mammals from increased vessel traffic in Pacific waters. All forms of marine vessel traffic appear to be on the increase whether from increased visitors or freight to and from the islands. However, the proposed action will not contribute to cumulative impacts on these species because there will be no increase in the number of tugs and barges coming to Hawaii or returning to the mainland as a result of this proposed action. Barges will come to Hawaii bringing construction materials and other cargo not regulated by APHIS. APHIS has no authority over the number of tugs and barges that travel to and from Hawaii. Rather than returning empty to the mainland, barges will carry baled GRG from Hawaii. It is not financially feasible for waste haulers to send barges to Hawaii solely for the purpose of hauling baled GRG.

References

Brocke, R.H., K.A. Gustafson and L.B. Fox. 1991. Restoration of Large Predators: Potentials and Problems. In: Decker, D.J., M.E. Krasny, G.R. Groff, C.R. Smith and D.W. Gross. Editors: Challenges in the Conservation of Biological Resources - A Practitioners Guide.

Gilbert, T., and J. Wooding. 1996. An Overview of black bear roadkills in Florida 1976-1995. In: Evink, G.L.; Garrett, P.; Ziegler, D.; and J. Berry (Eds.) Trends In Addressing Transportation Related Wildlife Mortality. Proceed ings of the TransportationRelated Wildlife Mortality Seminar.

Wienert, M. 2007. In Hawaii, $9.2 Billion in Visitor Spending Realized Year-to-Date. Hawaii Reporter, October 25, 2007. http://www.hawaiireporter.com/story.aspx?5df8dad9-1c91-4796-

9342-08299dfa6ef3 last accessed November 20, 2007.

Idaho Transportation Department, Transportati on Planning Division (ITD). 1996. Idaho State

Rail Plan. http://itd.idaho.gov/planning/railfreight/railplan/raildown.html last accessed September 27, 2007.

Office of Solid Waste Management. 2006. Report to the twenty-fourth legislature, State of27 Hawaii, Department of Health, December, 2006. 6 pp.

Oregon Department of Transportati on (ODT). 2001. Oregon Rail Plan. http://www.oregon.gov/ODOT/RAIL/docs/railplan01.pdf last accessed September 26, 2007.

OSWM

− see Office of Solid Waste Management

R.M. Towhill Corp., 1999. Oahu Municipal Refuse Disposal Alternatives Study, Waste Composition Study. Honolulu, HI. 36 pp.

U.S. Army Corps of Engineers. 2002. Waterborne Commerce of the United States: Calendar Year 2000, Part 5. Corps of Engineers, United States Army, Washington, D.C. 2002. 140 pp.

U.S. Army Corps of Engineers. 2003. Waterborne Commerce of the United States: Calendar Year 2001, Part 5. Corps of Engineers, United States Army, Washington, D.C. 2002. 98 pp. U.S. Army Corps of Engineers. 2006. Waterborne Commerce of the United States: Calendar Year 2004, Part 4 – Waterways and Harbors Pacific Coast, Alaska and Hawaii Corps of Engineers, United States Army, Washington, D.C. 2002. 197 pp.

U.S. Department of Transportation, Federa l Highway Administration. 2002a. Freight Transportation Profile

− Washington Freight Analysis Framework. FHWA-OP-03-046, EDL 13734. 2 pp.

U.S. Department of Transportation, Fede ral Highway Administration. 2002b. Freight Transportation Profile

− Idaho Freight Analysis Framework. FHWA-OP-03-042, EDL 13730. 2

pp.

U.S. Department of Transportation, Federal Hi ghway Administration. 2002c. State Profile – Oregon: 1998, 2010, 2020 6 pp. http://ops.fhwa.dot.gov/freight/freight_ana lysis/state_info/oregon/profile_or.htm last accessed September 20, 2007.

U.S. Department of Transportation, Federal Highway Administration. 2002d. State Profile – Hawaii: 1998, 2010, 2020 6 pp. http://ops.fhwa.dot.gv/freight/freight_ana lysis/state_info/hawaii/profile_hi.htm last accessed November 20, 2007.

United States Department of Agriculture, Animal and Plant Health Inspection Service. 2006. The Risk of Introduction of Pests to the Continental United States via Plastic-Baled Municipal Solid Waste from Hawaii, 41 p.

United States Department of Agriculture, Animal and Plant Health Inspection Service. 2006. The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal Solid Waste from Hawaii, 8 p.

Waller, J.S., C. Serveen, and D.A. Patterson. 2005. Probabilistic measure of road lethality.28 John Muir Institute of the Environment, Road Ec ology Center, University of California, Davis. http://repositories.cdlib.org/jmie/roadeco/Waller2005a last accessed August 28, 2007.

Washington State Transportation Commission (WST C). 2006. State Rail Capacity and State Needs Study. Task 1.1.A – Washington State’s Freight Rail System. Technical Memorandum. http://www.wstc.wa.gov/Rail/TM1_1_A_WashStateFreightRailsys.pdf last accessed September 26, 2007.

Washington State Department of Transporta tion (WSDOT). 2007. Washington State Rail System Map. http://www.wsdot.wa.gov/freight/Rail% 20System%20Map%20%20Update%20Aug2007.pdf

last accessed September 26, 2007.



## II. Listed Species and Program Assessments

Section 7 of the Endangered Species Act (ESA) and its implementing regulations require Federal agencies to ensure that their actions are not likely to jeopardize the continued existence of endangered or threatened species or result in the destruction or adverse modification of critical habitat. This BA considers the effects of transportation by barge, truck, and train, and landfilling of baled Hawaiian GRG on listed species and designated critical habitat in Oregon, Idaho, and Washington, and on species occurring in the Pacific Ocean where barges would cross from

Hawaii to the Columbia River.

APHIS has determined that the proposed action will have no effect on the species or their designated critical habitat listed in tables 2-5, including plants, birds, aquatic species, and

butterflies.

APHIS is requesting concurrence with its determination that, with the implementation of certain protection measures (in some cases), the proposed action may affect, but is not likely to adversely affect, the humpback whale, blue whale, fin whale, sei whale, sperm whale, Southern Resident killer whale (and designated critical habitat), green sea turtle, hawksbill sea turtle (and designated critical habitat), olive ridley sea turtle, leatherback sea turtle (and designated critical habitat), loggerhead sea turtle, steller sea-lion (and designated critical habitat), and the Hawaiian monk seal (and designated critical habitat) during the barging of baled GRG from Hawaii to the

continental United States.

In the unlikely event that a barge accident were to occur and GRG bales were to fall into the Columbia River, or that oil/fuel would leak from tugs into the river, APHIS requests concurrence with its determination that this may affect, but is not likely to adversely affect salmon, steelhead, and bull trout in the Columbia River. The proposed action may affect, but is not likely to adversely affect the designated critical habitat of these fish.

APHIS is requesting concurrence with its determination that the increased transport of GRG via train or truck, potentially increasing mortality from strikes, may affect, but is not likely to29 adversely affect the Columbian white-tailed d eer, Canada lynx, grizzly bear, northern Idaho ground squirrel, woodland caribou, gray wolf, and the pygmy rabbit (Columbian Basin DPS).

Measures necessary to protect listed species as a result of this and/or future consultations with NMFS and FWS (i.e., steller sea-lion, whales, Hawaiian monk seal, etc.) will be included in all compliance agreements between APHIS and the applicants.

In the occurrence of a catastrophic event, such as the capsizing of a barge loaded with bales of Hawaiian GRG or an oil spill, APHIS will initiate emergency consultation with the Services. Spills and capsizing would be an unpredictable event (temporally/geographically) and therefore, not possible to assess at this time.

PPQ will provide to FWS an annual report for three years (first report should be submitted a year from when GRG shipments from Hawaii commence, and then at he same time for the next 2 years) concerning compliance agreement activities, a summary of any incidents documented on the bale manifests, and any PPQ quarantine-si gnificant pest found in association with themovement of baled garbage from Hawaii. If within those three years no PPQ quarantinesignificant pests are found in association with th e movement of baled garbage then PPQ will no longer send annual reports. After the three year reporting period, a report will only be issued by PPQ to the FWS and NMFS if formally requested. PPQ will notify FWS and NMFS within 3 business days of any known release of any unwanted organisms.



### Listed Marine Species That Could be Affected by Transport of GRG From

Hawaii to the Columbia River.

Hawaiian Monk Seal, Monachus schauinslandi

Status: The Hawaiian monk seal was listed as endangered on November 23, 1976 (FWS and NMFS, 1976). Critical habitat was designa ted on March 23, 1999 (USDOC, NMFS, 1999). A revised recovery plan for the Hawaiian monk seal was completed in August, 2007 (NMFS, 2007).

Pertinent Species Information: Hawaiian monk seals have limbs that are relatively short; forelimbs are somewhat flipper-like; hind limbs have fully webbed digits and cannot be turned forward or used effectively for terrestrial locomotion. Pup pelage is woolly and black. Juvenile pelage is silvery gray above and creamy white below, changing to dull brownish above and yellowish below. Adults are silvery gray to brownish above, whitish or silvery gray or yellowish below. Adult males average around 214 cm in total length and 170 kg; adult females may grow a little larger than this and attain much greater mass (e.g., 270 kg) when pregnant. Pup mass is 16-18 kg at birth. (From NatureServe, 2007)

Hawaiian monk seals are found throughout the northwestern Hawaiian Islands (NWHI) including the population’s six main reproductive sites in the NWHI: Kure Atoll, Midway Islands, Pearl and Hermes Reef, Lisianski Island, Laysan Island, and French Frigate Shoals (NMFS, 2007). Smaller breeding sub-populations occur on Necker Island and Nihoa Island, and

monk seals have been observed at Gardner Pinnacles and Maro Reef. Monk seals are now found30 throughout the main Hawaiian Islands, where births have been documented on most of the major islands (NMFS, 2007).

The Hawaiian monk seal is in a decline and only approximately 1,200 seals remain (NMFS, 2007).

Threats to this species include low survival of juveniles and sub-adults due to starvation, entanglement of seals in marine debris, predation by Galapagos sharks, human interactions in the main Hawaiian Islands, including recreational fishery interactions, mother-pup disturbance on popular beaches, and exposure to disease, seal-haul-out and pupping beaches are being lost to erosion (NMFS, 2007).

Assessment: Honolulu Harbor, around Barber’s Point (west Mamala Bay) and the Port of Hilo in Hilo Harbor, Hawaii are currently proposed harbors for loading baled GRG. It is possible that Hawaiian monk seals may be present within the harbors used by barges transporting baled MSW. Hawaiian monk seals have been sighted in the harbors of Maui and Kauai and some of these

harbors are known to have resident seals. Fo r example, in Maalaea Harbor, Maui, a resident monk seal is known to swim almost daily throughout the harbor. That particular individual is tagged and monitored. There is no discussion of Hawaiian monk seals and harbor occurrences in the recovery plan.

Although there is no published evidence that Hawaiian monk seals have been struck by vessels, one seal was found in 1986 with a broken jaw and presumed propeller cuts on his ventrum (NMFS, 2007). Another seal was found off Kona with an injured back and broken vertebrae and may have been due to a vessel strike (NMFS, 2007). As occurrences of Hawaiian monk seals and vessel traffic both increase in the Main Hawaiian Islands, the chance of collision is likely to

increase.

The potential for collisions between the tug/barge and Hawaiian monk seals is very low due to the slow tow speed (6-9 knots). In addition, implementation of the proposed action will not result in an increase in vessel traffic because the barges used for transport of baled GRG would be coming to Hawaii and returning to the mainland regardless of APHIS approval of GRG transport. The barges would carry GRG bales rather than returning to the mainland empty. However, the following protection measures will be implemented and included in compliance agreements: Vessel operators will be on the lookout for Hawaiian monk seals when transiting to and leaving harbor waters. In the event that a seal is in the harbor, the vessel must be prepared to

stand down until the seal leaves on its own volition. Should a vessel collision occur with a Hawaiian monk seal, immediately contact the Na tional Oceanic and Atmospheric Administration (NOAA) Fisheries hotline at 1-888-256-9840. This incident should be reported to APHIS.

APHIS will initiate formal consultation with NMFS.

With the implementation of these measures, APHIS has determined that the proposed action may affect, but is not likely to adversely affect the Hawaiian monk seal.

References:

National Marine Fisheries Services (NMFS). 2007. Recovery Plan for the Hawaiian Monk Seal31 ( Monachus schauinslandii ). Second Revision. National Marine Fisheries Service, Silver Spring, MD. 165 pp.

U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Services (NMFS). 1976. Hawaiian Monk Seal Final Regulations. Fe deral Register, Vol. 41, p.51611-51612, November 23, 1976.

United States Department of Commerce. 1999. Na tional Marine Fisheries Service. Endangered and Threatened Species; regulations Conso lidation. Federal Register, Vol. 64, p. 14052-14077, March 23, 1999.

Steller Sea Lion, Eumetopias jubatus

Status: The steller sea lion was emergency listed as endangered west of 1440 west longitude (USDOI, FWS, 1990a). It was emergency listed as threatened in locations other than west of 1440 west longitude on April 5, 1990 (USDOI, FWS, 1990b). Critical habitat has been designated for this species.

Pertinent Species Information: ( From National Marine Mammal Laboratory http://nmml.afsc.noaa.gov/AlaskaEcosystems/sslhome/StellerDescription.html last accessed June 7, 2006).

The steller sea lion is the largest member of the Otariid (eared seal) family. Males may be up to 325 cm (10-11 ft) in length and can weigh up to 1,100 kg (2,400 lb). Females are smaller than males, 240-290 cm (7.5-9.5 ft) in length and up to 350 kg (770 lb) in mass. Males and females are light buff to reddish brown and slightly darker on the chest and abdomen; naked parts of the skin are black. Wet animals usually appear darker than dry ones. Pups are about 1 m (3.3 ft) in length and 16-23 kg (35-50 lb) at birth and grow to about 30-40 kg (65-90 lb) after 6-10 weeks. Pups are dark brown to black until 4 to 6 months old when they molt to a lighter brown. By the end of their second year, pups have taken on the same pelage color as adults.

Bulls become mature between 3 and 8 years of age, but typically are not massive enough to hold territory successfully until 9 or 10 years old. Females reproduce for the first time at 4 to 6 years of age, bearing at most a single pup each year. Pups are born from late May through early July, with peak numbers of births during the second or third week of June. Females stay with their pups for about 9 days before beginning a regular routine of foraging trips to sea. Females mate 11 to 14 days after giving birth. Implantation takes place in late September or early October, after a 3-4 month delay. Weaning is not sharply defined as it is for most other pinniped species, but probably takes place gradually during the wint er and spring prior to the following breeding season. It is not uncommon to observe 1- or 2-year-old sea lions suckling from an adult female.

Steller sea lions are distributed across the No rth Pacific Ocean rim from northern Hokkaido, Japan, through the Kuril Islands, Okhotsk Sea, and Commander Islands in Russia, the Aleutian Islands, central Bering Sea, and southern coast of Alaska, and south to the Channel Islands off California. During the May-to-July breeding season, steller sea lions congregate at more that 40rookeries, where adult males defend territories, pups are born, and mating takes place. Nonreproductive animals congregate to rest at more than 200 haul-out sites where little or no breeding takes place. Sea lions continue to gather at both rookeries and haul-out sites outside of the breeding season.32 The world population of Steller sea lions includes two stocks divided at 144° W longitude (Cape Suckling, just east of Prince William Sound, Alaska). The stock differentiation is based primarily on differences in mitochondrial DNA, but also on differing population trends in the two regions.

Steller sea lions are opportunistic predators, feed ing primarily on a wide variety of fishes and cephalopods. Prey varies geographically and seasonally. Some of the more important prey species in Alaska include walleye pollock ( Theragra chalcogramma ), Atka mackerel ( Pleurogrammus monopterygius ), Pacific herring ( Clupea harengus ), Capelin ( Mallotus

villosus ), Pacific sand lance ( Ammodytes hexapterus ), Pacific cod ( Gadus macrocephalus ), and salmon ( Oncorhynchus spp.). Steller sea lions have been known to prey on harbor seal, fur seal, ringed seal, and possibly sea otter pups, but this would represent only a supplemental component

to the diet.

In Oregon, numbers have remained relatively stable since 1981 at about 2,000-3,000 animals. In California, numbers have declined, especially in the southern portion of range. Breeding colonies occur in Oregon and British Columbia but not in Washington (nonbreeding occurrences only). Breeding rookeries extend from the central Kuril Islands and the Okhotsk Sea in the west to Ano Nuevo Island and San Miguel Island, California, in the east, though the latter rookery is nearly or actually defunct; none have been seen on the Channel Islands since 1984. (From NatureServe, 2006).

Factors suggested as potential causes for the declines of steller sea-lions in Alaska and Russia include reduced food availability, possibly resulting from competition with commercial fisheries, incidental take and intentional kills during commercial fish harvests, subsistence take, entanglement in marine debris, disease, pollution, and harassment. Steller sea-lions are also sensitive to intrusion at rookeries and haul-out sites. (From NatureServe, 2006).

Assessment: The proposed action would have no effect on steller sea-lion prey. Ship strikes are not reported as a threat to the steller sea-lion and the slow movement of the barges (6-9 knots) would make a strike unlikely.

Marine debris and pollution will be prevented by the measures included in the compliance agreements with waste management companies, including the frequent inspection of bales for breaks, training of waste management personnel in proper handling procedures, and labeling and

identification of all bales.

To avoid distubance of rookeries and collisions with steller sea-lions, APHIS will implement the following protection measures:

Vessel operators will maintain a sharp lookout for Steller sea lions and other collision hazards. Operators are advised to post at least one pers on dedicated to lookout for sea lions on route to

the Columbia River.

Tugs and barges will not travel above a speed of 12 knots.33 C C ontact APHIS and NOAA's No rthwest Regional Office if involved in a collision: (206) 526-6 733 . APHIS will re-initiate consultation with NMFS.

No barge will approach within three nautical m iles of the Steller sea lion ro o keries in Oregon (Rogue Reef: Pyramid Rock and Orford Reef: L ong Brown Rock and Seal Rock) and California (Ano Nuevo Island, Southeast Farallon Island, Sugarloaf Island, and Cape Mendocino).

With the implementation of these protection measures, APHIS has determined that the proposed barging of garbage from Hawaii to the mainland United States may affect, but is not likely to adversely affect the steller sea lion or its designated critical habitat.

References:

NatureServe. 2006. NatureServe Explorer: An on line encyclopedia of life [web application]. Version 4.7. NatureServe, Arlington, Virginia. Av ailable http://www.natureserve.org/explorer. (Accessed: June 12, 2006 ).

United States Department of the Interior, 1990a. Fish and Wildlife Service. Endangered and threatened wildlife and plants; emergency listing of the steller sea lion. Federal Register, Vol. 55, p.13488, April 10, 1990.

United States Department of the Interior, 1990b. Fish and Wildlife Service. Endangered and threatened wildlife and plants; Listing of st eller sea lions as threatened under Endangered Species act with Protective Regulations. Vol. 55, p. 12645-12662, April 5, 1990.

Whales

Humpback Whale

, Megaptera novaeangliae

Status: The humpback whale was first listed as endangered on June 2, 1970 (USDOI, FWS, 1970).

Pertinent Species Information: The humpback whale is a mostly black or gray baleen whale with very long (up to one-third of body length) fli ppers that often are white or partly white. In front of the paired nostrils, the head is flat and covered with knobs. The rear edge of flippers and flukes is scalloped. The dorsal fin is variable, but often has a hump or step along the front edge. The throat has about 14-35 longitudinal grooves. The baleen generally is all black, up to 70 cm long. The females reach 16 meters and males reach 15 meters. Its blow is bushy and V-shaped. It often raises its flukes high when starting a dive. (From NatureServe, 2006).

It occurs in pelagic and coastal waters, sometimes frequenting inshore areas such as bays. It winters largely in tropical/subtropical waters near islands or coasts, and summers in temperate and subpolar waters. (From Nature Serve, 2006)

It is primarily dependent upon schooling fishes and krill (essentially krill only in the Southern Hemisphere). It feeds singly or in groups. It feeds mainly in high latitudes, though stranded individuals in Virginia and Georgia had eaten sciaen id fishes. It may feed at the surface or while submerged. It employs various foraging methods, including cooperative feeding on prey34 enclosed in "nets" of exhaled air bubbles. (From NatureServe, 2006).

The humpback whale was depleted by past overharvesting. Currently, it is vulnerable to marine pollution, disturbance by boat traffic, and entanglement in fishing gear. (From NatureServe, 2006)

According to scientists, the shallow, warm waters surrounding the main Hawaiian Islands constitute one of the world's most important habitats for the endangered humpback whale. Nearly two-thirds of the entire North Pacific population of humpback whales migrates to Hawaii each winter. Here, they engage in breeding, calving and nursing activities critical to the survival of their species. Most North Pacific humpback whales begin their annual migrations from the Gulf of Alaska in early fall. They move to three primary locations in the southern latitudes of the North Pacific. One group will travel to the co ast of Baja in Mexico. Another will migrate to a group of islands south east of Japan. But the largest population (over 60%) will find themselves in the Hawaiian Islands, a distance of nearly 3500 miles from their feeding grounds in Alaska. This migration takes the humpback approximately 4 to 8 weeks to complete. The majority of the humpbacks that travel to Hawaii end up in the waters off of Maui. It is a "trickle migration with the juveniles usually arriving first, followed by the adult males, adult females, then the pregnant females. (From http://www.whalewatchmaui.com/migration.html Last

accessed June 5, 2006.)

The Hawaiian Islands Humpback Whale National Marine Sanctuary is comprised of five separate areas abutting six of the major islands of the State of Hawai`i. The five areas of the sanctuary cover relatively shallow offshore areas built up from the sea floor by the development of the Hawaiian Islands chain. (Sources. Hawaii topography: USGS DEM, Ocean bathymetry: ETOPO5, Humpback Whale NMS boundary: NOAA). From http://hawaiihumpbackwhale.noaa.gov/maps/maps.html Last accessed June 5, 2006.

Assessment: Adverse impacts to the humpback whale could come from accidental whale/vessel collisions, displacement due to traffic or noise fr om vessel traffic, or from ingestion of or entanglement in marine debris. Direct collision or displacement conflicts are at a minimum due to the consistent and relatively slow speeds of barge traffic. (From http://www.earthtrust.org/wlcurric/whales.html Last accessed June 5, 2006.)

Noise or visual disturbance will not likely occur since marine mammals have demonstrated little behavioral reaction to slow-moving vessels, according to surveys conducted (NMFS, 2006). The baled garbage will be inspected at multiple points in the transport process to ensure that bales are intact and garbage will not be released.

The potential for collisions between the tug/barge and the humpback whale is very low due to the slow tow speed (6-9 knots). However, because the Hawaiian Islands are such an important habitat for the humpback whale, the following protection measures will be implemented:

Within 200 nautical miles of the Hawaiian Islands, barges will not approach or cause an object to approach within 100 yards of any whale species.

Vessel operators will maintain a sharp lookout for whales and other collision hazards. Vessel operators will also l ook ahead for “blows” (puffs or mists), dorsal fins, tails, etc.35 Operators are advised to post at least one person dedicated to lookout for whales from November through May, the peak period for humpback whales in Hawaiian waters.

Tugs and barges will not travel above a speed of 12 knots.

The barges will use appropriate VHF radio protocol or other means to alert other vessels of whales that may be in their path.

Vessel operators will move out of the way of approaching whales.

If possible, vessel operators will attend educational workshops held in Hawaii and sponsored by the State of Hawaii or NOAA Fisheries on whale etiquette.

Vessel operators will call the NOAA Hotline if involved in a collision: (888) 256-9840 or hail the U.S. Coast Guard on VHF channel 16. This incident would also be reported to APHIS and NOAA’s Pacific Islands Regional Office. APHIS will re-initiate consultation with NMFS.

With the implementation of these measures, APHIS has determined that the proposed action may affect, but is not likely to adversely affect the humpback whale.

References:

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes of marine mammals incidental to specified activities; movement of barges through the Beaufort Sea between West Dock and Cape Simpson or Po int Lonely, Alaska. Federal Register, Vol. 71, p34064, June 13, 2006.

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2,

1970.

Blue Whale, Balaenoptera musculus

Status: The blue whale was listed as endangered on June 7, 1970 (USDOI, FWS, 1970).

Pertinent Species Information: The blue whale is a very large (the largest living animal) baleen whale; its body is mottled bluish gray. Its h ead is flat in front of the paired nostrils, broad and nearly U-shaped in dorsal view, with a single median ridge that extends forward from the raised area in front of the nostrils (the ridge does not quite reach the tip of snout). The dorsal fin, located in the last quarter of the back, is very small. The throat has 55-68 longitudinal grooves. Its belly may appear yellowish due to diatom accumulations. Its flippers are long and slim and its baleen is black. The potential maximum length of the blue whale is over 30 meters, with the largest females averaging slightly longer than the largest males. (From NatureServe, 2006).

The blue whale mates May-September in the Northern Hemisphere. Gestation is reported as 1136 or 12 months. Adult females bear one calf every 2-3 years. Young are weaned in about 8 months. Females reach sexual maturity in about 10 years. The maximum lifespan is uncertain; it is reportedly only about 20 years or up to 80-90 years. It is usually solitary or in pairs or threes, but may congregate in good feeding areas. It eats primarily krill. Feeding occurs primarily in high latitude waters. (From NatureServe, 2006).

The blue whale occurs throughout the world's oceans. There are three major breeding groups: North Pacific, North Atlantic, and Antarctic; there is perhaps a separate breeding population in the Indian Ocean. It is seen with some regularity in deep coastal canyons off central and southern California, far inside the Gulf of St. Lawrence, and in the Denmark Strait. For all practical purposes the Northern Hemisphere and Southern Hemisphere stocks do not mix. (From Nature Serve, 2006)

Most migrate to high latitude feeding areas for summer and return to lower latitude breeding areas for winter. For example, those that summe r off Alaska winter off southern California and Baja California. There may be a basically re sident or short distance migratory population off California and Baja California. Of individuals tagged off southern California, where apparently they were feeding or foraging, one moved to waters off northern California and four moved southward to Baja California, two passing Cabo San Lucas and one of these moving an additional 3000 km to near the Costa Rican Dome (an upwelling feature), which may be a calving/breeding area. Data on vocalizations support the idea that blue whales off North America and in the eastern tropical Pacific re present a single stock. Hydrophone recordings suggest possible winter and late summer migra tions off Oahu (Hawaii). (From NatureServe, 2006).

The distribution of the blue whale in the western North Atlantic generally extends from the

Arctic to at least mid-latitude waters. Blue whal es are most frequently sighted in the waters off eastern Canada, with the majority of recent records from the Gulf of St. Lawrence. The blue whale is considered only an occasional visitor in the United States. Records have suggested an occurrence of this species south to Florida and the Gulf of Mexico, although the actual southern limit of the species’ range is unknown. (From http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/blue_whale.doc ).

The Eastern North Pacific Stock feeds in California waters in summer/fall (from June to November) and migrates south to productive areas o ff Mexico and as far south at the Costa Rica Dome in winter/spring. Blue whales are occasi onally seen or heard off Oregon, but sightings are rare. (From http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/blue_whale.doc ).

Blue whales are extremely rare in Hawaii. It is believed that the Hawaiian stock feeds off the

Aleutian Islands in summer and winters in offshore waters north of the Hawaiian Islands. There is little published evidence of blue whale sightings in Hawaii, and most evidence comes from acoustic recordings made off Oahu and Midway Islands. The recordings made off Oahu showed bimodal peaks throughout the year, suggesting that the animals were migrating into the area in summer and winter. (From http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/blue_whale.doc ).

Historically, the blue whale was over-harvested. Today the species may be negatively affected37 by food-chain alterations resulting from commercial fishing/whaling. There is concern among some biologists that underwater sound waves, such as those to be transmitted as part of the Acoustic Thermometry of Ocean Climate project, may detrimentally impact marine mammals; all agree that more information is needed on the impact of noise on marine mammals. (NatureServe, 2006).

Blue whales are at least occasionally injured or killed by ship collisions. Several blue whales have been photographed in California with large ga shes in their dorsal surface that appear to be from ship strikes. It is estimated that between 9-25% of the whales in the Gulf of St. Lawrence have injuries or scars attributed to contact with ships. The St. Lawrence Seaway has heavy ship traffic during the time of year when blue whales are relatively abundant there. (From http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/blue_whale.doc ).

Assessment: This species may be harassed by the noise generated by the tug boats, by physical disturbance from visual or other cues, and collisions with the tug/barge. The potential for collisions between the tug/barge and the blue whale is very low due to the slow tow speed (6-9 knots). Noise or visual disturbance will not likely occur since marine mammals have demonstrated little behavioral reaction to slow-moving vessels, according to surveys conducted (NMFS, 2006). The baled garbage will be inspected at multiple points in the transport process to ensure that bales are intact and garbage will not be released. Therefore, APHIS has determined that the proposed action may affect, but is not lik ely to adversely affect the blue whale.

However, APHIS will implement the following protection measures:

Vessel operators will maintain a sharp lookout for whales and other collision hazards. Vessel operators will also l ook ahead for “blows” (puffs or mists), dorsal fins, tails, etc.

Operators are advised to post at least one pers on dedicated to lookout for whales while on route

to the mouth of the Columbia River.

Tugs and barges will not travel above a speed of 12 knots.

Vessel operators will contact APHIS and NOAA’s Northwest Regional Office if involved in a collision: (206) 526-6 733 . APHIS will re-initiate consultation with NMFS.

References:

NatureServe. 2006. NatureServe Explorer: An online encyclopedia of life [web application]. Version 4.7. NatureServe, Arlington, Virginia. Av ailable http://www.natureserve.org/explorer. (Accessed: June 7, 2006 ).

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes of marine mammals incidental to specified activities; movement of barges through the Beaufort Sea between West Dock and Cape Simpson or Po int Lonely, Alaska. Federal Register, Vol. 71, p34064, June 13, 2006.

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United38 States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2,

1970.

Fin Whale, Balaenoptera physalus

Status: The fin whale was listed as endangered on June 2, 1970 (USDOI, FWS, 1970).

Pertinent Species Information: The fin whale is a large dark gray to brownish black baleen whale. It has a narrow V-shaped rostrum with a prominent median ridge. The dorsal fin is angled strongly rearward, and is located about one-third the body length forward from the fluke notch. The throat has numerous longitudinal gr ooves. Many individuals have a whitish chevron on each side of the back above the flippers. The right lower lip and right front baleen are whitish. The left lower lip is dark and the remainder of baleen is streaked with yellowish white and bluish gray. The flippers are fairly long and narrow. The baleen is up to 72 cm long. It grows to about 26.8 meters, with females reaching larger sizes than males. It mates in winter. Gestation lasts 11-12 months. Adult females bear 1 young every 2-3 years. Young are weaned at 6-8 months. It is sexually mature at a minimum age of about 5-6 years in the western Atlantic. The life span may be 40-100 years. (From NatureServe, 2006)

In the North Pacific, the fin whale eats fishes, krill, calanoid copepods, and squid. In the North Atlantic, its primary foods are fishes (e.g., capelin, herring, sand launce), krill, and calanoid copepods. In the Southern ocean, its main diet is krill. In the Gulf of California, it eats euphausiids in winter and spring. Newly wean ed young eat crustaceans. Fine fringing on the baleen of young facilitates capture of copepods. (From NatureServe, 2006)

The fin whale is widespread in the Atlantic, Paci fic, Indian, and Southern oceans. Populations were greatly reduced by historical commercial whaling; approximately 102,000-122,000 remain from pre-exploitation levels of over 450,000. It is threatened by general deterioration of the marine ecosystem. Most populations apparently have increased little if at all since commercial harvest was ended in the 1970s. The population off the coast of the eastern United States may be increasing. However, a ten-year survey (published in 1989) of prime Antarctic waters yielded far fewer numbers than expected, raising concern. (From NatureServe, 2006)

The fin whale occurs worldwide in temperate and polar waters in several distinct breeding stocks. In the western North Atlantic, it summers north to arctic Canada and Greenland, and winters south to Gulf of Mexico and Caribbean region. In the eastern North Pacific, it summers north to the Chukchi Sea, and winters north to California (From NatureServe, 2006)

Populations of fin whales in all oceans were gr eatly reduced by historical commercial whaling. They are also threatened by heavy metal pollution from dumped waste in the Mediterranean. Human exploitation of euphausiids in the southern ocean is a potential threat. (From NatureServe, 2006)

Assessment: This species may be harassed by the noise generated by the tug boats, by physical disturbance from visual or other cues, and collisions with the tug/barge. The potential for collisions between the tug/barge and the fin whale is very low due to the slow tow speed (6-939 knots). Noise or visual disturbance will not likely occur since marine mammals have demonstrated little behavioral reaction to slow-moving vessels, according to surveys conducted (NMFS, 2006). The baled garbage will be inspected at multiple points in the transport process to ensure that bales are intact and garbage will not be released. Therefore, APHIS has determined that the proposed action may affect, but is not likely to adversely affect the fin whale.

However, APHIS will implement the following protection measures:

Vessel operators will maintain a sharp lookout for whales and other collision hazards. Vessel operators will also l ook ahead for “blows” (puffs or mists), dorsal fins, tails, etc.

Operators are advised to post at least one pers on dedicated to lookout for whales while on route

to the mouth of the Columbia River.

Tugs and barges will not travel above a speed of 12 knots.

Vessel operators will contact APHIS and NOAA’s Northwest Regional Office if involved in a collision: (206) 526-6 733 . APHIS will re-initiate consultation with NMFS.

References:

NatureServe. 2006. NatureServe Explorer: An online encyclopedia of life [web application]. Version 4.7. NatureServe, Arlington, Virginia. Av ailable http://www.natureserve.org/explorer. (Accessed: June 7, 2006 ).

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes of marine mammals incidental to specified activities; movement of barges through the Beaufort Sea between West Dock and Cape Simpson or Po int Lonely, Alaska. Federal Register, Vol. 71, p34064, June 13, 2006.

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2,

1970.

Sei Whale, Balaenoptera borealis

Status: The sei whale was first listed as endangered on June 2, 1970 (USDOI, FWS, 1970).

Pertinent Species Information: The sei whale is a large dark gray baleen whale often with ovoid grayish-white scars. The front edge of its prominent dorsal fin is angled upward more than 40 degrees from the back. The tip of the snout is turned slightly downward. There are many longitudinal grooves on throat. The flippers are pointed and relatively small. The tail fluke is relatively small. The baleen is uniformly ash-black with fine white fringes. The sei whale grows to 18.6 meters in the northern hemisphere and 21 meters in the southern hemisphere, with40 females reaching the largest sizes (largest males average a couple meters shorter than the largest females). (From NatureServe, 2006)

A single calf is born usually in winter after a gestation period of about 11-12 months. The young nurse for about 5-9 months. The calving interval fo r individual adult females is 2-3 years. They are sexually mature at an average age of 6-10 years. They usually travel in groups of 2-5, but may concentrate in larger numbers on feeding grounds. The sei whale eats copepods, euphausiids, squid, and various small schooling fishes. It may skim feed on copepods at the surface or gulp feed on krill and small fishes (From NatureServe, 2006)

The sei whale occurs worldwide, but its distribution and movements during much of year are poorly known. It is found from the Coast of Mexico to the Gulf of Alaska in the eastern North Pacific. It is found in the Bering Sea to Japan and Korea in the western North Pacific. It is found in the Gulf of Mexico to Davis Strait (especially off eastern Canada) in the western North Atlantic. It occurs from Norway to Spain and northwestern Africa in the eastern North Atlantic. In the Southern Hemisphere, it occurs from the Antarctic Ocean to the coasts of Brazil, Chile, South Africa, and Australia. (From NatureServe, 2006)

The total population of sei whales is estimated at less than 51,000: about 14,000 in the Northern Hemisphere (mainly in the North Pacific), 37,000 or less in the Southern Hemisphere. A survey of Antarctic waters in the summer of 1989 found only 1,500 in an area where perhaps 10,000 were expected. The North Atlantic population numbers a few thousand. Populations in all oceans have been depleted by overexploitation. (From NatureServe, 2006)

Twelve aerial surveys were made within 25 nautical miles of the main Hawaiian Islands in 1993- 98 (Mobley et al., 1998) but no sightings of sei whales were made. A 2002 shipboard linetransect survey of the entire Hawaiian Islands Exclusive Economic Zone resulted in a summer/fall abundance estimate of 77 sei whales (Barlow, 2003). No data are available on the current population trend. Although whales can get tangled in longline fishing gear, between 1994 and 2002, no interactions with sei whales were observed in the Hawaii-based longline fishery. (From National Marine Fisheries Serv ice Stock Assessment Report for Hawaiian Stock

of Sei Whale http://www.nmfs.noaa.gov/pr/pdfs/sars/po04seiwhalehawaii.pdf last accessed June 8, 2006).

Only 2 confirmed sightings of sei whales and 5 possible sightings were made in California, Oregon, and Washington waters during extensive ship and aerial surveys in 1991-93, 1996, and 2001 (Hill and Barlow, 1992; Carretta and Forney, 1993; Mangels and Gerrodette, 1994; Von Saunder and Barlow, 1999; Barlow, 2003). Green et al. (1992) did not report any sightings of sei whales in aerial surveys of Oregon and Washington. The abundance estimate for California, Oregon, and Washington waters out to 300 nautical miles is 56 sei whales (Barlow, 2003). (From National Marine Fisheries Service Stoc k Assessment Report for Eastern North Pacific

Stock of Sei Whale http://www.nmfs.noaa.gov/pr/pdfs/sars/po2003seiwhale_en.pdf last

accessed June 8, 2006).

Assessment: Sei whales are very rare within the proposed action area. However, this species may be harassed by the noise generated by the tug boats, by physical disturbance from visual or41 other cues, and collisions with the tug/barge. The potential for collisions between the tug/barge and the sei whale is very low due to the slow tow speed (6-9 knots). Noise or visual disturbancewill not likely occur since marine mammals have demonstrated little behavioral reaction to slowmoving vessels, according to surveys conducted (NMFS, 2006). The baled garbage will be inspected at multiple points in the transport process to ensure that bales are intact and garbage will not be released. Therefore, APHIS has dete rmined that the proposed action may affect, but is not likely to adversely affect the sei whale.

However, APHIS will implement the following protection measures:

Vessel operators will maintain a sharp lookout for whales and other collision hazards. Vessel operators will also l ook ahead for “blows” (puffs or mists), dorsal fins, tails, etc.

Operators are advised to post at least one pers on dedicated to lookout for whales while on route

to the mouth of the Columbia River.

Tugs and barges will not travel above a speed of 12 knots.

Vessel operators will contact APHIS and NOAA’s Northwest Regional Office if involved in a collision: (206) 526-6 733 . APHIS will re-initiate consultation with NMFS.

References:

Barlow, J. 2003. Cetacean abundance in Hawaiian waters during summer/fall 2002. Admin. Rep. LJ-03-13. Southwest Fisheries Science Ce nter, National Marine Fisheries Service, 8604 La Jolla Shores Drive, La Jolla, CA 92038.

Caretta, J.V. and K.A. Forney. 1993. Report on two aerial surveys for marine mammals in California coastal waters utilizing a NOAA DeHavilland Twin Otter Aircraft: March 9-April 7, 1991 and February 8-April 6, 1992. U.S. Depart ment of Commerce. NOAA Technical Memo. NMFS-SWFSC-185. 77 pp.

Green, G.A., J.J. Brueggeman, R.A. Grotefendt, C.E. Bowlby, M.L. Bonnell, K.C. Balcomb, III.

1992. Cetacean distribution and abundance o ff Oregon and Washington, 1989-1990. Chapter 1

In: J.J. Brueggeman (ed.). Oregon and Washington rine Mammal and Seabird Surveys. Minerals Management Service Contract Report 14-12-0001-30426.

Hill, P.S. and J. Barlow. 1992. Report of a marine mammal survey of the California coast aboard the research vessel McARTHUR July 28-November 5, 1991. U.S. Department of Commerce. NOAA Technical Memo. NMFS-SWFSC-169. 103 pp.

Mangels, K.F. and T. Gerrodette. Report of cetacean sightings during a marine mammal survey in the eastern Pacific Ocean and the Gulf of California aboard NOAA ships McArthur and

David Starr Jordan July 28-November 6, 1993. U.S. Department of Commerce. NOAA Technical Memo. NMFS-SWFSC-221. 88 pp.42 Mobley Jr., J.R., S.S. Spitz, K.A. Forney, R.A. Grotefendt, and P.H. Forestall. 2000. Distribution and abundance of odontocete species in Hawaiian waters: preliminary results of 1993-98 aerial surveys. Admin. Rep. LJ-00-14C. Southwest Fisheries Science Center, National Marine Fisheries Service, P.O. Box 271, La Jolla, CA 92038. 26 pp.

NatureServe. 2006. NatureServe Explorer: An on line encyclopedia of life [web application]. Version 4.7. NatureServe, Arlington, Virginia. Av ailable http://www.natureserve.org/explorer. (Accessed: June 8, 2006 ).

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes of marine mammals incidental to specified activities; movement of barges through the Beaufort Sea between West Dock and Cape Simpson or Po int Lonely, Alaska. Federal Register, Vol. 71, p34064, June 13, 2006.

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2,

1970.

Von Saunder A., and J. Barlow. 1999. A report of the Oregon, California and Washington Linetransect Experiment (ORCAWALE) conducted in west coast waters during summer/fall 1996. U.S. Department of Commerce. NOAA Technical Memo. NMFS-SWFSC-264. 40 pp.

Sperm Whale, Physeter catodon ( =macrocephalus )

Status: The sperm whale was first listed as endangered on June 2, 1970 (USDOI, FWS, 1970).

Pertinent Species Information: The sperm whale is found throughout the world's oceans; adult females and young generally stay between 40 degrees N and 40 degrees S latitude. Nonbreeding males range into high latitude waters. Northern and southern hemisphere populations apparently are reproductively isolated from each other. It is pelagic, and prefers deep water, but is sometimes found around islands or in shallow shelf waters (e.g., 40-70 meters). (From NatureServe, 2006)

Sperm whale gestation lasts 14-15 months. Births occur May-September in the Northern Hemisphere and November-March in the Southern Hemisphere. A single young is produced every 3-6 years. Young are weaned in about 1.5-3.5 years, though young may continue to nurse for several years. Females sexually mature at 7-11 years; pregnancy rate gradually declines after age 14. Males may not breed until about 25 years old. Sperm whales may live up to at least 60- 70 years. (From NatureServe, 2006)

The sperm whale eats primarily large squids, and sometimes also octopus and various fishes. It dives deeply when foraging; some dives over 1800 meters have been recorded, but most are less than 500 meters. It apparently feeds throughout the year. (From NatureServe, 2006)

The basic social unit of the sperm whale is a mixed school of adult females plus their calves and juveniles (usually about 20-40 individuals). As males grow older they leave this group and form bachelor schools (of variable sizes up to about 50 individuals). The largest males tend to be solitary. (From NatureServe, 2006)43 The Hawaiian Islands marked the center of a major nineteenth century whaling ground for sperm whales. Since 1936, at least five strandings ha ve been reported from Oahu, Kauai and Kure Atoll. Sperm whales have also been sighted around several of the Northwestern Hawaiian Islands, off the main island of Hawaii, in the Kauai Channel and in the Alenuihaha Channel between Maui and the island of Hawaii. In addition, the sounds of sperm whales have been recorded throughout the year off Oahu. (From National Marine Fisheries Service Stock Assessment Report for Hawaiian Stock of Sperm Whale http://72.14.203.104/search?q=cache:r7VnMELgVVEJ:www.nmfs.noaa.gov/pr/PR2/Stock_Asse ssment_Program/Cetaceans/Sperm_Whale_(Hawa ii)/POD00spermwhale_hawaii.pdf+sperm+wh ale+hawaii&hl=en&gl=us&ct=clnk&cd=1 last accessed June 9, 2006).

The best estimate for sperm whales occurring in U.S. waters of Hawaii is 66. This abundance underestimates the total number of sperm whales off Hawaii because areas around the Northwest Hawaiian Islands and beyond 25 nautical miles from the main islands were not surveyed when compiling this estimate. (From NOAA Fisheries, Office of Protected Resources, http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/spermwhales.htm last accessed June 12, 2006.)

The most recent abundance estimate of the California-Oregon-Washington Stock for the period between 1996 and 2001 is 1,233 sperm whales. Sperm whale abundance appears to have been

rather variable off California between 1979/1980 and 1996, but does not show any obvious trends. (From NOAA Fisheries, Office of Protected Resources, http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/spermwhales.htm last accessed June 12, 2006.)

Historically, the sperm whale was hunted for spermaceti, ambergris, and oil. It is no longer threatened by direct catching, but entanglement in fishing gear may cause mortality in some areas. It is potentially threatened by ocean pollution and ingestion of plastics. (From NatureServe, 2006)

Assessment: This species may be harassed by the noise generated by the tug boats, by physical disturbance from visual or other cues, and collisions with the tug/barge. The potential for collisions between the tug/barge and the sperm whale is very low due to the slow tow speed (6-9 knots). Noise or visual disturbance will not likely occur since marine mammals have demonstrated little behavioral reaction to slow-moving vessels, according to surveys conducted (NMFS, 2006). The baled garbage will be inspected at multiple points in the transport process to ensure that bales are intact and garbage will not be released. Therefore, APHIS has determined that the proposed action may affect, but is not lik ely to adversely affect the sperm whale.

However, APHIS will implement the following protection measures:

Vessel operators will maintain a sharp lookout for whales and other collision hazards. Vessel operators will also l ook ahead for “blows” (puffs or mists), dorsal fins, tails, etc.

Operators are advised to post at least one pers on dedicated to lookout for whales while on route44 to the mouth of the Columbia River.

Tugs and barges will not travel above a speed of 12 knots.

Vessel operators will contact APHIS and NOAA’s Northwest Regional Office if involved in a collision: (206) 526-6 733 . APHIS will re-initiate consultation with NMFS.

References:

NatureServe. 2006. NatureServe Explorer: An on line encyclopedia of life [web application]. Version 4.7. NatureServe, Arlington, Virginia. Av ailable http://www.natureserve.org/explorer. (Accessed: June 9, 2006 ).

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes of marine mammals incidental to specified activities; movement of barges through the Beaufort Sea between West Dock and Cape Simpson or Po int Lonely, Alaska. Federal Register, Vol. 71, p34064, June 13, 2006.

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport Fisheries and Wildlife, Conservation of endangere d species and other fish or wildlife, United States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2,

1970.

Killer Whale, Southern Resident Distinct Population Segment, Orcinus orca

Status: The southern resident killer whale was listed as endangered on November 18, 2005 (DOC, NOAA, 2005). Critical habitat was designated on November 29, 2006 (DOC, NOAA, 2006).

Pertinent Species Information: Killer whales are members of the family Delphinidae, which includes approximately 20 genera of marine dol phins. They are the world’s largest dolphin. Killer whales are black dorsally and white ventrally, with a conspicuous white oval patch located slightly above and behind the eye. A highly variable gray or white saddle is usually present behind the dorsal fin. Sexual dimorphism occurs in body size, flipper size, and height of the dorsal fin (DOC, NOAA, 2005).

Killer whales occur in all oceans, but it is most common in coastal waters and at higher latitudes, with fewer sightings from tropical regions (NM FS, 2005). In the North Pacific, killer whales occur in waters off Alaska, including the Aleutia n Islands and Bering Sea, and range southward along the North American coast and continental slope (NMFS, 2005). Killer whales occur broadly in the world’s other oceans, with the exception of the Arctic Ocean (NMFS, 2005).

They are highly social animals that occur primarily in pods of up to 50 animals. Vocal communication is an essential element of the species’ complex social structure. They produce numerous types of vocalizations that are usef ul in navigation, communication and foraging. There are three categories of sounds: echolocation clicks, tonal whistles and pulsed calls. Killer whales hear sounds through the lower jaw and other portions of the head, which transmit the sound signals to receptors in the middle and inner ears.45 Killer whales swim at speeds of 5-10 kilometers per hour, but can attain speeds of 40 kilometers per hour. While in the inshore waters of southern British Columbia and Washington, the southern residents spend 95% of their time underwater, nearly all of which is between the surface and a depth of 30 meters. As top-level predators, they feed on a variety of organisms ranging from fish to squid to other marine mammal species. Cooperative hunting, food sharing, and innovative learning are notable foraging traits in killer whales. (From NMFS, 2005)

Three distinct forms of killer whales, termed as residents, transients, and offshores, are recognized in the northeastern Pacific Ocean. There is considerable overlap in their ranges, but the populations display significant genetic differences due to a lack of interchange of member animals. The southern resident population consists of three pods that reside for part of the year in the inland waterways of Washington State and British Columbia (Strait of Georgia, Strait of San Juan de Fuca, and Puget Sound), mainly during the late spring, summer and fall. Pods have visited coastal sites of Washington and Vancouver Island and are known to travel as far south as central California and as far north as the Queen Charlotte Islands. Winter and early spring movements and distribution are largely unknown for the population. Although there is considerable overlap between the ranges of northern and southern residents, pods from the two populations have not been observed to intermix. (From NMFS, 2005)

Threats to the killer whale include reduced prey availability, environmental contaminants, vessel effects and sound, oil spills, disease, and chronic effects from multiple stressors (NMFS, 2005)

Assessment: This species may be harassed by the noise generated by the tug boats, by physical disturbance from visual or other cues, and collisions with the tug/barge. The potential for collisions between the tug/barge and the southern resident killer whale is very low due to the slow tow speed (6-9 knots). Vessel strikes are rare, but do occur and can result in injury, such as in the collision of a southern resident whale with a vessel in the San Juan Islands in July 2005 (NMFS, 2005).

The National Oceanic and Atmospheric administration (NOAA) has little information about the effects of vessel activity on killer whales (DOC, NOAA, 2006). Whale watching vessels are of particular concern. Vessel traffic may have contri buted to the decline of the Southern Resident killer whale population through collisions (rare), chemicals such as unburned fuel and exhaust, masking echolocation signals, and disruption of feeding activity resulting in increased energy expenditure and reduced energy acquisition (Bain et al., 2006). However, NOAA is uncertain

about the extent to which these effects interfere with the survival and recovery of the Southern Residents but studies have linked vessels with short-term behavioral changes in these animals (DOC, NOAA, 2006). Although there can be occurrence of these whales as far south as central California, the area where the barges will travel is south of the spring, summer, and fall range of the Southern Resident. Thus, there is a low likelihood that barges will interact with Southern Resident killer whales. Therefore, APHIS has determined that the proposed action is not likely to adversely affect the southern resident killer whale. In addition, the proposed action will not adversely modify proposed critical habitat since the mouth of the Columbia River is south of this area and barges will not enter the area where the habitat has been designated.

However, APHIS will implement the following protection measures:

Vessel operators will maintain a sharp lookout for whales and other collision hazards.46 Vessel operators will also look ahead for “blows” (puffs or mists), dorsal fins, tails, etc.

Operators are advised to post at least one pers on dedicated to lookout for killer whales on route

to the Columbia River.

Tugs and barges will not travel above a speed of 12 knots.

C ontact APHIS and NOAA’s Northwest Regional Office if involved in a collision: (206) 526-6 733 . APHIS will re-initiate consultation with NMFS.

References:

Bain, D.E., J.C. Smith, R. Williams, and D. Lusseau. 2006. Effects of vessels on behavior of southern resident killer whales ( Orcinus sp.). NMFS Contract Report No. AB133F03SE0959 and AB133F04CN0040. 61 pp.

Department of Commerce, National Oceanic and Atmospheric Administration. 2005. Endangered and threatened wildlife and plants; Endangered status for Southern Resident killer whales. Vol. 70, p. 69903-69912, November 18, 2005.

Department of Commerce, National Oceanic and Atmospheric Administration. 2006. Endangered and threatened species; Designation of critical habitat for the Southern Resident killer whale. Vol. 71, p. 69054-69070, November 29, 2006.

National Marine Fisheries Service. 2005. Propos ed Conservation Plan for Southern Resident Killer Whales ( Orcinus orca ). National Marine Fisheries Service, Northwest Region, Seattle Washington. 183 pp.



### Sea turtles

The following five sea turtles are all marine organisms, except when nesting on beaches. The potential impacts due to program activities are the same for all five species. For this reason, the assessment for the green sea turtle, the hawksbill sea turtle, the Olive Ridley sea turtle, the leatherback sea turtle, and the loggerhead sea turtle has been combined and follows the species

accounts of the five sea turtles.

Green Sea Turtle, Chelonia mydas

Status: The green sea turtle was listed as endangered on July 28, 1978, (USDOI, FWS, 1978).

Pertinent Species Information: The green sea turtle has a brown carapace, often with radiating mottled or wavy dark markings or large dark brow n blotches. There are 4 costal plates on each side of carapace. There is one pair of prefrontal plates between the eyes. Its limbs are flattened flippers. The young are black to dark brown above, mainly white below, with a middorsal keel and two plastral keels. They are 4-6 cm at hatching. The adult carapace length usually is 90-122 centimeters (cm) (to 153 cm) and mass is 113-204 kilograms (kg) (to 295+ kg). (From NatureServe, 2006).

Green sea turtles spend most of their lives feeding on sea grasses and algae along the Continental47 Shelf. They migrate long distances and return to the same beaches at intervals of 2 to 4 years to nest. Nesting beaches need to be relatively undisturbed by humans and predators, and they must have stable temperatures and moisture for the incubation period.

Turtles in the northern Gulf of California overwinter in a dormant condition. In Hawaii, green sea turtles may bask on beaches mid-morning to mid-afternoon, especially after period of rainy weather (NatureServe, 2006).

The green sea turtle lays 1-8 clutches, averagi ng about 90-140 eggs, at about two-week intervals, usually every 2-4 years. It nests generally at night. It nests March-October in Caribbean-Gulf ofMexico region, with peak May-June. In Florida, it nests in May-September. It nests AprilOctober, with a peak between mid-June and early August, in Hawaii. Eggs hatch usually in 1.5- 3 months. Hatchlings emerge between early July and late December (peak mid-August to early October) in Hawaii. Females mature probably at an average age of 27 years in Florida, but growth rates and hence age of maturity may vary greatly throughout the range (slower growth in Australia, Hawaii, and Galapagos than in Florida and West Indies region). (From NatureServe, 2006)

The threats to the green sea turtle include development of beaches, hunting for their meat, poaching of the eggs, and drowning as a result of being caught in shrimp nets. The State of Florida is working to preserve the nesting areas, and the National Marine Fisheries Service has regulations (50 CFR Part 227) requiring the use of turtle excluder devices (TED's) on larger shrimp boats in both the Atlantic and the Gulf of Mexico (World Wildlife Fund, 1990).

Hawksbill Sea Turtle, Eretmochelys imbricata

Status: The hawksbill sea turtle was listed as endangered on June 2, 1970 (USDOI, FWS, 1970). Critical habitat has been designated in Puerto Rico (50 CFR 17.95(c) and 226.71).

Pertinent Species Information: The hawksbill is one of the smaller of the sea turtles. Mature turtles grow to a length of 2 feet and weigh 100 pounds. The name “hawksbill” is derived from the turtle’s prominent hooked beak.

The hawksbill sea turtle is primarily carnivorous feeding on jellyfish, sponges, and other sedentary organisms near coral reefs. The species does not migrate and occupies a small range. In tropical waters, the turtle breeds year-round, and the species tends to nest alone. The female will scoop out a nest in an isolated, undisturbed, sandy beach area and deposit about 160 eggs, which incubate in about 50 days.

Global protection needs include: A ban on international commercial trade of shells, protection of nesting beaches and adjacent land and waters from human disturbance, and a requirement of year-round use of turtle excluder devices (NatureServe, 2006).

Currently found throughout the world in tropical seas, the hawksbill sea turtle represents two distinct subspecies in the Atlantic and Indo-Pacific. No population estimates exist. The hawksbill is pelagic and spends most of its time in the open ocean (World Wildlife Fund, 1990). The hawksbill is virtually unknown along coastal waters of the U.S. Pacific continental coast (NMFS and USFWS, 1998).48 In Hawaii, there are numerous protected areas for the hawksbill turtle throughout the islands.

Kure Atoll at the northwest end of the chain is a wildlife refuge and potentially important to nesting and foraging sea turtles. The northwest atolls and islands between Pearl and Hermes to the northwest and Kaula to the southeast are part of the Hawaiian National Wildlife Refuge complex. The state of Hawaii administers a system of state parks and Marine Life Conservation Districts throughout the main islands, and one coastal natural preserve on Maui. The Hawaii

Volcanoes National Park includes coastal areas on the southeast coasts of Hawaii and Maui islands. Honaunau and Pu’u Kohola are also national parks with coastal areas along the coast of Hawaii Island. All of these areas afford protection for foraging and nesting sea turtles in Hawaii. (From NMFS and USFWS, 1998).

Olive Ridley Sea Turtle, Lepidochelys oliveacea

Status: The olive ridley sea turtle was listed as endangered in the breeding colony populations on Pacific coast of Mexico and threatened wherever found other than where listed as endangered on July 28, 1978, (USDOI, FWS, 1978).

Pertinent Species Information: (From NOAA Fisheries, National Marine Fisheries Service, Office of Protected Resources, Olive ridley turtle species account. < http://www.nmfs.noaa.gov/prot_res/species/turtles/olive.html > last accessed June 6, 2006.)

The olive ridley is a small, hard-shelled marine turtle, one of the two species of the genus Lepidochelys , and a member of the family Cheloniidae. The species may be identified by the uniquely high and variable numbers of vertebral and costal scutes. Although some individuals have only five pairs of costals (the number s hown by almost all individuals of the congener Lepidochelys kempii ), in nearly all cases some division of costal scutes occurs, so that as many as six to nine pairs may be present. They are primarily carnivorous, eating jellyfish, shellfish, and other marine animals. Algae may also be an important dietary component.

The most dramatic aspect of the life history of the olive ridley is the habit of forming great nesting aggregations, generally known as “arribadas.” Although not every adult olive ridley participates in these arribadas, the vast majority of them do. Formerly these nesting concentrations occurred at several beaches along the Pacific coast of Mexico, including Piedra del Tlacoyunque, Bahia Chacahua, and El Playon de Mismaloya, but in recent years the Mexican arribadas have been largely restricted to La Escobilla, although smaller nesting concentrations have been reported from Morro Ayuta. In Costa Rica, a major nesting aggregation is found at Ostional, on the Nicoya Peninsula, and smaller arribadas occur at Nancite, in the Santa Rosa National Park. Smaller arribadas also occur in Nicaragua at La Flor and Chacocente and at several localities in Panama. In the Indian Ocean, four arribada sites have been reported in the Indian State of Orissa, the most important bei ng Gahirmatha Beach. In the Atlantic, only small arribadas, numbering at most a few hundred animal s per night, have been reported from a single locality.

Individual olive ridleys may nest one, two or three times per season, typically producing 100-110 eggs on each occasion. The internesting interval is variable, but for most localities it is approximately 14 days for solitary nesters and 28 days for arribada nesters. The genus is also unique in that ridleys of both species commonly, and probably typically, nest each year, without intervening non-breeding seasons as shown by dermochelyids and other cheloniids. The ridleys49 nesting in an arribada could not be sustained by the productivity of immediately adjacent marine ecosystems, and the species is indeed migratory. Recent investigations show that olive ridleys

reside in oceanic habitats of the eastern P acific Ocean during the non-reproductive portion of its life cycle.

Despite its abundance, there are surprisingly few data relating to the feeding habits of the olive ridley. However, those reports that do exist suggest that the diet in the western Atlantic and eastern Pacific includes crabs, shrimp, rock lobsters, jellyfish, and tunicates. In some parts of the world, it has been reported that the principal food is algae.

The range of the olive ridley is essentially tropical. In the eastern Pacific nesting takes place from southern Sonora, Mexico, south at least to Colombia. Non-nesting individuals occasionally are found in waters of the southwestern United States. They occur abundantly in Pacific Colombia and Ecuador, but only in small numbers in Peru and Chile.

The olive ridley has been recorded occasionally from Galapagos waters, but it is essentially very rare throughout the islands of the Pacific, and indeed even in the western Pacific it is scarce everywhere, although widespread low-density nesting occurs. In the Indian Ocean it only achieves abundance in eastern India and Sri Lanka, although minor nesting occurs alongside the green turtles at Hawke's Bay, Pakistan, and some nesting also occurs in New Britain, Mozambique, Madagascar, peninsular Malaysia, and various other localities.

Washington State has only a single olive ridley record, a turtle that was found dead in Grays Harbor County. Oregon has two records. They are rarely found in waters north of southern California. (Richardson, 1997) In Hawaii, olive ridley turtles are rarely seen; nesting has only been recorded once, on Maui in 1985.

In the Atlantic Ocean, the olive ridley occurs widely, but probably not in great abundance, in waters of West Africa, from about Mauritania s outhward at least to the Congo. In the western Atlantic, nesting formerly occurred abundantly in eastern Surinam, as well as in western French Guiana and northwestern Guyana. Non-nesting indi viduals occur regularly as far west as Isla Margarita and Trinidad, but they rarely penetrate any further into the Caribbean than this. The species occurs in Brazil, and nests in the states of Bahia and Sergipe, but it seems to be rare. Because of the continued existence of several larg e arribadas, it is probable that the olive ridley is, in terms of absolute numbers of adult individuals in existence, the most abundant sea turtle species in the world. Nevertheless, there is evidence of downward trends at several arribada beaches. The various populations are under considerable stress, and the concentration of such a large proportion of the reproductive animals into a few arribadas may be a liability, not only in that such aggregation facilitates industrial-scale exploitation, as it has in Mexico as well as on the feeding grounds in Ecuador, but also because a rribadas do not seem to be an efficient method of guaranteeing maximum reproductive efficiency. Indeed, at the relatively undisturbed arribada beach of Nancite, within Santa Rosa National Park, Costa Rica, it has been estimated that only about 5% of eggs laid actually produce hatchlings.

The number of ridleys nesting during an arribada is difficult to count, although methodologies to estimate arribada size have been developed that are useful if nesting is well supervised by50 competent biologists. On the other hand, estimates by laymen of numbers of turtles in a given arribada are probably so inaccurate as to be useless. Because nesting in successive years is commonplace for olive ridleys, and may well be the norm for the species, the erratic nesting population trend lines often shown by loggerhead or green turtle populations, that very rarely nest in successive years, are not shown by olive ridley populations. It is thus much easier and more justified to draw conclusions about overa ll ridley population trends from a few years of comprehensive nest counts than it is for those species with multi-year nesting cycles.

Threats include: pesticides, heavy metals and PCB's, oil spills, consumption of marine debris such as plastic bags, plastic and styrofoam pieces, tar balls, balloons and raw plastic pellets, and in areas where recreational boating and ship traffic is intense, propeller and collision injuries are

not uncommon.

Leatherback Sea Turtle, Dermochelys coriacea

Status: The leatherback sea turtle was listed as endangered on June 2, 1970 (USDOI, FWS, 1970). Critical habitat has been designated in the Virgin Islands (50 CFR 17.95(c) and 226.71).

Pertinent Species Information: The leatherback sea turtle is the largest sea turtle in the world and is known to migrate great distances. It spends most of its adult life in the open ocean, entering shallow waters only at breeding time. It eats twice its body weight of jellyfish each day with supplements of soft-bodied creatures. The turtles grow as large as nine feet (2.7 meters) long, six feet (1.8 meters) wide and wei gh over 1,000 pounds (454 kilograms). Leatherback turtles are covered in a namesake rubbery shell and can dive 4,922 feet (1,500 meters) deep in search of soft-bodied prey like jellyfish.

Leatherback turtles roam tropical and sub-tropical waters of the Pacific, Atlantic, and Indian Oceans. They are found as far north as the British Isles to as far south as Australia.

The United States nesting beaches include barrier islands in south central Florida from Vero Beach to Boca Raton. The other nesting area is on St. Croix in the U.S. Virgin Islands. Nesting begins in March and continues until July. The females come ashore at night and lay about 35 eggs. The eggs incubate approximately 60 days before hatching.

Leatherbacks are commonly seen by fishermen in Hawaiian offshore waters, generally beyond the 100-fathom curve but within sight of land. Sightings often take place off the north coast of Oahu and the Kona coast of Hawaii. North of the Hawaiian Islands, a high seas aggregation of leatherbacks is known to occur at 35°-45°N, 175°-180°W.

The major threat is egg collecting. It is jeopardized to some extent by destruction/degradation of nesting habitat. In Malaysia, a major decline was attributed primarily to mortalities associated with high seas fisheries and to a long history of egg exploitation. Mortality associated with the swordfish gillnet fisheries in Peru and Chile represents the single largest source of mortality for East Pacific leatherbacks. Many eggs are lost to beach erosion in some areas; short-term erosion and accretion cycles along a nesting beach in the Virgin Islands resulted in an annual loss of 40- 60% of the nests, though nest relocations recently have reduced this loss. Nesting females are slaughtered in some areas (e.g., Guyana, Trinidad, Colombia, Pacific coast of Mexico). Ingestion of plastics could be an important mortality factor. Collisions with boats and entanglement in fishing gear (especially offshore driftnets) result in some mortality, as does the ingestion of plastic refuse in the ocean. Pollution of ocean waters may pose problems. Beach development51 and illumination may make beaches unsuitable for successful reproduction. Other threats include beach erosion, beach armoring, beach nourishment, artificial lighting, beach cleaning, increased human presence, recreational beach equipment, exotic dune and beach vegetation, nest loss to abiotic factors, predation, and poaching. (From NatureServe, 2006).

Loggerhead Sea Turtle, Caretta caretta

Status: The loggerhead sea turtle was listed as threatened on July 28, 1978 (USDOI, FWS, 1978).

Pertinent Species Information: The loggerhead sea turtle is a reddish-brown sea turtle with a relatively large head. It has 5 or more costals (pleurals) on each side of the carapace. Three (usually) or 4 large poreless scutes are found on the bridge between shells. Its limbs are flattened flippers. The tail of adult males (exte nds past tips of back-stretched hind flippers) is much longer than that of adult females (barely reaches rear edge of carapace). The young are brown or reddish-brown dorsally and have 3 dorsal keels and 2 plastral keels. The adult carapace length is usually 70-125 centimeters (cm) (to 122+ cm), mass 70-180 kilograms (kg) (to 227+ kg). The hatchling shell length is 4-5 cm, with a mass of about 20 grams. (From NatureServe, 2006)

It is carnivorous and has strong jaws to crush heavy-shelled mollusks and crustaceans. From May to August adult females lay an average of two clutches of eggs at 13-day intervals. Each clutch size is approximately 120 eggs. The eggs incubate for 2 months, with the hatchlings emerging, usually at night, and making their way to the ocean. The females require well-drained dunes, clean sand, and grassy vegetation for nesting.

In the central North Pacific, loggerheads travel westward and move seasonally north and south, primarily through the region 28-40 N latitude (J. Polovina, personal communication) (Oahu latitude is 21.433 N). Few loggerheads are found in Hawaii. Most nesting occurs in Japan. Juveniles are rarely seen in Hawaii, and generally north of 22 degrees latitude ( http://www.hawaii.gov/dlnr/dar/pubs/sawcs/mr_loggerhead.pdf last accessed June 14, 2006).

The factors affecting the decline of the loggerhead sea turtle are habitat destruction, predation, and drowning from being caught in shrimp nets. The States of North Carolina, South Carolina, Georgia, and Florida are taking steps to prevent beach destruction and predation, and the Atlantic and Gulf shrimpers are using TED's (50 CFR Part 227) to prevent drowning (World Wildlife Fund, 1990).

Assessment for Sea Turtles: Sea turtles occur within the proposed action area and may be harassed by the noise generated by the tug boats, by physical disturbance from visual or other cues, by marine debris entanglement or ingestion, and collisions with the tug/barge. The potential for collisions between the tug/barge and these turtles are very low due to the slow tow speed (6-9 knots). The baled garbage will be inspected at multiple points in the transport process to ensure that bales are intact and garbage will not be released. The proposed action will have no effect on beach habitat or nesting activities of these turtles.

Although the potential for collision of barges with s ea turtles is low due to the slow vessel speed, APHIS will implement the following protection measure:52 Vessels will operate at low speeds and have observers look out for sea turtles in Hawaii to avoid

direct encounters with them.

Should vessel collisions with sea turtles occu r , th is incident will be reported to APHIS and NOAA’s Pacific Islands Regional O ffice at 808-983-5730. APHIS will re-initiate

consultation with NMFS.

W ith the implementation of these measures, APHIS has determined that the proposed action may affect, but is not likely to adversely affect the green sea turtle, the hawksbill sea turtle, the olive ridley sea turtle, the leatherback sea turtle, or the loggerhead sea turtle. Designated critical habitat of the hawksbill and leatherback sea turtles does not occur in the

program area.

References:

NatureServe. 2006. NatureServe Explorer: An online encyclopedia of life [web application]. Version 4.7. NatureServe, Arlington, Virginia. Av ailable http://www.natureserve.org/explorer. (Accessed: June 6, 2006 ).

National Marine Fisheries Service and U.S. Fi sh and Wildlife Service (NMFS and USFWS). 1998. Recovery Plan for U.S. Pacific Populations of the Hawksbill Turtle ( Eretmochelys

imbricate ). National Marine Fisheries Service, Silver Spring, MD.

Richardson, S. 1997. Washington State Status Report fro the Olive Ridley Sea Turtle. Washington Department of Fish and Wildlife, Olympia. 14 pp.

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2,

1970.

United States Department of the Interior, 1978. Fish and Wildlife Service. Endangered and threatened wildlife and plants; listing and protecting loggerhead sea turtles as "threatened species" and populations of green sea and olive sea turtles as threatened or endangered. Rules issued by the Department of Commerce, National Marine Fisheries Service, and Department of the Interior, Fish and Wildlife Service. Federal Register, Vol. 43, p. 32808, July 28, 1978.

World Wildlife Fund, 1990. The Official World Wildlife Fund Guide to Endangered Species of North America. Vols. 1, 2, & 3. Walton Beacham. Washington, DC, 1647 pp.



### Fish Species That Occur in the Columb ia River That Could be Affected by Transport of GRG by Barge

The potential impacts due to program activities are the same for all listed fish species that occur in the Columbia River. For this reason, the assessment for these fish have been combined and it follows the species accounts.53 Chinook Salmon Life History and Description: Chinook salmon belong to the family Salmonidae and are one of eight species of Pacific salmonids in the genus Oncorhynchus

. Chinook salmon are easily the largest of any salmon, with adults often exceeding 40 pounds; individuals over 120 pounds have been reported. Chinook salmon are very similar to coho salmon in appearance while at sea (blue-green back with silver flanks), except for their large size, small black spots on both lobes of the tail, and black pigment along the base of the teeth. Chinook salmon are anadromous and semelparous.

Adult female chinook will prepare a spawning bed, called a redd, in a stream area with suitable gravel composition, water depth and velocity. The adult female chinook may deposit eggs in 4 to 5 nesting pockets within a single redd. After laying eggs in a redd, adult chinook will guard the redd from 4 to 25 days before dying. Eggs are deposited at a time to ensure that young salmon fry emerge during the following spring when the river or estuary productivity is sufficient for juvenile survival and growth. Juvenile chinook may spend from 3 months to 2 years in freshwater after emergence and before migrating to estuarine areas as smolts, and then

into the ocean to feed and mature.

Juveniles feed on plankton, then later eat insects and small fish. Coastwide, chinook salmon remain at sea for 1 to 6 years (more commonly 2 to 4 years), with the exception of a small proportion of yearling males (called jack salmon) which mature in freshwater or return after 2 or 3 months in salt water. Adults do not feed during the freshwater spawning migration.

Lower Columbia River Chinook Salmon, Oncorhynchus tshawytscha

Status: The lower Columbia River ESU chinook salmon was listed as a threatened species on March 24, 1999 (64 FR 14308). Critical habitat was designated on February 16, 2000 (65 FR 7764).

Pertinent Species Information: Critical habitat for this ESU is designated to include all river reaches accessible to listed chinook salmon in Columbia River tributaries between the Grays and White Salmon Rivers in Washington and the Willamette and Hood Rivers in Oregon, inclusive. Excluded are tribal lands and areas above sp ecific dams or above long-standing, naturally impassable barriers (i.e., natural waterfalls in existence for at least several hundred years). The following counties lie partially or wholly within these basins (or contain migration habitat for the species): Oregon - Clackamas, Clatsop, Columbia, Hood River, Marion, Multnomah, Wasco, and Washington; Washington - Clark, Cowlitz, Klic kitat, Lewis, Pierce, Pacific, Skamania, Wahkiakum, and Yakima.

Factors contributing to the decline of chinook salmon in this ESU include hatchery introgression, habitat blockages, logging, eruption of M ount Saint Helens, hydropower development, predation, and harvest.Upper Columbia River Spring-run Chinook Salmon, Oncorhynchus tshawytscha

54 Status: The Upper Columbia River spring-run chinook salmon was listed as an endangered species on March 24, 1999 (64 FR 14308). Critical habitat was designated on February 16, 2000 (65 FR 7764).

Pertinent Species Information: This ESU includes stream-type chinook salmon spawning above Rock Island Dam - that is, those in the Wenatchee, Entiat, and Methow Rivers, as well as the Columbia River and estuary. Designated habitat includes all river reaches accessible to chinook salmon in Columbia River tributaries upstream of the Rock Island Dam and downstream of Chief Joseph Dam in Washington, excluding the Okanogan River. Counties in Washington include Chelan, Douglas, Okanogan, Grant, Kittitas, Benton, Franklin, Yakima, Klickitat, Walla Walla, Skamania, Clark, Cowlitz, and Wahkiakum. In Oregon, critical habitat is found in the counties of Gilliam, Morrow, Sherman, Umatilla, Hood River, Wasco, Multnomah, Clatsop, and

Columbia.

Factors contributing to the decline of the Upper Columbia River spring-run chinook salmon include Columbia River hydroelectric development which has resulted in a major disruption of migration corridors and affected flow regimes and estuarine habitat. Some populations in this ESU must migrate through nine mainstem dams. Access to a substantial portion of historical habitat was blocked by Chief Joseph and Grand Coulee Dams. There are local habitat problems related to irrigation diversions and hydroelectric development, as well as degraded riparian and instream habitat from urbanization and livestock grazing.

Upper Willamette River Chinook Salmon, Oncorhynchus tshawytscha

Status: The Upper Willamette River spring-run chinook salmon was listed as a threatened species on March 24, 1999 (64 FR 14308). Critical habitat was designated on February 16, 2000 (65 FR 7764).

Pertinent Species Information: Major river basins known to support this ESU include the Willamette, Milalla, North Santiam, and McKenzie Rivers, as well as the Columbia River and estuary. The Upper Willamette River ESU is located in portions of Clark, Cowlitz, Wahkiakum, and Pacific, Washington and Clatsop, Columbia, Douglas, Lane, Benton, Lincoln, Linn, Polk, Clackamas, Marion, Washington, Yamhill, Tillamook, and Multnomah counties in Oregon. This ESU includes naturally spawned spring-run chinook salmon populations below Cottage Grove, Dorena, Fern Ridge, Blue River, Big Cliff, and Green Peter Dams.

Although it is unlikely that this species occurs within the action area, it may occur in the Columbia River estuary and is thus being included in this analysis of effects.

Key factors affecting chinook in this ESU incl ude habitat blockages, hatchery introgression, urbanization, logging, hydropower development, and harvest.

Snake River Fall Chinook Salmon, Oncorhynchus tshawytscha

Status: The Snake River fall Chinook salmon was listed as a threatened species on April 22, 1992 (57 FR 14653). This status was reclassified to endangered by an emergency interim rule on55 August 18, 1994 (59 FR 42529). Critical habitat for the Snake River fall Chinook salmon was designated on December 28, 1993 (58 FR 68543).

Pertinent Species Information: From the Pacific Ocean, Snake River fall salmon enter the Columbia River and travel upstream about 324 miles (520 kilometers) to the Snake River. The majority of spawning is in the mainstream Snake River, from the upper extent of Lower Granite Dam pool to Hells Canyon Dam. Spawning also occurs in the lower reaches of the Imnaha, Grande Ronde, Clearwater, and Tucannon Rivers.

Snake River fall Chinook salmon have declined to low numbers of fish that are thinly spread over a large and complex river system. Hydropower development, water withdrawal and diversions, water storage, harvest, inadequate regulatory mechanisms, and artificial propagation are factors contributing to the decline, and represent a continued threat to the Snake River fall

Chinook salmon.

Snake River Spring/Summer Chinook Salmon, Oncorhychus tahawytscha

Status: The Snake River spring/summer Chinook salmon was listed as a threatened species on April 22, 1992 (57 FR 14653). This status was r eclassified to endangered by an emergency interim rule on August 18, 1994 (59 FR 14653). Critical habitat for the Snake River spring/summer Chinook salmon was designated on December 28, 1993 (58 FR 68543).

Pertinent Species Information: From the Pacific Ocean, Snake River Spring/summer Chinook salmon enter the Columbia River and travel upstream about 324 miles (520 kilometers) to the

Snake River. The Snake River contains five principle subbasins that currently produce spring

and/or summer-run Chinook. Three of the five subbasins, the Clearwater, Grande Ronde, and Salmon Rivers, are large, complex systems: the others, the Tucannon and Imnaha Rivers, are small systems in which the majority of salmon production is in the mainstream rivers. The Asotin, Granite, and Sheep Creeks are small streams that enter the Snake River and provide small spawning and rearing areas.

Snake River spring/summer Chinook salmon declined to low numbers thinly spread over a large and complex river system. Hydropower developm ent, water withdrawal and diversions, water storage, harvest, inadequate regulatory mechanisms, and artificial propagation are factors contributing to their decline and represent a continued threat to the Snake River spring/summer

Chinook salmon’s existence.

Columbia River Chum Salmon, Oncorhynchus keta

Status: The Columbia River chum salmon was listed as a threatened species on March 25, 1999 (64 FR 14508). Critical habitat was designated on February 16, 2000 (65 FR 7764).

Pertinent Species Information: Chum salmon belong to the family Salmonidae and are one of eight species of Pacific salmonids in the genus Oncorhynchus . Chum salmon are anadromous, semelparous, and spawn primarily in fresh water. They have the widest natural geographic and spawning distribution of any Pacific salmonid, primarily because its range extends farther along56 the shores of the Arctic Ocean than that of the other salmonids. Juvenile chum salmon are distinguished by parr marks of relatively regular height that are smaller than the vertical diameter of the eye, and that are faint or absent below the lateral. Adult chum salmon have greenish to dusky mottling on the sides, with males exhibiting distinctive reddish-purple vertical barring. Adult chum in Washington range in size from 17 to 38 inches, with an average weight of 9 to 11 pounds. Chum salmon spawn in the lowermost reaches of rivers and streams, typically within

100 km of the ocean.

This ESU includes all naturally spawned populations of chum salmon in the Columbia River and its tributaries in Washington and Oregon. Critical habitat for the Columbia River chum salmon is designated to include all river reaches accessible to listed chum salmon (including estuarine areas and tributaries) in the Columbia River downstream from Bonneville Dam, excluding Oregon tributaries upstream of Milton Creek at rive r km 144 near the town of St. Helens. Also included are adjacent riparian zones. The following counties lie partially or wholly within these basins (or contain migration habitat for the species): Oregon - Clatsop, Columbia, Multnomah, and Washington; Washington - Clark, Cowlitz, Lewis, Pacific, Skamania, and Wahkiakum.

The decline of the Columbia River chum salmon is due to habitat loss and overfishing. Habitat loss is due to channel excavations, dewatering, channelization, flood control, major water diversions, poor forestry practices, and bulkheading of nearshore marine habitats.

Snake River Sockeye Salmon, Oncorhynchus nerka

Status: The Snake River sockeye salmon was listed as an endangered species on November 20, 1991 (56 FR 58619). Critical habitat was designated for the Snake River sockeye salmon on December 28, 1993 (58 FR 68543).

Pertinent Species Information: The Snake River sockeye salmon is a member of the trout family ( Salmonidae ). These Pacific salmon are anadromous, spending their adult life in the ocean and traveling into freshwater to spawn a nd complete their early life histories. Redfish Lake in Custer County, Idaho supports the only remaining run of Snake River sockeye salmon.

Adult Snake River sockeye salmon usually enter Redfish Lake in August, and spawning occurs near shoreline shoals in October. Eggs hatch in the spring, and the juveniles remain in Redfish lake for normally 2 years before migrating to the ocean. Migrants leave Redfish Lake from late April through May. Smolts migrate almost 900 miles through the Salmon, Snake, and Columbia Rivers to the ocean where they usually spend 2 years. Adults return to Redfish Lake in the fourth or fifth year of life, and begin their migration in June and July.

Hydropower development, water withdrawal and di versions, water storage, harvest, predation, and inadequate regulatory mechanisms are factors contributing to the Snake River sockeye salmon’s decline and represent a continued threat to the Snake River sockeye salmon’s

existence.

Steelhead Life History and Description: Steelhead exhibit one of the most complex life histories of any salmonid species. Steelhead may exhibit anadromy or freshwater residency.57 Resident forms are usually referred to as rainbow trout, while anadromous life forms are termed steelhead. Like all trout, the steelhead are positively separated from the various salmon species by having eight to twelve rays in the anal fin. Steelhead are separated from brook trout, lake trout, and Dolly Varden by the complete absence of teeth at the base of the tongue. Coloration on the back is basically blue-green shading to olive with black, regularly spaced spots. The black spots also cover both lobes of the tail. Steelhead from the ocean are much more silver than resident rainbow trout. Spawning steelhead deve lop a distinct pink to red strip-like coloration that blends along the side, both above and below the lateral line.

Juvenile steelhead trout are identical to rainbow trout until the period prior to their ocean migrations. Prior to migrating to the sea, juvenile steelhead become very silvery and resemble miniature adults. They are called smolt during this life phase. Steelhead typically migrate to marine waters after spending two years in freshwater. They then reside in marine waters for two to three years prior to returning to their natal stream to spawn. Within the range of west coast steelhead, spawning migrations occur throughout the year, with seasonal peaks of activity. Summer steelhead enter fresh water up to a year prior to spawning. Depending on water temperature, steelhead eggs may incubate in redds for one and one half to four months before hatching as alevins. The alevins remain within the redds, living on the rich nutrients contained in the yolk sac. In 3 to 4 weeks they emerge as fry and feed on small insects and drifting plankton. They then develop into parr (about 3 inches in length) feeding primarily on aquatic and flying insects, although small fish become an in creasingly important part of their diet as they grow. Juveniles rear in freshwater from one to four years, then migrate to the ocean as smolts.

Upper Columbia River Steelhead, Oncorhynchus mykiss

Status: The Upper Columbia River steelhead was listed as an endangered species on August 18, 1997 (62 FR 43974). Critical habitat was de signated on February 16, 2000 (65 FR 7764).

Pertinent Species Information: Critical habitat is designated to include all river reaches accessible to listed steelhead in Columbia River tributaries upstream of the Yakima River, Washington, and downstream of Chief Joseph Dam. Excluded are tribal lands and areas above specific dams or above long-standing, naturally impassable barriers (i.e., natural waterfalls in existence for at least several hundred years). The following counties lie partially or wholly within these basins (or contain migration habitat for the species): Oregon - Clatsop, Columbia, Gilliam, Hood River, Morrow, Multnomah, Sherman, Umatilla, and Wasco; Washington - Benton, Chelan, Clark, Cowlitz, Douglas, Franklin, Grant, Kittitas, Klickitat, Okanogan, Pacific, Skamania, Wahkiakum, Walla Walla, and Yakima. Habitat degradation, juvenile and adult mortality in the hydrosystem, and unfavorable

environmental conditions in both marine and freshwater habitats have contributed to the declines of this ESU and represent risk factors for the future. Harvest in lower river fisheries and genetic homogenization from composite broodstock collec tion are other factors that may contribute significant risk to the Upper Columbia River steelhead.Snake River Basin Steelhead, Oncorhynchus mykiss

58 Status: The Snake River Basin steelhead was listed as a threatened species on August 18, 1997 (62 FR 43974). Critical habitat was designated on February 16, 2000 (65 FR 7764).

Pertinent Species Information: Critical habitat is designated to include all river reaches accessible to listed steelhead in the Snake River and its tributaries in Idaho, Oregon, and Washington. Excluded are tribal lands and areas above specific dams identified or above longstanding, naturally impassable barriers (i.e., Napias Creek Falls and other natural waterfalls in existence for at least several hundred years). The following counties lie partially or wholly within these basins (or contain migration habitat for the species): Idaho - Adams, Blaine, Boise, Clearwater, Custer, Idaho, Latah, Lemhi, Lewi s, Nez Perce, and Valley; Oregon - Baker, Clatsop, Columbia, Hood River, Morrow, Multnomah, Sherman, Umatilla, Union, Wallowa, and Wasco; Washington - Asotin, Benton, Clark, Columb ia, Cowlitz, Franklin, Garfield, Klickitat, Skamania, Wahkiakum, Walla Walla, and Whitman.

Widespread habitat blockage from hydrosystem management, potentially deleterious genetic effects from straying, and introgression from hatche ry fish have contributed to the decline of

Snake River Basin steelhead.

Lower Columbia River Steelhead, Oncorhynchus mykiss

Status: The Lower Columbia River steelhead was listed as a threatened species on March 19, 1998 (63 FR 13347). Critical habitat was de signated on February 16, 2000 (65 FR 7764).

Pertinent Species Information: Critical habitat is designated to include all river reaches

accessible to listed steelhead in Columbia River tributaries between the Cowlitz and Wind Rivers in Washington and the Willamette and Hood Rivers in Oregon, inclusive. Excluded are tribal lands and areas above Bull Run Dam 2 and Merwin Dam or above long-standing, naturally impassable barriers (i.e., natural waterfalls in existence for at least several hundred years). The following counties lie partially or wholly within these basins (or contain migration habitat for the species): Oregon - Clackamas, Clatsop, Columbia, Hood River, Marion, Multnomah, and Washington; Washington - Clark, Cowlitz, Le wis, Pacific, Skamania, and Wahkiakum.

Habitat loss, hatchery steelhead introgression, and harvest are major contributors to the decline

of Lower Columbia River steelhead.

Middle Columbia River Steelhead, Oncorhynchus mykiss

Status: The Middle Columbia River steelhead was listed as a threatened species on March 25, 1999 (64 FR 14517). Critical habitat was de signated on February 16, 2000 (65 FR 7764).

Pertinent Species Information: Critical habitat is designated to include all river reaches accessible to listed steelhead in Columbia River tributaries (except the Snake River) between Mosier Creek in Oregon and the Yakima River in Washington (inclusive). Excluded are tribal lands and areas above specific dams (Condit Dam and Pelton Dam) or above longstanding, naturally impassable barriers (i.e., natural waterfalls in existence for at least several hundred years). The following counties lie partially or wholly within these basins (or contain migration59 habitat for the species): Oregon -Clatsop, Columbia, Crook, Gilliam, Grant, Harney, Hood River, Jefferson, Morrow, Multnomah, Sherman, Umatilla, Union, Wallowa, Wasco, and Wheeler; Washington - Benton, Clark, Columbia, Cowlitz, Franklin, Kittitas, Klickitat, Pacific, Skamania, Wahkiakum, Walla Walla, and Yakima.

The recent and dramatic increase in the percentage of hatchery fish in natural escapement in the Deschutes River Basin is a significant risk to natural steelhead in this ESU.

Bull Trout, Salvelinus confluentus

Status: The bull trout was listed as a threatened species on June 12, 1998 (USDOI, FWS, 1998). Critical habitat was designated on September 26, 2005 but does not occur within the mainstem of the Columbia River (USDOI, FWS, 20045.

Pertinent Species Information: Bull trout, members of the family Salmonidae, are native to the Pacific Northwest and western Canada. Juvenile bull trout have a slender body form and exhibit the small scalation typical of char. The back and upper sides are typically olive-green to brown with a white to dusky underside. The dorsal surface and sides are marked with faint pink spots. They lack the worm-like vermiculations and reddish fins commonly seen on brook trout ( Salvelinus fontinalis ). Spawning bull trout, especially males, turn bright red on the ventral surface with a dark olive-brown back and black markings on the head and jaw. The spots become a more vivid orange-red and the pectoral, pelvic, and anal fins are red-black with a white leading edge. The males develop a pronounced hook on the lower jaw. Bull trout have an obvious notch on the end of the nose above the tip of the lower jaw.

In the United States, bull trout occur in rivers and tributaries throughout the Columbia Basin in Montana, Idaho, Washington, Oregon, and Nevada, as well as the Klamath Basin in Oregon, and several cross-boundary drainages in extreme southeast Alaska.

Bull trout populations are known to exhibit four di stinct life history forms: resident, fluvial, adfluvial, and anadromous. Resident bull trout spend their entire life cycle in the same (or nearby) streams in which they were hatched. Fluvial and adfluvial populations spawn in tributary streams where the young rear from 1 to 4 years before migrating to either a lake (adfluvial) or a river (fluvial) where they grow to maturity. Anadromous bull trout spawn in tributary streams, with major growth and maturation occurring in the ocean. Bull trout spawn in the fall, primarily in September or October when water temperatures drop below 9 oC (48 oF).

Juvenile bull trout feed primarily on aquatic insects. Adults are opportunistic and largely nondiscriminating fish predators. Adult bull tr out, like the young, are strongly associated with the bottom, preferring deep pools in cold water rivers, as well as lakes and reservoirs.

Bull trout in other Columbia River tributaries (e.g. Hood and Wenatchie Rivers) are known to migrate downstream to the mainstem of the Columbia River (FWS, 2002). The extent to which the Lower Columbia River Recovery Unit uses the mainstem of the Columbia River is unknown (FWS, 2002). Adult bull trout do appear to use the mainstem Columbia River for foraging,60 overwintering and as a migratory corridor and it contains core habitat requirements considered important for bull trout recovery (FWS, 2002).

The decline of the bull trout is primarily due to habitat degradation and fragmentation, blockage of migratory corridors, poor water quality, past fisheries management practices, and the introduction of nonnative species.

The following bull trout core areas occur and feed into the mainstem Columbia River between

the mouth of the Columbia River and Klickita t County, where barging of bales of GRG from Hawaii will occur: Klickitat, John Day River, Upper Willamette, Lower Deschutes, Hood River, and Lewis. Only the migratory stage of bull trout from these core areas would be exposed to program activities because only the migratory stage would be present in the mainstem. Little is known about the presence of each individual bull trout subpopulation in the mainstem. Therefore, this assessment will assume that migratory adults from any subpopulation may be present in the mainstem. Freshwater feeding, migration, and overwintering habitats outside core areas, including the Columbia River, are difficult to evaluate due to the nature of this habitat and the limited information on its relationship to core areas. Bull trout from multiple core areas may use the Columbia River, making it extremely difficult to evaluate the overall effect to individual core areas. It is recognized that the Columbia River is an important component of the overall habitat network for migratory bull trout to complete their life history.

The following narratives have been provided by the U.S. Fish and Wildlife Service to describe

the baseline condition of the bull trout core areas considered in this risk assessment:

Lewis Core Area

The eruption of Mt. St. Helens affected wate r quality in the Muddy River and Pine Creek. Riparian vegetation was destroyed and mud flows and ash deposits have contributed high levels of fine sediments to Pine Creek, Muddy Rive r, and the Lewis River above Swift Creek Reservoir. Stream temperatures above 16 degr ees Celsius (61 degrees Fahrenheit) have also been measured in Pine Creek although the most current data collected did not exceed 14.3 degrees Celsius. While the exact cause of these elevated stream temperatures are not well understood, it is suspected that channel widening from high levels of timber harvest, and the 1980 mudflows and the loss of riparian vegetation from the Mt. St. Helens eruption, have all contributed to elevated stream temperatures in Pine Creek. Merwin Dam (located on te Lewis River), Yale Dam, and Swift Number 1 and 2 Powerhouses on the Lewis River prevent upstream migration of bull trout and other resident fish. Lack of passage at these hydroelectric facilities within the Lower Columbia River Unit has fragmented bull trout populations and prevented migration into the lower Lewis and Columbia Rivers. Forest management practices in the Lewis River basin have combined to alter flow regimes, riparian conditions and instream habitat. Flood events in the 1970’s sent large pulses of sediment into Rush Creek increasing the average channel width 38 percent. The stream has adjusted to these sediment pulses over time by channel narrowing and down cutting.

Key reference: Bull trout draft recovery plan, Chapter 20 (FWS, 2002).61 Klickitat Core Area

Water quality is poor in the lower Klickitat (i.e ., the area below the confluence with the Little Klickitat), with several tributaries listed as a 303(d) impaired waterway. Parameters that do not meet state water quality in portions of the Little Klickitat, Snyder Canyon, and Swale Creek include temperature, instream flow, fish passage ba rriers, and fish habitat. Sediment and various chemical contaminants have also been detected in the lower Klickitat, but did not exceed water quality standards. It is important to note that the Service has not completed consultation on water quality standards in terms of potential effects to listed species. In any case, sediment yields in the middle and upper Klickitat are elevated by a legacy of logging, road-building, and grazing impacts. In addition, high natural rates of sediment are associated with extensive glacial outwash from Big Muddy Creek.

Habitat access is limited in the Klickitat through physical, temperature, and instream flow obstructions. Numerous existing and abandoned roads, especially in the lower Klickitat, limit fish access to tributaries and side channel habitat directly or by poor culvert design or placement. Passage is impaired or precluded depending on flow , species, and life history form at Lyle Falls, the Klickitat Hatchery, and Castile Falls. While some of these areas appear to allow at least some passage during certain flow conditions, others prevent passage across a range of flows.

Development in the lower Klickitat for agriculture and a long history of logging and grazing in the middle and upper Klickitat has resulted in an extensively degraded system. As described above, access to off-channel habitat is reduced, and temperatures and flow conditions may be inadequate to support fish. Elevated sediment yields have increased embeddedness and filled pools in some locations. A long history of agriculture and logging has simplified habitat conditions, and all but eliminated refugia.

Development for agriculture, including loss of wetlands, intensive logging, and an extensive road network has substantially modified the hydrology of the Klickitat. This has resulted in pronounced changes in the timing and magnitude of peak flows, storage and recharge capacity. In addition, low flows appear to occur earlier, last longer, and consist of less total streamflow than similarly-sized watersheds..

The road network throughout the core area is extensive, approximating 8 miles/mile 2 across all FMO habitats. In particular, roads in the West Fork Klickitat local population involve 39 stream crossings. Riparian areas have been highly mana ged or have removed most riparian vegetation in the development and conversion to agriculture in the lower Klickitat. Similarly, logging, road-building, and grazing have substantially impacted all aspects of riparian areas in the middle and upper Klickitat. Human perturbations of the Klickitat have also impacted the natural disturbance regime, nearly eliminating frequent , low-intensity fires and altering all hydrological

processes.

(key reference: 2004 Klickitat Subbasin Plan)Upper Willamette Core Area

62 The Upper Willamette Core Area is comprised of three local populations, McKenzie River, South Fork McKenzie, and Trailbridge Reservoir. Population estimates indicate less than 300 adult bull trout survive in this core area. Annual redd counts have decreased gradually over the last five years (2000-2004) in the mainstem Mc Kenzie River local population, from a high of 92 redds in 2000, to 61 redds in 2003. Over the same time frame, redd counts have remained stable for the South Fork McKenzie River local population (annual average of 29), and increased in the Trail Bridge local population from two redds in 2000 to 25 redds in 2004. ODFW has been annually reintroducing bull trout fry into historic, unoccupied habitat in the Middle Fork Willamette River. No reproduction has been noted, but adult bull trout were captured in Hills Creek Reservoir in 2003 and 2004, and several age classes of bull trout were collected in and below the bull trout release sites. While there is some limited connectivity within and among local populations in this core area, there are some significant fish passage barriers posed by large dams. Habitat and population baseline conditions for the bull trout in the Willamette Basin are degraded, based on current condition, elevated risk from stochastic events, and the low probability of recolonization through dispersal due to the distance to other bull trout core areas in

the lower Columbia River.

Hood River Core Area

The Hood River Core Area is comprised of two local populations, Clear Branch and Hood River. Accurate adult abundance estimates for the Hood River Core Area are not available; however, 300 or less bull trout are believed to occur in the core area. Trap count and snorkel count data support this belief: Snorkel surveys conducted at Clear Branch above the dam found a total of 51 to 200 bull trout annually between 1996 and 2003, while surveys below the dam found a total of 0 to 3 bull trout annually between 1996 and 2003. Some migratory forms occur in the core area,

and are believed to overwinter in the lower Hood River and Bonneville Pool of the Columbia River. The two local populations are isolated by an impassable dam. Bull trout are consistently found in the Hood River, the Middle Fork Hood River, and the Clear Branch of Hood River.

Bull trout distribution in the East and West Forks of Hood River are based on isolated, infrequent sightings. Historical distribution is believed to approximate current distribution based on existing knowledge. Habitat baseline conditions are degraded in the Hood River Core Area, with numerous water diversions impacting connectivity. The Forest Service has undertaken numerous habitat restoration activities in the Clear Branch local population area.

Lower Deschutes Core Area

The Lower Deschutes Core Area includes all current and historic bull trout habitat in the Deschutes River and tributaries from Big Falls downstream to the confluence of the Deschutes with the Columbia River. It contains five local populations: Shitike Creek, Warm Springs River, Whitewater River, Jefferson/Candle/Abbot rive r complex, and Canyon/Jack/Heising/mainstem Metolius river complex. Spawning, rearing, foraging, migrating, and overwintering habitats are present in the core area. Redd count data collected between 1998 and 2004 found that bull trout63 spawner numbers had generally increased in two of the three Metolius River basin local populations (Jefferson/Candle/Abbot river complex and Canyon/Jack/Heising/mainstem Metolius river complexes combined redd counts increased from 180 in 1998 to 1,045 in 2004), remained stable in the Metolius basin’s Whitewater River (data from the Whitewater River are limited, but suggest that the population there is about 30 adults), and remained stable in the lower Deschutes River’s Shitike Creek and Warm Springs River populations (Shitike Creek remained steady between 1998 and 2004: 117 redds were counted in 1998, and counts have averaged 137 redds (110 adults) in the last five years. In the Warm Springs River 101 redds were counted in 1998, and redd counts averaged 89 redds (71 adults) in the last five years). In late summer of 2003, the 91,902 acre B&B fire burned through large areas of the Metolius

River basin. It burned areas of the Je fferson/Candle/Abbot river complex and Canyon/Jack/Heising/mainstem Metolius river complex, but did not affect the Whitewater River population. Habitat conditions in the two burned local populations are at elevated risk from increased sediment delivery, with resultant changes including sedimentation of spawning areas, loss of juvenile rearing habitat, increases in peak flows, and increases in stream temperature. Little data exists as to the current use of the mainstem Columbia River by bull trout in this recovery unit.

John Day River Core Area

The Middle Fork John Day Core Area consists of three local populations: Granite Boulder Creek, Big Creek, and Clear Creek. Total numbers of bull trout, consisting of primarily juvenile and subadult fish, were estimated in 1999 to be 1,950 individuals in Big Creek, 640 individuals in Clear Creek, and 368 individuals in Granite Boulder Creek. Resident bull trout are the predominant life history form in the core area, and occupy tributary habitats, but some migratory bull trout have been collected in the Middle Fork John Day River and on spawning locations

within tributaries. Sedimentation within this core area is a severe problem. Catastrophic fires burned through the core area in recent years causing erosion and high sediment yields. These effects combine with sedimentation from mining, the removal of streamside vegetation by livestock, and already existing habitat fragmentation to make the path to bull trout recovery

difficult.

The North Fork John Day River Core Area consists of seven local populations: Upper North Fork John Day River, Upper Granite Creek, B oulder Creek, Clear/Lightning creeks above ditch, Clear Creek below ditch, Desolation Creek, and S outh Fork Desolation Creek above the falls. Resident and migratory forms are found in the co re area. Overall population trend for the North Fork John Day Core Area is upward. Habitat fragmentation, connectivity and water quality issues still occur. The threats associated with mining still exist, but have been reduced through improved administration and cooperation between the Forest Service and local miners. The presence of brook trout throughout the core area, including the high mountain lakes, continues to

be a serious threat to bull trout.

The John Day River Core Area consists of two local populations: Upper John Day River and Indian Creek. Spawning surveys in 1999 and 2000 of bull trout habitat in tributary streams to the mainstem John Day River showed few fish spawning in the local population, with most occupied streams having less than 20 redds. Redd surveys in 1990 estimated that the upper64 mainstem, and Call and Rail creeks may have more than 300 total spawning adults. Some new, small populations of resident bull trout have been discovered in smaller Core Area streams. Migratory bull trout commonly occur from the John Day River headwaters to the City of John Day, with at least seasonal use as far down as the town of Spray, below the John Day and North Fork John Day rivers’ confluence. Indian Creek is seasonally blocked by a diversion that dewaters the lower reaches and creates a migration barrier. The overall trend for bull trout in this core area is upward. Water quality issues, passage problems and competition from brook trout all continue to be major problems.

Anadromous fish access to the John Day River basin is constrained by passage through the 3 mainstem Columbia River dams. Bull trout use of the Columbia River in the vicinity of these

dams is not well documented.

Bull Trout Matrix

The following table (table 2) is a summary of the documentation of the environmental baseline and effects of proposed actions on relevant indi cators, provided in the document “A Framework to Assist in Making Endangered Species Act Dete rminations of Effect for Individual or Grouped Actions at the Bull Trout Subpopulations Scale”, prepared by the U.S. Fish and Wildlife Service. Although the checklist for documentation includes many indicators, including habitat access, habitat elements, channel conditions and dynamics, flow/hydrology, and watershed conditions, APHIS considered only subpopulation characteristics and water quality because these were the relevant factors to the proposed action. Subpopulation characteristics included subpopulation size, growth and survival, life history diversity and isolation, and persistence and genetic integrity of the subpopulation. Water quality included temperature, sediment, chemical contamination, and nutrients. “H” indicates s ubpopulations functioning at an unacceptable risk, “M” indicates subpopulations functioning at ris k, and “L” indicates subpopulations functioning appropriately.65 Table 2. Summary of the documentation of the environmental baseline and effects of proposed

actions on relevant indicators.

ore Area Local Population/Potential Local Population Subpopulation

characteristics Water Quality Risk Rating

Klickitat West Fork Klickitat River H H H

upper North Fork John Day

River L L L
upper Granite Creek L L L

Boulder Creek L L L
Clear/Lightning Creek L L L

Clear Creek below Pete Mann

ditch L L L

Desolation Creek L L L

South Fork Desolation Creek L L L

Clear Creek (in Middle Fork) M H H

Granite Boulder Creek M H H
Big Creek M H H
upper John Day River L M M John Day River

Indian Creek L M M

McKenzie River M L M

South Fork McKenzie M L M Upper

Willamette Trail Bridge M L M

Shitike Creek M L M
Warm Springs River M L M

Whitewater River M L M

Jefferson/Candle/Abbot River M M M Lower

Deschutes

Canyon/Jack/Heising/

mainstem Metiolus river M M M

Clear Branch M L M Hood River Hood River M L M

Rush and Pine Creek H L M Lewis Cougar Creek H L M

Subpopulations of bull trout considered most at risk based on subpopulation characteristics and water quality were West Fork Klickitat River in the Klickitat Core Area, and Clear Creek, Granite Boulder Creek, and Big Creek in the John Day River Core Area.

Assessment for all listed fish in the Columbia River area:

No disinfectants or detergents are required to be used to clean up spills of GRG that might occur, thus none of these chemicals will enter the Columbia River. Barge traffic on the Columbia River has been estimated to increase by approximately 100 trips per year (1%) as a result of this proposed action but this minimal increase would ha ve no significant effect on any of these fish66 species. There is no evidence that barges in the Columbia River adversely affect listed species (other than the modifications made to the river to accommodate barges). Chance of pest escape from bales is very low and plant pest escape and establishment would not affect these fish. No animal pests are found in Hawaii that are not already found the continental United States.

However, if an accident were to occur and bales of GRG were to fall into the Columbia River, debris might have an adverse effect on listed fish. Although the Columbia River mainstem is primarily a migration route for salmon and steelhead rather than a spawning area, some ESUs have been found to spawn in the Columbia River ma instem. There is a possibility that if a bale fell from the barge and broke open in the river that GRG could drift into spawning areas.

It is unlikely that a bale would fall from the barge in the mainstem since bales will be well secured on the barge and the chance of a barge accident is very low. U.S. Army Corps of Engineers (2002, 2003) gave a mean accident rate for barges of 28.3 per billion ton-miles. Of those, only 4 of the 167 accidents on the Columbia River involved freight barges (Marine Safety Offices, 2006). Although loss of a bale in the river as a result of a barge accident is unlikely, both applicants have prepared emergency response plans to retrieve bales and loose GRG from

the river. All efforts will be made to retrieve lost bales.

The most likely location where bales could be lost is at the transloading points on the Columbia River where bales are unloaded from the barges. Bales could possibly be dropped into the River as they are being unloaded from the barge. Fish spawning areas are not likely to occur at the transloading points because the water would be too deep at the transloading point to accommodate redds. Hazardous materials are prohibited from inclusion in the bales; thus, bale

contents would not be toxic to fish. As stat ed previously, applicants must have emergency response plans in place should bales fall into the water and all efforts will be made to retrieve GRG. These plans will be included as appendices to the compliance agreements. Thus, bales falling into the Columbia River as a result of a barge accident or being dropped during transloading are not likely to adversely affect lis ted fish in the Columbia River or designated critical habitat. If an entire barge were to capsize in the Columbia River, an emergency consultation with the Services would be initiated. Capsizing would be an unpredictable event (temporally/geographically) and therefore, not possible to assess at this time.

Other than accidental spills, the only effect of barging GRG on bull trout, steelhead or salmon would be water quality if a gas or fuel spill from the barge were to occur. A catastrophic spill of fuel or oil is extremely unlikely and would be considered under an emergency consultation with the Services. However, routine leakage of small amounts of fuel or oil in the Columbia River is

considered in this assessment. Effects of the fu el could directly poison bull trout or indirectly affect bull trout by poisoning invertebrate or pr ey species. Oil and petroleum products vary considerably in their toxicity, and the sensitivity of fish to petroleum varies among species. The sublethal effects of oil on fish include changes in heart and respiratory rates, gill hyperplasia, enlarged liver, reduced growth, fin erosion, impaired endocrine system, and a variety of biochemical, blood, and cellular changes, and beha vioral responses (from page B-32: Biological Opinion, May 9, 2003, U.S. Fish and Wildlife Service, Montana Ecological Services Field Office).67 Analysis of impacts of a gas/fuel spill:

Duration: Any effect from a gas/fuel spill from a barge is expected to be a short term event whose effects are relaxed almost immediately because of the small size of spills and the rapid evaporation of the most toxic fractions of the fuel.

Disturbance Frequency: For this assessment, APHIS is expecting only two barges hauling GRG from Hawaii per week. The barge companies do not expect to leak fuel or oil from their tugs. However, for this assessment, APHIS is using a conservative estimate that 0.01% of the fuel would be lost through normal operations during the trip up the river for a total of 0.01 gal/hr.

Disturbance Intensity: One company submitted information indicating that 13,500 gallons of fuel will be used to travel from the mouth of the river to Klickitat County (253 miles) over a five day period resulting in the consumption of 112.5 ga of fuel/hr over the five day trip. Based on comments from the companies regarding the lack of leaks from the operation of their tugs and the economics APHIS assumed that 0.01% of the fuel would be lost through normal operations during the trip up the river for a total of 0.01 gal/hr. Converting this to L/hr results in a value of

0.042 L/hr.

APHIS used flow data from McNary Dam which is at river mile 292. There are three other dams below McNary, creating uncertainty when trying to determine concentrations of fuel in the water downstream. APHIS used the Army Corps of Engineer’s lowest discharge rate below the dam (30,000 cfs or 224,415 ga/hr) and the average (191,000 cfs or 1,428,775 ga/hr ) to estimate the volume of water that is moving down the Columbia River near the location of the landfill.

Minimum water discharge from McNary Dam = 30,000 cfs or 224,415 ga/hr or 849,503.19 L/hr) Average yearly discharge from McNary Dam = 191,000 cfs or 1,428,775 ga/hr or 5,408,503.6 L/hr)

To relate these numbers to a toxicity value APHIS converted the 0.042 L/hr discharge rate to mg/L/hr using the average density of diesel fuel (0.827 mg/L). Making all the conversions from ga to liter result in:

0.042 L/hr * 0.827 g/mL (density of diesel fuel) = 34,734 mg/L/h of diesel fuel from the tug.

34,734 mg/L/hr // 849,503.19 L/h = 0.04 mg/L/hr (concentration) 34,734 mg/L/hr // 5,408,503.6 L/h = 0.006 mg/L/hr (concentration)

When compared to the 48-hour Daphnia EC 50 value of 1.43 mg/L the above values fall well below the toxicity value. Information from the EPA OW Gold Book Standard states that oil toxicity is highly dependent on the type and gr ade of fuel so no standards are stated. EPA recommends using a 0.01 factor of the lowest resident species EC/LC 50 value which in this case (0.0143) would approximate the calculated exposure concentrations at a minimum discharge from the dam but would be an order of magnitude below potential levels at the average yearly68 discharge. However the above calculations are extremely conservative and reflect the use of available data using very simple assumptions. Assumptions:

1. The amount of loss from the tug is considered a conservative estimate of loss over the period of the trip up the Columbia River. The companies have stated that no fuel is lost during normal operations of their tugs; however APHIS recognizes that a sheen could appear during normal operations of the tug. Estimates were based on economic considerations for an acceptable loss of fuel and were considered to occur during the entire five day trip.

2. The calculation of cfs is based solely on discharge rates from the outflow of the McNary Dam and does not consider the volume of water already below the dam. Water discharging from the dam into a large volume of water will substantially increase the volume available for

dilution.

3. The calculations assume that the entire length of the Columbia River has the same flow rate. Three dams are located downstream of the McNary Dam, as well as numerous tributaries

that drain into the Columbia River and create a volume at the mouth that is one to two orders of magnitude greater than the flow from McNary Dam. The added input from the additional drainages would be expected to dilute any possible oil sheening orders of magnitude below the

above calculated values.

4. The above calculations assume that the diesel fuel will be uniformly mixed within the water column which will not be the case since diesel fuel has an average density (0.827 mg/mL) which is less than water from the Columbia River. The lighter diesel fuel will remain at the surface of the water column where the more toxic components will be lost through evaporation and other biotic and abiotic pathways.

5. The comparison of toxicity values expressed as (mg/L) to a rate expressed as (mg/L/hr) creates uncertainty in calculating risk. For reasons discussed above the concentration per hour calculated for this exercise would never been seen in the Columbia River. Making a comparison to toxicity values expressed over 48 to 96 hr is overly conservative and does not represent actual exposure scenarios.

Conclusion from oil/fuel spill risk assessment:

APHIS has determined that because toxicity to listed fish from the routine leakage of fuel or oil in the Columbia River is not expected, the proposed barging of GRG in the Columbia River may affect, but is not likely to adversely affect any listed fish, including salmon, steelhead, and subpopulations of bull trout, including those cons idered most at risk due to subpopulation characteristics and low water quality within the core area. Direct toxicity to fish or indirect effects from toxicity to prey species are unlikely based on the small amount of fuel to which these species could be exposed to in a large body of water. In addition, barge traffic on the Columbia River has been estimated to increase only 1 percent (100 barges per year) as a result of this proposed action but this minimal increase would have no significant effect on salmon, steelhead, or bull trout. There is no evidence that barges in the Columbia River adversely affect69 listed species (other than the modifications made to the river to accommodate barges). For these reasons, the proposed action may affect, but is not likely to adversely affect listed salmon, steelhead, and bull trout in the Columbia River. The proposed action is also not likely to adversely affect designated critical habitat of these species.

Potential Risk of Copper Exposure from Barges Containing Hawaiian Garbage to Salmonids

As a means to assess the risk of copper leaching from anti-hull fouling paints used on barges currently using the Columbia River and potentially carrying baled GRG from Hawaii, a conservative exposure estimate was calculated to compare to effect thresholds for salmonids. Several published articles have documented copper-related impacts to the olfaction response of

salmonids that could result in sublethal adverse effects. A recent overview of these effects resulted in the establishment of proposed benchmark concentrations that provide threshold concentrations above which dissolved copper concentrations could be expected to impact olfaction and behavior (Hecht et al ., 2007). Biologically relevant benchmark concentrations to unexposed salmonids were calculated to range from 0.59 to 2.1 μg/L. This range was used as the effects endpoint for this assessment since it is the most sensitive compared to other endpoints

that have been documented in other studies.

Exposure concentrations were derived based on multiple conservative assumptions to provide a copper concentration that could be compared to the benchmark values previously discussed. To calculate an exposure concentration, the literature was reviewed to determine potential leaching rates of copper from ships when an anti-hull fouling paint was used. As expected, leaching rates are variable depending on several factors, such as the type of copper-containing paint that is used, when it was applied, and other environmental factors that can affect leaching rates.

Hattum et al. (2002) in a review of leaching rates used to develop an environmental fate model, documented copper leaching rates ranging from 1 to 101 μg Cu/ cm 2 /day with a proposed default rate of 50 μg Cu/ cm 2 /day. This value is on the upper end of another study conducted in the United States in-situ and in the laboratory which documented initial laboratory leaching rates of 25 to 65 μg Cu/ cm 2 /day and then declining to 8 to 22 μg Cu/ cm 2 /day within two months. Variability in the rates was attributed to the different types of copper coatings used in the studies. In-situ leaching rates were much less with rates ranging from 3.8 to 8.2 μg Cu/ cm 2 /day (Valkirs

et al. 2003). The rate used in this assessment was 50 μg Cu/ cm 2 /day.

Barges that potentially could be moving baled GRG can range in size from 80 to 100 feet in width and 400 to 450 feet in length. To maximize the amount of leaching, the barge with the largest surface area was used in the calculation which after converting to meters, results in a total surface area of 4,179 square meters. This value was used as a means to determine potential copper loading in a day to surrounding waters in a port. As another means of maximizing copper concentrations, the volume of water was assumed to be small relative to the area of the barge. For this calculation, the water body was assumed to be 200 m by 800 m and 25 m deep, resulting in a total volume of 400 M L. The surface area was based on taking a value approximately five to six times the size of the barge that would allow a tug to move around in the enclosed port. In reality, the volume of water is going to be much greater and will also be influenced by water flow from the river as well as potential tidal influences. In this example the volume of water is assumed to be a closed system with no contribution of flow or tide that would dilute copper70 concentrations further. Based on this 400 M L volume and the total load of copper from a barge 4,179 sq meters discharging 50 μg Cu/ cm 2 /day of copper, the estimated copper concentration would be 0.52 μg/L. This value is below the threshold range of 0.59 and 2.0 μg/L which suggests the risk of copper to salmonids is low. The exposure value should not be interpreted as actual copper levels that could result from current barge use in ports along the Columbia River. The exposure value is extremely conservative since it assumes a relatively high rate of leaching would occur uniformly across the entire surface area of the largest possible barge that could be used. Also, as discussed above, the leaching is occurring into a comparatively small water body than would occur at an actual port without a ny flow. Significantly more dilution would be expected in ports and rivers where flowing wa ter and tidal fluctuations would dilute copper concentrations. In addition, the calculated exposure concentration in this assessment assumes that 100% of the copper is bioavailable and in the dissolved phase which would not be the case in natural waters that would contain suspended solids, organic carbon, acid volatile sulfides as well as having other water quality parameters that would affect the concentration of dissolved copper (Comber et al. 2002).

Based on this assessment, APHIS has determined that anti-hull fouling treatments may affect, but are not likely to adversely affect listed salmonids in the Columbia River. In addition, use of such treatments may prevent invasive species from being carried into the Columbia River.

References:

Comber, S.D.W., G.Franklin, M.J. Gardner, C.D. Watts, A,B.A. Boxall and J. Howcraft. 2002. Partitioning of marine antifoulants in the marine environment. Science of the Total Env.

286:61-71.

Hecht, S.A., D.H. Baldwin, C.A. Mebane, T. Hawkes, S.J. Gross and N.L. Scholz. 2007 An overview of sensory effects on juvenile salmoni ds exposed to dissolved copper: Applying a benchmark concentration approach to evaluate s ublethal neurobehavioral toxicity. U.S. Dept. Commer., NOAA Tech. Memo. NMFS-NWFSC-83, 39 pp.

United Stated Department of the Interior. 1998. Fish and Wildlife Service. Endangered and threatened wildlife and plants; determination of threatened status for the Klamath River and Columbia River distinct population segments of bull trout. Federal Register, Vol. 63, p. 31674, June 10, 1974.

United Stated Department of the Interior. 2005. Fish and Wildlife Service. Endangered and Threatened Wildlife Plants; Designation of Critical Habitat for the Bull Trout; Final Rule. Federal Register, Vol. 70, p. 56211-56260, September 26, 2005.

U.S. Fish and Wildlife Service, 2002. Chapter 20, Lower Columbia Recovery Unit, Washington. 89. p. In : U.S. Fish and Wildlife Service. Bull Trout ( Salvelinus confluentus ) Draft Recovery Plan. Portland, Oregon.

Valkirs, A.O., P.F. Seligman, E. Haslbeck, J.S. Caso. 2003. Measurement of copper release rates from antifouling paint under laboratory and in situ conditions: implications for loading71 estimation to marine water bodies. Marine Pollution Bulletin. 46: 763-779.

van Hatttum, B., A.C. Baart and J.G. boon. 2002. Computer model to generate predicted environmental concentrations (PECs) for antifouling products in the marine environment. 2 nd
edition accompanying the release of Mam-Pec version 1.4. Report Number E-02-04/Z 3117. 73

pp.



### Listed Species That Could be Struck by Trucks or Trains Transporting GRG From the Barge Off-load Site to the Designated Landfill

The assessments for listed species that could be struck by trucks or trains have been combined and it follows the species accounts.

Columbian White-tailed Deer, Columbia River DPS, Odocoileus virginianus leucurus

Status: The Columbia River DPS of the Columbian white-tailed deer was listed as endangered on March 11, 1967 (USDOI, FWS, 1967).

Pertinent Species Information: The Columbian white-tailed deer is one of 38 recognized subspecies of virginianus , a species with a continuous geographic distirbution that extends from southern Canada to South America. There are 2 distinct population segments (DPS) of the Columbia white-tailed deer. The Columbia River DPS is located along the lower Columbia River. The Douglas County DPS, also known as the Roseburg population, located 320 km south, has been delisted because of recovery.

The Columbian white-tailed deer was formerly locally common in the bottomlands and prairie woodlands of the lower Columbia, Willamette, and Umpqua river basins in Oregon and southern Washington. It has been reduced to two distinct populations (NatureServe, 2007). The Columbia River DPS occurs on both banks of the river in Clatsop and Columbia counties, Oregon, and Wahkiakum and Cowlitz counties, Wa shington (NatureServe, 2007). Most of these occur along the lower Columbia River in Oregon and Washington from Wallace Island (RM 50) downstream to Karlson Island (RM 32).

It prefers wet prairie and lightly wooded bottomlands or "tidelands" along streams and rivers; woodlands are particularly attractive when interspersed with grasslands and pastures. Along the Columbia River, Sitka spruce, dogwood, cottonwood, red alder, and willow dominate the vegetation; in inland habitats, and along the Umpqua River, the tree community consists of Oregon white oak, madrone, California black oa k, and Douglas-fir, with a shrubby ground cover of poison oak and wild rose (NatureServe, 2007).

Reasons for decline include habitat degradation, automobile collisions, poaching, entanglement in barbed wire fences, competition with livestock, flooding, disease and parasites, black-tailed deer competition and hybridizationand Roosevelt elk competition (FWS, 1983).

References:72 NatureServe. 2007. NatureServe Explorer: An on line encyclopedia of life [web application]. Version 6.2. NatureServe, Arlington, Virginia. Av ailable http://www.natureserve.org/explorer. (Accessed: August 14, 2007 ).

United States Department of the Interior. 1967. Endangered Species List - 1967. Federal Register, Vol. 32, p. 4001, March 11, 1967.

U.S. Fish and Wildlife Service (FWS). 1983. Revised Columbian White-tailed Deer Recovery Plan. U.S. Fish and Wildlife Service, Portland, OR, 75 pp.

Canada Lynx, Lynx canadensis

Status: The Canada lynx was listed as a threatened species on March 24, 2000 (USDOI, FWS, 2000). Cirtical habitat was designate d on November 9, 2006 (USDOI, FWS, 2006).

Pertinent Species Information: The Canada lynx is a medium-sized cat, similar to the bobcat but with longer legs and very large, well-furred paws -- adaptations to the deep winter snows typical throughout its range. It also has unique l ong tufts of hair on the ears and a short, blacktipped tail. Adult males average 22 pounds in weight and 33.5 inches in length while females

are somewhat smaller.

From NatureServe, 2004: In the contiguous United States, the Canada lynx is considered historically resident in 16 states represented by five ecologically distinct regions: Cascade Range (Washington, Oregon), northern Rocky Mountains (northeastern Washington, southeastern Oregon, Idaho, Montana, western Wyoming, nor thern Utah), southern Rocky Mountains (southeastern Wyoming, Colorado), northern Great Lakes (Minnesota, Wisconsin, Michigan ), and northern New England (Maine, New Hamp shire, Vermont, New York, Pennsylvania, Massachusetts). Resident populations currently exist only in Maine, Montana, Washington, and possibly Minnesota. The lynx is considered ex tant but is no longer sustaining self-supporting populations in Wisconsin, Michigan, Oregon, Ida ho, Wyoming, Utah, and Colorado. It may be extirpated from New Hampshire, Vermont, Ne w York, Pennsylvania, and Massachussets (USDOI, FWS, 1998). In Canada, the lynx is still widespread and relatively abundant in most of historic range.

Lynx are highly dependent on snowshoe hare, but when hare populations drop they also prey on other small mammals and birds. This change in diet causes sudden drops in the productivity of adult females and survival of young. Prey scarcity suppresses breeding and may result in mortality of nearly all young (Brand and Keith, 1979).

In the western United States, lynx live in subalpine coniferous forests of northern latitudes. The

U.S. Forest Service et al. (1993) listed three primary habitat components for lynx in the Pacific Northwest: (1) foraging habitat (15-35-year-old lodgepole pine) to support snowshoe hare and provide hunting cover, (2) denning sites (patches of >200-year-old spruce and fir, generally less than 5 acres, and (3) dispersal/travel cover (variable in vegetation composition and structure). Early successional forest stages provide habitat for the lynx's primary prey, the snowshoe hare.73 The home range of a lynx can be 5 to 94 square miles and they are capable of moving long

distances in search of food.

Canada lynx avoid openings such as clearcuts a nd grasslands because snowshoe hares also are unlikely to use such areas, and because these areas lack the cover necessary for both species.

Forest management practices that result in the loss of diverse age structure, fragmentation, roading, urbanization, agriculture, recreational developments, and unnatural fire frequencies have altered suitable habitat in many areas. As a result, many states may have insufficient habitat quality and/or quantity to sustain lynx or their prey. Human access into habitat has increased dramatically over the last few decades contri buting to direct and indirect mortality and displacement from suitable habitat. Although legal take is highly restricted, existing regulatory mechanisms may be inadequate to protect small, remnant populations or to conserve habitat. Competition with bobcats and coyotes may be a concern in some areas (NatureServe, 2004).

References:

Brand, C. J., and L. B. Keith. 1979. Lynx demography during a snowshoe hare decline in Alberta. J. Wildl. Manage. 43:827-849.

NatureServe. 2004. NatureServe Explorer: An on line encyclopedia of life [web application]. Version 4.0. NatureServe, Arlington, Virginia. Av ailable http://www.natureserve.org/explorer. (Accessed: September 14, 2004 ).

United States Department of the Interior. 1998. Endangered and Threatened Wildlife and Plants: Proposal To List the Contiguous United States Distinct Population Segment of the Canada Lynx; Proposed Rule. Federal Register, Vol. 63, p. 36993, July 8, 1998.

United States Department of the Interior. 2000. Endangered and Threatened Wildlife and Plants: Determination of Threatened Status for the Contiguous U.S. Population Segment of the Canada Lynx and Related Rule. Federal Register, Vol. 58, p. 16085, March 24, 2000.

United States Department of the Interior. 2006. Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for the Contiguous United States Distinct Population Segment of the Canada Lynx; Final Rule. Federal Register, Vol. 71, p. 66007-66061, November 9, 2006.

U.S. Forest Service, et al. 1993. Draft supplemental environmental impact statement on management of habitat for late-successional and old-growth forest related species within the range of the northern spotted owl. Published separately is Appendix A: Forest Ecosystem Management Assessment Team. 1993. Forest ecosystem management: an ecological, economic, and social assessment (FEMAT Report).74 Grizzly (Brown) Bear, Ursus arctos horribilis

Status: The grizzly bear was listed as a threatened species on March 11, 1967 (USDOI, FWS, 1967). On November 17, 2000, the grizzly bear was designated as a non-essential, experimental population in the United States in portions of ID and MT (USDOI, FWS, 2000).

Pertinent Species Information: Grizzly bears are generally larger than black bears and can be distinguished by longer curved claws, humped shoulders, and a face that appears to be concave. A wide range of coloration from light brown to nearly black is common. Guard hairs are often paled at the tips, hence the name “grizzly.” Spring shedding, new growth, nutrition and climate all affect coloration (FWS, 1993).

An occasional male may exceed 1,000 pounds but the average weight is closer to 500 - 600 pounds. Females are generally smaller. Adults stand 3-1/2 to 4-1/2 feet at the hump when on all fours, and they may rear up on their hind legs to over eight feet (FWS, 1993). The muscle structure in grizzly bears is deve loped for massive strength, quickness, and running speeds up to 25 miles per hour. Movement includes the normal position on all fours and an upright position on the hind legs which improves the opportunity to see and smell (FWS, 1993).

Grizzlies are omnivorous and consume carrion, rodent s, fish, grasses, roots, berries, fruits and leaves at varying times of the year. The b ears are typically carnivorous during the pregrowing season. As summer progresses and into the fall they began to feed on vegetable matter. They are opportunistic feeders and will prey or scavenge almost any available food (FWS, 1993). Optimum habitat includes extensive timbered areas adjacent to grassland/herbland, shrubland, or other open feeding sites. Forest cover is very important to grizzly bears fro use as beds (FWS, 1993). In the fall, grizzly bears excavate dens for winter hibernation. Dens are in isolated areas

that will be covered with a thick blanket of snow to prevent escape of body-warmed air (FWS, 1993).

Breeding occurs in late May or early June and delayed implantation occurs at about the time that the females enter dens in late October through November. One or two cubs are born in January or February and remain with the mother for about 2.5 years. Due to the length of time it takes to wean the cubs, females only breed every second or third year.

Grizzly bears are normally solitary and shy animals which require large amounts of isolated acreage in which to wander. The occurrence of the bear in North America has been only where spacious habitat insulated it from excessive human-related mortality. Populations in the 48 contiguous States have survived primarily due to the preservation of suitable habitat, as required by the Wilderness Act of 1964.

In the conterminous 48 States, only six areas are known to contain either self-perpetuating or remnant populations. Only 1,000 to 1,100 grizzly bears remain in a few isolated populations in Montana, Wyoming, Idaho, and Washington (USDOI, FWS, 2000). Reasons for decline of the grizzly bear include human-caused mortality and loss of habitat (USDOI, FWS, 2000).75 References:

United States Department of the Interior. 1967. Endangered Species List - 1967. Federal Register, Vol. 32, p. 4001, March 11, 1967.

United States Department of the Interior. 2000. Endangered and Threatened Wildlife and Plants: Establishment of a Nonessential Experimental Popul ation of Grizzly Bears in the Bitterroot Area of Idaho and Montana. Federal Register, Vol. 65, p. 69623, November 17, 2000.

U.S. Fish and Wildlife Service. 1993. Grizzly b ear recovery plan. Missoula, MT. 181 pp.

Northern Idaho Ground Squirrel, Spermophilus brunneus brunneus

Status: The Northern Idaho ground squirrel was listed as a threatened species on April 5, 2000 (USDOI, FWS, 2000).

Pertinent Species Information: The Northern Idaho ground squirrel is a relatively small member of the genus Spermophilus with males typically measuring 9.25 inches -- slightly longer than the average female.

The Northern Idaho ground squirrel emerges in late March or early April, remains active above ground until late July or early August, and spends the rest of the year in hibernation underground (Yensen and Sherman, 1997). Seasonal torpor (a state of sluggishness or inactivity) generally occurs in early to mid-July for males and females, and late July to early August for juveniles.

Northern Idaho ground squirrels consume the roots, bulbs, leaf stems, and flower heads of 45 to 50 plant species during spring and summer (Dyni and Yensen, 1996). Seeds of forbs, lupines, and composites are important, while roots, bulbs, leaf stems, and flower heads are a minor component of their diet (FWS, 2003). To stor e energy for winter, the ground squirrel must consume large amounts of seed from Poa species (bluegrass) and other grasses (Dyni and Yensen, 1996).

The Northern Idaho ground squirrel often digs burrows under logs, rocks, or other objects. Dry vegetation sites with shallow soil horizons above basalt bedrock are preferred. Nesting burrows are found in well-drained soils greater than 3 feet deep (Yensen et al., 1991), in areas not covered with trees or used by Columbian ground squirrels.

The Northern Idaho ground squirrels is known to occur in dry, rocky meadows associated with deeper, well-drained soil surrounded by coniferous forests of ponderosa pine and/or Douglas-fir at elevations of 3,000 to 5,400 feet in Adams and Valley Counties of western Idaho (FWS, 2003).

In the spring of 2002, the northern Idaho ground squirrel population was estimated to be 450 to 500 animals (FWS, 2003). It is primarily threatened by habitat loss due to forest encroachment into meadow habitats (FWS, 2003). The subspecies is also threatened by competition from the76 larger Columbian ground squirrel, land use changes, recreational shooting, poisoning, genetic drift, genetic isolation, and naturally occurring events (FWS, 2003).

References:

Dyni, E. and E. Yensen. 1996. Dietary similarity in sympatric Idaho and Columbian ground squirrels ( Spermophilus brunneus and Spermophilus columbianus ). Northwest Science. 70:99–

108.

United States Department of the Interior. 2000. Fish and Wildlife Service. Endangered and threatened wildlife and plants; Determination of Threatened Status for the Northern Idaho Ground Squirrel. Federal Register, Vol. 65, p. 17786, April 5, 2000.

U.S. Fish and Wildlife Service. 2003. Recovery Plan for the Northern Idaho Ground Squirrel ( Spermophilus brunneus brunneus ). Portland, Oregon, 68 p.

Yensen, E., M.P. Luscher, and S. Boyden. 1991. Structure of burrows used by the Idaho ground squirrel, Spermophilus brunneus. Northwest Science. 65:93–100. Yensen, E. and P.W. Sherman. 1997. Spermophilus brunneus. Mammalian Species. 560: 1–5.

Woodland Caribou, Rangifer tarandus caribou

Status: The woodland caribou was listed as an endangered species on January 14, 1983 (USDOI, FWS, 1983).

Pertinent Species Information: The woodland caribou is a brown hoofed mammal with large mossy antlers, and a hanging neck mane. Adult bulls weigh up to 270 kg but average about 180 kg. Cows average 115 kg. Both males and females grow antlers but cows' are shorter and have fewer points.

Most remain in forested habitats year-round. They migrate 80 km or more between their forested foothills winter range and alpine summer range. The woodland caribou's habitat consists of forested mountain regions and it prefers dense stands of fir and spruce. The woodland caribou's major food sources are arboreal lichens and they depend on them for up to six months of the year (FWS, 1993). They also eat huckleberry leaves, boxwood, and smooth woodrush during the spring and summer (FWS, 1993).

Caribou mate in early to mid-October. Calves ar e born by early June. Pregnant females move to typical spring habitat in April or May, then move back onto snow-covered areas often at higher elevations to calve (FWS, 1993). This behavior may function to avoid predators, thus increasing calf survival (Servheen and Lyon, 1989). A cow first calves at 3 years of age and will usually have one calf per year.

Historically, this species once populated most of the northern portion of the United States, ranging from New England to Washington. The onl y surviving populations in the United States are found in the Selkirk Mountain ecosystem of Idaho and Washington. All other populations within the lower 48 states have been extirpated.77 Threats to the woodland caribou include logging, co al mining, and oil and gas exploration which have greatly reduced the woodland caribou's habitat. When large areas of old-growth coniferous forests are logged, moose, deer and elk populations increase. As their prey become more plentiful, more wolves move in. Woodland caribou are most vulnerable to wolves so they suffer the greatest losses.

References:

Servheen, G. and J. Lyon. 1989. Habitat use by woodland caribou in the Selkirk Mountains. J. Wildlife Management. 53:230–237.

United States Department of the Interior. 1983. Endangered and Threatened Wildlife and Plants: Emergency Determination of Endangered Stat us for the Population of Woodland Caribou Found in Washington, Idaho, and Southern British Columbia. Federal Register, Vol. 48, p. 1726, January 14, 1983.

U.S. Fish and Wildlife Service. 1993. Recovery Plan for Woodland Caribou in the Selkirk Mountains. Portland, OR. 71 pp.

Gray Wolf, Canis lupus

Status: The gray wolf has been designated as threatened in the western distinct population segment (CA, ID, MT, NV, OR, WA, WY, UT north of U.S. Highway 50, and CO north of Interstate Highway 70, except where listed as an experimental population).

Designation of a Northern Rocky Mountain Gray Wolf Distinct Population Segment (Montana, Wyoming, Idaho, eastern Washington, eastern Oregon, and north central Utah) has been proposed and this population has been proposed for delisting (USDOI, FWS, 2007).

Critical habitat was designated for this species on March 9, 1978 (USDOI, FWS, 1978) but does not occur in the program area.

Pertinent Species Information: The gray wolf is a member of the Canidae family and resembles a large dog, but differs in having relatively longer legs, larger feet, and narrower chest. Wolves also have tails that are straight rather than curved upward posteriorly like those of dogs. Total length is about 51 to 71 inches, and weight is above 44 to 176 pounds for males.

Wolves live in groups or packs, consisting generally of two to eight members (FWS, 1992). Packs are primarily family groups, consisting of a breeding pair, their pups from the current year, offspring from the previous year, an occasionally, an unrelated wolf. Packs defend a territory of 20 to 214 square miles.

Wolves gain sexual maturity in their second year, but often do not breed until the third. It is believed that wolves mate for life. The mating season may be any time between January and April depending upon locale. The gestation period is 63 days with an average of four to six pups (range of 1 to 11). Dens are usually in a sheltered place in a hole, rock crevice, or hollow log.78 Unlike most mammals, wolves do not construct or make use of shelters, except for dens used to give birth and rear young for about 2 months. Seasonal activity can be categorized into limited wanderings during the rest of the year (40 miles or more a day). Wolves prey on large mammals primarily--white-tailed and mule deer, caribou, moose, Dall sheep, bighorn sheep, and beaver. Only rarely are rodents and birds consumed. Wolves spend almost all of their waking time eating or hunting in packs, usually fewer than eight members.

Gray wolves do not seem particular about habitat. They originally occurred in arctic tundra, taiga, plains or steppes, savannahs, and ha rdwood, softwood, and mixed forests (Chapman and Feldhamer, 1982).

Reasons for decline include negative attitudes towards wolves by humans, leading to poisoning, trapping, shooting, and State and Federal bounties resulted in extirpation of this species from more than 95 percent of its range in the 48 coterminous states to scattered populations in northern Minnesota and the northern Rocky Mountains.

References:

Chapman, J. A. and Feldhamer, G. [eds.]. 1982. Wild mammals of North America. Baltimore, MD: The Johns Hopkins University Press. 1147 p.

United States Department of the Interior. 1967. Endangered Species List - 1967. Federal Register, Vol. 32, p. 4001, March 11, 1967.

United States Department of the Interior. 1978. Endangered and Threatened Wildlife and Plants; Reclassification of the Gray Wolf in the United States and Mexico, With Determination of Critical Habitat in Michigan and Minnesota. Federal Register, Vol. 43, p. 9607, March 9, 1978.

U.S. Fish and Wildlife Service. 1992. Recovery Pl an for the Eastern Timber Wolf. Twin Cities, MN. 73 pp.

United States Department of the Interior. 2003. Endangered and Threatened Wildlife and Plants; Final Rule To Reclassify and Remove the Gr ay Wolf From the List of Endangered and

Threatened Wildlife in Portions of the Cont erminous United States; Establishment of Two Special Regulations for Threatened Gray Wolv es. Federal Register, Vol. 68, p. 15803, April 1,

2003.

United States Department of the Interior. 2007. Endangered and Threatened Wildlife and Plants; Designating the Northern Rocky Mountain Populati on of Gray Wolf as a Distinct Population Segment and Removing This Distinct Population Segment From the Federal List of Endangered and Threatened Wildlife; Proposed Rule. Federal Register, Vol. 72, p.6105-6139, February 8,

200779 Pygmy Rabbit (Columbian Basin Distinct Population Unit), Brachylagus idahoensis

Status: The pygmy rabbit (Columbian Basin Distinct Population Unit) was listed as an endangered species on November 30, 2001 (USDOI, FWS, 2001).

Pertinent Species Information: The smallest rabbit species in North America, the pygmy rabbit measures 9.2-11.6 inches (23.5-29.5 cm) in length, weighs a slight 0.88-1.02 lbs (398-462 g). The pygmy rabbit is typically colored brown/slate gray with short, white-margined, ears and

a small tail.

The breeding season of pygmy rabbits lasts from March through May in Idaho; in Utah, it lasts from February through March (Chapman and Fe ldhamer, 1982). The gestation period of pygmy rabbits is unknown. An average of six young are born perlitter and a maximum of three litters are produced per year (Green and Flinders, 1980).

Big sagebrush is the primary food source, but grasses and forbs are eaten in mid- to late summer (Green and Flinders, 1980; Lyman, 1991). Pygmy rabbits may be active at any time of day; however, they are generally most active at dusk and dawn. They usually rest near or inside their burrows during midday (Green and Flinders, 1980). Pygmy rabbits are generally limited to areas on deep soils with tall, dense sagebrush which they use for cover and food (Flath, 1994; Green and Flinders, 1980). Individual sagebrush plants in areas inhabited by pygmy rabbits are often 6 feet or more in height (Flath, 1994). Extensive, well-used runways interlace the sage thickets and provide travel and escape routes (Green and Flinders, 1980).

The pygmy rabbit is the only native leporid that digs burrows. Juveniles use burrows more than other age groups. Early reproductive activities of adults may be concentrated at burrows (Green and Flinders, 1980). Burrows are usually located on slopes at the base of sagebrush plants, and face north to east. Tunnels widen below the surface, forming chambers, and extend to a maximum depth of about 3.3 feet.

A distinct population segment of the pygmy rabbit is found only in one area of Washington, Sagebrush Flat, and is nearly extinct. It has declined greatly in eastern Washington, from six colonies to probably just one, and from at leas t 150 individuals to fewer than 30 in the last decade (USDOI, FWS, 2001, 2003). Recently the Washington Department of Fish and Wildlife has initiated a captive-breeding program with hopes of revitalizing the population. Originally planning on crossbreeding with Idaho pygmies, the idea was scrapped in favor of preserving the Washington sub-species when it was found the two are genetically different (Pacific Diversity Institute, 2004).

The loss of habitat is probably the most significant factor contributing to pygmy rabbit population declines.

References:

Chapman, J. A. and Feldhamer, G. [eds.]. 1982. Wild mammals of North America. Baltimore, MD: The Johns Hopkins University Press. 1147 p.80 Flath, D. 1994. Bunnies by the bunch. Montana Outdoors. 25(3):8-13.

Green, J. S. and J. T. Flinders. 1980. BRACHYLAGUS IDAHOENSIS. Mammalian Species.

125:1-4.

Lyman, R. L. 1991. Late Quaternary biogeography of the pygmy rabbit (BRACHYLAGUS IDAHOENSIS) in eastern Washington. J. Mamm. 72:110-117.

Pacific Biodiversity Institute, Endangered Species Information Network. Pygmy Rabbit.

< www.pacificbio.org/ESIN/Mammals/PygmyRabbit/pygmyrabbit.html> last accessed September 8, 2004.

United States Department of the Interior. 2001. Fish and Wildlife Service. Endangered and threatened wildlife and plants. Emergency Rule To List the Columbia Basin Distinct Population Segment of the Pygmy Rabbit ( Brachylagus idahoensis ) as Endangered. Federal Register, Vol. 66, p. 59749, November 30, 2001.

United States Department of the Interior. 2003. Fish and Wildlife Service. Endangered and threatened wildlife and plants; final rule to lis t the Columbia Basin Distinct Population Segment of the Pygmy Rabbit ( Brachylagus idahoensis ) as endangered. Federal Register, Vol. 68, p. 10409, March 5, 2003.

Program Assessment for Species that Coul d be Struck by Trucks or Trains: APHIS has determined that transport of GRG from Hawaii via rail or truck may affect, but is not likely to adversely affect the Columbian white-tailed d eer (Columbia River DPS), Canada lynx, grizzly bear, northern Idaho ground squirrel,woodland caribou, gray wolf, and pygmy rabbit (Columbian Basin Distinct Population Unit) for the following reasons:

• Only currently established routes will be used. No new railways or roads will be

constructed.

• No spillage of garbage is likely –the chance of an accident is low, and bales are tied down to the trucks and/or railcars. If a spill were to occur, very low amounts of greenwaste (< 3 percent) are in the bales and will not attract bears or other animals to forage and be struck by trains or trucks.

• There will be only a slight increase in rail or truck traffic as a result of the proposed action. Rail traffic is expected to increase by only less than 1 percent in Oregon and Washington, and by 3 percent in Idaho. These estimates of rail increase are very conservative and assume that all of the GRG from Hawaii would be transported by rail, a scenerio that is unlikely. Truck/highway transport of freight would increase by only 0.2, 0.1, and 0.5 percent in Oregon, Washington, and Idaho, respectively. Again, this assumes that all GRG would be transported by truck to landfills.

### Discussion of Remaining Species and Designated Critical Habitat That Occur

81 

### in Washington, Oregon, and Idaho.

If plant pests from Hawaii were to escape and establish in the environments of Washington, Oregon, and Idaho, some of these might attack federally-listed plants. However, APHIS has determined that there will be no effect on the following plant species (table 3) or designated

critical habitat of the Wenatchee Mountains checker mallow because of the negligible risk of pest escape and establishment of Hawaiian plant pests in Washington, Oregon, and Idaho, as described previously in this document and determined in the APHIS risk assessments (see appendices C-F).

Table 3. Listed Plants in Idaho, Oregon, and Washington.

Common Name Scientific Name State of

Occurrence Listing

Status Critical

Habitat? Applegate’s milk-vetch Astragalus applegatei OR E No Bradshaw’s desert parsley Lomatium bradshawii WA, OR E No

Cook’s lomatium Lomatium cookii OR E No Gentner’s fritillary Fritillaria gentneri OR E No Golden paintbrush Castilleja levisecta WA T No Kincaid’s lupine Lupinus sulphureus ssp. kincaidii WA, OR T No

Large-flowered woolly

meadowfoam Limnanthes floccosa ssp. grandiflora OR E No

MacFarlane’s four-o’clock Mirabilis macfarlanei ID, OR T No

Nelson’s checkermallow Sidalcea nelsoniana WA, OR T No Rough popcornflower Plagiobothrys hirtus OR E No Showy stickseed Hackelia venusta WA E No Spalding’s catchfly Silene spaldingii ID, WA, OR T No

Ute ladies’tresses Spiranthes diluvialis ID, WA T No

Water howellia Howellia aquatilis ID, WA, OR T No

Wenatchee Mountains

checkermallow Sidalcea oregana var. calva WA E Yes

Western lily Lillium occidentale OR E No Willamette daisy Erigeron decumbens var. decumbens OR E No

Certain birds have been discussed previously in this BA because of the possibility of being struck by trucks or trains carrying baled GRG. However, APHIS has determined that the proposed action will have no effect on the following birds (table 4) or the critical habitat of the marbled murrelet because they would not occur in areas where they could be struck by trucks or trains carrying GRG.Table 4. Listed Birds in Washington, Oregon, and Idaho not mentioned previously in this document.

82 Common Name Scientific Name State of

Occurrence Listing Status Critical

Habitat? Brown pelican Pelecanus

occidentalis WA, OR E No

Eskimo curlew Numenius borealis ID, OR E (likely extinct) No

Marbled murrelet Brachyramphus

marmoratus WA, OR T Yes

Northern spotted owl Strix occidentalis

caurina WA, OR T Yes

Short-tailed albatross Phoebastria albatrus WA E No

Fish species occurring in the mainstem Columbia River have been discussed previously in this document as potentially being affected by decreased water quality from oil/fuel spillage or GRG bales dropped and broken in the Columbia River at the barge unloading point. However, APHIS has determined that there will be no effect on the following aquatic species or their critical habitat (table 5) because they do not occur in the mainstem Columbia River where GRG bales would be barged.83 Table 5 Listed aquatic species in Washington, Oregon, and Idaho but not occurring in the

Columbia River.

Common Name Scientific Name State of

Occurrence Listing Status Critical

Habitat? Banbury Springs limpet Lanx sp. ID E No Bliss Rapids snail Taylorconcha serpenticola ID T No

Borax Lake chub Gila boraxobius OR E Yes Bruneau hot springsnail Pyrgulopsis

bruneauensis ID E No

Foskett speckled dace Rhinichthys osculus

ssp. OR T No

Hood Canal summer-run

chum salmon Oncorhynchus keta WA T Yes

Hutton tui chub Gila bicolor ssp. OR T No

Lahontan cutthroat trout Oncorhynchus clarki

henshawi OR T No

Lost River sucker Delistes luxatus OR E No Oregon coast Coho

salmon Oncorhynchus kisutch OR T Yes

Oregon chub Oregonichthys

crameri OR E No

Ozette Lake sockeye

salmon Oncorhynchus nerka WA T Yes

Puget Sound chinook

salmon Oncorhynchus tshawytscha WA T Yes

Shortnose sucker Chamistes brevirostris OR E No Snake River physa snail Physa natricina ID E No

Utah valvata snail Valvata utahensis ID E No Vernal pool fairy shrimp Branchinecta lynchi OR T Yes

Warner sucker Catostomus

warnerensis OR T Yes

White sturgeon, Kootenai River system Acipenser

transmontanus ID E Yes

APHIS has determined that there would be no direct effects on the listed butterflies from the proposed action (table 6). In addition there w ould be no indirect effects caused by plant pests escaping and establishing in the environment to attack host plants of these species. Therefore APHIS has determined that the proposed action would have no effect on the Oregon silverspot and Fender’s blue butterflies or the critical habitat of the Oregon silverspot.84 Table 6. Listed butterfly species occurring in Washington and Oregon (none are listed in Idaho).

Common Name Scientific Name State of

Occurrence Listing Status Critical

Habitat? Fender’s blue butterfly Icaricia icarioides fenderi OR E No

Oregon silverspot butterfly Speyeria zerene hippolyta WA, OR T Yes85 

## Appendix A. Compliance Agreements

1. Example Compliance Agreement for Movement of GRG Bales From

Hawaii

UNITED STATES DEPARTMENT OF AGRICULTURE
ANIMAL AND PLANT HEALTH INSPECTION SERVICE
PLANT PROTECTION AND QUARANTINE

COMPLIANCE AGREEMENT According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid OMB control
number. The valid OMB control number for this information collection is 0579- 0054. The time required to complete this information collection is estimated to average 1.25 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.

1. NAME AND ADDRESS OF PERSON OR FIRM Hawaiian Waste Systems, LLC

91-165 Kalaeloa Boulevard Kapolei, HI 96810 2. LOCATION

Kapolei, HI

3. REGULATED ARTICLE(S) Garbage and Regulated (domestic) Garbage from Honolulu, Hawaii

4. APPLICABLE FEDERAL QUARANT INE(S) OR REGULATIONS 7 CFR 330.400, 7 CFR 318.13, 7 CFR 318.47, 7 CFR 318.30, 7 CFR 318.60, 9 CFR 94.5 ,

5. PORTS OF COVERAGE: Honolulu, Hawaii Areas (Covered by) USDA OFFICES IN: Honolulu.

6. I/We agree to the following:

General

This Compliance Agreement (CA) on Garbage and Regulated (domestic) Garbage Handling Procedures authorizes Hawaii Waste Systems, LLC (HWS) and its authorized representatives to handle and transport Garbage and Regulated ( domestic) Garbage from Honolulu, Hawaii to the Roosevelt Regional Landfill, Washington, in accord ance with the provisions of the applicable Federal Quarantines and the Administrator’s a pproval and under the following conditions approved by the United States Department of Agriculture, Animal Plant Health Inspection Service, Plant Protection and Quarantine (USDA, APHIS, PPQ). Specifically, this Compliance Agreement applies to the baling, wrapping, and handling of Garbage a nd Regulated (domestic) Garbage from the city and county of Honolulu, Hawaii. The bales are to be free of all agricultural waste and wrapped according to APHIS regulations. The bales are to be transported from Honolulu by barge to Roosevelt, Washington, and then buried without breaking and spreading waste in accordance with the regulations for solid waste disposal and all app licable Federal, State, and Local ordinances. All Foreign Garbage, not of Hawaii origin, is sp ecifically prohibited from movement under this compliance agreement.

DEFINITIONS Terms found in the agreement shall refer to the following:86 Agricultural waste - Byproducts generated by the rearing of animals and the production and harvest of crops or trees. Animal waste, a large component of agricultural waste, includes (e.g.) feed waste, bedding and litter, and feedlot and paddock runoff from livestock, dairy, and other animal-related agricultural and farming practices.

Bale means the confined unit of Garbage and Regulated (domestic) Garbage that has been approved for transport and burial. Bales are formed meeting all APHIS requirements in 7CFR330.

Barge means the conveyance via ocean and the Columbia River on which the baled Garbage and Regulated (domestic) Garbage will be carried.

Collections of agricultural waste and yard wast e refers to bulk collections/pick-up of waste which is made up of primarily agricultural waste and yard waste. All collections of agricultural and yard waste shall not be accepted.

Commingling means the mixing of any regulated and non-regulated materials (including incinerated ash) within the bales, at any staging or transport area.

Company Name – Hawaiian Waste Systems, LLC; (HWS)

Compression refers to the process in which the waste articles are crushed under high pressure, expelling air from, and compacting waste articles into a high density bale.

Foreign garbage means all materials, associated with fruits, vegetables, meats or animal products, that have been removed (in Hawaii) from any means of conveyance originating from a port outside the continental United States (including Alaska) or Canada, which has not been treated in accordance with 7 CFR part 330 for foreign pests and animal diseases. The disposal method described in this compliance agreement has not been

evaluated for the risk of animal diseases.

Garbage is defined as urban (commercial and residential) solid waste from municipalities on any Hawaiian island.

HWS refers to Hawaiian Waste Systems, LLC , 91-165 Kalaeloa Boulevard, Kapolei, HI 96707. It is the location of the HWS Transfer Station operated by HWS

Inspector A properly identified employee of the USDA or other person authorized by the USDA to enforce the provisions of the Plant Protection Act and related legislation, quarantines, and regulations.

Offloading means to move bales from the means of conveyance to its final destination spot; the bales will not be placed on any other means of conveyance.

Patch is made of impermeable film made of low density polyethylene, of at least 16 micrometers thickness, that is coated on one side with a non-hardening mastic/adhesive.87 The patch must be sufficient to establish an airtight seal.

Plant pest means any living stage of any insects, mites, nematodes, slugs, snails, protozoa, or other invertebrate animals, bacteria, fungi, other parasitic plants or reproductive parts thereof, viruses, noxious weeds, or any organisms similar to or allied with any of the foregoing, or any infectious substances which can directly or indirectly injure or cause disease or damage in any plants or parts thereof, or any processed, manufactured, or other products of plants.

PPQ Hawaii means the local office of the United States Department of Agriculture, Animal Plant Health Inspection Service, Plant Protection and Quarantine (USDA, APHIS, PPQ), Port of Honolulu located at 3375 Koapaka Street, Honolulu, HI 96819, phone number, (808) 861-8446 and fax, (808) 861-8450.

PPQ Washington means an office of the USDA, APHIS, PPQ in Washington State; located at 222 N. Habana Street, Spokane, WA 99202, phone number, (509)353-2950 and fax, (509)353-2637.

Puncture - any hole which is found in the plastic of the bale which goes through all four layers of the wrapping.

Regulated Garbage refers to waste articles generated in Hawaii that are restricted from movement to the continental U.S. under various quarantine regulations established to prevent the spread of plant pests (including insects, disease, and weeds) into areas where the pests are not prevalent.

Roosevelt Regional Landfill refers to the landfill site located at 500 Roosevelt Grade Road, Roosevelt, Washington.

Rupture refers to a rupture or tear in the wrapping film where an observer or inspector is able to see Garbage and Regulated (domestic) Garbage that is no longer covered by film.

Shredding refers to the process used to reduce bulky articles into scraps.

Soil means the loose surface material of the earth in which plants grow, in most cases consisting of disintegrated rock with an admixture of organic material and soluble salts.

Staging Area refers to the defined area where bales with apparent air tight seals are held and monitored to ensure air tight integrity. The Staging Area is located at Barber’s Point, Pier 5 at Barber’s Point Deep Water Harbor located in Campbell Industrial Park, Kapolei, HI. Barber’s Point shall be the site of the secondary Wrapping Area, the Storage Area, the Transport Area and the barge loading site (unless APHIS-approved alternative site is designated). Attached hereto is a site map illustration the location of Barber’s Point and the operational sites as described herein.

Tear - any rupture found in the plastic of the bales which goes through all four layers of88 wrapping.

Transloading means the movement of regulated articles from one means of conveyance to any other means of conveyance.

Transport Area refers to the location where bales approved for movement onto the barge are positioned for loading. The transport area is located at Barber’s Point, Pier 5 at Barber’s Point Deep Water Harbor located in Campbell Industrial Park, Kapolei, HI.

Washington compliance agreement refers to the agreement between PPQ Washington and Hawaiian Waste Systems, LLC, 1011 SW Klickitat Way #C-109, Seattle, WA

98134.

Wrapping - The wrapping material shall be an impermeable film made of low densitypolyethylene, of at least 16 micrometers thickness, that is coated on one side with a nonhardening mastic/adhesive. Bales are mechanically wrapped to achieve an air tight seals.

Wrapping Area refers to the station where the bale wrapping machinery is located. The wrapping equipment should be located at each point where bales are handled. The two wrapping areas identified for this compliance agreement are: The initial wrapping area

shall be located at HWS Transfer Stati on at 91-165 Kalaeloa Blvd., Kapolei, Oahu; and a wrapping area will be located at Barber’s Point, Pier 5 at Barber’s Point Deep Water Harbor located in Campbell Industrial Park, Kapolei, HI. The HWS Transfer Station is located approximately [2.5] miles from the Barb er’s Point Pier facility. Attached hereto is a map showing the relative locations of the two facilities and the proposed trucking

route.

Yard waste – Solid waste composed predominantly of grass clippings, leaves, twigs, branches, and other garden refuse.

Collection of Garbage and Regulated (domestic) Garbage for transport Garbage and Regulated (domestic) Garbage collected by refuse trucks shall be delivered to the HWS facility at HWS Transfer Station at 91- 165 Kalaeloa Blvd., Kapolei, HI 96707. Trucks of agricultural waste and yard waste shall not be accepted. Waste materials, containers, and bins associated with Foreign Garbage are strictly prohibited and shall not be accepted. The ground surface of the all areas for handling the Garbage and Regulated (domestic) Garbage should be level, solid, and impervious surface of asphalt or cement.

The risk assessments for the movement of Garbage and Regulated (Domestic) Garbage were conducted based on the specific details provided by HWS. These details included the exclusion of incinerator ash and the removal of all hazardous and liquid waste prior to baling. HWS will notify PPQ if the company plans change to include such materials so that the proper risk

assessments can be conducted.

Preparation and Baling of Garbage and Regulated (domestic) Garbage for transport89 The following is a description of the Garbage and Regulated (domestic) Garbage waste handling and processing steps:

The waste transfer station will receive only household and commercial waste acceptable for disposal at Roosevelt Regional Landfill. Collection trucks will deliver waste picked up from existing collection routes. After waste is tipped onto the tipping floor it will be inspected for unacceptable waste including yard waste, (other than incidental amounts not to exceed 3% of the total waste stream pursuant to 7 CFR Part 330), agricultural waste, industrial waste, infectious waste, loads predominantly of construction and demolition waste and regulated hazardous waste. Any segregated unacceptable waste will be separated for further processing. Loads consisting predominately of construction and demolition (C&D) waste will be transferred to a C&D handling facility. Other waste will be drummed or otherwise contained and arrangements made for its proper transportation and disposal. Notwithstanding the foregoing, it is acknowledged and agreed that follow-up inspection of the route that was the source of the unacceptable waste will be conducted to try to locate the source and correct the waste handling process that allowed unacceptable waste to be collected.

Each load of waste received at the facility will be weighed and the date, time, company, driver name, truck number (i.e., company fleet number), wei ght (loaded), weight (empty), and origin of load, will be recorded. Records will be kept for a minimum of three years.

Step-by-step waste receiving and processing description is as follows:

1. Waste is delivered by collection truck to the HWS Transfer Station. The truck is weighed and then proceeds to the baling facility where it tips its waste onto the tipping floor. The collection truck is weighed again as it exits the site and continues on its collection routes. A weigh ticket is generated and kept on file.

2. A loader operator inspects the waste and segregates any non-household or noncommercial waste. Household and commercial waste is pushed onto the in-feed conveyor by the loader. Segregated waste is set aside and handled separately as described previously.

3. Garbage and Regulated (domestic) Garbage moves along the conveyor to the intake feed of the baler. The baler operator introduces waste into the baler where it is compressed using a compactor that produces bale densities of approximately 1000 kg per cubic meter for the most waste materials. The same force compaction will be used regardless of the material in the processing line. Companies will provide documentation of the equipment used and compactor specifications. The baler operator monitors the baler operation and replaces baling wire or strapping and makes other adjustments as needed.

4. The compacted bale moves from the baler via conveyor belt to the plastic wrapper. Theplastic wrapper automatically wraps the bale with a minimum of 4 layers of prestretched, mastic-backed polyethylene plastic, of at least 16 micrometers thickness, and extrudes it onto a roller conveyor. The baler operator or loader operator will inspect eachbale for integrity of the plastic wrap. Any bale with unsatisfactory wrapping will be resent through the wrapper.

5. The wrapped bale moves down the roller conveyor and is removed by a loader with a special attachment that picks up the bale by squeezing it between two hydraulically90 operated smooth faced arms, or another piece of equipment designed to handle the bales without tearing or damaging them in any way. The smooth faced arms prevent damage to the plastic wrap.

6. The loader moves the bale onto the bale storage area - which has a solid, impervious (concrete or asphalt) surface that is kept free of soil or other contaminants -- or directly onto a flat bed truck, if one is available. The loader then returns to pick up another bale from the roller conveyor.

7. Bales that are placed onto the bale storage area will be loaded onto flat bed trucks as they

become available.

8. Flat bed trucks will haul the bale to Barber’s Point where they will be unloaded and stacked in the Staging Area. The same type of loader attachment (or equivalent equipment) will be used for unloading to prevent damage to the plastic wrap. The loader operator will inspect each bale for damage to the plastic wrap. If damage is found it will be returned to a wrapping area for rewrapping.

9. Bales cannot be loaded onto the barge until they have been staged for at least five days. After five days, the bales are considered ready for transport and the area will be designated the Transport Area. HWS will maintain a clear separation between those bales ready for transport and those bales in the staging process.

10. Bales at the Barbers Point Harbor facility will be stored until a barge is ready to be loaded. Barge loading will occur approximately monthly. When a barge is ready for loading, the bales in the Transport Area will be transferred onto the barge, again using squeeze-arm hydraulic equipment or other comparable, appropriate lifting equipment to prevent damage to the plastic wrap. The loading supervisor will inspect each bale once the bale is loaded onto the barge. Any damaged bale will be returned to the Transfer Station for rewrapping and restaging or be re wrapped and restaged on site at Barber’s

Point.

11. When the barge is fully loaded it will proceed to its destination at the Roosevelt Regional Landfill in Washington State.

The compression settings on the baler shall be 1,000 kg per per cubic meter or more.

Records indicating the size and weight of each bale shall be maintained.

Garbage and Regulated (domestic) Garbage which has fallen apart from an unwrapped compressed bale, or has been otherwise improperly compressed, shall be set aside for a subsequent compression cycle.

The unwrapped, compressed bales shall be bound with plastic or metal clamps, netting, or strapping devices to retain its shape.

Compressed bales that do not hold together shall be rejected and set aside for a subsequent compression cycle. Records of re-compressed bales shall be maintained by HWS and available for monitoring by PPQ.

Each compressed bale will be wrapped by HWS using a process approved by USDA, APHIS.91 The wrapping process will follow the compliance agreement guidelines as outlined below:

The compressed bale shall be physically isolated by an air tight barrier. The air tight barrier shall be built with multiple layers of highly tensile, impermeable film (made of low density polyethylene wrap, of at least 16 micrometers thickness, coated on one side with a non-hardening mastic/adhesive), covering all surfaces of the bale, and completely isolating the internal contents.

To ensure a strong air tight barrier, a minimum four layers of wrap shall be used to

isolate each bale.

Machinery that repeatedly achieves the criteria required shall be used.

Machinery used for wrapping shall be programmed to dispense a standard amount (length) of polyethylene wrap, in each wrap cycle. The length of the wrap programmed into each cycle, shall be in excess of the amount needed to provide four layers of wrap around a bale of maximum handling size and meet the wrapping specifications as listed in the definitions of this compliance agreement.

HWS will examine each wrapped bale to ensure the air tight integrity and proper wrapping. Any bales that are punctured, ruptured, or torn will be re-wrapped by HWS.

HWS will ensure that all wrapped bales will not contact surfaces contaminated by Garbage and Regulated (domestic) Garbage or soil. Any bales which come in contact with contaminated surfaces will be either re-wrapped or cleaned, and removed of any outside debris.

Maintaining records of bales produced

HWS must maintain a log which records bale identification, date of baling, inspections done, any remedial measures (e.g., patches, rewrapping). A manifest for each bale produced shall be maintained by HWS for statistical and tracking purposes. Information recorded shall include :

Bale identification number

Date wrapped

Weight of bale

Size of bale

Records of ruptures, punctures or tears to include the date, name of inspecting personnel, action taken and names of personnel completing action

Dates of entry into the staging, transport, and barge controlled areas and the name of personnel responsible for inspecting and authorizing movement of the bale into92 those areas

Barge information (name and voyage #)

Date of departure (Honolulu)

Date of arrival (Washington)

Inspection reports of the condition of the bale upon arrival its arrival at the Roosevelt Regional Landfill in WA and any subsequent patching or re-wrapping required.

The records must be maintained and be available upon request by USDA-APHIS-PPQ. To ensure compliance, PPQ officers will be permitted access to the firm’s premises and relevant records without prior appointment. Records will be kept for a minimum of 3 years from the date the bale is shipped to the continental U.S.

Marking and Identification of Bales

The bales must be permanently marked with the words “REGULATED GARBAGE,” printed in a contrasting color to the wrap. The size of the letters shall be 3 inches in height and easily visible and legible.

Manifest and tracking identification numbers required on each bale include the Bale Identification Number, the Date Wrapped, and the Date Placed in Staging Area. These marking must be in a contrasting color to both the wrap and the words “REGULATED GARBAGE.”

Markings on all bales must be viewable without moving the bales or climbing on top bales by the USDA APHIS PPQ inspector and/or designated c ooperators. If markings are not viewable as stated above, a HWS operator will need to move the bales for viewing.

Movement to the Designated Staging Area

Bales approved for movement to the staging area shall be trucked by HWS or its authorized representative to the designated Staging Area.

Bales shall be moved using machinery best designed for holding, lifting and supporting its load with minimum or no breakage.

Bales shall be inspected upon placement onto the truck. Trained HWS personnel shall ensure that punctured, ruptured, or torn bales and bales that are externally contaminated by garbage or

soil are not forwarded.93 Bales that are punctured, ruptured, or torn while being loaded onto the truck shall be removed from the truck and re-wrapped. The date of re-wrapping shall be indicated in the bale manifest as specified under “Marking and Identification of Bales.”

Bales that have been rewrapped shall be returned to the staging area for a minimum of 5 days. The date of placement in the Staging Area shall be indicated on the bale manifest.

Staging Area Operation Requirements

A wrapping machine which meets all approved wrapping technology shall be located at the HWS Transfer Station within [2.5] miles of Barbe r’s Point. If wrapping machinery is located at the Staging area, HWS will ensure that the wrapping machinery located at the Staging Area shall be programmed to dispense a standard amount (lengt h) of polyethylene wrap in each cycle. The length of the wrap programmed into each cycle shall be in excess of the amount needed to provide four layers of wrap around a bale of maximum handling size.

HWS will ensure that the Staging Area be kept clean and free of loose garbage and soil. The Staging Area shall be clearly marked and physically separated from the Transport Area. Operational procedures pertinent to the Staging and Transport areas shall be posted in a location visible to all HWS personnel and authorized representatives.

HWS shall develop and enforce plans for pest exclusion and eradication programs to control pests that may be attracted to the bales in the staging and loading area (i.e. rodents, birds, mollusks, etc.) These plans shall be submitted for approval by USDA, APHIS, PPQ in Honolulu,

Hawaii.

Movement into the Staging Area

Bales with air tight integrity shall be forwarded to the staging area. The date of placement into the staging area shall be indicated in the bale manifest.

The bales shall be off loaded from the truck using machinery best designed for holding, lifting and supporting its load with minimum or no breakage.

Bales shall be inspected for punctures, ruptures and tears and external contaminants (i.e. garbage, soil or mollusks). Records of dates a nd identification of the personnel responsible for the inspection shall be indicated in the bale manifest.

Bales shall be grouped together by their projected lapse date in the staging area. Physical separations shall be used to differentiate these groups and signage indicating such separation shall be posted in a position visible to all personnel.

Bales shall be retained in the staging area for a minimum of 5 days.

Bales that have been punctured, ruptured, or torn enroute to the (staging area) site shall be94 marked with colored tape and set aside for re-wrapping and returned to a wrapping area. The date of re-wrapping shall be indicated in the bale manifest and on the outside of the bale as indicated in the “Marking and Identification” section of this agreement.

Bales that have been rewrapped shall be returned to the staging area for a minimum of 5 days. The date of placement in the Staging Area shall be indicated on the bale manifest.

After the minimum 5 day hold, bales shall be inspected for punctures, ruptures and tears and external contaminants. Date and identification of personnel responsible for inspection shall be

indicated in the bale manifest.

Transport Area Operation Requirements

HSW will ensure that the Transport Area be kept clean and free of loose Garbage and Regulated (domestic) Garbage and soil. The Transport Area shall be clearly marked and physically separated from the Staging Area. Operational pr ocedures pertinent to the Staging and Transport areas shall be posted in a location visible to all HWS personnel and authorized representatives.

HSW shall develop and enforce plans for pest exclusion and eradication programs to control pests that may be attracted to the bales in the staging and loading area (i.e. rodents, birds, mollusks, etc.) These plans shall be submitted for approval by USDA, APHIS, PPQ in Honolulu,

Hawaii.

Movement into the Transport Area

Bales with air tight integrity are allowed movement to the designated transport area. Date and identification of personnel responsible for authorization of the movement shall be indicated in

the bale manifest.

Any movement of bales shall be forwarded with machinery best designed for holding, lifting and supporting its load with minimum or no breakage.

Bales moved to the transport area, shall be inspected for punctures, ruptures, and tears upon placement. Date of placement in the transpor t area and the identification of the personnel responsible for the inspection shall be indicated in the bale manifest.

HWS will manage the placement of bales, such that the handling of bales will be minimized. HWS will track bales placement and date, such that all bales completing the 5-day staging requirement prior to a scheduled barge loading are maintained in a readily identified area. These bales shall be separated from bales that will not meet the 5-day staging requirement by the scheduled barge loading date. In this manner, the bales are not physically moved from the Staging Area to the Transport Area, but rather the bales achieving the minimum 5-day staging criteria are then designated to be within the Transport Area. The date of designation and the person authorizing the designation shall be indicated in the bale manifest

For example, if the barge is scheduled for loading beginning on August 1 st , then only those bales95 staged on or before July 26 th will be eligible for loading. HWS will maintain physically separate areas for those bales stacked on or before July 26 th from those stacked on July 27 th or after. The bales in the area stacked on or before July 26 th will have transitioned into the Transport Area and are eligible for loading onto the barge. The bales stacked on July 27 th or after will be eligible for loading onto the next barge arriving in approximately one month.

Bales found punctured, ruptured, or torn shall be immediately marked with colored tape and removed from the transport area for rewrapping.

Bales with contaminants on the outside of the bale (e.g. soil, debris, pests, etc) shall be immediately cleaned or removed from the transport area.

Re-wrapped bales shall be moved back into the staging area for a minimum 5 day holding period. The date of re-wrapping and placement into the Staging area shall be indicated in the bale manifest and on the outside of the bale as indicated in the “Marking and Identification” section of this agreement.

Bales held for more than 75 days shall be re-wrapped. The date of re-wrapping and placement into the Staging area shall be indicated in the bale manifest and on the outside of the bale as indicated in the “Markings and Identification” section of this agreement.

Bales in the transport area which have met the requirements for the transport to the mainland are authorized for movement onto the barge and shall be forwarded by machinery best designed for holding, lifting and supporting its load with minimum or no breakage.

The bales must be permanently marked as specified in the “Markings and Identification” section on this agreement.

Markings on all bales must be viewable without moving the bales or climbing on top bales by the USDA APHIS PPQ inspector and/or designated c ooperators. If markings are not viewable as stated above, a HWS operator will need to move the bales for viewing.

Movement onto the Barge

HWS personnel or their authorized representative shall conduct a full inspection of each bale upon placement onto the barge. Bales shall be inspected for any punctures, ruptures, or tears and external contaminants (i.e. soil, garbage, mollusks) upon placement onto the barge. The date and identification of the personnel responsible for the inspection and authorization for forward

movement shall be indicated in the bale manifest.

Barge information (Name and Voyage no.) and Date of departure from Honolulu shall be

indicated on the bale manifest.

Any bale found punctured, ruptured, or torn before the barge leaves the port shall beimmediately marked with colored tape and removed from the barge for re-wrapping. Rewrapped bales shall be moved back into the staging area for a minimum 5 day holding period.96 The date of re-wrapping and placement into the Staging area shall be indicated in the bale

manifest and on the outside of the bale as indi cated in the “Marking and Identification” section of this agreement.

Any other material (regulated or non-regulated, such as non-rolling equipment, empty containers, and non-regulated recyclables) placed on the same barge as the bales of Garbage and Regulated (domestic) Garbage must be secured to the barge in such a manner that they will not move or come in contact with the wrapped bales. Any other material placed on the same barge must be separated from the bales of Garbage and Regulated (domestic) Garbage approved for movement under this compliance agreement and must be easily distinguishable from the bales of Garbage and Regulated (domestic) Garbage approved for movement under this compliance

agreement.

CLEANUP PROCEDURES FOR GARBAGE AND REGULATED (DOMESTIC) GARBAGE SPILLS AND EQUIPMENT

HWS must provide personnel and appropriate measures to control the Garbage and Regulated (domestic) Garbage in the event of a spill or other emergency. HWS will follow the clean-up protocols specified for spills as outlined in Appendix 1 of this compliance agreement. Any changes to these protocols must be review ed and approved by USDA, APHIS, PPQ, and all appropriate Federal, State and Local regulations.

A contingency plan should be in place to handle any spills or breakage during any part of the voyage, transloading, offloading, and/or transporta tion of the bales. All company employees, designees, drivers, and handlers of the baled Garbage and Regulated (domestic) Garbage shall be informed of the contingency plan.

APPENDIX 1 clean up protocols will be followed. APPENDIX 1 is attached to this

document.

If spillage occurs during transport, USDA, APHIS, PPQ must be notified immediately. See list of contact numbers provided below:

Contact Numbers

Compliance Officer Honolulu, HI 808-861-8446 Supervisory Compliance Officer Honolulu, HI 808-861-8465

For after hour, seven days a week Operations Desk Honolulu, HI 808-861-8490

PPQ CLEARANCE IN HONOLULU

USDA, APHIS, PPQ in Honolulu, Hawaii shall be notified by facsimile 48 hours in advance of97 the departure date for each shipment of baled Garbage and Regulated (domestic) Garbage destined to Washington. The notification shall include:

Barge name and Voyage no.

Date of departure from Honolulu

First U.S. mainland port of entry

Estimated date of arrival at the first U.S. mainland port of entry

Name and phone number of the contact personnel responsible for the shipment.

A list of the identification numbers for all bales included in the shipment.

HWS personnel are responsible for notifying PPQ by facsimile 48 hours in advance of the barge departure. PPQ may schedule or conduct a compliance inspection prior to departure of the barge.

Movement of the bales of Garbage and Regulated (domestic) Garbage is authorized only to the state of Washington through the Roosevelt Seaport. The tug/barge shall not be diverted to any other seaport.

Bales must remain on the same barge from the port of Honolulu to the authorized port. Transloading to any other barge or means of conveyance prior to arrival at the authorized U.S. mainland port of entry is prohibited.

Before leaving Hawaii, all bales must be well secured on the barge and within the railing to prevent falling during the voyage.

TRAINING

HWS shall present a training program to employees before they are permitted to handle and transport or supervise the handling and transport of Garbage and Regulated (domestic) Garbage. This training program should be at least one (1 ) hour in duration. Previously trained employees shall be provided review training annually. A reco rd of employees and their training dates shall be maintained and available for PPQ review.

The training package must be approved by the local PPQ officer in charge, and may include both formal classroom training and on-the-job trai ning. It must contain the following topics:

Procedures for maintaining control of Garbage and Regulated (domestic) Garbage

Define “Garbage” and “Regulated (domestic) Garbage” and “Foreign Garbage”98 Explain the regulation and its purpose.

Explain the compliance agreement and its purpose.

Include film, slides, or other training aids on Hawaiian soil, plant diseases and

pests

Specifically outline, by demonstration, illustration, or picture, proper regulated garbage handling procedures and transport

Explain the manifesting process

Be presented in English and other appropriate languages.

Procedures for reporting and data; procedures and reporting results of inspection of bales

Procedures for cleaning and disinfecting contaminated equipment and areas.

Records of training administered to employees shall be made available to PPQ personnel upon

request.

RECORDS AND MONITORING (INSPECTIONS)

HWS must maintain a log which records all information as specified in the “Maintaining records of bales produced” section of this compliance agr eement. This includes bale identification, date of baling, inspections completed and any remedial measures performed (e.g., patches, rewrapping).

These records must be kept for a minimum of 3 years from the date that the bale was shipped to

the continental U.S.

To ensure compliance, USDA, APHIS, PPQ personnel shall be allowed to monitor operations during normal business hours without prior notification. HWS shall ensure a safe location is available for the inspector to conduct all aspects of the inspection. Safe viewing areas will be established as approved by PPQ Hawaii. This may be a stanchioned area near, but not directly in the path of the barge loading operators. The handling equipment shall allow tilting of the bale or offer some other method of inspection for the bottom of the bale without requiring the PPQ inspector to stand underneath or within the drop line of a machine-held bale.

Inspectors shall be allowed to safely view any unwrapped bales at the time of inspection.

The compression process and the scale station and readouts shall be visible to the inspector from

a safe location.

The wrapping procedure and wrapping readouts s howing calibration shall be visible to the inspector from a safe location.

Records of all bales shall be maintained and made available to inspectors during business hours.

ENVIRONMENTAL PROTECTION AND OTHER REGULATORY AGENCIES99 By signing this agreement, the signer certifies that his/her facility has met or will meet the requirements of all applicable environmental and any other applicable regulatory authorities in addition to the Garbage and Regulated (domestic) Garbage handling regulated by the Animal and Plant Health Inspection Service.

ENDANGERED SPECIES ACT COMPLIANCE

For the barging of Garbage and Regulated (domestic) Garbage bales from Honolulu, Hawaii to the continental United States (mouth of the Columbia River), the following protection measures will be adhered to for the Steller sea-lion and Humpback whale. This is required for compliance with the Endangered Species Act:

Steller sea-lion No barge will approach within 3 nautical miles of the steller sea lion rookeries in Oregon (Rogue Reef: Pyramid Rock and Orford Reef: Long Br own Rock and Seal Rock) and California (Ano Nuevo l., Southeast Farallon 1., Sugarloaf l. and Cape Mendocino).

Humpback whale Within 200 nautical miles of the Hawaiian Islands, the barge will not approach or cause an object to approach within 100 yards of any humpb ack whale and the speed of the vessel will not

exceed 13 knots.

NOTIFICATION

PPQ shall be notified within 7 days of any change in business status, business operations, telephone number, business address, management, ownership or business dissolution.

COMPLIANCE

This compliance agreement is only valid in conjunction with a valid Washington compliance agreement issued to HWS, for handling Garbage and Regulated (domestic) Garbage from Hawaii destined to the Roosevelt Regional Landfill.

This compliance agreement is nontransferable. If the person identified in section 7 of PPQ Form 519 leaves their present employer, HWS or position, then he/she must notify the local PPQ office immediately. This agreement will then be terminated.

If Garbage and Regulated (domestic) Garbage is handled by other personnel within the HWS, those persons must be under the permittee’s supervision and must be aware of and able to adhere to all stipulations in this agreement.

This compliance agreement may be amended as necessary by USDA, APHIS, PPQ. HWS will

be notified of all amendments.100 NOTE: “Any person who knowingly violates the Pl ant Protection Act (PPA) (7 U.S.C. §§ 7701 et. Seq.) And/or the Animal Health Protection Act (AHPA) (7 U.S.C. §§ 8301 et. Seq.) may be criminally prosecuted and found guilty of a misdemeanor which can result in penalties, and one year prison term, or both. Additionally, any pers on violating the PPA and/or the AHPA may be assessed civil penalties of up to $250,000 per violation or twice the gross gain or gross loss for any violation that results in the person deriving pecuniary gain or causing pecuniary loss to another, whichever is greater.”

WITHDRAWAL OF COMPLIANCE AGREEMENT

This compliance agreement may be canceled, by a PPQ Officer orally or in writing, if such officer determines that the holder thereof has not complied with any of the conditions stated in this compliance agreement. If the cancellation is oral, the cancellation and the reasons for the cancellation will be confirmed in writing as promptly as circumstances allow. Any person whosecompliance agreement has been canceled may appeal the decision in writing to USDA- APHISPPQ within ten (10) days after receiving the wr itten notification of the withdrawal. The appeal

must be directed to the State Plant Health Direct or of Hawaii. The appeal must state all of the facts and reasons upon which the person relies to show that the compliance agreement was wrongfully canceled. USDA-APHIS-PPQ shall grant or deny the appeal, in writing, stating the reasons for such decision, as promptly as circumstances allow. If there is a conflict as to any material fact, a hearing shall be held to resolve such conflict. Rules of practice concerning such a hearing will be adopted by USDA-APHIS-PPQ.

Agreement

By signing this agreement, the primary holder of Hawaiian Waste Systems, LLC agrees to maintain the scope and intention of this compliance agreement. The signature further certifies that the listed business has met or will meet the requirements of all other applicable environmental authorities prior to the processing of any USDA regulated garbage.

This agreement may be immediately canceled or revoked for noncompliance.

I have read and understand the conditions of this compliance agreement.

6.Signature

 7. Title 8. Date Signed

The affixing of the signatures below will validate this agreement, which shall remain in effect until canceled, but may be revised as necessary or revoked for noncompliance. 10. Date of Agreement 11. Agreement Number

PPQ OFFICIAL (Name and Title) ADDRESS101 Signature
PPQ FORM 519 (FEB 2002)United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

102 

### APPENDIX 1 - Spill Response Plan for Hawaiian Waste Systems, LLC

HWS Emergency Response Planning

HWS shall, either directly or through its contracted service providers, at all times have emergency response procedures in place at all times while shipment of baled, wrapped Hawaiian waste is occurring.

HWS has contracted with Brusco Tug and Barge (Brusco) for the transport of baled and wrapped MSW from Oahu to the Roosevelt Intermodal Facility. As a marine carrier with over 35 years of tug and barge experience throughout the West coast and Hawaii, Brusco has longstanding internal response plans in place and in addition, Brusco is and shall remain under contract with MSRC Corporation and the Cowlitz County Clean Sweep. A copy of the MSRC contract is attached.

HWS has contracted with Regional Disposal Company (RDC, a wholly owned subsidiary of Allied Waste, Inc.) for the handling, transportation and disposal of the bales, such contract commencing at the Roosevelt Intermodal and includes acceptance of the bales on RDC trucks, transport of the bales to the Landfill, offloading of the bales at the Landfill and disposal of the bales at the Landfill. RDC, with over fifteen years of operational experience and over 30 million tons disposed of to date, has long standing emergency response plans (ERPs) in place. A copy of the standard form RDC ERP, amended to address th e specifics of baled Hawaiian waste handling, is

attached.

In brief, spills will be addressed as follows:

• On Oahu : If a bale ruptures or there is a spill in transit to the barge facility or in loading, such bale and any loose waste shall be loaded into a roll-off container and returned to the Campbell park baling/wrapping facility for re-processing. Any affected spillage site shall be cleaned so as to restore the affected site to its pre-spill state.

• In marine transit : If a bale is dislodged from the barge, Brusco shall report such incident as promptly as practicable and using either Brusco equipment (available for mobilization from its Longview facilities) or contracted equipment shall locate and retrieve such bale as practicable using a crane or other appropriate equipment. If a bale is ruptured as a result of being dislodged from the barge or being recovered, 6-mil hazardous waste bags will be available on the barge, which will be used to contain the ruptured bale in a manner similar to the “burrito” style burst bale protocol as described in the Compliance Agreement. The sealed bag will be delivered to the Roosevelt dock for offloading, transport to and disposal

in the Landfill.

• In Klickitat County : Any bales that significantly rupture or are ‘spilled’ during offloading shall be handled in accordance with the burst bale protocol provided for in the Compliance Agreement. In transit from the Roosevelt Intermodal to the Landfill, any spill shall be handled in accordance with RDC’s existing spill protocols – which entail a promptUnited States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

103 response, clean up of the affected area, and bur ial of the spilled material in the Landfill. Such spill response is laid out in greater detail in the attached RDC ERP.



### WASTE SPILL PROTOCOL ON LAND

REGIONAL DISPOSAL COMPANY (RDC)

EMERGENCY RESPONSE PLAN (ERP)

TRANSPORT OF BALED AND WRAPPED

HAWAIIAN MUNICIPAL SOLID WASTE

FROM THE ROOSEVELT DOCK

TO ROOSEVELT LANDFILL

Prepared by

Regional Disposal Company (RDC)

June 2006104 Table of Contents

1.0 INTRODUCTION AND PURPOSE ....................................... Error! Bookmark not defined. 1.1 Emergency Response Team (ERTeam) Scope..................... Error! Bookmark not defined. 1.2 Objective............................................................................... Error! Bookmark not defined.

2.0 EMERGENCY RESPONSE PROCEDURES AND NOTIFICATION SCHEDULE Error! Bookmark not d e 2.1 ERTeam Duties And Responsibilities .................................. Error! Bookmark not defined.

2.1.1 ERCoordinator ............................................................... Error! Bookmark not defined.

2.1.2 ERLeader........................................................................ Error! Bookmark not defined.

2.1.3 ERTeam Members.......................................................... Error! Bookmark not defined. 2.2 Emergency Response Notification ....................................... Error! Bookmark not defined. 2.3 Emergency Response Plan.................................................... Error! Bookmark not defined.

2.3.1 Criteria and Circumstances for Implementing ERP....... Error! Bookmark not defined. 2.3.2 Types of Emergencies and Actions Required ................ Error! Bookmark not defined. 2.3.3 Response to All Other Emergencies .............................. Error! Bookmark not defined. 2.4 Transportation Procedures.................................................... Error! Bookmark not defined.

2.5 Public Relations.................................................................... Error! Bookmark not defined. 2.6 Post-Emergency Critique...................................................... Error! Bookmark not defined.

3.0 Appendices 3.1 Call Report 3.2 Emergency Response Report 3.3 Broken Bale Remediation and Cleanup Protocol 3.4 Emergency Response Directory 3.5 Required Equipment Inventory 3.6 Emergency Response Team (ERTeam) Contacts

List of Tables

Table 1 Emergency Response

FOR 24-HOUR EMERGENCY RESPONSE CALL

Primary Number: (800) 275-5641

or Secondary Number: (206) 332-7700United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 105 

## 1.0 INTRODUCTION AND PURPOSE

The purpose of the Emergency Response Plan (ERP ) is to outline emergency response procedures

and establish a notification schedule for re sponding to emergencies involving the handling, transport, and disposal of Baled and Wrappe d Municipal Solid Waste from Hawaii (“Hawaiian Waste”) by the Regional Disposal Company (RDC). The primary facilities for handling, transport, and disposal of waste include the dock facility at the Roosevelt Intermodal (“Dock”) and the Roosevelt Regional Landfill. RDC will transport the waste from the Dock to the Roosevelt Regional

Landfill.



## 1.1 Emergency Response Team (ERTeam) Scope

The RDC Emergency Response Team (the ERT eam) will respond to any emergency involving Hawaiian Waste from Hawaii, once offloaded from ma rine-based equipment, during its transport to and disposal at the Roosevelt Regional Landfill.



## 1.2 Objective

RDC will maintain a team of emergency response personnel, under the direction of an Emergency Response Coordinator (the ERCoordinator) and Em ergency Response Leader (ERLeader), trained and equipped to respond to any emergency involving Hawaiian Waste en route from the Dock to the Roosevelt Regional Landfill.



## 2.0 EMERGENCY RESPONSE PROCEDURES AND

NOTIFICATION SCHEDULE

This section discusses the following: ERTeam duties and responsibilities; emergency response notification procedures; the Emergency Response Pl an (ERP); transportation procedures; public relations; and post-emergency procedures.



## 2.1 ERTeam Duties And Responsibilities

The ERTeam includes an ERCoordinator, ERLeader , and ERTeam Members. In an emergency, the

ERCoordinator will be located at the Roosevelt Re gional Landfill site office, and the ERLeader will assemble the ERTeam Members and accompany them to the scene of the emergency, if an off-site response is necessary. Duties and responsibilities of the ERCoordinator, ERLeader and ERTeamUnited States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 106 Members are described in this section.



### 2.1.1 ERCoordinator

Preparedness

• Maintain written, detailed, up-to-date emergency response procedures • Be experienced and knowledgeable in emergency response procedures, and on-call and

available on a 24-hour basis • Be thoroughly acquainted with the properties and general characteristics of RDC's primary transport and disposal system for Hawaiian Waste

• Maintain list of locations and contacts for outside resources • Keep record of training received by each ERTeam Member • Be prepared to respond to questions from the news media about emergency situations, if

necessary • Serve as ERLeader, if necessary

Response

• Coordinate response planning with ERLeader • Arrange transportation for ERTeam to scene of emergency • Communicate with caller to give additional advice and notify that ERTeam is responding • Contact regulatory agencies, as necessary • Maintain frequent communication with ERTeam at scene • Arrange for additional personnel and supplies at the scene, if necessary • Update RDC contacts regularly on status of emergency • Arrange for relief ERTeam Members, as needed



### 2.1.2 ERLeader

Preparedness

• Maintain emergency equipment in operable condition at all times • Ensure availability of sufficient number of ERTeam Members • Be experienced and knowledgeable in emergency response procedures, and on-call and

available on a 24-hour basis • Participate in exercises at least annually to demonstrate emergency preparedness • Evaluate and update equipment at least yearly • Serve as ERCoordinator, if necessaryUnited States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 107 Response

• Coordinate assembly of ERTeam Members and equipment • Maintain contact with person or official in charge at scene • Consult and work under the direction of the person in charge at scene

• Direct ERTeam in on-site activities • Communicate frequently with ERCoordinator for advice and, if necessary, assistance in obtaining additional equipment • Monitor the health and safety of ERTeam Members • Ensure equipment is cleaned and stored after emergency • Complete post-emergency critique and Emergency Response Report



### 2.1.3 ERTeam Members

Preparedness

• Train and practice on emergency response equipment • Serve as ERLeader, if necessary

Response

• Work under direction of ERLeader at scene • Work in a safe, efficient manner • Ask for help from ERLeader, if necessary



## 2.2 Emergency Response Notification

Because RDC’s handling of Hawaiian Waste will commence after offloading from marine-based equipment, such handling will occur almost excl usively on RDC-controlled property. The exception to this will be transportation on Roosevelt Grad e Road and the crossing of WA SR14. The ERTeam will likely receive notification of an emergency fr om RDC personnel, but may receive notification of an emergency, generally by telephone, from several sources including outside customers or facilities, government agencies, or other interested parties. The person receiving the call (the Contact), who may or may not be a member of the ERTeam, will get as much information as possible from the caller, using the Call Report (contained in Appendi x 3.1) to record the information. The Contact

will transfer the information to the ERCoordina tor, or ERTeam Member on-call (see Figure 1), which will initiate the ERTeam Emergency Response Plan (ERP).United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 108 

## 2.3 Emergency Response Plan

Upon receiving a call from the Contact regarding an emergency call received, the ERCoordinator will determine the type of response that is necessary.



### 2.3.1 Criteria and Circumstances for Implementing ERP

Based on an immediate initial assessment, the ERC oordinator will use his or her best judgment to determine when to initiate the ERP. An emerge ncy poses a threat requiring implementation of the ERP if the emergency has the potential to:

• Expose Hawaiian Waste to the environment a nd thus quarantine risk through a tear or rupture to a waste bale

• Threaten human health or the environment fr om fire and/or explosion, or exposure to Municipal Solid Waste or contaminated water • Contaminate surface water or ground water • Result in significant soil contamination • Result in impacts to fisheries resources or • Disrupt commonly-used transportation routes

If any of these criteria are satisfied, the ERCoordinator will implement the ERP immediately.

Circumstances that have the potential to satisfy one more of the above criteria include:

• Release of solids and/or liquids en route to the Roosevelt Regional Landfill • Release of liquids from the Roosevelt Regional Landfill • Fire and/or explosion en route or at the Roosevelt Regional Landfill • Release of gases en route or at the Roosevelt Regional Landfill • Vehicle accident en route or at the Roosevelt Regional Landfill

Each circumstance is described briefly in Section 2.3.2.



### 2.3.2 Types of Emergencies and Actions Required

Table 1 identifies the types of emergencies that have the potential to occur and the nature of response that will be required. The table also iden tifies who will be responsib le for initial response, who will be responsible for mobilizing for a res ponse, and under what circumstances. Emergency situations rarely involve local agencies. Each type of emergency and the actions that will be required are described in this section. SectionUnited States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 109 2.3.3 describes specific procedures that will be followed in emergencies which will require either minor or full ERTeam response by RDC.

Table 1: EMERGENCY RESPONSE Emergency Situation Responsible for Response Type of Response

Initial Response Mobilization Responsibilit

y Minor

ERTeam Response Full

ERTeam Response

Broken Bale - Release of Solids, Gases, and/or Liquids en Route to

the Roosevelt Regional Landfill. RDC RDC Likely Possible

Fire and/or Explosion en Route

or at the Roosevelt Regional Landfill. RDC RDC Possible Likely

Release of Gases en

Route or at the Roosevelt Regional

Landfill. RDC RDC Possible LikelyUnited States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 110 Table 1: EMERGENCY RESPONSE, CONTINUED Emergency Situation Responsible for Response Type of Response

Initial Response Mobilization Responsibilit

y Minor

ERTeam Response Full

ERTeam Response

Truck Accident en

Route or at the Roosevelt Regional

Landfill. RDC RDC Possible Unlikely

Problem With a

Truck or Chassis During Short Haul. RDC RDC Possible Unlikely

Broken Bale and Potential Release of Solids and/ or Liquids en Route to the Roosevelt Regional

Landfill

In the event of a broken bale and the potential re lease of solids and/or liquids en route to the Roosevelt Regional Landfill, RDC will be respons ible for the initial response which includes determination of the actual response necessary. Response procedures are described in Section 2.3.3

of this ERP.

If solids and/or liquids are released along the tr ansportation route, RDC will be responsible for

response.United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 111 Fire and/or Explosion En Route or at the Roosevelt Regional Landfill

In the event of fire and/or explosion en rout e to the Roosevelt Regional Landfill, RDC will be responsible for the initial respons e and will determine the response necessary. Response procedures

are described in Section 2.3.3 of this ERP.

Release of Gases En Route or at the Roosevelt Regional Landfill

The release of gases en route is extremely unlik ely. Methane gas generation is highly unlikely due to the baling, wrapping and handli ng protocols associated with the Hawaiian Waste prior to its delivery to the Dock. If an ERTeam response is required, the procedures described in Section 2.3.3 of this ERP will be followed, as appropriate.

Truck Accident En Route or at the Roosevelt Regional Landfill

In the event of a truck accident en route or at the Roosevelt Regional Landfill, RDC will be responsible for any required response. The ERC oordinator will be notified as soon as possible by the truck driver. The ERCoordinator will notify the Washington State Patr ol and Washington State Department of Transportation, as appropriate, to de scribe the nature, location, date and time of the accident, and other pertinent information. If th e accident involves a release of Hawaiian Waste, response procedures described in Section 2.3.3 of this ERP will be followed.



### 2.3.3 Response to All Other Emergencies

Emergencies either will require minor response to the scene of the emergency, or full ERTeam response to the scene (see Table 1 in Section 2.3.2). It is anticipated that most emergencies will require minor ERTeam response. Procedures that will be followed for each type of emergency are

discussed in this section.United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 112 Emergencies Requiring Response to the Scene

If a response to the scene of the emergency is n ecessary, the ERCoordinator will determine, to the extent possible, the type of response required. Emergencies either will require minor response, involving one or two ERTeam members, or full ERT eam response. In either case, the ERLeader first will determine how many ERTeam Member s will respond. The ERL eader will notify the ERTeam Members chosen to respond and brief them on the situation.

At the same time, the ERCoordinator, located at RDC's Roosevelt office, will:

• Contact the caller and advise the caller on res ponse measures to take while the ERTeam is traveling to the scene • Gather as much information as possible from the caller to determine personnel and equipment needed for the response • Contact the ERLeader to discuss the type of response necessary and the transportation mode

to be used • Arrange for necessary transportation • Contact, if necessary, government agencies and officials at the scene to notify them of the ERTeam's location and approximate time of arrival • If the response involves air transport, arrange for land transport when the ERTeam arrives.

Upon arriving at the scene, the ERLeader will:

• Contact the individual in charge, or take char ge if he or she is the only response person on

site • Thoroughly evaluate the situation

• Consult with officials at the scene

• Determine what action will be taken

• Communicate the information to the ERCoordina tor, who will then decide if additional

resources are necessary.

If the incident involves a broken bale and/or rel ease of Hawaiian Waste, upon arriving at the scene, the ERLeader, will:

• Identify the character, source, amount, and extent of the release • Assess the direct, indirect, or immediate imp acts to human health and the environment that may result • Direct the ERTeam in containing the release • Initiate remedial action and cleanup (See Appendix 3.3 for Broken Bale Remediation protocol) • Arrange for reloading of the waste • Document the release (i.e., with photogra phs), and complete the Emergency Response Report (see Appendix 3.5).United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 113 Follow-up Actions for All Emergencies Requiring ERTeam Response

After the initial evaluation, the ERLeader will cont act the ERCoordinator w ith updated information on the situation, and request additional personnel or equipment, if necessary. The ERLeader and ERCoordinator will maintain pe riodic communications throughout the incident until the emergency

has been resolved.

The ERTeam will remain at the scene until releas ed by the person in charge. The ERCoordinator will arrange travel for the ERTeam's return to base. The ERCoordinator will contact appropriate government agencies and other interested parties to advise them that the emergency is over.

Refer to Section 2.6 of this ERP for a description of the required post-emergency critique.



## 2.4 Transportation Procedures

If an ERTeam response to the scene of the emerge ncy is necessary, transportation will be required. The type of transportation used will be determined by the ERCoordinator, based on several factors:

• Urgency of response

• Distance to scene

• Available access to scene • Amount of equipment needed • Number of team members required to respond, and

• Weather conditions.

If immediate response is necessary, the fastest mode of transportation to the scene will be used. If air transportation is used, arrangeme nts will be made for travel to th e scene from the nearest airfield. The ERCoordinator will make travel arrangements.

If the response is less urgent, or is to provide b ackup or to relieve another ERTeam Member at the scene, then ground transportation will be used.



## 2.5 Public Relations

Calls from the news media will be directed to the ERCoordinator identified in Appendix 3.2 of the ERP. If the ERCoordinator is not available, ca lls will be directed to the person designated by the ERCoordinator as the appropriate media contact. If an ERTeam Member is approached at the scene by a reporter or photographer, the team member will direct the inquiry to the ERLeader.United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 114 Upon arrival at the scene, the ERLeader will:

• Check with the person in charge and notify hi m or her that the ERTeam will to keep all appropriate people up-to-date on the status of the emergency • Offer to have appropriate questions from the news media directed to the ERLeader • Be prepared to answer questions about the ERTeam and its activities • Keep an informal log of reporters and camera crews with whom the ERLeader has interacted, including their affiliations, telephone numbers, and information

communicated.

In talking to the news media, the ERLeader will:

• Be available to respond to questions in th e early morning and early afternoon, the most likely times when reporters on deadline will be seeking information • Brief the news media at least once every 30 minutes on the status of the emergency and, even when new information is not available, be accessible to answer questions that may

arise • Treat television and newspaper representatives equally • Be brief and factual in responses, never specu late on probable causes, and explain the facts simply, so the reporter will not have to check back later • Know the facts (an inaccurate or misleadi ng answer can be more detrimental than no answer); if a response is not available, indicate when a response is expected • Be courteous and responsive, maintain a level, factual tone of voice, and do not get agitated • Never speak "off the record" • Never use the words "no comment," use the response: "I don't have enough information to answer that question" or "I really don't think I can talk about that." • Never attempt to assign a dollar estimate to damage that has occurred • Never release names of injured people; tell reporters the hospital where the injured people have been taken, if appropriate • Never comment on the competency or perf ormance of another person responding to the

emergency. • Never attempt to physically restrain a member of the news media (i.e ., at a barricade); notify local law enforcement personnel, who will respond appropriately.United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 2/11/2008 115 

## 2.6 Post-Emergency Critique

Upon return to base, the ERLeader will supervis e the cleaning and storage of equipment. The ERLeader will conduct a critique of the incident with all ERTeam Member s. The ERLeader will complete an Emergency Response Report (see Appendix 3.5) and provide a copy to the ERCoordinator, RDC management and other responsible agents upon request.United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

116 3.0 APPENDIX

3.1 CALL REPORT

RDC EMERGENCY

CALL REPORT

Date Call Report No.

Time (on/off) Call Taken By

EMERGENCY DISPATCH AGENCY

EMERGENCY NAME

CALLER

ORGANIZATION

CALL BACK LOCATION

(City, County, State)

CALL BACK TELEPHONE

PROBLEM

(Include Type of Emergency)

Time

Details/Injuries

IMMEDIATE

ENVIRONMENTAL

CONCERNS

ACTION ALREADY TAKEN

Police and/or Fire Called?

Railroad and/or RDC Called?United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

117 ERCoordinator Called?United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

118 LOCATION OF EMERGENCY

(City, County - if other than caller location)

Hwy No./Distance-Direction From

Weather/Temperature

Populated/Open Area

Terrain (flat/hilly/etc.)

Nearest Airfield

Directions to SceneUnited States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

119 3.2 EMERGENCY RESPONSE REPORT

(Attach Additional Pages as Necessary)

Date: Emergency Response Report No.:

Time: Completed By:

Location & Phone Number Where Report may be Located: ( )

Type and Location of Incident:

Date: Time:

Remediation Completed: Date: Time:

Response Taken: Date: Time:

Number of ERTeam Members Reporting to Scene:

Names of all Team Members Responding:

Possible Impacts to Human Health or the Environment:

Description of Actions Taken:

Extent of Injuries, if any:United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

120 If Release of Solid Waste is Involved:

Disposition of Recovered Material:

Identification of Material:

Quantity:

Appearance of Site after Cleanup (include before and after photos):

Equipment & Supplies Used:

Signature Title:United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

121 

### 3.3 Broken Bale Remediation and Cleanup Protocol

Substantially Damaged/Broken Ba le Remediation Protocol

Bales that incur only minor ruptures will be repaired by resealing the opening with appropriate adhesive and plastic liner/sheeting.

In the event that a bale is substantially ruptured during RDC transport to the Landfill, the following mitigation measures will be immediately enacted:

1) The ruptured bale and its contents will be isolated.

2) A cleanup crew will scoop up the contents and any remnants of the broken bale and place it in waiting super-sacks – polypropylene bags lined on the interior with a minimum 6-mil plastic liner. The 6-mil plastic liner will be wrapped/folded over the waste and sealed with duct, thus creating a “burrito” wrapped waste bale. The sealed waste bale will then be secured inside the super sack to allow lifting the recovered waste to and from transportation equipment. This “burrito” wrapping of waste has been used effec tively, under Washington State Department of Ecology supervision, to manage “contained-in” regulated remediation waste

delivered to Roosevelt Landfill.

3) Once the super sack is secured it will be placed on a flatbed trailer for transport to

the active face of the Landfill where it will be lifted from the trailer and placed in the waste pile for subsequent coverage by other waste or soil cover. The “burrito” bag will be lifted and placed rather than tipped to ensure that it is not ruptured during tipping.United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

122 3.4 EMERGENCY RESPONSE DIRECTORY

Emergency Response Team (ERTeam) Contacts

Regional Disposal Company

ERCoordinator Matt Henry (Landfill) (800) 275-5641 (Roosevelt Office) (509) 727-1488 (Mobile)

ERLeader Dan Wedgwood (800) 275-5641 (Office) (541) 288-7027 (Mobile)

ERLeader (Backup) Dave Gunderson (800) 275-5641 (Office) (509) 366-2646 (Mobile)

ERTeam Member Jim Wright (800) 275-5641 (Office)

EMERGENCY RESPONSE DIRECTORY

For 24-Hour Emergency Response Call

Primary Number: (800) 275-5641United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

123 

## Agencies And Locations Where ERP Is Available

The agencies and locations listed below will receive copies of the AOP:

• RDC's Corporate Headquarters

54 S Dawson St. Seattle, WA 98134 (206)332-7700

• Hawaiian Waste Systems, LLC 1011 SW Klickitat Way, #C-109 Seattle, WA 98134 (206)292-2929

• Klickitat County Public Works 205 S. Columbus, Room 103 Goldendale, Washington 98620 (509) 773-4616

• Roosevelt Regional Landfill Main Office

P.O. Box 204

1800 Roosevelt Grade Road Roosevelt, Washington 99356 (509) 374-5641 or (800) 275-5641

• State of Washington Department of Ecology Central Regional Office 15 Yakima Way, Suite 200 Yakima, WA 98902

509-575-2490

3.5 EQUIPMENT INVENTORY

REQUIRED EQUIPMENT INVENTORYUnited States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



### COMPLIANCE AGREEMENT

124 RDC maintains several vehicles and pieces of equipment on site at the Roosevelt Regional Landfill for responding to accidents or emergenc ies in the Roosevelt area, including the following:

•

• tow vehicles

• water storage trucks equipped with a fire hose.

RDC will use these vehicles to assumes res ponsibility for first response for landfill-related accidents or emergencies in the Roosevelt area.

Table 3.5.1A contains a list and brief descrip tion of required emergency equipment, its function, and location at the Roosevelt Regional Landfill.125 Table 3.5.1A Emergency Equipment (RDC)

Material/Equipment Function Location

Telephone For routine and emergency

communication. Administration Building

Emergency Vehicle To provide transport of injured people. On site

Tow Vehicle To move disable trucks. On site

Diesel-powered generator To provide power for essential equipment. Maintenance Building

First Aid Kits To treat minor injuries. Administrative Building, Shop, Selected Vehicles

Safety Locker To store emergency equipment. Maintenance Building

Two-way Radios For routine and emergency

communication. Administrative Building, assigned to operations personnel

Portable and fixed cellular phones For routine and emergency

communication. Administrative Building, assigned to operations personnel

Dump Truck To transfer solid waste to

landfill. On site

Wheelloader To load spilled solid waste. On site

Equipment Manufacturer/Model Number Dozer Caterpillar/D10R WDA 1

Dozer Caterpillar/D9L WDA 1 Dozer Caterpillar/D6H WDA 1

Grader Caterpillar / 14G and 140G 1 Compactor Various Models 1 Wheelloader Caterpillar/980 and 966B 1 Excavator Caterepillar 235 and 320 1 Backhoe Caterpillar/466 1

Fuel Truck 1

Service Truck 1 Dump Truck 1126 

### WASTE SPILL PROTOCOL ON WATER127128129130131132133134135 

## 2. Example Compliance Agreement for Handling

Hawaiian GRG in the Continental United States.

UNITED STATES DEPARTMENT OF AGRICULTURE
ANIMAL AND PLANT HEALTH INSPECTION SERVICE
PLANT PROTECTION AND QUARANTINE

COMPLIANCE AGREEMENT According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a
valid OMB control number. The valid OMB control number for this information collection is 0579-0054. The time required to complete this information collection is estimated to average 1.25 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.

1. NAME AND ADDRESS OF PERSON OR FIRM Hawaiian Waste Systems, LLC 1011 SW Klickitat Way, #C-109 Seattle, WA 98134  2. LOCATION

3. REGULATED ARTICLE(S) Garbage and Regulated (domestic) Garbage from the State of Hawaii 

4. APPLICABLE FEDERAL QUARANT INE(S) OR REGULATIONS 7 CFR 330.400, 7 CFR 318.13, 7 CFR 318.47, 7 CFR 318.30, 7 CFR 318.60, 9 CFR 94.5 ,

5. PORTS OF COVERAGE:

WASHINGTON STATE AREAS (Covered by) USDA OFFICES IN: Spokane, Seattle, Ellensburg

6. I/We agree to the following:

General

This Compliance Agreement (CA) that regulates the handling and transport of Garbage and Regulated (domestic) Garbage of Hawaiian origin only authorizes Hawaiian Waste Systems, LLC and its authorized representatives to handle and transport Garbage and Regulated (domestic) Garbage from the State of Hawaii to the Roosevelt Regional Landfill, Washington, in accordance with the provisions of the applicable Federal Quarantines and the Administrator’s approval and under the following conditions approved by the United States Department of Agriculture, Animal Plant Health Inspection Service, Plant Protection and Qu arantine (USDA, APHIS, PPQ). Specifically, this Compliance Agreement applies to the handling and disposal of Garbage and Regulated (domestic) Garbage from the State of Hawaii, baled in adhesive backed plastic film barriers made of low density polyethylene (LDPE). The bales are to be transported from the State of Hawaii by barge to Roosevelt, Washington, by truck to the Roosevelt Regional Landfill in Klickitat County, and then buried without breaking and spreading waste and in accordance with the regulations for solid waste disposal and all applicable Federal, State, and Local ordinances. All Foreign Garbage, not of Hawaii origin, is specifically prohibited from movement under this compliance agreement.

DEFINITIONS136 Terms found in the agreement shall refer to the following:

Agricultural waste Byproducts generated by the rearing of animals and the production and harvest of crops or trees. Animal waste, a large component of agricultural waste, includes (e.g.) feed waste, bedding and litter, and feedlot and paddock runoff from livestock, dairy, and other animal-related agricultural and farming practices.

Bale means the confined unit of Garbage and Regulated (domestic) Garbage that has been approved for transport and burial. Bales are formed meeting all APHIS requirements in 7CFR330.

Barge means the conveyance via ocean and Columbia River on which the Garbage and Regulated (domestic) Garbage will be carried.

Collections of agricultural waste and yard wast e refers to bulk collections/pick-up of waste which is made up of primarily agricultural waste and yard waste. All collections of agricultural and yard waste shall not be accepted.

Commingling means the mixing of any regulated and non-regulated materials (including incinerated ash) within the bales, at any staging or transport area.

Company Name – Hawaiian Waste Systems, LLC; (HWS)

Compression refers to the process in which the waste articles are crushed under high pressure, expelling air from, and compacting waste articles into a high density bale.

Foreign Garbage means all materials, associated with fruits, vegetables, meats or animal products, that have been removed (in Hawaii) from any means of conveyance originating from a port outside the continental United States (including Alaska) or Canada, which has not been treated in accordance with 7 CFR part 330 for foreign pests and animal diseases. The disposal method described in this compliance agreement has not been evaluated for the risk of

animal diseases.

Garbage is defined as urban (commercial and residential) solid waste from municipalities on any Hawaiian island.

Inspector A properly identified employee of the USDA or other person authorized by the USDA to enforce the provisions of the Plant Protection Act and related legislation, quarantines, and regulations.

Offloading means to move bales from the means of conveyance to its final destination spot; the bales will not be placed on any other means of conveyance.137 Patch is made of impermeable film made of low density polyethylene, of at least 16 micrometers thickness, that is coated on one side with a non-hardening mastic/adhesive. The patch must be sufficient to establish an airtight seal.

Plant pest means any living stage of any insects, mites, nematodes, slugs, snails, protozoa, or other invertebrate animals, bacteria, fungi, other parasitic plants or reproductive parts thereof, viruses, noxious weeds, or any organisms similar to or allied with any of the foregoing, or any infectious substances which can directly or indirectly injure or cause disease or damage in any plants or parts thereof, or any processed, manufactured, or other products of plants.

PPQ Hawaii means the local office of the United States Department of Agriculture, Animal Plant Health Inspection Service, Plant Protection and Quarantine (USDA, APHIS, PPQ), Port of Honolulu located at 3375 Koapaka Street, Honolulu, HI 96819, phone numbe r, (808) 861-8446 and fax, (808) 861-

8450.

PPQ Washington means an office of the USDA, APHIS, PPQ in Washington State; located at 222 N. Havana Street, Spokane, WA 99202, phone number, (509)353-2950 and fax, (509)353-2637.

Puncture - any hole which is found in the plastic of the bale which goes through all four layers of the wrapping.

Regulated (domestic) Garbage refers to articles generated in Hawaii that are restricted from movement to the continental U.S. under various quarantine regulations established to prevent the spread of plant pests (including insects, disease, and weeds) into areas where the pests are not prevalent.

Rewrapping means the entire bale is rewrapped again using the exact same material and same amount of materials as in the initial wrap of bales. The original wrap will not be removed from the bale.

Roosevelt Regional Landfill refers to the landfill site located at 500 Roosevelt Grade Road, Roosevelt, Washington.

Rupture refers to a rupture or tear in the wrapping film where an observer or inspector is able to see Garbage and Regulated (domestic) Garbage that is no longer covered by film.

Shredding refers to the process used to reduce bulky articles into scraps.

Soil means the loose surface material of the earth in which plants grow, in most cases consisting of disintegrated rock with an admixture of organic material and

soluble salts.138 Staging Area refers to the solid flat impervious surface of asphalt or cement located at Roosevelt, WA where the bales will be staged pending transport to final destination. Wrapping machine will be located at this location.

Tear means any rupture found in the plastic of the bales which goes through all four layers of wrapping.

Transloading means the movement of Garbage and Regulated (domestic) Garbage from one means of conveyance to any other means of conveyance.

Transport Area refers to the location where bales approved for movement onto the barge are positioned for loading. The transport area is located pier side of Pier

5 at Kalaeloa Barbers Point Harbor.

Washington compliance agreement refers to the agreement between PPQ Washington and Hawaiian Waste Systems, LLC, 1011 SW Klickitat Way #C-109, Seattle, WA 98134.

Wrapping The wrapping material shall be an impermeable film made of low density polyethylene, of at least 16 micrometers thickness, that is coated on one side with a non-hardening mastic/adhesive. Bales are mechanically wrapped to achieve an air tight seal.

Wrapping Area refers to the station where the bale wrapping machinery is located. The wrapping equipment will be located at the baling facility in Hawaii and the staging area at the Port of Roosevelt.

Yard waste – Solid waste composed predominantly of grass clippings, leaves, twigs, branches, and other garden refuse.

Garbage and Regulated (domestic) Garbage Handling Procedures

The risk assessments for the movement of Garbage and Regulated (Domestic) Garbage were conducted based on the specific details provided by HWS. These details include the exclusion of incinerator ash and the removal of all hazardous and liquid waste prior to baling. HWS will notify PPQ if the company plans change to include such materials so that the proper risk assessments can be conducted.139 Garbage and Regulated (domestic) Garbage arriving by transport barge in Washington State from State of Hawaii will be categorized as Garbage and Regulated (domestic) Garbage. All Garbage and Regulated (domestic) Garbage arriving in Washington State will be baled using technology specified in 7 CFR 330.400, to create wrapped bales weighing approximately 1.5 to 4 tons. All waste bales shall be structurally sound and wrapped with a minimum of four layers of low density impermeable plastic film to provide an airtight and leak-proof enclosure. This will be demonstrated by conformance to applicable Hawaii Compliance Agreements. The Garbage and Regulated (domestic) Garbage will be continually maintained in securely closed and leak-proof bales which have been properly sealed in Hawaii, and will be disposed of in an approved manner at the Roosevelt Regional Landfill in Washington State. Every necessary precaution must be taken to reduce risk of opening or damage to the bale in Washington where the garbage is a quarantine article.

Upon arrival in Washington State the bales of Garbage and Regulated (domestic) Garbage will be routed directly to the Port of Roosevelt and inspected by a HWS supervisor to verify that the wrapping of the bales is intact. The condition of bales will be noted on the manifest for each numbered bale. The Garbage and Regulated (domestic) Garbage will be kept completely segregated at all times from all other kinds of waste and non-regulated garbage during packaging and staging to eliminate commingling of materials. Any other material (regulated or non-regulated, such as non-rolling equipment, empty containers, and non-regulated recyclables) placed on the same barge as the bales of Garbage and Regulated (domestic) Garbage must be secured to the barge in such a manner that they will not move or come in contact with the wrapped bales. Any other material placed on the same barge much be separated from the bales of Garbage and Regulated (domestic) Garbage approved for movement under this compliance agreement and must be easily distinguishable from the bales of Garbage and Regulated (domestic) Garbage approved for movement under this compliance agreement.

Equipment used during transloading operations will be appropriately blunted to minimize the potential for punctures, ruptures, or tears. A HWS supervisor will be present during all trans-loading and ensure proper handling equipment is used.

Each bale will be inspected and marked with a manifest and tracking identification number. The inspection of the wrapping of the bale will be noted on the bale manifest prior to allowing the bale to progress to the next protocol step.140 Any time a puncture, rupture, or tear is detected, the bale will be visibly marked and moved to a designated area for subsequent pa tching or rewrapping. Punctures, ruptures, and tears which are 6 inches or smaller, will be covered with an adhesive patch which will extend at least 6 inches beyond the limits of the tear or puncture. Punctures, ruptures,and tears which are more than 6 inches, will be covered with a patch and then rewrapped. Any bales that have been repaired shall be prioritized for immediate transport to the landfill. The bale manifest will note any patch, any re-wrapping, and delivery to the landfill. If a bale is broken open, appropriate clean up procedures will be implemented per the clean up protocols of this compliance agreement.

A wrapping machine will be located at the Port of Roosevelt which is currently the only transfer, staging and handling point appr oved for transloading. HWS will establish protocols for ensuring wrapped bales are pr operly inspected throughout the handling and loading processes. These protocols will be written, and available to USDA APHIS and/or its designated cooperators and HWS supervisors.

The protocol must include at least one poi nt in the process where the wrapping around the bale is completely and thoroughly inspected from every angle for punctures or tears. HWS will have a supervisor present at the transloading from barge to truck at the Port of Roosevelt, WA docks and must be able to safely view this inspection in action. A record on the bale manifest will show by initials or some other accountable way that a thorough inspection was performed and that no punctures or tears were found.

Imperfectly sealed bales will be visibly marked and sent to the staging area for rewrapping. Movement and rewrapping of bales will be recorded on the bale manifest. Bale identification numbers of bales requiri ng rewrapping prior to departure from Hawaii

will also be available for review.

Bales will be re-inspected for punctures, ruptures, and tears any time the bales are moved

or an incident occurs that would increase risk of puncturing, rupturing or tearing the

bales.

The Staging and Transport Area

This is a new process for handling Garbage and Regulated (domestic) Garbage from Hawaii. The integrity of the bales at the Hawaii port is important to review and maintain throughout the entire baling and transportation process. All punctures, ruptures, and tears will be documented and reported regularly. All spills will be documented on the bale manifest and reported immediately to the HWS Supervisor for proper cleaning in accordance with Appendix 1 of this compliance agreement. All spills will be reported to PPQ immediately.

Garbage and Regulated (domestic) Garbage handling procedures pertinent to the transport and staging areas will be conspicuously posted. The procedures must be in English and other appropriate languages.141 The staging and transport area shall be kept clean and free of loose garbage and soil. The areas will be controlled for birds, rodents, mollusks, and any other pests that may be

attracted to the bales.

Very little biodegradation or production of gases occurs in the properly compressed and wrapped bales. Therefore, wrapped bale s which exude unusual odors, or bulges could

indicate improper processing and will immediately be completely rewrapped. The baleidentity and the company’s supervisor inquiry will be noted for tracking results. Rewrapped bales will be prioritized for movement to the landfill.

After inspection at the first port of call at Roosevelt, Washington the Garbage and Regulated (domestic) Garbage will be trucked to the Roosevelt Regional Landfill.

The designated landfill, Roosevelt Regional Landfill meets the criteria of a modern facility that meets regulations and EPA guidelines for design and operations. HWS will immediately notify Honolulu and Washington PPQ if the landfill fails to meet these standards and will discontinue transport of Garbage and Regulated (domestic) Garbage until authorized by PPQ.

USDA, APHIS, or its designated cooperators in Washington shall be notified by facsimile 48 hours in advance (during normal business hours -Monday-Friday, 0730- 1600 hours) of each Garbage and Regulated (domestic) Garbage shipment arrival at the mouth of the Columbia River. This notification may be followed up with alternate means of communication (i.e. phone, email) at the discretion of HWS.

The notification shall include:

Barge name and Voyage no.

Date of departure from the State of Hawaii

First Port of Entry to continental U.S.

Estimated date and time of arrival at the first port of entry to Continental U.S.

Name and phone number of the contact personnel responsible for the shipment.

A list of the identification numbers for the bales in the shipment.

USDA APHIS or its designated cooperators will be notified by facsimile 48 hours prior to the trans-loading of the Garbage and Regulated (domestic) Garbage from the staging area to road trailers (during normal business hours -Monday-Friday, 0730-1600 hours). This notification may be followed up with alternate means of communication (i.e. phone, e-mail) at the discretion of HWS. The company must have a supervisor on site at all142 times to monitor the loading and securing of the bales on the trailers before transport to the Roosevelt Regional Landfill.

Garbage and Regulated (domestic) Garbage staged at the Port of Roosevelt will be cleared from the staging area prior to the arrival of a second barge but in no way shall the total of 75 days from the date of wrapping be exceeded. Once the bales are transported from the staging area to the landfill they must be buried in lined landfill cells under a

minimum of 6 inches of soil in the Roosev elt Regional Landfill within 24 hours of arrival as required by EPA guidelines. The landfilled bales must be completely buried under a minimum of 7 feet of material in the Roosevelt Regional Landfill within 75 days of being staged in Hawaii.

A HWS supervisor will be present during all handling and transport of Garbage and Regulated (domestic) Garbage. The company operates under this compliance agreement and operations will be monitored by USDA APHIS and/or its designated cooperator.

The vehicle transporting the bales of Garbage and Regulated (domestic) Garbage from the Roosevelt, WA docks must take a direct and expeditious route to the Roosevelt Regional landfill where burial will take place. Drivers must report any spills or breakage immediately to the HWS Supervisor for proper cleaning. The spill or breakage must be cleaned immediately according to Appendix 1 of this compliance agreement. All spills or breakages must be documented on bale manifest and reported to PPQ immediately.

HWS will arrange and ensure the transport of Garbage and Regulated (domestic) Garbage directly to the Roosevelt Regional landfill by the transportation method and route approved under the APHIS-PPQ Washington State Compliance Agreement. Routing will be shown on the shipping manifests for the barge, and will be available for

review.

The routing of Garbage and Regulated (domestic) Garbage from Hawaii is to be directly to the Roosevelt, WA dock. Hawaii PPQ will approve the routing which shows the designated Port of Entry. No other stops are approved while enroute to the Roosevelt,

WA dock.

Transloading of the Garbage and Regulated (domestic) Garbage from barge to barge is prohibited. Transloading of the Garbage and Regulated (domestic) Garbage from barge to over-the-road carriers/trailers will be restricted to the designated staging area at the Port of Roosevelt dock and inter-modal facility.

HWS will use only the Roosevelt Regional Landfill as described under the APHIS-PPQ Washington State office Compliance Agreement. Any deviation from this designated landfill must be authorized through a different Compliance Agreement approved by USDA-APHIS-PPQ.

HWS is responsible for all Garbage and Regulated (domestic) Garbage it transports and will not allow its unauthorized removal, diversion, or use.143 Should HWS subcontract transport, handling, stor age, or final destination of Garbage and Regulated (domestic) Garbage to another firm then that firm must also be a USDA approved company and under compliance with USDA, APHIS, PPQ. PPQ in Hawaii and Washington will be notified in advance if another firm is to be used. Substitution and approval is NOT automatic. Movement of Garbage and Regulated (domestic) Garbage may be temporarily or indefinitely delayed depending on the outcome of the approval

process.

Bales which are punctured, ruptured, or torn and require rewrapping must be visibly marked for easy observation. The marked bales will be moved to the designated staging area for bales requiring rewrapping. The staging area will clearly separate bales for rewrapping from other bales.

Garbage and Regulated (domestic) Garbage must be processed under the described conditions and securely lodged on the barge prior to departure from Hawaii. To avoid accidental shipment of bales marked for rewrapping, bales for rewrapping must be immediately removed and separated from the bales for immediate transport. This separate area will be clearly designated for both the garbage handlers and the inspector.

Marking and Identification of Bales

The bales must be permanently marked with the words “REGULATED GARBAGE,” printed in a contrasting color to the wrap. The size of the letters shall be 3 inches in height and easily visible and legible.

Manifest and tracking identification numbers required on each bale include the Bale Identification Number, the Date Wrapped, and the Date Placed in Staging Area. These markings must be in a contrasting color to both the wrap and the words “REGULATED

GARBAGE.” Markings on all bales must be viewable without moving the bales or climbing on top bales by the USDA APHIS PPQ inspector and/or designated cooperators. If markings are not viewable as stated above, a HWS operator will need to move the bales for viewing.144 Transport, staging and handling areas

Wrapped bales are clean and shall be handled so that they stay free of soil and attractant debris. No “grounding” or staging of the bales on Washington soil will be allowed. All staging will be conducted on a level, solid and impervious surface of asphalt or cement.

All necessary safety precautions and anticipated precautions will be discussed with Washington PPQ prior to set up of the equipment.

Any bale dropped or torn during the transport process must be immediately patched or removed and rewrapped.

Bales will not be lifted higher than 3 meters except by recorded incident/explanation.

All Garbage and Regulated (domestic) Garbage must be protected from birds, rodents, and mollusks during staging and transport.

The bales of Garbage and Regulated (domestic) Garbage will be isolated from close proximity to exposed fresh fruits, plants, or other activities which may attract hitchhiking plant pest. Barriers will be erected if this occurs due to unusual and unavoidable circumstances if the operations cannot be moved.

CLEANUP PROCEDURES FOR GARBAGE AND REGULATED (DOMESTIC) GARBAGE SPILLS AND EQUIPMENT

HWS must provide personnel and appropriate measures to control the Garbage and Regulated (domestic) Garbage in the event of a spill or other emergency. HWS will follow the clean-up protocols specified for spills as outlined in Appendix 1 of this compliance agreement. Any changes to these protocols must be reviewed and approved by USDA, APHIS, PPQ, and all appropriate Federal, State and Local regulations.

In the event of a spill or leak the trailer must be cleaned at the disposal site by using a method approved for use at the site. The barge transport must also be inspected for spills that may have occurred during transit.

A contingency plan should be in place to handl e any spills or breakage during any part of the voyage, transloading, offloading, and/or tr ansportation of the bales. All company employees, designees, drivers, and handlers of the baled Garbage and Regulated (domestic) Garbage shall be informed of the contingency plan.

Waste Spill Protocol for the breakage of bales on land145 In the event that a bale is ruptured during offloading, the following mitigation measures will be immediately enacted:

4) The ruptured bale and its contents will be isolated .

5) A cleanup crew will scoop up the contents and any remnants of the broken bale and place it in waiting super-sacks – polypropylene bags with spread straps for machine lifting --lined on the interior with a 6-mil plastic liner.

6) Once loaded, the plastic liner inside the super-sack will be folded over the material and sealed with duct tape, thus creating a “burrito” wrapped waste bale. The sealed waste bale will then be secured inside the super sack to allow lifting the recovered waste to and from transportation equipment.

4) The super-sacks will be lifted with a forklift or similar equipment and placed on a flatbed trailer or similar transportation equipment for transport to the active face

of the Landfill.

Upon reaching the active face of the Landfill th e super sacks containing “burrito” bags will be lifted and placed in the waste pile for subsequent coverage by other waste or soil

cover.

APPENDIX 1 clean up protocols will be follow, attached to this document.

If spillage occurs during transport, USDA, APHIS, PPQ must be notified immediately. See list of contact numbers provided below:

Contact Numbers

The contact phone and fax numbers for the USDA offices are as follows:

USDA OFFICE CONTACT PHONE FAX

Spokane, WA George Bruno or Steve Miller (509) 353-2950 (509) 353-

2637

Ellensburg, WA Jordan Krug (509) 925-1188 (509) 925-

4678

Seattle, WA Barbara Chambers, SPHD (206) 592-9057 (206) 592-

9043146 TRAINING

HWS shall present a training program to employees before they are permitted to handle and transport or supervise the handling and transport of Garbage and Regulated (domestic) Garbage. This training program should be at least one (1) hour in duration. Previously trained employees shall be provi ded review training annually. A record of employees and their training dates shall be maintained and available for PPQ review.

The training package must be approved by the local PPQ officer in charge, and may include both formal classroom training and on-the-job training. It must contain the following topics:

Procedures for maintaining control of Garbage and Regulated (domestic) Garbage

Define “Garbage” and “Regulated (domestic) Garbage” and “Foreign Garbage”

Explain the regulation and its purpose.

Explain the compliance agreement and its purpose.

Include film, slides, or other training aids on Hawaiian soil, plant diseases and pests

Specifically outline, by demonstration, illustration, or picture, proper regulated garbage handling procedures and transport.

Explain the manifesting process.

Be presented in English and other appropriate languages.

Procedures for reporting and data; procedures and reporting results of inspection

of bales

Procedures for cleaning affected equipment and areas.

Records of training administered to employees shall be made available to PPQ personnel

upon request.147 RECORDS AND MONITORING (INSPECTIONS)

HWS must maintain a log which records bale identification, date of baling, inspections done, any remedial measures (e.g., patches, rewrapping), and must document any spills or other mitigation actions taken.

HWS must maintain records to indicate the date, weight, container number, and seal number when each load is destroyed. The records must be maintained and be available upon request by USDA-APHIS-PPQ.

HWS must maintain a log which records the date, time, number, type and weight of the containers of Garbage and Regulated (domestic) Garbage transported and disposed of, and the name of the vehicle’s driver. This log will be made available to PPQ upon request. These records must be kept for a minimum of 3 years from the end of the month

that the movement was made.

To ensure compliance, PPQ officers will be permitted access to the firm’s premises and relevant records without prior appointment.

ENVIRONMENTAL PROTECTION AND OTHER REGULATORY AGENCIES

By signing this agreement, the signer certifies that his/her facility has met or will meet the requirements of all applicable environmental and any other applicable regulatory authorities in addition to the Garbage and Regulated (domestic) Garbage handling procedures specified by the Animal and Plant Health Inspection Service

.

NOTIFICATION

PPQ shall be notified within 7 days of any change in business status, business operations, telephone number, business address, management, ownership or business dissolution.

COMPLIANCE

This compliance agreement is nontransferable. If the person identified in section 7 as the signer of PPQ Form 519 leaves their present employer, company or position, then he/she must notify the local PPQ office immediately. This agreement will then be terminated.

If Garbage and Regulated (domestic) Garbage is to be handled by other personnel within the company, those persons must be under the permittee’s supervision and must be aware of and able to adhere to all stipulations in this agreement.

This compliance agreement may be amended as necessary by USDA, APHIS, PPQ. HWS

will be notified of all amendments.

NOTE: “Any person who knowingly violates the Pl ant Protection Act (PPA) (7 U.S.C. §§ 7701 et. Seq.) And/or the Animal Hea lth Protection Act (AHPA) (7 U.S.C. §§ 8301 et. Seq.) may be criminally prosecuted a nd found guilty of a misdemeanor which can result in penalties, and one year prison term , or both. Additionally, any person violating148 the PPA and/or the AHPA may be asse ssed civil penalties of up to $250,000 per violation or twice the gross gain or gross lo ss for any violation that results in the person deriving pecuniary gain or causing pecuniary loss to another, whichever is greater.”

WITHDRAWAL OF COMPLIANCE AGREEMENT

This compliance agreement may be canceled, by a PPQ Officer orally or in writing, if such officer determines that the holder thereof has not complied with any of the conditions stated in this compliance agreement. If the cancellation is oral, the cancellation and the reasons for the cancellation will be confirmed in writing as promptly as circumstances allow. Any person whose compliance agreement has been canceled may appeal the decision in writing to USDA- AP HIS- PPQ within ten (10) days after receiving the written notification of the withdrawal. The appeal must be directed to the State Plant Health Director of Washington. The appeal must state all of the facts and reasons upon which the person relies to show that the compliance agreement was wrongfully canceled. USDA-APHIS-PPQ shall grant or deny the appeal, in writing, stating the reasons for such decision, as promptly as circumstances allow. If there is a conflict as to any material fact, a hearing sha ll be held to resolve such conflict. Rules of practice concerning such a hearing will be adopted by USDA-APHIS-PPQ.

Agreement

By signing this agreement, the primary holder of Hawaiian Waste Systems, LLC agrees to maintain the scope and intention of this compliance agreement. The signature further certifies that the listed business has met or will meet the requirements of all other applicable environmental authorities prior to the processing of any USDA, APHIS, PPQ Garbage and Regulated (domestic) Garbage.

This agreement may be immediately canceled or revoked for noncompliance.

I have read and understand the conditions of this compliance agreement.

6.Signature

 7. Title 8. Date Signed

The affixing of the signatures below will validate this agreement, which shall remain in effect until canceled, but may be revised as necessary or revoked for noncompliance. 10. Date of Agreement 11. Agreement Number

PPQ OFFICIAL (Name and Title)

Signature ADDRESS

STATE AGENCY OFFICIAL (Name and Title) ADDRESS149 Signature
PPQ FORM 519 (FEB 2002)150 

## Appendix B. Marine Mammal Protection Act

The Marine Mammal Protection Act (MMPA) prohibits, with certain exceptions, the take of marine mammals in U.S. waters and by U.S. citizens on the high seas, and the importation of marine mammals and marine mammal products into the U.S. All marine mammals are protected under the MMPA.

Hawaii’s Marine Mammals:

(From http://www.konawhalewatch.com/main_file.php/general/27/ last accessed June 13, 2006)

Baird’s Beaked Whale ( Berardius bairdii ) family: Ziphiidae

Blainville’s Beaked Whale ( Mesoplodon densirostris ) family: Ziphiidae

Bryde’s Whale ( Balaenoptera edeni ) family: Balaenopteridae

Cuvier’s Beaked Whale ( Ziphius cavirostris ) family: Ziphiidae

Dwarf Sperm Whale ( Kogia simus ) family: Physeteridae

False Killer Whale ( Pseudorca crassidens ) family: Delphinidae

Fin Whale ( Balaenoptera physalus ) family: Balaenopteridae

Humpback Whale ( Megaptera novaeangliae ) family: Balaenopteridae

Killer Whale ( Orcinus orca ) family: Delphinidae

Melon-headed Whale ( Peponocephala electra ) family: Delphinidae

Minke Whale ( Balaenoptera acutorostrata ) family: Balaenopteridae151 Northern Right Whale ( Eubalaena glcialis ) family: Balaenidae

Pacific Bottlenose Dolphin ( Tursiops gilli ) family: Delphinidae

Pygmy Killer Whale ( Feresa attenuata ) family: Delphinidae

Pygmy Sperm Whale ( Kogia breviceps ) family: Physeteridae

Risso’s Dolphin ( Grampus griseus ) family: Delphinidae

Rough-toothed Dolphin ( Steno bredanensis ) family: Delphinidae

Short-finned Pilot Whale ( Globicephala macrorhynchus ) family: Delphinidae

Sperm Whale ( Physeter macrocephalus ) family: Physeteridae

Spinner Dolphin ( Stenella longirostris ) family: Delphinidae

Spotted Dolphin ( Stenella attenuata ) family: Delphinidae

Striped Dolphin ( Stenella coeruleoalba ) suborder: Odonticeti family: Delphinidae

Hawaiian Monk Seal (From: http://www.earthtrust.org/wlcurric/seals.html last

accessed June 13, 2006) ( Monachus schauinslandi ) family: Phocidae152 Washington’s Marine Mammals

(From http://www.washington.edu/burkemuseum/collections/mammalogy/mamwash/mamwash.

html#cetacea last accessed June 13, 2006)

Northern Right Whale, ( Eubalaena glacialis ) family: Balaenidae

Minke Whale ( Balaenoptera acutorostrata ) family: Balaenopteridae

Sei Whale ( Balaenoptera borealis ) family: Balaenopteridae

Blue Whale ( Balaenoptera musculus ) family: Balaenopteridae

Fin Whale ( Balaenoptera physalus ) family: Balaenopteridae

Humpback Whale ( Megaptera novaeangliae ) family: Balaenopteridae

Gray Whale ( Eschrictius robustus ) family: Eschrichtidae

Short-Beaked Saddleback Dolphin ( Delphinus delphis ) family: Delphinidae

Short-finned Pilot Whale ( Globicephala macrorhynchus ) family: Delphinidae

Risso’s Dolphin ( Grampus griseus ) family: Delphinidae

Pacific White-sided Dolphin ( Lagenorhynchus obliquidens ) family: Delphinidae

Northern Right-Whale Dolphin ( Lissodelphis borealis ) family: Delphinidae

Killer Whale ( Orcinus orca ) family: Delphinidae

False Killer Whale153 ( Pseudorca crassidens ) family: Delphinidae

Striped Dolphin ( Stenella coeruleoalba ) family: Delphinidae

Rough-toothed Dolphin ( Steno bredanensis ) family: Delphinidae

Bottle-nosed Dolphin ( Tursiops truncates ) family: Delphinidae

Pygmy Sperm Whale ( Kogia breviceps ) family: Kogiidae

Dwarf Sperm Whale ( Kogia sima ) family: Kogiidae

Harbor Porpoise ( Phocoena phocoena ) family: Phocoenidae

Dall's Porpoise ( Phocoenoides dalli ) family: Phocoenidae

Sperm Whale ( Physeter macrocephalus ) family: Physeteridae

Baird's Beaked Whale ( Berardius bairdii ) family: Ziphiidae

Hubbs Beaked Whale ( Mesoplodon carlhubbsi ) family: Ziphiidae

Pacific Beaked Whale ( Mesoplodon stejnegeri ) family: Ziphiidae

Cuvier's Beaked Whale ( Ziphius cavirostris ) family: Ziphiidae

Sea Otter ( Enhydra lutris ) family: Mustelidae

Northern Fur Seal ( Callorhinus ursinus ) family: Otariidae

Steller Sea Lion ( Eumetopias jubatus ) family: Otariidae154 California Sea Lion ( Zalophus californianus ) family: Otariidae

Northern Elephant Seal ( Mirounga angustirostris ) family: Phocidae

Harbor Seal ( Phoca vitulina ) family: Phocidae

Oregon’s Marine Mammals

(From http://www.mammalsociety.org/statelists/ormammals.html last accessed June 13, 2006)

Black Right Whale, ( Eubalaena glacialis ) family: Balaenidae

Minke Whale ( Balaenoptera acutorostrata ) family: Balaenopteridae

Sei Whale ( Balaenoptera borealis ) family: Balaenopteridae

Blue Whale ( Balaenoptera musculus ) family: Balaenopteridae

Fin Whale ( Balaenoptera physalus ) family: Balaenopteridae

Humpback Whale ( Megaptera novaeangliae ) family: Balaenopteridae

Gray Whale ( Eschrictius robustus ) family: Eschrichtidae

Sperm Whale ( Physeter macrocephalus ) family: Physeteridae

Pygmy Sperm Whale ( Kogia breviceps ) family: Kogiidae

Baird's Beaked Whale ( Berardius bairdii ) family: Ziphiidae155 Pacific Beaked Whale ( Mesoplodon stejnegeri ) family: Ziphiidae

Cuvier's Beaked Whale ( Ziphius cavirostris ) family: Ziphiidae

Pacific Striped Dolphin ( Lagenorhynchus obliquidens ) family: Delphinidae

Dall Porpoise ( Phocoenoides dalli ) family: Delphinidae

Harbor Porpoise ( Phocoena phocoena ) family: Delphinidae

Pilot Whale, ( Globicephala macrorhynchus ) family: Delphinidae

Killer Whale ( Orcinus orca ) family: Delphinidae

Rough-toothed Porpoise ( Steno bredanensis ) family: Delphinidae

Northern Right Whale Dolphin ( Lissodelphis borealis ) family: Delphinidae

False Killer Whale ( Pseudorca crassidens ) family: Delphinidae

Risso's Dolphin ( Grampus griseus ) family: Delphinidae

Northern Fur Seal ( Callorhinus ursinus ) family: Otariidae

Steller Sea Lion ( Eumetopias jubatus ) family: Otariidae

California Sea Lion ( Zalophus californianus ) family: Otariidae

Northern Elephant Seal ( Mirounga angustirostris ) family: Phocidae

Harbor Seal156 ( Phoca vitulina ) family: Phocidae

Sea Otter ( Enhydra lutris ) family: Mustelidae

California’s Marine Mammals (within program action area)

(From http://www.dfg.ca.gov/Mrd/mambk_a.pdf last accessed June 13, 2006)

Northern Right Whale, ( Eubalaena glacialis ) family: Balaenidae

Minke Whale ( Balaenoptera acutorostrata ) family: Balaenopteridae

Sei Whale ( Balaenoptera borealis ) family: Balaenopteridae

Blue Whale ( Balaenoptera musculus ) family: Balaenopteridae

Fin Whale ( Balaenoptera physalus ) family: Balaenopteridae

Humpback Whale ( Megaptera novaeangliae ) family: Balaenopteridae

Gray Whale ( Eschrictius robustus ) family: Eschrichtidae

Short-Beaked Saddleback Dolphin ( Delphinus delphis ) family: Delphinidae

Short-finned Pilot Whale ( Globicephala macrorhynchus ) family: Delphinidae

Risso’s Dolphin ( Grampus griseus ) family: Delphinidae

Pacific White-sided Dolphin ( Lagenorhynchus obliquidens ) family: Delphinidae

Northern Right-Whale Dolphin ( Lissodelphis borealis ) family: Delphinidae157 Killer Whale ( Orcinus orca ) family: Delphinidae

Harbor Porpoise ( Phocoena phocoena ) family: Phocoenidae

Dall's Porpoise ( Phocoenoides dalli ) family: Phocoenidae

False Killer Whale ( Pseudorca crassidens ) family: Delphinidae

Striped Dolphin ( Stenella coeruleoalba ) family: Delphinidae

Rough-toothed Dolphin ( Steno bredanensis ) family: Delphinidae

Bottle-nosed Dolphin ( Tursiops truncates ) family: Delphinidae

Pygmy Sperm Whale ( Kogia breviceps ) family: Kogiidae

Dwarf Sperm Whale ( Kogia sima ) family: Kogiidae

Sperm Whale ( Physeter macrocephalus ) family: Physeteridae

Baird's Beaked Whale ( Berardius bairdii ) family: Ziphiidae

Hubbs Beaked Whale ( Mesoplodon carlhubbsi ) family: Ziphiidae

Cuvier's Beaked Whale ( Ziphius cavirostris ) family: Ziphiidae

Northern Fur Seal ( Callorhinus ursinus ) family: Otariidae

Steller Sea Lion ( Eumetopias jubatus ) family: Otariidae158 California Sea Lion ( Zalophus californianus ) family: Otariidae

Northern Elephant Seal ( Mirounga angustirostris ) family: Phocidae

Harbor Seal ( Phoca vitulina ) family: Phocidae

Sea Otter ( Enhydra lutris ) family: Mustelidae

Assessment:

These species could be harassed by the operation of towing vessels during barge movement. The physical presence of tugs and ba rges could lead to disturbance of marine mammals by visual or other cues. Marine debris could be generated if integrity of bales

is not maintained.

The potential for collisions between the tug/barge and marine mammals is very low due to the slow tow speed (6-9 knots). Noise or visual disturbance will not likely occur since marine mammals have demonstrated little behavioral reaction to slow-moving vessels, according to surveys conducted (NMFS, 2006). The baled garbage will be inspected at multiple points in the transport process to ensure that bales are intact and garbage will not be released. Therefore, implementation of the proposed action is expected to be protective of marine mammals within the action area.

Reference:

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes of marine mammals incidental to specified activities; movement of barges through the Beaufort Sea between West Dock and Cape Simpson or Point Lonely, Alaska. Federal Register, Vol. 71, p34064, June 13, 2006.15 9 

### Appendix C. Risk of Introduction of Pests to the Continental United States via Municipal Solid Waste from Hawaii.

### United States Department of Agriculture

Animal and Plant Health Inspection

Service

March 2006
Updated August 2006 

## The Risk of Introduction of Pests to the

Continental United States via Plastic-Baled Municipal Solid Waste from Hawaii

Executive Summary

Companies have proposed transpor ting large volumes of Hawaiian municipal solid waste (MSW) in airtight bales to landfills in the

continental United States. The ba les are created by shredding, compressing, and wrapping MSW in adhesive-backed, plastic film barriers. Airtight enclosure from cr eation to burial would mitigate plant pest risks, but this technology is st ill relatively new. Moreover, federal regulations prohibit garbage from Ha waii from entering the continental United States. Thus, the Center for Plant Health Science and Technology (CPHST) was asked to assess the risks of plant pest establishment via this pathway. Specifically, we assessed the soundness of baling technology and the safety of the general pathway, considering here those processes likely to apply to all company proposals. We also did a generic quantitative analysis of the likelihoo d of bale-rupturing accidents via the different conveyances: trucks, trains , and barges. Some proposal-specific parameters, such as the locations of landfills on the mainland and the types of transport to be used, will be eval uated separately for each particular proposal to identify any exceptiona lly significant risk factors.

Published, independent scientific testing of the baling technology confirmed manufacturers’ specifications and indicated that it is likely to mitigate the risk from all types of plant pests. In particular, insects, mollusks, and some pathogens are unlik ely to survive in the bales because of compression, anoxia, and the absen ce of hosts. Other procedures, such as bale construction, monitoring during transport, and burial in regulated landfills, should adequately protect against escapes from within bales via accidental ruptures and punctures during handling and transport. Compliance with general procedures, such as diversion of yard and agricultural waste, and proper staging and prompt shipment of bales, is also important. The accident rate anal ysis indicated a very low likelihood of bale-rupturing accidents for all conveyances. If these procedures are followed, transporting municipal solid wa ste from Hawaiian cities in bales poses an insignificant risk of plan t pest introduction. In addition, we recommend that the pathway be mo nitored to ensure that pathway processes and compliance do not di ffer significantly from proposals

evaluated here.PRA for Baled Hawaiian Solid Waste 161 

### Table of Contents

Executive Summary.............................................................................................................. .................... 1

I. Introduction ................................................................................................................ ........................... 3

II. Definitions................................................................................................................ ............................. 3

III. Detailed overview ......................................................................................................... ...................... 4

IV. Validity of the baling technology.......................................................................................... ............. 5

V. Potential plant pests....................................................................................................... ...................... 6

VI. Pest risk mitigations ...................................................................................................... ..................... 7

Mitigations from th e baling technology......................................................................................... ......... 7 Mitigation from pathway procedures............................................................................................. ......... 7 VII. Risk of bale-rupturing accidents .......................................................................................... ........... 9

Model development a nd parameterization......................................................................................... ..... 9

Results and discussion ......................................................................................................... ................. 10 VIII. Qualitative risk assessment.............................................................................................. ............. 11

IX. Conclusions ................................................................................................................ ....................... 12

Contact........................................................................................................................ ............................. 13

References..................................................................................................................... ........................... 13

Appendices..................................................................................................................... .......................... 12

Appendix A. Lists of selected Hawaiian pests, including insects, pathogens , and pest plants of quarantine significance to the continental United Stat es. The lists focus on plan t pests but also include other categories of pests, su ch as human health pests. ......................................................................... 12 Appendix B. Modeling the likelihood of bale-ruptur ing accidents during transport of baled municipal solid waste (MSW) by truck, rail, or barge..................................................................................... ...... 37PRA for Baled Hawaiian Solid Waste 1 62 

## I. Introduction

Companies have proposed transporting up to 300,000 tons (lbs) of baled municipal solid waste (MSW) per year from Hawaii to landfills in the continental United States. Bales will be created by compressing and wrapping MSW in adhesive-backe d, plastic film barriers made of low density polyethylene (LDPE), creating airtight packages. Bales would be transp orted by barge to the mainland and then perhaps by other means to landfills, and ultimately buried int act, in accordance with regulations for solid waste disposal (40CFR§258; EPA (1993)). Garbage from Hawaii is not enterable under cu rrent federal regulations for plant pests (7CF R§330.400). Therefore, an assessment of the risks of plant pest introduction via baled Hawaiian MSW to the continental United States is needed. At the request of the State of Hawaii, this assessment was done by the Center for Plant Health Science and Technology (CPHST), part of the Animal and Plant Health Inspection Service (APH IS) of the U.S. Department of Agriculture (USDA).

The objective of this report is to evaluate wh ether the baling technology will effectively mitigate potential plant pest risks associ ated with MSW from Hawaii. The assessment focuses upon the planned use of the baling technology, because airtight enclosur e from creation to burial would mitigate the risks of establishment by any plant pests (Appendix A) . We address the following three questions: 1) Does the baling technology provi de a strong, airtight barrier? 2) How likely are bale-rupturing accidents for ba rges, trucks, and trai ns during transport? 3) How likely are punctures? and 4) Will general pathway procedures reduce pest inci dence in the bales and the chances of escape in the event of accidental ruptures or punctures? In addition, we give qualitative ri sk ratings for different pest t ypes based on the likelihood of introduction. Only those pathway processes likely to be common to all compa ny proposals to transport baled Hawaiian waste were considered. Separate assessments for particular company proposals will

address factors such as the destin ation landfill, type of transportation to be used on the mainland, and pest species that may pose particular threats.



## II. Definitions

Garbage is defined as urban (commercial and resi dential) solid waste from municipalities on any Hawaiian island, such as Honolulu on Oahu, and Hilo on Hawaii. Based on company proposals to move baled waste (not shown), this analysis assumed that yard and agricultural wast e will be excluded from the waste stream. Therefore, the volume of any such waste accidentally entering the pathway should be minimal. If it was found that ya rd and agricultural wa ste was not typically excluded, a revised assessment might be necessary.

A spill is defined as the escape of waste materi al from a bale and contact with the surrounding environment, e.g. ground, truck, tractor, barge, or other terrestrial features.

Other important terms are defined as follows (Merriam-Webster, 2004): Anoxia: hypoxia especially of such severi ty as to result in permanent damage Anoxic: greatly deficient in oxygen Hypoxia: a deficiency of oxygen in organisms/bodily tissuesPRA for Baled Hawaiian Solid Waste 1 63 Anaerobic means living, active, occurring, or existing in the absence of free oxygen. Thus, the term anaerobic is only correctly applied to organisms, not non-living things like bales, or the conditions

within them.



## III. Detailed overview

Some details will be specific to each company propos al, such as the landfill site and means of transport within the continental U.S., but general characteristics related to the pathway include the following: 1) The material to be trans ported is municipal solid waste 2) Agricultural and yard wa ste will be diverted to other transfer stations and waste streams, and actively removed at some processing centers ; only incidental amounts of yard waste are likely to enter the waste baling process 3) A baling system will be used to create high-de nsity bales (ca. 1000 pounds per cubic yard) wrapped with at least four layers of adhesive-backed plastic 4) The shape and weight of the bales depends on the technology used but recta ngular bales with weights from 2 to 12 tons might be expected 5) Bales will be stored, or ‘staged,’ for a shor t time—e.g., five days (Pac ific Rim Environmental Resources, 2004)—before transport to allow bales to become anoxic 6) Manifested bales will be moved on barges to the mainland, a trip of about 12 to 18 days 7) Bales will eventually be unloaded a nd moved by truck or by rail to a landfill 8) In procedures likely to be specified in complia nce agreements, companies will monitor bales to detect ruptures and punctures during transport, with par ticular regard for handli ng operations (loading and unloading) 9) Landfilled bales will be covere d with at least six inches of soil within 24 hours (EPA, 1993) 10) Landfilled bales will ultimately be covered by at least seven feet of material if placed on the top (final) waste layer, but many more feet if placed closer to the bottom layer

Other important points include the following:

▪ Hazardous and liquid wastes wi ll be diverted or removed before shredding and baling

▪ Waste and bales will not contact soil after collecti on or wrapping (i.e., stored on asphalt, concrete, etc)

▪ Imperfectly sealed bales found during stagi ng in Hawaii will be rewrapped and re-staged

▪ Fewer ruptures of bales seem likely to occur with tr actors that have grabbing rather than forked lift arms (Figure 1)

▪ Companies will deal appropriately with puncture s and small ruptures detected after shipment

▪ Companies will handle larger ruptures by collect ing spilled waste, storing all waste in sealed containers, and rewrappi ng and re-staging waste

▪ Spills will be cleaned up and disinfected accord ing to USDA guidelines for spills of international garbage (PPQ, 2004)

▪ All ruptures and punctures will be documented and reported regularly to PPQ and State officials

▪ Destination landfills will be mode rn facilities that meet all regul ations for design and operation (e.g., EPA, 1993)

Finally, we presumed here that af ter creation, bales will only be move d once into staging, and then once again onto barges bound for the mainland. (Of cour se, bales will once again be handled on the mainland.) Additional handling in Hawaii, for instance to transport bales from other islands to a central location for staging and barge loading, would increase the risk of punctures and ruptures.PRA for Baled Hawaiian Solid Waste 16 4 Figure 1. Example tractor with ‘grabbing’ lift arms for handling bales.



## IV. Validity of the baling technology

Although sizes and shapes of bales depend on the ex act technology used, bale creation processes and specifications are similar across different manuf acturers (e.g., DEKRA (1996), Roll Press Pack International, Ltd. (2004), RPP America (2004), and Cross Wrap (2004)). Information from manufacturers (e.g., DEKRA, 1996) was corroborated by independent research (s ee below). During the baling process waste material is shredded if n ecessary, compressed to a high density, wrapped with bands or netting to maintain shape (Fig. 2), and then wrapped with adhesive-coa ted LDPE. At least four layers of plastic are used, form ing a strong, airtight barrier (Appe ndix A). Bale shape depends on the process, with cylinders created in “roll-press” systems and rectangl es created in ramming systems (e.g., Baldasano et al., 2003). Roll-press systems tend to re sult in bales with less trapped air (Sieger and Kewitz, 1997). The degree of compression is typically gr eater with rectangular ba les, and more liquid is pressed out as well. Bale densities are expe cted to be in the range of 800 to 1100 kg/m 3 (ca. 1300 to 1800 lbs/yd 3 ) (Baldasano et al., 2003).

The bales become anoxic within a few days after wr apping (Paillat and Gaillar d, 2001; Robles-Martinez and Gourdon, 1999). The O 2 concentration of normal air is 21 pe rcent (21 kPa), but concentrations in bales were near 2 percent (ca. 2 kPa). Because of th at and other factors, very little biodegradation or production of gases occurs.

The wrapping is strong as well as airtight. Accord ing to Baldasano et al. (2003), the LDPE “...has a high, although not total, degree of re sistance to perforation and tearing.” Pre-stretching helps maintain bale shape, increases adhesion, and helps prevent ruptures. Bales weighing less than 1000 kg did not rupture when dropped from a height of 3 m (DEKRA, 1996). A user in Utah reported that bales larger than 1000 kg rupture when dropped 3.1 to 7.6 m (10 to 25 ft) onto the vertical si des of railroad cars (pers. comm., Barry Edwards, North Pointe Waste Transfer Station, Lindon, UT). USDA will not allow Hawaiian baled MSW to be handled that way. Pointed or sharp objects within the bales might perforatePRA for Baled Hawaiian Solid Waste 1 6 5 the plastic (Baldasano et al., 2003) but we found no indication that this has commonly occurred, and compression would reduce that possibility.

Under normal storage conditions, the bales typically remain airtight for many months (Robles-Martinez and Gourdon, 2000). LDPE film degrades over time when exposed to sunlight. The plastic film used in this baling process is expected to remain effective for at least 100 days (Paillat and Gaillard, 2001) and possibly for up to 12 months (Baldasano et al., 2003) in direct sunlight. The combined storage and

transit time from Hawaii to the mainland is unlikely to exceed 100 days (see below).

The adhesive-backing provides the pl astic film with a self-sealing capability: small ruptures (size unspecified) tend to become airti ght again (Paillat and Gaillard, 2001). That, and the density of the waste itself, should help mitigate the chance of ma terial escaping through punctures and small ruptures but cannot be relied upon exclusively. The plastic or metal netting used in some baling technologies to maintain shape would also limit the chance of wast e and plant pests escaping through ruptures but the rectangular bale system apparently uses straps rather than netting.

Overall, the waste baling technol ogies using adhesive-backed plasti cs seem very sound, creating strong, airtight bales that can be safely handled, stored, and transported.

©2006 PAALGroup. Used by permission Figure 2. A representative high-density ba le of compacted solid waste, ready to be wrapped in adhesive-backed plastic.



## V. Potential plant pests

Specific pests are not discussed here because the sp ecies of interest will depend upon the destination, and because the baling technology will be universally eff ective against all types of pests if bales remain airtight. Lists of selected Hawaiia n insects, pathogens, and pest pl ants of quarantine concern for thePRA for Baled Hawaiian Solid Waste 16 6 contiguous 48 states are given in Ap pendix A. Those lists include both plant pests and other pests that pose human health risk s (e.g., cockroaches).



## VI. Pest risk mitigations

Mitigations considered here either result from the baling technology its elf or features of the proposed pathway, including the waste type, and how bale s are staged, handled, transported, and buried.



### Mitigations from the baling technology

Bales that remain airtight from creation until burial completely mitigate the risk from all plant pests because the pests and pest propagules cannot escape. Th at mitigation is universal, i.e. it does not depend on pest type or taxonomy, and probably applies equally to both current and future pests that establish in Hawaii. Because of the possibility of accidental ruptures or punctures, however, we also consider pest mortality and the effects of other pathway factors.

Given that achieved bale de nsities should be about 1000 kg/m 3 , compaction would likely kill most insects, regardless of stage (see Montgomery and Manning, 2004). This would therefore greatly reduce the possibility of boring-type insects chewing th rough the plastic wrapping, which, moreover, would only be possible if those insects ended up on the outermost surface of the compacted waste. In addition, compaction ensures no whole fruit will enter bales. Compaction may also neutralize some weed seeds and nematodes, but at a greatly reduced rate than for other organism types. Shredding will have some mitigative effects if done, but that would depend on the technology used and the pest organism type.

Anoxia would kill any insects and in sect propagules or mollusks that remain viable in the bales, probably within a few days (Hinton, 1981; Hoback and Stanley, 2001; Montgomery and Manning, 2004; Navarro and Donahaye, 2005; Robinson, 2006; Woods and Hill, 2004). This idea has been used for centuries for pest-free food storage (e.g., De Lima , 1990). Concentrations of less than 3 percent O 2 provide control, while concentra tions of less than 1 percent provi de rapid control (Navarro and Donahaye, 2005). Adults and eggs of insects ar e probably most sensitive to hypoxia (Hoback and Stanley, 2001). Insect and mollusk mortality is important because, of the pest organisms considered here, only those actively disperse.

Anoxia by itself would not kill most weed seeds (P aillat and Gaillard, 2001). Some pathogens would be killed by persistent anoxia, such as some bacteria and nematodes, but many ot hers could be unaffected (L.M. Ferguson, 2005, CPHST, pers. commun.,).



### Mitigation from pathway procedures

Waste stream . For MSW in the United States, paper is th e single largest component at 35 percent, on average, while inorganic components (e.g., plastic, glass) make up an additional 32 percent (EPA, 2005). Food waste and yard trimming each make up 12 percent, and wood makes up 6 percent of the waste stream. Exclusion of yard and agricultural waste from the ba ling waste stream in Hawaii should reduce the number of potential pest s and pest propagules in this pa thway to very low levels. Green recycling operations in urban areas (e.g., Refuse Division, 2006) that sepa rate the collection and processing of yard and agricultural waste from gene ral MSW may also help reduce the chance of wastePRA for Baled Hawaiian Solid Waste 16 7 contamination. Regulated plant pests or pest propagules are likely to only be present in an extremely small proportion of any baled yard waste.

On Oahu, the MSW most likely to be diverted to baling and transport is raw MSW going to Waimanalo Gulch landfill, which has a mean of 6.0 percent ya rd waste (± 3.4 percent) (R. M. Towill Corporation, 1999). Likewise, MSW on Hawaii has a mean percenta ge of yard waste of 5.4 percent (M. Dworsky, County of Hawaii, 2006, pers. commun. to D. Alontag a). By comparison, the yard waste fraction in

residential MSW on Oahu—which is ve ry unlikely to enter the baling pr ocess—is almost 30 percent (R. M. Towill Corporation, 1999). Companies plan to furt her screen and remove visible yard waste in transfer stations or on bale proce ssing lines. If those procedures were 50 percent effective, they would reduce the fraction of yard waste in baled Hawaiian MSW from 6 percent to 3 pe rcent or less. Screening and exclusion is likely to be made more effectiv e because most yard waste in MSW will be clumped (e.g., bags of grass clippings or leaves). As the pr oportion of yard waste decrea ses, removal will become increasingly difficult. Given the mitigations from baling and other pathway f actors, we think these incidental amounts probably still represent a Low risk of plant pest introduction.

Staging . The minimum staging plus transport time is about 15 days, which is more than enough time for the bales to become anoxic. The maximum staging plus trip time is unknow n. We recommend a waiting period before transport of less than 75 days to av oid nearing the 100-day peri od for the earliest possible degradation by sunlight.

During staging, bales might become contaminated with hitchhiking plant pests, and mollusks in particular (Robinson, 2006). For exampl e, plastic-wrapped pallets of stone and tiles from Italy that are left in fields before shipping ha ve often become contaminated w ith snails and slugs (USDA-APHISPPQ, 2005). The requirement that bales not contact soil should reduce the risk of contamination. Still, we strongly recommend that the two following precautions also be taken: 1) that bales be staged or stored as far from vegetation and pavement borders as possible, and 2) that bale s be certified as snailand slug-free before shipment (details to be specified in compliance agreements).

Handling . Ruptures and punctures of ba les are most likely to occur during loading and unloading; moving accidents will probably be ra re. These rates are as yet unknown. P unctures seem very unlikely to occur if tractors have grabbing lift ar ms rather than forks. Bales may r upture if dropped from heights of 3 m or more; that depends upon bale weight and shape and other factors. Using tr actors like that in Fig. 1 will greatly reduce the risk of drops from si gnificant heights—because bales are clamped during

movement rather than balanced on forks—even if bales are occasionally stacked 3 m high or more, such as might happen during staging.

Monitoring. Companies will likely be required to monitor bales for two things: 1) punctures and ruptures, and 2) the presence of hitchhiking snail and slug pests befo re bales depart for the mainland (above). If bales are to be certifie d mollusk-free, responsible parties will need to be specified in compliance agreements. Ruptures are likely to be de tected, since they will probably result from drops, and we expect any dropped bales to be inspected carefully at the tim e. Punctures are less likely to be detected but are much less likely to occur if grabbing- type lift arms are used, and are most likely to selfseal (see above). All compliance will be monitored by PPQ and/or State personnel.

Transport on the mainland . See Section (VII) below.PRA for Baled Hawaiian Solid Waste 16 8 Clean up . Bale density, binding materials, and the self-s ealing ability of the LD PE should all limit the amount of escaping material. Most weed seeds and pl ant pathogens will have little or no ability to disperse after a spill. One ex ception may be spores which are small enough for wind-dispersal. Pathogens dispersing to a susceptible host, or invasive plant seeds disper sing to a suitable site for growth are highly unlikely, assuming clean-up procedures are followed scrupulousl y. Thorough cleaning should capture nearly all waste material, and proper us e of approved disinfectan ts (PPQ, 2004) will likely control any escaped pathogens.

Landfilling . Because of monitoring, bale-handling technolog ies, and the low number of times bales will be handled, only airtight bales are likely to enter the landfill. If the handling equipment used in the landfills is similar to that used previously, ruptur es during placement will be unlikely. Covering with a

6-inch barrier of soil or other material (see 40CFR§258.21) within 24 hours will further mitigate the possibility of dispersal of plan t pests or propagules, by both natura l and vector-caused means. Baled waste is unlikely to be attractiv e to vectors because of its compos ition, appearance, and the lack of odorous biodegradation (above). Most proposals specify that bales will be landfilled separately from other waste (“monofilled”); this means bales will not be subjected to compacting of regular, loose MSW by tractors. Ultimately, landfilled bales will be covered with from seven to dozens of feet of materials (see 40 CFR §258.60), depending upon the layer in which they are placed. In addition, the final cover has water-impermeable layers (EPA, 1993).



## VII. Risk of bale-rupturing accidents

Model development and parameterization

We estimated the annual accident rates for trucks, trai ns, and barges, and years to the first bale-rupturing accident for each, in a probabilistic model (Appendix B) . We did this for generic but realistic travel distances of 25 miles by truck, 500 miles by rail, and 140 miles by barg e on the Columbia River. From the number of 3.3-ton bales required to transport 300,000 tons of MSW, and th e number of bales per truck (25 ton capacity, 7 bales per truck on averag e), barge (10,000 ton capac ity, ca. 2,900 bales per barge), and train (ca. 2900 bales), we calculated the annual number of trips require d, total vehicle miles traveled (VMT), and, for barges, annual ton-miles (the product of tons a nd distance transported). Importantly, not every accident woul d rupture bales. For trucks, for example, fender-benders would not represent a risk for bale ruptures, while rollovers would. Thus we assu med that only bales ejected from the conveyance would be likely to rupture.

Truck . The mean national accident rate for trucks was 1.96 per million VMT (2000 to 2004) (Analysis Division, 2006; Federal Motor Carrier Safety Admini stration, 2004). The fraction of those relevant to the transportation of baled MSW—accidents to flat bed trailers moving intrastate—was about 1.5 percent . The fraction of accidents that released some cargo was 0.325 for flat bed trucks (1991 to 2000: Craft, 2004).

Train . For the period from 1996 to 2005, the mean accid ent rate for trains was 3.94 per million VMT (all rail modes: Office of Safety Analysis, 2006). The fraction of those accidents relevant to baled MSW was the product of the proportion that occurred on main lines (i.e., greater speed), about 0.55, and the proportion of those that occurred to freight tr ains, about 0.47 (e.g., Federal Railroad Administration, 2005b). Finally, data from the same source on the proportions of accidents in which hazardous materialsPRA for Baled Hawaiian Solid Waste 1 6 9 were released for 2000 to 2004 indicated that the m ean likelihood for a cargo spill (i.e., bale rupture) was 0.039 (3.9 percent).

Barge . The average haul distance for the Columbia Ri ver of 140 miles was es timated directly from freight transport data (e.g., U.S. Army Corps of Engineers, 2003): that di stance approximated the average known distances that bales will likely be moved by transport companies. For the most recent available data, the number of accidents on the Co lumbia River was 80 in 2000 and 87 in 2001 (Marine Safety Offices, 2006). Accounting for the amount of freight moved (U.S. Army Corps of Engineers, 2002, 2003) gave a mean accident rate for barges of 28.3 per billion ton-miles [a ton-mile is the product

of the mass and distance moved]. Of those, only 4 of the 167 accidents (2.4 percent) on the Columbia River involved freight barges (Mar ine Safety Offices, 2006). The mean fraction of accidents that might cause bales to rupture was 0.11, estimated from th e number accidents involving hazardous materials which resulted in releases (spills) from 1990 to 1997 (Office of Hazardous Materials Safety, 1999).



### Results and discussion

Using the above parameter estimates in a probabi listic model (@Risk version 4.5.4 - Professional Edition, Palisade Corporation, Ithaca, NY), we estimat ed that the annual like lihood of a bale-rupturing accident was 0.0035 for trucks, 0.0007 for trains, and 0.0029 for barges. The corresponding mean time to first bale-rupturing accident was 285 yr for trucks, 344 yr for barges , and more than 1,400 yr for trains (Fig. 3). We found a 95 percent chance that the first bale-rupturing accident w ould occur only after 15 yr for trucks, after 18 yr for barg es, and after 74 yr for trains.

Reductions in trip distance below 25 miles for trucks, 500 miles for trains, or 140 miles for barges would decrease the likelihood of bale-rupturing accidents. Fo r example, the distance from the off-loading point to the landfill in Roosevelt, WA, is only 8 miles, m eaning the risk of a truck accident for that particular pathway would likely be about two-thirds less. Sim ilarly, accident rates would be proportionate to the total amount of MSW transported, so accident rates would be somewhat less at the start of operations until the capacity increased. Typically, proposals to move baled MSW from Hawaii use only two of the three conveyance types.PRA for Baled Hawaiian Solid Waste 1 70 0 0.2 0.4 0.6 0.8

1

0 1000 2000 3000 4000

Years to first bale-rupturing accident (no.)Cumulative probability

Trucks

Trains

Barges

Figure 3 . Model results for years to first bale-rupturing via three types of

conveyances. Arrows indicate mean va lues of the output distributions.



## VIII. Qualitative risk assessment

The baling technology is sound and shoul d ensure that MSW is shipped on ly in strong, airtight bales. Compaction and the use of the baling technology may not kill seeds of invasive plants or some types of plant pathogens but makes their escape extremely unlik ely. It especially mitigates against insect pests because of anoxia-induced mortality within a few days. Pathogens and seeds of invasive plants cannot actively disperse and except for significant ruptures would have little chance of escaping and coming into contact with acceptable hosts or suitable growth sites. Because of the structure of the bales, only catastrophic ruptures—which should al ways be detected—might facilita te significant dispersal of pests or pest propagules. The handling procedures, strength of the plasti c wrapping and strapping materials, and the probable small accident rate for final transport to the landfill (above) reduce the likelihood of ruptures. Other procedures, such as patching or re-wrapping bales, cleanup and disinfection, and restaging bales will provide further mitigation.

We qualitatively assessed the likelihood of introduction for general pest classes of insects, pathogens, and pest plants (invasive plants and weeds). We followed the PPQ guidelines for conducting pathwayinitiated risk assessments (PPQ, 2000), and modified them where appropriate. Some subelements were removed because they did not apply to this pathway, and totals were revised accordingly. Only the general pest classes of insects, mo llusks, pathogens, and pest plants (invasive plants and weeds) were scored, because the baling technol ogy is so broadly effective, and the very small likelihood of introduction for any particular pest. For each subeleme nt a score of either none = 0, low = 1, moderate = 2, or high = 3, was given. Values of zero are not us ually possible but were r easonable here because ofPRA for Baled Hawaiian Solid Waste 1 71 the potential effectiveness of th e technology. Cumulative risk rating intervals were Low = 0 to 6, Moderate = 7 to 9, and High = 10 to 12 (after PPQ, 2000).

The likelihood of introduc tion of plant pests inside bales of MSW was least for insects and mollusks (score = 1; Table 1), as expected due to mortality from anoxia. Cu mulative ratings for pathogens and pest plants were greater because of the increased likelihood of survival inside the bales, but were still

Low overall. Even if we assumed a moderate rate for accidental ruptures of bale s, so that the likelihoods of pests dispersing and coming in co ntact with a suitable host or site were equal to 1, the overall risk estimates would still be Low (tot al = 6, for pathogens and weeds).

Lastly, we did not include hitchhiking mollusks in Table 1, because as contaminating pests they would

not reside in the bales, but under the same scoring they w ould rate High risk (1 + 3 + 3 + 3 = 10). This highlights the need to properly stag e bales and certify them as being mollusk-free before shipment (see above).

Table 1 . Qualitative risk ratings for th e likelihood of introduction into the continental United States for three pest types via Hawaiian municipal solid wast e in airtight bales. H itchhiking pests were not considered here (see text).

Pests Risk subelements

1 2 3 4 Annual quantity imported Survive baling and shipment Moved to

suitable habitat Contact suitable

host or site Cumulative risk ratings

Insects 1 a 0 0 0 1

Mollusks 1 0 0 0 1 Pathogens 1 2 2 0 5 Pest plants 1 2 2 0 5

a The total amount of baled municipal solid waste may be high, but the proporti on of waste that might harbor plant pests is low.



## IX. Conclusions

Transporting urban solid waste from Hawaiian cities to the continenta l United States in airtight bales poses a Low risk of pest introduction. That is beca use the baling technology mitigates the risk from all types of plant pests, and the other pathway proce dures should adequately protect against accidental ruptures and punctures in bales during the handling and transport process and subsequent escapes of pests and pest propagules. We also recommend proper staging of bale s and certifying them as molluskfree to mitigate against contaminating pests. So l ong as those processes and the procedures proposed by the companies—including diversion of yard and ag ricultural waste, prompt shipment, monitoring and inspection of bales, and thorough clean up of any rupt ures that do occur—are followed, establishment of Hawaiian plant pests via this pathway is highly un likely. We recommend that this new pathway be monitored for some time to ensure that pathway proce dures match those described here from proposals.PRA for Baled Hawaiian Solid Waste 1 72 Lastly, only the plant pest risk associated with the pathway was a ddressed here. Although we concluded that the overall pest risk was Low, complete approval by USDA for the pathway or particular procedures should not be inferred. The pathway, in whole or in part, may still be subject to denial or modification based upon other constraints (pest or non-pest related), such as logistics, availabl e resources, or other Federal regulations.



## Contact

Barney P. Caton, Ph.D., Ecologi st and Pest Risk Analyst CPHST, Plant Epidemiology and Risk Analysis Laboratory (PERAL) 1730 Varsity Drive, Suite 300 Raleigh, NC 27606 919-855-7504; 919-855-7595 (fax) barney.p.caton@aphis.usda.gov

Authors : Barney P. Caton, Lisa M. Ferguson, a nd Betsy Randall-Schadel (PERAL, CPHST)



## References

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pp. Woods, H.A., and R.I. Hill. 2004. Temperature-depende nt oxygen limitation in insect eggs. The Journal of Experimental Biology 207:2267-2276.PRA for Baled Hawaiian Solid Waste175AppendicesAppendix A.Lists of selected Hawaiian pests, including insects,pathogens, and pest plants of quarantine significance tothe continental United States. The lists focus on plant pests but also include other categories of pests, such as humanhealth pests.Table A1. Selected exotic or quarantine-significant plant pests from Hawaii for the 48 contiguous statesin the United States. NOTE: This isnot a complete list of all quarantine-significant pests from Hawaii and should not be regarded as such.Pest Geographic Distribution1ReferencesINSECTAACARITetranychidaeOligonychus biharensis(Hirst)HI Bolland, et al., 1998; CABI, 2004; Nishida, 2002Oligonychus mangiferus(Rahman & Sapra)HI Bolland et al., 1998BLATTODEABlaberidaeDiploptera punctata(Eschscholtz)HI Anon., 2005; Evans, 2004; Nishida, 2002BlattellidaeBlattella lituricollis(Walker)HI Anon., 2005; Evans, 2004; Nishida, 2002BlattidaeNeostylopyga rhombifolia(Stoll)HI Anon., 2005; Evans, 2004; Nishida, 2002Platyzosteria soror(Brunner)HI Anon., 2005; Evans, 2004; Nishida, 2002PolyphagidaeEuthyrrhapha pacifica(Coquebert)HI Anon., 2005; Evans, 2004; Nishida, 2002COLEOPTERAAnthribidaeExillis lepidusJordanHI Swezy, 1950BostrichidaeSinoxylon conigerumGerstaekerHI CABI, 2004; Nishida, 2002PRA for Baled Hawaiian Solid Waste176Pest Geographic Distribution1ReferencesCerambycidaeCeresium unicolor(F.)HI Nishida, 2002Coptops aedificator(F.)HI Bridwell, 1920Lagocheirussp.HI, US Nishida, 2002; USDA-APHIS-PPQ, 2005Oopsis nutator(F.)HI Swezy, 1950Sybra alternans(Wiedemann)HI Nishida, 2002; UH-CTAHR and HI-DoA, 2005;USDA-APHIS-PPQ, 2005ChrysomelidaeMetriona circumdata(Herbst)HI CABI, 2001; HI-DoA, 2002Octotoma scabripennisGuerin-MenevilleHI CABI, 2003; Nishida, 2002CucujidaeParandrita aenea(Sharp) (=Laemophlaeus minutus[Oliv.])HI Nishida, 2002CurculionidaeElytroteinus subtruncatus(Fairmaire)HI UH-CTAHR and HI-DoA, 2005; USDA-APHISPPQ, 2002Euscepes postfasciatus(Fairmaire)HI, CA HI-DoA, 2002; O’Brien and Wibmer, 1982Dryophthorus distinguendusPerkinsHI Swezy, 1950Orchidophilus aterrimus(Waterhouse)HI Tenbrink and Hara, 1994aOrchidophilus perigrinator(Buchanan)HI Tenbrink and Hara, 1994bOxydema fusiformeWollastonHI Swezy, 1950NitidulidaeCarpophilus oculatusMurrayHI Ewing and Cline, 2005; Gillogly, 1962; Nishida,2002Epuraea munda(Sharp)HI Ewing and Cline, 2005Epuraea ocularisFairmaire (= Haptoncus ocularis[Fairmaire])HI Chûjô and Lee, 1994; Ewing and Cline, 2005;Nishida, 2002Haptoncus ocularis(Fairmaire)HI Gillogly, 1962; Nishida, 2002PRA for Baled Hawaiian Solid Waste177Pest Geographic Distribution1ReferencesPhenolia attenuata(Reitter)HI Ewing and Cline, 2005Phenolia limbata(F.)HI Ewing and Cline, 2005PlatypodidaePlatypus cupulatusChapuisHI Wood and Bright, 1992ScarabaeidaeAdoretus sinicusBurmeisterHI CABI, 2004; Nishida,2002; USDA-APHIS-PPQ,2005Protaetia fusca(Herbst)HI CABI, 2004; Nishida,2002; USDA-APHIS-PPQ,2005ScolytidaeCoccotrypessp.HI USDA-APHIS-PPQ, 2005Ericryphalus henshawiHopkinsHI Swezy, 1949Ericryphalus sylvicola(Perkins)HI Swezy, 1950Ericryphalus trypanoidesBeesonHI Van Zwaluwenburg, 1956Euwallacea fornicatus(Eichhoff)HI CABI 2004; Hill 1994; Nishida, 2002; UH-CTAHRand HI-DoA, 2005; Wood and Bright, 1992Hypothenemus ruficepsPerkinsHI Swezy, 1941Xyleborus fornicatusEichhoffHI Swezy, 1950Xyleborus perforans(Wollaston)HI CABI, 2004Xylosandrus morigerus(Blandford)HI CABI, 2004; Wood and Bright, 1992DIPTERAAgromyzidaeLiriomyzahuidobrensis(Blanchard)HI, CA CABI, 2004; Nishida, 2002; USDA-APHIS-PPQ,2005Melanagromyza splendidaFrickHI Frick, 1953Ophiomyia phaseoliTryonHI CABI, 2003; Hill, 1994; Nishida, 2002; Spencer andSteyskal, 1986PRA for Baled Hawaiian Solid Waste178Pest Geographic Distribution1ReferencesLauxaniidaeHomoneura hawaiiensis(Grimshaw)HI Hardy and Delfinado, 1980LonchaeidaeLamprolonchaea metatarsata(Kertész)HI Hardy and Delfinado, 1980MuscidaeAtherigona hendersoniMallochHI Hardy, 1981OtitidaeEuxesta annonae(F.)HI, FL Steyskal, 1969; Stone et al., 1965Euxesta wettsteiniHendelHI Hardy and Delfinado, 1980PhoridaePuliciphora luciferaDahlHI Hardy, 1964SciaridaeBradysia spatitergum(Hardy) (= Sciara spatitergumHardy)HI Hardy, 1960; Nishida, 2002Scatopsciara nigritaHardyHI Hardy, 1960StratiomyidaeCephalochrysa maxima(Bezzi) (=Cephlochrysa[sic]hovas[Bigot])HI Hardy, 1960; Nishida, 2002Exaireta(=Noexaireta)spinigera(Wiedemann)HI Hardy, 1960; Nishida, 2002SyrphidaeSyritta oceanicaMacquartHI Hardy, 1964Syritta orientalisMacquartHI Hardy, 1964TephritidaeBactrocera cucurbitae(Coquillett)HI CABI, 2003; Nishida,2002; USDA-APHIS-PPQ,2005; White and Elson-Harris, 1994Bactrocera dorsalis(Hendel)HI CABI, 2004Bactrocera latifrons(Hendel)HI CABI, 2004Ceratitis capitata(Wiedemann)HI CABI, 2003; Liquido et al., 1991PRA for Baled Hawaiian Solid Waste179Pest Geographic Distribution1ReferencesTipulidaeLimonia perkinsi(Grimshaw)HI Hardy, 1960HEMIPTERAAleyrodidaeAleurocanthus woglumiAshbyHI, FL CABI 2004; Hill 1994; HI-DoA 2005; Nishida,2002; USDA-APHIS-PPQ, 2005Aleurothrixus antidesmaeTakahashiHI Nishida, 2002; UH-CTAHR and HI-DoA, 2005Aleurotulus anthuricolaNakaharaHI Nishida, 2002; UH-CTAHR and HI-DoA, 2005Orchamoplatus mammaeferus(Quaintance & Baker)HI Nakahara, 1982Parabemisia myricae(Kuwana)HI, CA, FL Nishida,2002; USDA-APHIS-PPQ, 2005Trialeurodes vaporariorum(Westwood)HI, FL UH-CTAHR and HI-DoA, 2005AphididaeMelanaphis sacchari(Zehnter)HI, FL CABI, 2001; Zimmerman, 1948Sitobion(=Macrosiphum)luteum(Buckton)HI, FL Johnson, 2006; Tenbrink and Hara, 1995Toxoptera citricida(Kirkaldy)HI, FL CABI 2004; Nishida, 2002; USDA-APHIS-PPQ,2005CicadellidaeGyponana germari(Stal)HI Nishida, 2002; USDA-APHIS-PPQ, 2005CoccidaeCoccus capparidis(Green)HI Nishida, 2002; USDA-APHIS-PPQ, 2005Coccus viridis(Green)HI, FL Ben-Dov et al., 2005; Wood, 2000Vinsonia stellifera(Westwood)HI, AL, FL, GA Ben-Dov etal., 2005; CABI, 2004; Dawson, 1999CoreidaePhysomerus grossipes(F.)HI HI-DoA, 2002DelphacidaeAloha ipomoeaeKirkaldyHI Giffard, 1917Nesosydne ipomoeicolaKirkaldyHI Fullaway, 1943PRA for Baled Hawaiian Solid Waste180Pest Geographic Distribution1ReferencesDerbidaeLamenia caliginea(Stål)HI Kessing and Mau, 1992DiaspididaeAndaspis punicae(Laing)HI Nishida, 2002; USDA-APHIS-PPQ, 2005Lepidosaphes laterochitinosaGreen (=L. spinulosaBeardsley)HI Beardsley, 1966, 1975; Ben-Dov et al., 2005;Nishida, 2002Parlatoria ziziphi(Lucas)HI, MS CABI, 2003;USDA-APHIS-PPQ, 2005Pseudaulacaspis subcorticalis(Green)HI Ben-Dov et al., 2005FlatidaeSiphanta acuta(Walker)HI Nishida, 2002; UH-CTAHR and HI-DoA, 2005LygaeidaeGraptostethus manillensis(Stal)HI Sakimura, 1944MiridaeHalticus tibialisReuterHI CABI, 2001; HI-DoA, 2002Hyalopeplus pellucidus(Stal)HI HI-DoA 2005; UH-CTAHR and HI-DoA, 2005PseudococcidaeMaconellicoccus hirsutus(Green)HI, CA, FL CABI, 2003; USDA-APHIS-PPQ, 2005Nipaecoccus viridis(Newstead)HI Ben-Dov et al., 2005; CABI, 2004Paracoccus marginatusWilliams & Granara deWillinkHI, FL CABI 2004; USDA-APHIS-PPQ, 2005Pseudococcus cryptusHempel (=P. citriculusGreen)HI Ben-Dov, 1994; USDA-APHIS-PPQ, 2005Pseudococcus dendrobiorumWilliamsHI UH-CTAHR and HI-DoA, 2005; Nishida, 2002Puto barberi(Cockerell)HI Nishida, 2002; USDA-APHIS-PPQ, 2005PsyllidaeBlastopsylla occidentalisTaylorHI Nishida, 2002; USDA-APHIS-PPQ, 2005HYMENOPTERAFormicidaeCamponotus variegatus(F. Smith)HI Anon., 2006; Nishida, 2002PRA for Baled Hawaiian Solid Waste181Pest Geographic Distribution1ReferencesPheidole megacephala(F.)HI Williams, 1931ISOPTERARhinotermitidaeReticulitermes speratus(Kolbe)HI Nishida, 2002; USDA-APHIS-PPQ, 2005TermitidaeNasutitermes cornigera(Motschulsky)HI Nishida, 2002; USDA-APHIS-PPQ, 2005LEPIDOPTERACrambidaeOmphisa anastomosalis(Guenee)HI HI-DoA, 2002Udea despecta(Butler)HI Zimmerman, 1958GeometridaeAnacamptodes fragilaria(Grossbeck)HI, CA HI-DoA, 2002LycaenidaeLampides boeticusLinnaeusHI CABI, 2003; Hill, 1994; Nishida, 2002; USDAAPHIS-PPQ, 2005; Zhang 1994LyonetiidaeBedellia orchilellaWalsingham (=B. somnulentella)HI HI-DoA, 2002NoctuidaeAchaea janataL.HI CABI, 2004; Hill, 1994; Nishida, 2002; Robinson etal, 2003; USDA-APHIS-PPQ, 2005Athetis thoracica(Moore)HI Zimmerman, 1958Chrysodeixis erioosoma(Doubleday)HI Swezy, 1944Eudocima fullonia(Clerck)HI CABI, 2004Spodoptera litura(Fabricius)HI CABI, 2003; Hill, 1994; Nishida, 2002; Pogue,2003; USDA-APHIS-PPQ, 2005; Zhang, 1994Spodoptera mauritiasubsp.acronyctoidesGuenéeHI CABI, 2003; Hill, 1994; Nishida, 2002; Pogue,2003; USDA-APHIS-PPQ, 2005; Zhang, 1994Stictoptera cucullioides(Guenée)HI Zhang, 1994PRA for Baled Hawaiian Solid Waste182Pest Geographic Distribution1ReferencesPieridaeColiassp.HI Nishida, 2002; USDA-APHIS-PPQ, 2005PyralidaeCryptoblabes gnidiella(Milliere)HI CABI, 2004; Nishida, 2002; Zhang 1994Hellula undalis(F.)HI Zimmerman, 1978Maruca vitrataFabriciusHI CABI, 2003; Hill, 1994; Nishida, 2002; Robinson etal, 2003; USDA-APHIS-PPQ, 2005; Zhang 1994TineidaeOpogona purpuriellaSwezyHI Zimmerman, 1978TortricidaeCryptophlebia illepida(Butler)HI Zimmerman, 1978Cryptophlebia ombrodelta(Lower)HI CABI, 2004; Robinsonet al., 2003; Zimmerman,1978Epiphyas postvittana(Walker)HI Ebeling 1959; HI-DoA, 2005; Nishida, 2002; UHCTAHR and HI-DoA, 2005; USDA-APHIS-PPQ,2005; Zhang, 1994ORTHOPTERAGryllotalpidaeGryllotalpa africanaPalisot de BeauvoisHI CABI, 2004PyrgomorphidaeAtractomorpha sinensisBolivarHI Holdaway, 1944TettigoniidaeConocephalus saltator(Saussure)HI Mau, 1977Elimaea punctifera(Walker)HI UH-CTAHR and HI-DoA, 2005Xiphidiopsis litaHebardHI Nishida, 2002; USDA-APHIS-PPQ, 2005PSOCOPTERAEctopsocidaeEctopsocus fullawayiEnderleinHI Zimmerman, 1948PRA for Baled Hawaiian Solid Waste183Pest Geographic Distribution1ReferencesTHYSANOPTERAThripidaeChaetanaphothrips signipennis(Bagnall)HI Wood, 2000Dichromothrips corbetti(Priesner)HI Nishida, 2002; UH-CTAHR and HI-DoA, 2005Frankliniella schultzei(Trybom)HI, FL CABI, 2004Helionothrips errans(Williams)HI Nishida, 2002; UH-CTAHR and HI-DoA, 2005Scirtothrips dorsalisHoodHI CABI, 2003Thrips palmiKarnyHI, FL CABI, 2004; Wood, 2000CHROMISTAAlbugosp. (Oomycetes: Peronosporales)HI Farr et al., 2006Aphanomycessp. (Oomycetes: Saprolegniales)HI Farr et al., 2006Phytophthora katsuraeKo & Chang (Oomycetes:Pythiales)HI Farr et al., 2006Phytophthora meadiiMcRae (Oomycetes: Pythiales)HI Farr et al., 2006Phytophthora tropicalisAragaki & J.Y. Uchida(Oomycetes: Pythiales)HI Farr et al., 2006FUNGIFarr et al., 2006Acremonium recifei(Leão & Lôbo) W. Gams(Ascomycetes: Hypocreales)HI Farr et al., 2006Acrodictys fimicolaEllis & Gunnell (Ascomycetes:Incertae sedis)HI Farr et al., 2006Allomyces arbusculusButler (Chytridiomycetes:Blastocladiales)HI Farr et al., 2006Alternaria aragakiiSimmons (Ascomycetes:Pleosporales)HI Farr et al., 2006Amazoniaspp. (Ascomycetes: Meliolales)HI Farr et al., 2006Anungitea fragilisSutton (Ascomycetes: Incertae sedis)HI Farr et al., 2006PRA for Baled Hawaiian Solid Waste184Pest Geographic Distribution1ReferencesAschersonia marginataEllis & Everh. (Ascomycetes:Hypocreales)HI Farr et al., 2006Ascochytaspp. (Ascomycetes: Incertae sedis)HI Farr et al., 2006Aspergillusspp. (Ascomycetes: Eurotiales)HI Farr et al., 2006Asteridiellaspp. (Ascomycetes: Meliolales)HI Farr et al., 2006Asteromella lantanaePetr. (Ascomycetes:Pleosporales)HI Farr et al., 2006Atichia solaridiscoideaMeeker (Ascomycetes: Incertaesedis)HI Farr et al., 2006Bactridium flavumKunze (Ascomycetes: Incertaesedis)HI Farr et al., 2006Beauveriasp. (Ascomycetes: Hypocreales)HI Farr et al., 2006Beltraniella portoricensis(Stevens) Piroz. & Patil(Ascomycetes: Xylariales)HI Farr et al., 2006Bipolarisspp. (Ascomycetes: Pleosporales)HI Farr et al., 2006Botryodiplodiasp. (Ascomycetes: Incertae sedis)HI Farr et al., 2006Botryosphaeria parvaPennycook & Samuels(Ascomycetes: Dothideales)HI Farr et al., 2006Botrytisspp. (Ascomycetes: Helotiales)HI Farr et al., 2006Calonectria insularisSchoch & Crous (Ascomycetes:Hypocreales)HI Farr et al., 2006Calonectria pauciramosaSchoch & Crous(Ascomycetes: Hypocreales)HI, FL Farr et al., 2006Cercospora aciculinaChupp (Ascomycota:Mycosphaerellales)HI Farr et al., 2006Ceuthospora latitans(Fr.:Fr.) Höhn. (Ascomycetes:Helotiales)HI, AK Farr et al., 2006Chaetophomasp. (Ascomycetes: Incertae sedis)HI Farr et al., 2006Cladosporiumspp. (Ascomycota: Mycosphaerellales)HI Farr et al., 2006PRA for Baled Hawaiian Solid Waste185Pest Geographic Distribution1ReferencesClypeoseptoria rockiiStevens & Young (Ascomycetes:Incertae sedis)HI Farr et al., 2006Colletotrichum artocarpiDelacr. (Ascomycetes:Phyllachorales)HI Farr et al., 2006; Raabe et al., 1981Colletotrichum dianellaeStevens & Young(Ascomycetes: Phyllachorales)HI Farr et al., 2006Coniothyrium nitidaeCrous & Denman (Ascomycetes:Pleosporales)HI Farr et al., 2006Cordana musae (Zimmerm.) Höhn. (Ascomycetes:Incertae sedis)HI Farr et al., 2006Cryptosporiopsis eucalyptiSankaran & B. Sutton(Ascomycetes: Helotiales)HI Farr et al., 2006Curvulariaspp. (Ascomycetes: Pleosporales)HI Farr et al., 2006Cylindrocarponspp. (Ascomycetes: Hypocreales)HI Farr et al., 2006Cylindrocladiumspp. (Ascomycetes: Hypocreales)HI Farr et al., 2006; Killgore, 2005; UH-CTAHR andHI-DoA, 2005Cylindrosporiumsp. (Ascomycetes: Helotiales)HI Farr et al., 2006Cytosporasp. (Ascomycetes: Diaporthales)HI Farr et al., 2006Dinemasporiumsp. (Ascomycetes: Incertae sedis)HI Farr et al., 2006Diplodia sheariiPetr. (Ascomycetes: Dothideales)HI Farr et al., 2006Discosiaspp. (Ascomycetes: Incertae sedis)HI CSREES, 2004Dothiorella opuntiaeSiemaszko ex Petr.(Ascomycetes: Dothideales)HI Farr et al., 2006Elsinoë batatasViégas & Jenkins (Ascomycota:Myriangiales)HI CABI, 2001; Raabe et al., 1981Enthallopycnidium gouldiaeStevens (Ascomycetes:Incertae sedis)HI Farr et al., 2006Eriosporella calami(Niessl) Höhn. (Ascomycetes:Incertae sedis)HI Farr et al., 2006PRA for Baled Hawaiian Solid Waste186Pest Geographic Distribution1ReferencesExserohilumspp. (Ascomycetes: Pleosporales)HI Farr et al., 2006Flavodon cervinogilvum(Jungh.) Corner(Basidiomycetes: Polyporales)HI CSREES. 2004; Farr etal., 2006; Gilbertson, et al.,2002Fomitopsis nivosa(Berk.) Gilb. & Ryvarden(Basidiomycetes: Polyporales)HI, FL, SC Farr et al., 2006; Gilbertson, et al., 2002Fusariumspp. (Ascomycetes: Hypocreales)HI Farr et al., 2006Fusicoccum canavaliaeLyon (Ascomycetes:Dothideales)HI Farr et al., 2006Gampsonema exile(Tassi) Nag Raj (Ascomycetes:Incertae sedis)HI Farr et al., 2006Gloeocoryneum hawaiienseSutton & Hodges(Ascomycetes: Incertae sedis)HI Farr et al., 2006Gloeosporiumspp. (Ascomycetes: Helotiales)HI UH-CTAHR and HI-DoA, 2005Harknessia gunneraeStevens & Young (Ascomycetes:Diaporthales)HI Farr et al., 2006Lasmeniasp. (Ascomycetes: Incertae sedis)HI Farr et al., 2006Leptothyrium gleicheniaeStevens & Young(Ascomycetes: Incertae sedis)HI Farr et al., 2006Libertella kokiaePetr. (Ascomycetes: Xylariales)HI Farr et al., 2006Marssoninasp. (Ascomycetes: Helotiales)HI Farr et al., 2006Melanconiumsp. (Ascomycetes: Diaporthales)HI Farr et al., 2006Microporus flabelliformis(Klotzsch) Pat.(Basidiomycetes: Polyporales)HI Farr et al., 2006Mycoacia kurilensisParmasto (Basidiomycetes:Polyporales)HI Farr et al., 2006;Gilbertson, et al., 2002Mycosphaerella artocarpiStevens & Young(Ascomycetes: Mycosphaerellales)HI Farr et al., 2006; Raabe et al., 1981Mycotribulus mirabilisNag Raj & Kendr.(Ascomycetes: Incertae sedis)HI Farr et al., 2006PRA for Baled Hawaiian Solid Waste187Pest Geographic Distribution1ReferencesNeonectria rugulosa(Pat. & Gaillard) Mantiri &Samuels [=Nectria rugulosaPat. & Gaillard](Ascomycetes: Hypocreales)HI Farr et al., 2006Penicilliumsp. (Ascomycetes: Eurotiales)HI CABI, 2001; Raabe et al., 1981Pestalotiasp. (Ascomycetes: Xylariales)HIPhanerochaete australisJülich (Basidiomycetes:Polyporales)HI Farr et al., 2006; Gilbertson and Adaskaveg, 1993Phellinus grenadensis(Murrill) Ryvarden(Basidomycetes: Hymenochaetales)HI, LA Farr et al., 2006Phlebia acanthocystisGilb. & Nakasone(Basidiomycetes: Polyporales)HI Farr et al., 2006;Gilbertson, et al., 2002Phoma agapanthi(Thüm.) Sacc. (Ascomycetes:Pleosporales)HI Farr et al., 2006Phoma caricae-papapae(Tarr) Punith. (Ascomycetes:Pleosporales)HI Farr et al., 2006Phomopsis caricae-papayaePetr. & Cif.(Ascomycetes: Diaporthales)HI Farr et al., 2006Phyllosticta acicolaBissett & Palm (Ascomycetes:Dothideales)HI Farr et al., 2006Pleurophomopsis eucalyptiPetr. (Ascomycetes:Incertae sedis)HI Farr et al., 2006Pyrenochaetasp. (Ascomycetes: Pleosporales)HI Farr et al., 2006Ramularia ipomoeaStevens (Ascomycetes:Mycosphaerellales)HI Farr et al., 2006Rhabdospora pittosporiStevens & Young(Ascomycetes: Incertae sedis)HI Farr et al., 2006Rhizoctoniaspp. (Basidiomycetes: Polyporales)HI Farr et al., 2006; Killgore, 2005Rhizopussp. (Zygomycetes: Mucorales)HI Raabe et al., 1981PRA for Baled Hawaiian Solid Waste188Pest Geographic Distribution1ReferencesRobillarda rhizophoraeKohlm. (Ascomycetes:Incertae sedis)HI Farr et al., 2006Septogloeum arachidisRacib. (Ascomycetes: Incertaesedis)HI Farr et al., 2006Septoria canavaliaeLyon (Ascomycetes:Mycosphaerellales)HI Farr et al., 2006Septoriella rockiana(Petr.) Nag Raj (Ascomycetes:Dothideales)HI Farr et al., 2006Sphacelomasp. (Ascomycetes: Myriangiales)HI Farr et al., 2006Sphaeropsis tumefaciensHedges (Ascomycetes:Incertae sedis)HI, FL CABI, 2004; Farr et al., 2005Sporonemasp. (Ascomycetes: Helotiales)HI Farr et al., 2006Stagonospora erythrinaeStevens & Young(Ascomycetes: Pleosporales)HI Farr et al., 2006Uredo artocarpiBerk. & Broome (Urediniomycetes:Urediniales)HI Gardner, 1991Verticillium sp.(Ascomycetes:Hypocreales) HI Farr et al., 2006Waydora typica(Rodway) B. Sutton (Ascomycetes:Incertae sedis)HI Farr et al., 2006MOLLUSCAAchatinidaeAchatina fulicaBowdichHI, FL Cowie, 1997, 2002b; Robinson, 2006AmpullaridaePila ampullaceae(Linne)HI Robinson, 2006Pila conica(Wood)HI Cowie, 1997, 2002a; Robinson, 2006Pilasp.HI Cowie, 2002b; Robinson, 2006Pomaceae canaliculata(Lamarck)HI, CA, TX, FL Cowie, 1997, 2002b; Robinson, 2006PRA for Baled Hawaiian Solid Waste189Pest Geographic Distribution1ReferencesHelicarionidaeParmarioncf.martensi(Simroth) [Tentative]HI Cowie, 1997, 2002b; Robinson, 2006HelicidaeCornu aspersum(Müller) [=Cryptomphalus aspersus(Müller);Helix aspersaMüller]HI, CA2, OR2, LA, PA2,NC2, NJ2, SC2, UT, WACowie, 1997, 2002b; Robinson, 2006PhilomycidaeMeghiamtium straitum(Hasselt)HI Cowie, 2002a; Robinson, 2006SubulinidaeBeckianum beckianum(Pfeiffer)HI Robinson, 2006Paropeas achatinaceum(Pfeiffer)HI Cowie, 1997; Robinson, 2006VeronicellidaeLaevicaulis alte(Ferussac)HI Cowie, 1997, 2002b; Robinson, 2006Veronicella cubensis(Pfeiffer)HI (Tentative), AS, PR Cowie, 1997, 2002b; Robinson, 2006NEMATODAAnguinidaeDitylenchus dipsaci(Kühn) FilipjevHI, US CABI, 2001AphelenchidaeAphelenchoidessp.HI USDA-ARS, 2005Seinura filicaudataChristie HI Handoo et al., 1998; USDA-ARS, 2005BelonolaimidaeTylopharynx annulatus(Cassidy) GoldenHI USDA-ARS, 2005CriconematidaeCriconemoides palmatum(Siddiqi & Southey)HI USDA-ARS, 2005HeteroderidaeMeloidogyne konaensisEisenbackHI Zhang and Schmitt, 1994MononchidaeMonochussp.HI USDA-ARS, 2005PRA for Baled Hawaiian Solid Waste190Pest Geographic Distribution1ReferencesPanagrolaimidaePanagrolaimussp.HI USDA-ARS, 2005PratylenchidaeHirschmanniella diversaSherHI USDA-ARS, 2005RhabditidaeRhabditussp.HI USDA-ARS, 20051Distribution: AK = Alaska, AL = Alabama, AS = American Samoa, CA= California, FL = Florida, GA= Georgia, HI = Hawaii, LA =Louisiana, MS = Mississippi, NJ = New Jersey, NC= North Carolina, OR= Oregon, PA= Pennsylvania, PR = Puerto Rico, SC = SouthCarolina, TX = Texas, UT= Utah, and WA = Washington2These states have quarantines and or eradication programs in placeTable A2. Selected pest plants (i.e., weeds, invasive plants) in Hawaii that are quarantine-significant for the contiguous 48 states intheUnited States. NOTE: This is not a completelist of all quarantine-significant plant pests from Hawaii and should not be regarded as such. Allpest plant referencesinclude USDA NRCS, 2006.Family Pest plant Geographic distribution1Noxious weed list2AdditionalHI Fed Other1ReferencesAcanthaceaeAsystasia gangetica(L.) T.Anders.HI, FLAgavaceaeFurcraea foetida(L.) Haw.HI, FL HEAR, 2006AmaranthaceaeAlternanthera sessilis(L.) R. Br.ex DC.HI, FL, GA, LA, TX9AL, AR, CA, FL, MA,MN, NC, OR, SC, VTAnacardiaceaeSchinus terebinthifoliusRaddiHI, CA, FL, PR, TX FL, TXAraliaceaeSchefflera actinophylla(Endl.)H.A.T. HarmsHI, FL, PRAsteraceaeAgeratina adenophora(Spreng.)King & H.E. Robins.HI, CA99AL, CA, FL, MA,MN, NC, OR, SC, VTElephantopus mollisKunthHI, PR9Montanoa hibiscifolia(Benth.)Standl.HI9PRA for Baled Hawaiian Solid Waste191Family Pest plant Geographic distribution1Noxious weed list2AdditionalHI Fed Other1ReferencesAsteraceaeSenecio madagascariensisPoir.HI9Tridax procumbensL.HI, FL, PR9AL, CA, FL, MA,MN, NC, OR, SC, VTBasellaceaeAnredera cordifolia(Ten.)SteenisHI, CA, DC, FL, LA, PR, TX9BignoniaceaeSpathodea campanulataBeauv.HI, FL, PR HEAR, 2006BoraginaceaeCordia glabraL.HI, PR APWG, 2006CactaceaeCereus hildmannianusK.Schum.HI, PR9Harrisia martinii(Labouret)Britt.HI9CasuarinaceaeCasuarina equisetifoliaL.HI, FL, PR FLCecropiaceaeCecropia obtusifoliaBertol.HI UH-Botany, 1998CommelinaceaeCommelina benghalensisL.HI, CA, FL, GA, LA9AL, CA, FL, MA,MN, NC, OR, SC, VTConvolvulaceaeIpomoea aquaticaForssk.HI, CA, FL9AL, AZ, AR, CA, FL,NC, OR, SC, TX, VTCucurbitaceaeCoccinia grandis(L.) VoigtHI, FL9FabaceaeCaesalpinia decapetala(Roth)AlstonHI, PR UH-Botany, 1998Prosopis juliflora(Sw.) DC.HI9Prosopis pallida(Humb. &Bonpl. ex Willd.) KunthHI, PR9AL, CA, MA, MN,NC, OR, SC, VTPueraria phaseoloides(Roxb.)Benth.HI, PR9Spartium junceumL.HI, CA, OR, WA9OR, WAUlex europaeusL.HI, CA, MA, NY, OR, PA,VA, WA, WV9CA, OR, WAPRA for Baled Hawaiian Solid Waste192Family Pest plant Geographic distribution1Noxious weed list2AdditionalHI Fed Other1ReferencesLamiaceaeHyptis pectinata(L.) Poit.HI, FL, PR9Hyptis suaveolens(L.) Poit.HI, PR9MalvaceaeMalachra alceifoliaJacq.HI, FL, PR9Urena lobataL.HI, FL, LA, PR9MarattiaceaeAngiopteris evecta(J.R. Forst.)HoffmannHI UH-Botany, 1998MelastomataceaeClidemia hirta(L.) D. DonHI, PR9ISSG, 2006Medinilla venosa(Blume)BlumeHIMelastoma candidumD. DonHI9Melastoma malabathricumL.HI9Miconia calvescensDC.HI9Oxyspora paniculata(D. Don)DC.HI UH-Botany, 1998Tibouchinaherbacea(DC.)Cogn.HI9Tibouchina longifolia(Vahl)Baill. ex Cogn.HI9Tibouchina urvilleana(DC.)Cogn.HI, PR9MimosaceaeAcacia mearnsiiWilld.HI, CA9MyricaceaeMorella faya(Ait.) WilburHI9MyrsinaceaeArdisia ellipticaThunb.HI, FL9MyrtaceaeMelaleuca quinquenervia(Cav.)BlakeHI, FL, LA, PR9AL, CA, FL, MA, NC,OR, SC, TX, VTRhodomyrtus tomentosus(Ait.)Hassk.HI, FL9FLPRA for Baled Hawaiian Solid Waste193Family Pest plant Geographic distribution1Noxious weed list2AdditionalHI Fed Other1ReferencesOleaceaeFraxinus uhdei(Wenzig)Lingelsh.HI, PR HEAR, 2006; UHBotany, 1998PapaveraceaeBocconia frutescensL.HI, PR9PassifloraceaePassiflora bicornisP. Mill.HI9PinaceaePinus caribaeaMoreletHI, PR UH-Botany, 1998PiperaceaePiper aduncumL.HI, FL, PR9PittosporaceaePittosporum undulatumVent.HI, CA9PoaceaeCenchrus echinatusL.HI, AL, AZ, CA, DC, FL, GA,LA, MS, NC, NM, SC, TXAZ, CA UH-Botany, 1998Chrysopogon aciculatus(Retz.)Trin.HI9AL, CA, FL, MA,MN, NC, OR, SC, VTCortaderia jubata(Lem.) StapfHI, CA, ORCymbopogon refractus(R. Br.)A. CamusHI9Digitaria abyssinica(Hochst. exA. Rich.) StapfHI9AL, CA, FL, MA,MN, NC, OR, SC, VTPaspalum scrobiculatumL.HI, AL, GA, MD, NJ, TX9AL, CA, FL, MA,MN, NC, OR, SC, VTPennisetum macrourumTrin.HI, CA, TX9AL, CA, FL, MA,MN, NC, OR, SC, VTSaccharum spontaneumL.HI, PR9AL, CA, FL, MA,MN, NC, OR, SC, VTThemeda villosa(Poir.) A.CamusHI9PolygonaceaeEmex spinosa(L.) Campd.HI, CA, FL, MA, TX99AL, CA, FL, MA,MN, NC, OR, SC, VTPontederiaceaeMonochoria vaginalis(Burm. f.)K. Presl ex KunthHI, CA9AL, CA, FL, MA, NC,OR, SC, VTPRA for Baled Hawaiian Solid Waste194Family Pest plant Geographic distribution1Noxious weed list2AdditionalHI Fed Other1ReferencesProteaceaeGrevilleabanksiiR. Br.HI9RhizophoraceaeBruguiera sexangula(Lour.)Poir.HI HEAR, 2006RosaceaeRubus ellipticusSm. var.obcordatusFockeHI9Rubus niveusThunb.HI, FL9Rubus sieboldiiBlumeHI9RubiaceaeCinchona pubescensVahlHI ISSG, 2006SolanaceaeSolanum robustumWendl.HISolanum torvumSw.HI, AL, FL, MD, PR9AL, CA, FL, MA,MN, NC, OR, SC, VTSterculiaceaeMelochia umbellata(Houtt.)StapfHI UH-Botany, 1998TiliaceaeHeliocarpus popayanensisKunthHI UH-Botany, 1998Triumfetta rhomboideaJacq.HI, FL, PR9Triumfetta semitrilobaJacq.HI, FL, GA, PR9UlmaceaeTrema orientale(L.) BlumeHI HEAR, 2006VerbenaceaeClerodendrum japonicum(Thunb.) SweetHI, MD HEAR, 2006; UHBotany, 1998ZingiberaceaeHedychium gardnerianumShepard ex Ker-Gawl.HI91Distribution: AL = Alabama, AR = Arkansas, AZ = Arizona, CA= California, DC = District of Columbia, FL = Florida, GA = Georgia, HI = Hawaii, LA= Louisiana, MD = Maryland, MA = Massachusetts, MN = Minnesota, MS = Mississippi, NC= North Carolina, NJ = New Jersey, NM = NewMexico, NY = New York, OR= Oregon, PA= Pennsylvania, PR = Puerto Rico, SC = South Carolina, TX = Texas, VA = Virginia, VT = Vermont,WA = Washington, and West Virginia.29= ListedPRA for Baled Hawaiian Solid Waste 19 5 Contact

Barney P. Caton barney.p.caton@aphis.usda.gov (919) 855-7504; (919) 855-7595 (fax)

Authors

Barney P. Caton, Thomas W. Culliney, Lisa M. Ferguson, Andrea V. Lemay, and Betsy RandallSchadel Plant Epidemiology and Risk Analysis Laboratory

Center for Plant Health Sc ience and Technology (CPHST) Plant Protection and Quarantine, Animal and Plant Health Inspection Service U. S. Department of Agriculture 1730 Varsity Drive, Suite 300 Raleigh, NC 27606

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USDA-ARS. 2005. USDA Nematode Collection Search [Online]. Nematology Laboratory, Agricultural Research Service (ARS), U.S. Department of Agriculture (USDA), Beltsville, MD. http://www.nem.barc.usda.gov/database/search.cfm ( verified March 7, 2006). USDA NRCS. 2006. The PLANTS Database, Version 3.5 [Online]. National Plant Data Center,

National Resources Conservation Se rvice (NRCS), U.S. Department of Agriculture (USDA), Baton Rouge, LA. http: //plants.usda.gov ( verified March 8, 2006).PRA for Baled Hawaiian Solid Waste 19 9 Van Zwaluwenburg, R.H. 1956. New records of Scol ytidae. Notes and exhibitions. Proc. Hawaii. Entomol. Soc. 16(1): 9. White, I.M. and M.M. Elson-Harris. 1994. Fruit Flies of Economic Significan ce: Their Identification and Bionomics. CAB International, Wallingford, United Kingdom. 601 pp. Williams, F.X. (comp.). 1931. Handbook of the Insects a nd Other Invertebrates of Hawaiian Sugar Cane Fields. Honolulu: Experiment Station of th e Hawaiian Sugar Planters’ Association. 400 pp. Wood, M. 2000. When “aloha!” means goodbye—to pest s: curbing pests in Hawaii’s ornamental paradise. Agricultural Research 48(9): 4-7. Wood, S.L. and D.E. Bright. 1992. A Catalog of Sc olytidae and Platypodidae (Coleoptera), Part 2: Taxonomic Index. Provo, Utah, Br igham Young University. 1552 pp. Zhang, Bin-Cheng. 1994. Index of Economically Impor tant Lepidoptera. Co mmonwealth Agricultural Bureau International, Wallingford, United Kingdom. 599 pp. Zhang, F., and D. P. Schmitt. 1994. Host status of 32 plant species to Meloidogyne konaensis

. Supplement to the Journal of Nematology 26:744-748. Zimmerman, E.C. 1948. Insects of Hawaii, Vols . 2, 3, 5. University of Hawaii Press, HI. Zimmerman, E.C. 1958. Insects of Hawaii, vols. 7, 8. Univ. Hawaii Press, HI. Zimmerman, E.C. 1978. Insects of Hawaii. Volume 9. Mi crolepidoptera, Part I. Monotrysia, Tineoidea, Tortricoidea, Gracillarioidea, Yponomeutoidea, a nd Alucitoidea. Honolulu: University Press of Hawaii. 882 pp.PRA for Baled Hawaiian Solid Waste 200 

### Appendix B. Modeling the likelihood of bale-rupt uring accidents during transport of baled municipal solid waste (MSW) by truck, rail, or barge.

I. Introduction

Here we describe the approaches used to estimate the likelihoods of bale-rupturing accidents to occur while moving baled MSW to landfills on the mainland Un ited States by either truck, rail, or barge. We did this here for generic but rea listic travel distances of 25 truck miles, 500 rail miles, and 140 barge

miles.

II. Models And Methods

A. Standard simulation settings and functions

All probabilistic analyses and si mulations were performed using @Risk ver. 4.5.2 Professional (Palisade Corporation, 31 Decker Road, Ne wfield, NY 14867). Simulation sett ings were as follows unless otherwise specified: number of ite rations = 20,000; sampling type = Latin Hypercube; and random seed = 101. Equations below are shown in their general form; actual equations used in @Risk can be found in the formulae section in Fig. 1.

Two equations were used most often for probabilistic predictions. Most nodes, or pathway processes, in the model were binomial, meaning that n independent identical trials were conducted, each with the same probability of success, p , as follows (e.g., Vose, 2000):

S

= binomial( n , p ) [1]

where S is the number of successes observed. Both n and p vary by iteration but are ‘constant’ across

the n trials in a single iteration.

The value of p was often determined from a beta distributi on, which estimates the pr obability of success from the observed number of successes, s , and the number of trials, n , as follows:

p = beta( s + 1, ( n

− s ) + 1) [2]

For example, for the probability of an acci dent happening to a freight barge (below), n = total number of

accidents and s = number of accidents for freight barges. Mo re generally, Eqn. (2) is the probability of success during the next (+1) time pe riod or event, given the number of successes and trials already

observed.

B. Numbers and distances of trips

This depended upon the annual amount of baled MSW transported, average bale mass, and the balecarrying capacity of each type of conveyance. We estimated the total annual amount of baled MSW as 300,000 tons (PRER, 2004) with ten percent variabil ity. The resulting distribution was uniform from 270,000 to 300,000 tons annually. In addi tion, the best estimate we have for the annual number of oceanic barge trips to transport that amount is about 36 trips. We estimated the number of trips required

as a uniform distribution between 32 and 36. The number of tons of baled MSW per trip was simply the total amount divided by the number of trips.PRA for Baled Hawaiian Solid Waste 201 From company information, bale mass was estimat ed as a uniform distri bution between 3.2 and 3.35 (lb.) tons (6,400 to 6,700 pounds), which is about 2900 to 3000 kg.

The annual number of bales transported was the to tal mass of baled MSW divided by the mass per bale, and rounded up to the nearest whole number. The mean number of bales per ba rge trip wa s the total number of bales divided by the number of barge tr ips, again rounded up to the nearest integer. The number of bales per train trip was assumed to be th e number per barge, since th e capacity of a 100-car train exceeded that necessary to m ove all the bales on a single barge. The carrying capacity of a flatbed

trailer truck is about 22.7 me tric tons, which gave 7 bales per truck on average.

The total number of trips was calcu lated as the annual number of bale s divided by the carrying capacity for each conveyance, and rounded up. The total numb er of vehicle miles traveled (VMT) was the product of the trip distance and the number of trips. For barges, the number of ton-miles was calculated as the product of total tons and the average trip distance.

C. Total numbers of accidents

In this case, as conveyance move over the total tr ip distance a constant probability of an accident occurring exists: this describes a Poisson process. In a Poisson process the two parameters are λ , the probability of an event (accident) occurring, and d , the amount of exposure. Here d is the distance traveled; in other situations time, t , is often the measure of e xposure. The number of events, s , occurring

within d is the following (Vose, 2000):

s = Poisson( λ d ) [3]

As the exposure level d or the rate λ increase, so does s

.

The national accident rates for trucks and trains ar e based on VMT, while that for barges is based on ton-miles. For trucks the estimated mean rate was 1.96 accidents per million VMT, based on data for numbers of fatal, non-fatal, and property damage-only accidents (Federal Motor Carrier Safety Administration, 2004) and total VMT (Analysis Division, 2006) for the years 2000 to 2004. We specified the rate as a pert dist ribution with the above mean, and minimum and maximum values equal to the lower and upper 99 percent confidence intervals over the fi ve years of data (Fig. B1).

For trains, we estimated the national accident rate from ten years of data, 1996 to 2005 (Office of Safety Analysis, 2006). The overall mean was 3.94 accidents per million VMT, for all companies and all modes (e.g., yards and main lines). The distribution based on the 99 percent confidence limits of the mean was a pert with minimum = 3.665, and maximum = 4.215 (Fig. B2). Ninety percent of the sampled values

were between 3.77 and 4.11.

For barges the accident rate was calculated from recen t statistics for accidents on the Columbia River. In 2000, 80 accidents were reported, and 87 were reporte d in 2001 (U.S. Army Corps of Engineers, 2002, 2003). The corresponding values for annual ton-miles (billions) of freight moved were 2.9 in 2000 and 3.0 in 2001, giving annual accident rates of 27.6 acci dents per billion ton-mile in 2000, and 29.0 in

2001. In the model we used the mean rate of 28.3 accidents per billion ton-miles.PRA for Baled Hawaiian Solid Waste 202 0 0.5

1 1.5

2 2.5

3 3.5

1.6 1.7 1.8 1.9 2 2.1 2.2 2.3

Truck accident rate (no. per million VMT)Probability density

Fig. B1 . The distribution for the truck accident rate, number per million vehicle miles traveled (VMT),

based on data from 2000 to 2004. Lines indicate the 5th and 95th percentiles, so 90 percent of the sampled values will fall in between the lines.

0 0.5

1 1.5

2 2.5

3 3.5

3.6 3.7 3.8 3.9 4 4.1 4.2 4.3

Accident rate for rail (no. per million VMT)Probability density

Fig. B2 . The distribution for the truck accident rate, in number per million vehicle miles traveled (VMT), based on data from 1996 to 2005. Lines indicate the 5th and 95th percen tiles, so 90 percent of the sampled values will fall in between the lines.PRA for Baled Hawaiian Solid Waste 203 D. Numbers of relevant accidents

Not every accident, however, is re levant to transportation of bale d Hawaiian MSW. For trucks in particular, we needed to estimate the number of intras tate accidents to flat-bed trucks, because trips to

landfills will not involve in terstate travel, and because trucks such as cargo vans will not be used to transport bales. In all cases, the number of relevant accidents was a binomial process with N = total

accidents and p = the likelihood of an accident being relevant.

For trucks, we estimated the likelihood of a rele vant accident as the prod uct of the likelihood of accidents during intrastate travel, and the proporti on of accidents occurring to body types that could carry bales (e.g., flatbed trailer vs. cargo van). Both of these were done specifically for data from the states of Idaho, Oregon, and Washington, because rates there may differ from na tionwide statistics. The probability of an accident during intrastate travel in those states was a beta distribution with s = 996 and

n = 6,703 (Federal Motor Carrier Safety Administra tion, 2004), which had a mean value of 0.15, and 90 percent of sampled values were between 0.142 and 0.156. The probability of an accident occurring to a bale-carrying truck body type was also a beta, with s = 361 and n = 3,483, based on data for fatal, injurious, and tow-away accidents (Analysis Divisi on, 2006). That distribution had a mean value of 0.10, and 90 percent of the sampled values were between 0.096 and 0.113.

For trains, we were interested in accidents to freight trains on main lines, sin ce about two-thirds of all

rail accidents occur in and around ra il yards (Office of Safety Analysis , 2006), which are likely to be lower speed accidents in which bales would not rupt ure. First we estimated the likelihood that an accident occurred to a freight tr ain based on data for 2000 to 2004 (F ederal Railroad Administration, 2001, 2003, 2004, 2005a, b). Overall, 8,251 accidents out of 17,588 were to freight trains. From 99 percent confidence intervals for th e annual means, this gave a pert distribution with mean = 0.47, minimum = 0.417, and maximum = 0.523. Ninety percent of the sampled values were between 0.437 and 0.503. Similarly, the likelihood of an accident be ing on a main line was based on data in which 4,524 of the 8,251 freight train accidents occurred on main lines. This data gave a pert distribution with mean = 0.55, minimum = 0.52, and maximum = 0.58, with 90 percent of sampled values between 0.53 and 0.57. The overall probability of an accident being relevant was the product of the two probabilities for freight and main line accidents.

For barges, we were only interested in accidents to freight barges. Very few accidents on the Columbia River in 2000 and 2001 (the most recent data) involved freight barges (U.S. Army Corps of Engineers, 2002, 2003). We estimated the likelihood that an accident was to a freight barge as a beta with s = 4 and

n = 167, which had a mean value of 0.03, and 90 per cent of sampled values were between 0.012 and

0.054.

The probability that a relevant accident would occur annually ( p rel ) was estimated, for each conveyance type, by calculating the number of itera tions in which at least one occurred.

E. Numbers of bale-rupturing accidents

Just as not every truck, train or barge accident will involve transport of baled MSW, not every accident involving baled MSW will result in ruptures of bales. For example, a “fender bender” can be counted as an accident but is highly unlikely to result in ej ection and rupture of cargo. Accordingly, the number ofPRA for Baled Hawaiian Solid Waste 20 4 potential bale-rupturing accident s was a binomial process with N = the number of re levant accidents and

p = the probability that an accident is of a type that could rupture bales.

For trucks, the number of accidents that could results in bale ruptures was determined from data from 1991 to 2000 on flatbed trucks carrying hazardous car go (Craft, 2004). Out of 5,208 total crashes (= n ), 1,690 (= s ) resulted in cargo spills. This beta distribu tion gave a mean of 0.325, and 90 percent of the sampled values were between 0.314 and 0.335 (Fig. B3).

For trains, we found total accidents and the number of accidents likely to cause bale ruptures from 2000

to 2004 data on releases of hazardou s materials relative to the total number of accidents involving hazardous materials (Federal Railroad Admini stration, 2001, 2003, 2004, 2005a, b). The data directly estimated the proportion of rail accidents in whic h spills occur, and since hazardous materials are packaged and handled similarly to baled MSW, usi ng these numbers seemed very appropriate. Overall, releases occurred in only 154 of 3,961 accidents involving hazardous materials. Using 99 percent confidence limits for the annual mean, we specified the distribution as a pert with mean = 0.039, a minimum value of 0.028, and a maximum value of 0.051, where 90 percent of the sampled values were

between 0.032 and 0.046.

For barges, we based our estimate of the likeliho od of bale-rupturing on the number of releases of material in accidents involving tran sport of hazardous material. As with trains, this data seemed most relevant to the quantity being es timated, and did not require assump tions about accident types based on speed or other proxies for release risk. The most recent available data was for 1990 to 1997 (Office of Hazardous Materials Safety, 1999). Over that peri od, 6 of 63 accidents involving hazardous materials

resulted in releases. A beta distribution with s = 6 and n = 63 gave a mean of 0.11, and 90 percent of sampled values were between 0.053 and 0.177 (Fig. B4).

The probability that a bale-rupturi ng accident would occur annually ( p rupt ) was estimated, for each conveyance type, by calculating the number of iterations in which at least one occurred.

Contact/Author

Barney P. Caton Plant Epidemiology and Risk Analysis Laboratory

Center for Plant Health Sc ience and Technology (CPHST) Plant Protection and Quarantine, Animal and Plant Health Inspection Service U. S. Department of Agriculture 1730 Varsity Drive, Suite 300 Raleigh, NC 27606 barney.p.caton@aphis.usda.gov (919) 855-7504; (919) 855-7595 (fax)20 5 

### Appendix D. Risk of Introduction of Pests to Washington State via Municipal Solid Waste from Hawaii.

### United States Department of Agriculture

Animal and Plant Health Inspection

Service

April 2005
Updated, September

2006 

## The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal Solid Waste

from Hawaii

Executive Summary

Companies have proposed transporting large volumes of municipal solid waste (MSW) in airtight bales from Hawaii to landfills in the continental United States. In a previous general pe st risk assessment, CPHST found that the risk of introduction of pests from Hawaii via this pathway was insignificant. Here we focus on a pro posal to transport baled MSW to a landfill in Klickitat County, Washingt on State. We assessed whether any exceptional risks associated with this particular proposal would justify a

different recommendation than wa s made for the general pathway.

Two companies propose to move ba led MSW by barge up the Columbia River, unload it in Roosevelt, WA, and move it eight miles by truck to the Roosevelt Regional Landfill. The landfill is a modern facility complying with relevant federal regulations. The trans portation methods involved are low risk,

and the local environment and climat e do not pose exceptional risks. In particular, the climate in Klickitat County is much drier and colder than that in most large cities in Hawaii, which sh ould greatly reduce th e compatibility of some Hawaiian pests. None of the releva nt Federal or State quarantine plant pests, which included insects, diseases, and pest plants (i.e., weeds, invasive plants), seemed to pose an exception al threat of surviving, escaping and establishing via this pathway.

In conclusion, this proposal closely followed the procedures outlined in the general pest risk assessment, a nd no factors justified a different recommendation. Thus, transportatio n of baled MSW from Hawaii to Klickitat County, Washington, poses an insignificant risk of pest establishment. We recommend that the pathway be monitored to ensure that procedures and compliance do not differ significantly from what was described here and in the ge neral pest risk assessment.PRA for Baled Solid Waste to WA 2 07 Introduction

The Center for Plant Health Science and Technology (CPHST) completed, at the request of the State of Hawaii, a pest risk assessment of the likelihood of introduction of pe sts into the continental United States via the transport of plastic-baled municipa l solid waste (MSW) from Hawaii (CPHST, 2006). The garbage will be baled by compressing it and wrapping it in adhesive-backed, plas tic film barriers made of low density polyethylene (LDPE), creating airtight packages. Bales would be transported by barge to a receiving facility on the mainland a nd buried intact in landfills in a ccordance with regulations for solid waste disposal (40CFR§258; EPA (1993)). Each co mpany would transport perhaps 300,000 tons of MSW per year. A pest risk assessment was required because garbage from Hawaii cannot enter the

continental U.S. under current fe deral regulations for plant pest s (7CFR§330.400). The assessment dealt with parts of the pathway expected to be valid for any company proposing to transport the baled waste.

In the pest risk assessment, CPHST concluded th at if the proposed procedures were followed, transportation of baled Hawaiian MSW posed an in significant risk of pest establishment (CPHST, 2006). Some reasons for that were th at exclusion of most yard and ag ricultural waste from the pathway would greatly reduce the presence of potential plant pests or propagules in the bales; insects, mollusks, and some pathogens and weed seeds are unlikely to survive compaction and tran sport in the bales; and other pathway procedures (e.g. prop er staging, mollusk-free certificatio n, monitoring during transport) would adequately protect against in troductions of pests. A qualitative risk analysis indicated that the cumulative risk ratings for the intr oduction of insects, mollusks, pat hogens, and pest plants in baled

MSW were each Low.

Pacific Rim Environmental Resources, Inc. (P RER) (Luneke, 2004; PRER, 2004) and Hawaii Waste Systems, LLC (HWS) (HWS, 2006), have proposed moving baled MSW from Ha waii to a landfill in Washington State. Bales will be tr ansported by barge to Roosevelt, Washington, and by truck to the Roosevelt Regional Landfill in Klic kitat County. The objective of this assessment is to evaluate the proposals to assess whether any excep tional risk factors warrant a re commendation other than the Low risk ratings given previously. Th e procedures for transporting baled MSW in the documents closely followed the general procedures evaluated in CPHST (2006). Specific items considered here include the destination landfill, the Federal and State quarantine pe sts of concern, the type(s) of transportation used to move bales after reaching the mainland, and any other notable factors in the proposals. Refer to CPHST (2006) for definitions of key terms.

Review of proposal

The details of the proposals are, for PRER, in PR ER (2004) and Luneke (2004), and, for HWS, in HWS (2006). As mentioned above, the general procedures cl osely follow those used in the general assessment (CPHST, 2006). Some important details include the following: 1) The baling system used will create rectangular bales weighing about 3 metric tons (pers. comm., Luneke, PRER Inc.), or between 2 and 4 pound tons (HWS, 2006); in both cas es bale density will be about 1000 kg per cubic meter 2) Bales will move on barges up the Columbia Rive r directly to Roosevelt, WA, a distance from the

ocean of about 253 miles 3) Bales will be unloaded and moved eight miles by truck to the landfillPRA for Baled Solid Waste to WA 208 In addition, the companies specified th eir intention to do the following:

▪ Not allow waste to cont act soil after collection;

▪ Rewrap and re-stage imperfectly seal ed bales found during staging in Hawaii;

▪ Use tractors with “grabbing-type” lift arms or well-padded tines to handle rectangular bales;

▪ Monitor bales for ruptures and punc tures, and track bales in an el ectronic manifesting system; and

▪ Place baling machines at handling s ites to seal ruptured bales when necessary, or move ruptured bales in re-sealed liners and bags designed fo r safe transport of hazardous waste.

Destination landfill Roosevelt Regional Landfill (see http://www.rabanco.c om/disposal.htm), in Klic kitat County near the town of Roosevelt (Fig. 1), is a modern facility that meets regulat ions and EPA guidelines for design and operation (e.g., EPA, 1993). We have no reason to e xpect improper landfilling of bales at this site, and therefore the mitigation likely to come from landfilling seems valid (CPHST, 2006).

Transportation of bales As discussed above, bales will be barged up the Colu mbia River to Roosevelt, offloaded onto trucks,

and driven about 4 miles to the landfill. Roosevelt Regional Landfill has only had one significant truck accident in eight years of transporting loads from the dock to the landfill in Washington (pers. comm., D. Luneke, PRER). Both of those means of transpor t are low risk for potential bale-rupturing accidents (CPHST, 2006). Adapting the generic qua ntitative risk analysis for bale -rupturing accidents to transport of bales to Roosevelt Regional Landfill required an increase in barge miles from 140 to 253, and a

decrease in truck miles from 25 to 4. When these changes were made, the risk of any bale-rupturing accident for trucks was reduced from 0.0035 to 0.0003, wh ile that for barges increased from 0.0029 to 0.0037. Mean years to the first bale -rupturing accident for trucks was 3333, and that for barges was 130. We found a 95 percent chance that the first truck accide nt would occur only after 171 years, or after 7 years for barge transport. The risk of catastrophic rupture of bales while they are being transported by truck or barge to Roosevelt Regional Landfill is therefore very low.

Local environment: geography and climate

Although the likelihood of pests or pest propagules escaping from bales is extremely low, for completeness we briefly discuss here the environmen t through which bales will be transported and into which bales will be deposited. Five general habitat t ypes exist in Klickitat C ounty: 1) dry coniferous forest, 2) dry grassland, 3) sagebr ush desert, 4) farmland (dry > ir rigated), and 5) riparian (Hoyle Consulting Services, 2002). The area around the town of Roosevelt and extending up to the landfill is largely made up of two habitat types, orchards (r ainfed) and dry cropland (H oyle Consulting Services, 2002: Appendix 1, Figure A-1). The great majority of crop area is devoted to fo rage and wheat (National Agricultural Statistics Service, 2004a). Smaller areas have fruits a nd nuts, and row crop vegetables.

As indicated above, a key feature of Klickitat County is the dryness of the area, which differs from many Hawaiian cities. Annual precipitation near Roosevelt Re gional Landfill is about 6 to 9 inches (Rabanco, 2004); Klickitat County is in the rain shadow of the Cascade Mountains (Department of Assessment and GIS, 2003). The average daily minimum temperature in the county is 24° F, and the average daily maximum is 80° F (Department of Assessment and GIS, 2003). In addition, average annual snowfall is about 10 inches. Below-freezing temperatures and snowfall would both mitigate against the establishment of tropical and subtropical Hawaiian pests.PRA for Baled Solid Waste to WA 209 Potential plant pests

Quarantine plant pests for Washingt on State include pathogens, insects, and pest plants (Laboratory Services Division, 1999; PRER, 2004: Exhibit 2). We expect an extrem ely low incidence of these pests in typical MSW (CPHST, 2006). Washington also has no quarantines for terrestrial mollusks, which pose no exceptional risks here (see CPHST, 2006).

No quarantine insects for Washington are pres ent in Hawaii (Montgomery and Manning, 2004) but some insects in Hawaii are Federal quarantine pe sts (CPHST, 2006). We do not discuss insects further since they are unlikely to survive in the bales.

Bacterial, fungal, and viral diseases of plants under Federal or Wash ington State quarantine are present in Hawaii (APS-APHIS Virus Worki ng Group, 2003; University of Hawaii and Hawaii Department of Agriculture, 2004) and could be tran sported (Table 1). For various r easons, these organisms are very unlikely to establish in Washingt on State via this pathway (Table 2), and, as above, no exceptional factors in the proposal appear to make pathogens more likely to esta blish in this case than in the previous assessment (CPHST, 2006).

Twenty quarantine pest plants for Washington are pr esent in Hawaii (Table 3, and Luneke (2004)). All of those species are present in Washington, al though perhaps under ongoing c ontrol or eradication (USDA NRCS, 2004). They seem more likely to disperse to new areas from within the state than via baled MSW from Hawaii. Other quarantine significant pest plants are also pr esent in Hawaii (CPHST, 2006), but no exceptional factors in th e proposal increased the risk asso ciated with pest plants here relative to the previous assessment.

Figure 1. Map 1 of Roosevelt Regional Landfill and surrounding locations.

The distance from West Roosevelt to the landf ill is about 4 miles.

1 From Klickitat County Solid Waste, 2001 (http://w ww.klickitatcounty.org/SolidWaste/ContentROne.asp? fContentIdSelected=1742226046&fCategoryIdSelected=1677677085)PRA for Baled Solid Waste to WA 210 Table 1 . Quarantine diseases for Wash ington State present in Hawaii.

Genus and species (if applicable) Common name Host (in HI) Type

Bean common mosaic potyvirus Bean common mosaic virus Beans Virus

Colletotrichum lindemuthianum Bean anthracnose Beans Fungus

C. truncatum Lentil anthracnose Alfalfa Fungus Clavibacter michiganensis spp . sepedonicus 1 Bacterial ring rot Potato, eggplant Bacteria

Erwinia carotovora subsp. atroseptica 1 Soft rot Potato Bacteria

Potato leaf roll polerovirus 1 Potato leaf roll virus Potato Virus

Potato Y potyvirus (N strain) Potato virus Y (necrotic) Potato Virus Pseudomonas syringae pv. phaseolicola Halo blight Beans Bacteria P. syringae pv. syringae Brown spot disease Beans Bacteria Sclerotium cepivorum Onion white rot Onions Fungus

Verticillium albo-atrum Verticillium wilt Potato, tomato Fungus

Xanthomonas albilineans 2 Sugarcane leaf scald Sugarcane Bacteria X. campestris pv . phaseoli Common bean blight Beans Bacteria X. phaseoli var. fuscans Fuscous blight Beans Bacteria

X. vasculorum 2 Sugarcane bacterial blight Sugarcane Bacteria

1 Washington State has a general quarantine for seed potat o diseases, and a specific quarantine for Potato virus Y (Laboratory Services Division, 1999)

2 Federal quarantine

Table 2. Rationales for pathogens being Low risk for es tablishment in Washington State via baled waste

from Hawaii.

Pathogen Rationale for Low risk rating

Bean common mosaic

potyvirus ▪ Seed-borne and aphid-vectored: inf ected seeds unlikely to be present and aphids highly unlikely to survive
Clavibacter michiganensis

spp . sepedonicus

Pseudomonas spp. Xanthomonas spp. ▪ These bacterial pathogens need ox ygen and are unlikely to survive in

the bales

Colletotrichum

lindemuthianum

C. truncatum ▪ Primarily seed-borne, therefore pres ence in the bale and dispersal after escape are unlikely

▪ Dormant agents may need oxygen for survival

Erwinia carotovora subsp. atroseptica ▪ Short-term survival outside of a suitable host (e.g., in soil)

▪ Low survival in dry conditions, so Klickitat County may be a poor

habitat

Potato virus Y potyvirus

Potato leaf roll polerovirus ▪ Aphid-vectored or spread by propa gative host material, both of which are highly unlikely to survive in the bales
Sclerotium cepivorum ▪ Germination induced by chemicals exuded by Allium sp. roots

▪ Low likelihood of contact with host because Klickitat County has few acres of onion (National Agricultur al Statistics Service, 2004b)

Verticillium albo-atrum ▪ Establishing anoxic soil conditions, i.e. flooding, is a commonly used cultural practice for control of Verticillium wilt, so it is unlikely to

survive in the balePRA for Baled Solid Waste to WA 211 Table 3 . Quarantine Hawaiian pest plants present (“ 9 ”), from three sources, and presence (+) in Washington State (WA). S ynonyms were not listed. Genus species Common name 1 Presence in HI (by source 2 ) WA PLANTS Bishop Manual

1 Carduus pycnocephalus Italian plumeless thistle 9 9 9 +

2 Centaurea biebersteinii spotted knapweed 9 9 9 +
3 C. melitensis Maltese star-thistle 9 9 9 +

4 Cirsium vulgare bull thistle 9 9 +

5 Convolvulus arvensis field bindweed 9 9 9 +
6 Cyperus esculentus chufa flatsedge 9 9 9 +

7 Cytisus scoparius scotchbroom 9 9 9 +
8 Egeria densa Brazilian waterweed 9 9 9 +
9 Hypericum perforatum common St. Johnswort 9 9 9 +
10 Leucanthemum vulgare oxeye daisy 9 9 9 +

11 Myriophyllum aquaticum parrotfeather watermilfoil 9 9 9 +

12 Picris hieracioides hawkweed oxtongue 9 9 9 +
13 Solanum elaeagnifolium silverleaf nightshade 9 9 9 +

14 S. rostratum 3 buffalobur nightshade 9 9 +
15 Soliva sessilis field burrweed 9 +
16 Sorghum halepense Johnsongrass 9 9 9 +
17 Spartium junceum Spanish broom 9 9 9 +
18 Tanacetum vulgare common tansy 9 9 +
19 Tribulus terrestris puncturevine 9 9 9 +
20 Ulex europaeus common gorse 9 9 9 +

1 According to PLANTS

2 Databases: PLANTS (USDA NRCS, 2004), Bishop (B ishop Museum, 2004), Manual (Wagner et al., 1999); latter two after PRER (2004)

3 Eradicated from Hawaii in 1977

Conclusions

We found no exceptional risks related to the two proposals that justified a conclusion different from that given in the previous assessment (CPHST, 2006). A few mitigating factors seemed particularly noteworthy: • The climate in Klickitat County is very different from that found in most Hawaiian cities; • Hawaiian pest plant species of concern are already present in Washington State; and • The risks from relevant diseases and pathogens s eem likely to be effectively mitigated by the baling

technology and other factors. Overall, transportation of urban MSW from Hawaii to Roosevelt Regional Landfill in Washington State by PRER or HWS in airtight ba les poses an insignificant risk of pest establishment.

Last, we note that only the pest risk associated with the proposals by PRER and HWS to move baled MSW from Hawaii to Washington State were addr essed here. Complete approval of the proposal (pathway) or particular procedur es should not be inferred. The path way and proposal in question may still be subject to denial or m odification, in whole or in part, ba sed upon other constraints (pest or nonpest related), such as available re sources or other Federal regulations.PRA for Baled Solid Waste to WA 212 References

APS-APHIS Virus Working Group. 2003. Widely Prevalent Virus List by State [Online]. Animal and Plant Health Inspection Service (A PHIS), U.S. Department of Ag riculture; and The Plant Virology Committee, American Phytopathological Society (A PS), Riverdale, MD, and St. Paul, MN (verified May 19, 2004). Bishop Museum. 2004. Bishop Museum--Hawaiian Flow ering Plant Checklist [Online]. The State

Museum of Natural and Cultu ral History, Honolulu, Hawaii. http://www.bishopmuseum.org/re search/natsci/botany/ botdbhome.html (verified June 1).

CPHST. 2006. The Risk of Introduction of Pests to the Continental United States via Plastic-Baled Municipal Solid Waste from Hawaii. Center for Plant Health Science and Technology (CPHST), Plant Protection and Quarantine, US DA-APHIS, Raleigh, NC. August 2006. 45 pp. Department of Assessment and GIS. 2003. 2003 P opulation and Economic Ha ndbook: Klickitat County [Online]. Clark County Department of Assessme nt and GIS, Clark County, Vancouver, Washington. http://gis.clark.wa.gov/applic ations/gishome/public ations/popecon_docs/27- klecon.pdf (posted January 2003; verified March 24, 2005). EPA. 1993. Safer Disposal For Solid Waste: The Federal Regulations for Landfills, EPA/530 SW-91 092,. Environmental Protection Agency (EPA), Washington, DC. 18 pp. Hoyle Consulting Services. 2002. 2000 Klickitat County Comprehensive Solid Waste Management Plan Update Including The Moderate Risk Hazardous Wa ste Management Plan Update. Prepared for Klickitat County Solid Waste Department, Goldendale, Washington. February 2002. 117 + Appendices pp.

HWS. 2006. HWS-APHIS Resource Co mpendium. Hawaii Waste System s, LLC, Seattle, Washington. March 28, 2006. 172 pp. Laboratory Services Division. 1999. Wa shington: Summaries of Exterior Quarantines. Department of Agriculture, State of Washingt on, Olympia, WA. August, 1999. 21 pp. Luneke, D. 2004. [Correspondence about the] Co mpliance Agreement for Honolulu Solid Waste Transportation. Pacific Rim Environmental Res ources, Inc., Goldendale, Washington. April 20, 2004. 6 pp. Montgomery, S.L., and A. Manning. 2004. (Exhibit 5) Memorandum: Multiple mortality factors for stowaway pests in sealed solid waste bales, an analysis for PRER, LLC. Honolulu Solid Waste Export Project: Waste Handling and Management Op erations Protocol. Pacific Rim Environmental Resources, Inc., Goldendale, WA. p. 3. National Agricultural Statis tics Service. 2004a. 2002 Census of Ag riculture County Profile: Klickitat, Washington [Online]. Washington Agricultural Statisti cs Service, National Agricultural Statistics Service, U.S. Department of Ag riculture, Olympia, Washington. http://www.nass.usda.gov/census/census02/prof iles/wa/cp53039.PDF (verified March 24, 2005). National Agricultural Sta tistics Service. 2004b. 2002 Census of Ag riculture -- County Data [Online]. National Agricultural Statistics Service, U.S. De partment of Agricultur e, Washington, D.C. http://www.nass.usda.gov/census/census02/volum e1/wa/index2.htm (verified March 24, 2005). PRER. 2004. Honolulu Solid Waste Export Project: Waste Handling and Management Operations

Protocol. Pacific Rim Environm ental Resources, Inc. (PRER), Goldendale, WA. February, 2004. 115 pp. Rabanco. 2004. Roosevelt Regional Landfill [O nline]. Rabanco,, Seattle Washington. http://www.rabanco.com/regional_landfill/d efault.aspx (verified March 24, 2005).PRA for Baled Solid Waste to WA 213 University of Hawaii and Hawaii Department of Agriculture. 2004. Crop Know ledge Master [Online]. University of Hawaii, College of Tropical Ag riculture and Human Resources (UH-CTAHR), and Hawaii Department of Agriculture ( HDA), Manoa, HI (verified May 19, 2004). USDA NRCS. 2004. The PLANTS Database, Version 3.5 [Online]. National Plant Data Center,

National Resources Conservation Se rvice (NRCS), U.S. Department of Agriculture (USDA), Baton Rouge, LA. http://plants.us da.gov (verified June 1). Wagner, W.L., D.R. Herbst, and S.H. Sohmer. 1999. Ma nual of the Flowering Plants of Hawai'i. Rev. ed. University of Hawaii Press, Bi shop Museum Press, Honolulu, HI. 1919 pp.

Authors

Barney P. Caton, Ecologist/Pest Risk Anal yst Lisa M. Ferguson, Plant Pathologist barney.p.caton@aphis.usda.gov lisa.m.ferguson@aphis.usda.gov (919) 855-7504; (919) 855-7595 (fax) (919) 855-7515

Center for Plant Health Science and Technology 1730 Varsity Drive, Suite 300 Raleigh, NC 276062 14 

### Appendix E. Risk of Introduction of Pests to Oregon via GRG from

Hawaii.Version 1, September 25, 2007



### United States Department of Agriculture

Animal and Plant Health Inspection

Service

September 2007 

## The Risk of Introducing Pests to Gilliam County, Oregon via Hawaiian Plastic-Baled Municipal Solid Waste

Agency Contact : Barney P. Caton

Authors : Betsy Randall-Schade l and Barney P. Caton

Plant Epidemiology and Risk Analysis Laboratory

Center for Plant Health Science and Technology Plant Protection and Quarantine 1730 Varsity Drive, Suite 300 Raleigh, NC 27606Hawaiian baled MSW to OR 2 16 Executive Summary

Proposals to move waste

to mainland landfills in airtight bales

This assessment focuses on proposed transport to a landfill in Oregon

Description of transport

means and route

Low risk conveyances

Unsuitable climate

Few relevant quarantine pests

Risk rating different than Low Risk not justified Companies are proposing to tr ansport large volumes of municipal solid waste (MSW) in airtight bales from Hawaii to

landfills in the continental United States. In a previous general pest risk assessment, CPHST f ound that the risk of introduction of pests from Hawaii via this pathway was insignificant. Here we assess a proposal by Waste Manage ment Disposal Services of Oregon, Inc., to transport baled MSW to the Columbia Ridge Solid Waste Landfill in Gilliam County, Oregon. Our objective is to determine if the proposal entails any exceptional risks, due to different procedures or the specifi c transport route or location of the landfill that would justify a different recommendation than was made for the general pathway.

The company proposes to barge the baled MSW to one of two ports in Oregon: the primary location is Arlington (Gilliam Count); the alternative location is Rainier (Columbia County). Bales will be transported to the landfill by truck from Arlington and by rail from Rainer. All tran sportation methods are low risk. The local environments and climates for the two ports and the Gilliam Country landfill do not pose exceptional risks. The climate in Gilliam County is drier and much colder than that in most Hawaiian cities and should mitigate the risk from tropical and sub-tropical pests. The landf ill is a modern facility that complies with relevant federal regulations. The environment of Columbia County is milder that Gilliam County. None of the relevant Federal or State quarant ine plant pests, which include insects, mollusks, pathogens a nd invasive plants, was found to present an exceptional threat of surviving, escaping and establishing via this pathway.

This proposal largely followed th e procedures outlined in the general pest risk assessment, and we found no factors that justified a pest risk rating other than Low risk. Transportation of baled Hawaiian MSW to Gilliam County, Oregon poses an insignificant risk of pest establishment. We recommend that the pathway be monitored to ensure that procedures and compliance do not differ significantly from wh at was described here and in the general pest risk assessment.Hawaiian baled MSW to OR 217 Introduction

Assess risk of plasticbaled waste from Hawaii

General pest risk

assessment had Low risk ratings for plant pests.

Waste Management

proposed shipping

baled MSW from Hawaii

to a landfill in Gilliam County, Oregon The Center for Plant Health Science and Technology (CPHST), at the request of Hawaii, c onducted a general pest risk assessment to analyze the likeli hood of introduction of pests into

the continental United States vi a the transport of plastic-baled municipal solid waste (MSW) from Hawaii (CPHST, 2006). TheMSW would be shredded, compressed, and wrapped in adhesivebacked, plastic film barriers ma de of low density polyethylene (LDPE), creating airtight packag es. Bales would be transported by barge to a receiving facility on the mainland, moved by rail or truck to the landfills, and then buried intact in accordance with regulations for solid waste di sposal (40CFR§258; EPA (1993)), with each company transporting perhaps 300,000 tons of MSW per year. A pest risk assessment was required because garbage

from Hawaii cannot enter the con tinental United States under current federal regulations fo r plant pests (7CFR§330.400). The assessment dealt only with parts of the pathway expected to be valid for any company proposing to transport the baled waste.

In the general pest risk assessment, CPHST (2006) concluded that, if the planned procedures were followed, transportation of baled Hawaiian MSW posed an insignificant risk of pest

establishment. Reasons included exclusion of most yard and agricultural waste from the pathway to greatly reduce the presence of potential plant pest s or propagules in the bales; inability of insects, mollusks, and most pathogens to survive in the bales; and establishment of pathway procedures (e.g. monitoring during transport) to protect against escapes via accidental ruptures and punctures during handling and transport. A qualitative risk analysis indicated that the cumulative risk ratings for the introduction of insects, mollusks, pathogens, and

weeds were each Low.

Waste Management Disposal Services of Oregon, Inc. (Waste Management or WMDSO) has proposed moving baled MSW from Hawaii to the Columbia Ridge Solid Waste Landfill (CRL) in Gilliam County, Oregon. Bales wi ll be transported by barge to either Rainier or Arlington, Ore gon, and then by truck or rail to the landfill. The objective of this assessment is to assess whether any exceptional risk factors in the proposal warrant a

recommendation other than the Low risk rating given in the general pest risk assessmen t (CPHST, 2006). Although a baling technology provider has not been decided upon by WMDSO, the procedures proposed by Wa ste Management (2005) for transporting baled MSW will closely follow the proceduresHawaiian baled MSW to OR 218 evaluated by CPHST (2006). Sp ecific items considered here include the destination landfill, the Federal and State quarantine pests of concern, the type(s) of tr ansportation used to move bales after reaching the mainland, and a ny other notable factors in the proposal.

Definitions of key terms

Definition of ‘garbage’

Definition of a ‘spill’

Other definitions Garbage is defined as urban (comme rcial and residential) solid

waste from Hawaiian munici palities. Based on company proposals to move baled MSW ( not shown), this analysis assumes that yard and agricultural waste will be actively

excluded from the waste stream.

A spill is defined as the escape of waste material from a bale and contact with the ground, tr uck, tractor, barge, or other terrestrial

feature.

Other important terms are defined as follows Merriam-Webster (2004):

Anaerobic: Living, active, occurring, or existing in the absence of free oxygen. The term only correctly applies to organisms, not non-living th ings like bales or the

conditions within them

Anoxia: Hypoxia especially of such se verity as to result in permanent damage

Anoxic: Greatly deficient in oxygen Hypoxia: A deficiency of oxygen reaching the tissues of the body

Basic Proposal

Eight important details

Agricultural and yard waste separated

Bale specifications

Bale staging conditions Following are some important details from the proposal by Waste Management (2005). 1) Agricultural and ya rd waste will be sepa rated, or diverted to

other disposal sites, so that it does not enter the pathway.

2) The waste compression and baling system used will create

rectangular bales weighing 2 to 3 tons, with a density of about 1600 to 2000 pounds per cubic yard (approx. 950 to 1200 kg/m 3 ). Densities should be about 1000 kg/m 3 (CPHST, 2006).

3) WMDSO did not specifically st ate that bales would not be

allowed to contact soil or other moist surfaces and to be distanced from vegetation, but they mentioned that bales would be kept in quarantine. New processing facilities built inHawaiian baled MSW to OR 21 9 Shipping 120,000 tons annually

Two transportation route options

Barge then truck

Barge then rail

Tracking bales

Monitor bales for damage

Transport in industrial bags if repair is not possible

Proposed bagging spills differs from previous proposals, but rewrapping restaging will be required in Hawaii. Hawaii, as well as unloading st ations on the mainland, need to accommodate this requirement.

4) Estimated shipping an annual maximum of 120,000 tons

(Willmann, 2007).

5) Bales will be moved up the Columbia River by barge, and

then to the landfill by one of the following routes (Fig. 1): a) 210 miles up river to the Po rt of Arlington, Oregon (Gilliam

County), then approx. 10 miles on truck and flatbed trailer to the landfill; or b) 52 nautical miles to a facility at Rainier, OR, near Portland,

then approximately 130 miles by ra il flatcar to the landfill.

6) Track bales using an el ectronic manifesting system.

7) Monitor bales for ruptures a nd punctures, and patch ruptured

bales when and where found.

8) If patching is not possible, MSW proposed that bale will be

contained and transported to the landfill in one or more industrial-grade bags (Super Sack®, B.A.G. Corp., Dallas,TX), with MSW inside 6-ml LPE liners. Liners will be handclosed to create an airtig ht package (Willmann, 2005). The

bales will need to be re-wra pped and re-staged if damage

occurs in Hawaii. If the ba le damaged is beyond patching and in route to Oregon or in Oregon, the bag protocol can be used. Though probably slightly inferior to re-baling, in terms of compression and forced evacuation of air, it offers the advantage of quickly collecting and sealing the MSW with less handling than if the MSW were put through the baling process again. As with bales (CPHST, 2006), the packages would be re-staged for several days before transport re-starts. If the clean-up, disinfection, and bag seal ing procedures described in the Waste Management proposal ( 2005) are followed, we think the pest risk mitigation will be equally effective.

Destination landfill

Columbia Ridge Recycling

and Landfill meets EPA guidelines The CRL (www.wmnorthwest.com/landfill/landfillcities/ columbia.html) in Gilliam County, near the town of Arlington (Fig. 2), is modern and meets regulations and EPA guidelines for design and operation, e.g. EPA (1993). We expect proper landfilling of bales at this site, and therefore the mitigation likely to come from landfilling seems valid (CPHST, 2006).Hawaiian baled MSW to OR 2 20 Figure 1 . Map showing the transport route by barge (light blue), and either rail (yellow) or truck (green) fo r baled MSW to the Columbia Ridge Landfill in Oregon.

Figure 2. Map of Columbia Ridge Landfill and surrounding locations.

Transportation of bales

Quantitative risk for transportation modes and

routes As discussed above, bales will be barged up the Columbia River, and then moved either onto trucks or onto railcars (Willmann, 2007). The generic quantitative risk analysis for bale-rupturingHawaiian baled MSW to OR 2 21 Tandem tows decrease number of trips accidents to transport of bales (CPHST, 2006) and modified (CPHST, 2007), Appendix A) was further adapted for the two routes proposed by Waste Management to the CRL. The proposed use of tandem tows (two barges towed inline) decreased the number of trips by half. The impact of accident rate on the tandem towing of barges was not examined. The two proposed routes and associated risks follow.

Main route option Barge then truck

Mean years to first balerupturing accident was
2,222 for trucks and 246 for barges

Low Risk route overall Unloading at the Willow Creek Barge Facility, Port of Arlington and trucking to the CRL requires an increase from 140 barge miles in the generic model to 210 miles, and a decrease in truck

miles from 25 to 10.

The risk of any bale-rupturi ng accident for trucks was 0.00045,while that for barges was 0.0041. Mean years to the first balerupturing accident for trucks was 2,222, and that for barges was 246. We found a 95 percent chance that the first truck accident would occur only after 5444 years, or after 1391years for barge transport. The risk of catastrophi c rupture of bale s while they are being transported by truck or barg e to CRL is therefore Low.

Alternate route option Barge then rail

Mean years to first balerupturing accident was

2222 for trucks and 247 for barges Unloading in Rainier, Oregon, and transporting by rail to CRL reduces rail miles in the model from 500 to 180, and barge

distance from 140 to 52 nautical miles.

The risk of any bale-ruptur ing accident by train was 0.00002,while that for barges was 0.0077. Mean years to the first balerupturing accident for trains was 50,000.4, and for barges was 130. We found a 95 percent chance that the first train accident would occur only after 921 years, or after 554 years for barge transport. The risk of catastrophi c rupture of bale s while they are being transported by truck or ba rge to CRL is therefore Low.

Local environment and climate comparison to Hawaii

Climate in Hawaii The tropical climate in Hawaii is characterized by relatively uniform day lengths and temperatures (Western Regional Climate Center, 2007). Annual climatic averages for Honolulu (Oahu) are maximum temperature = 84.0 °F, minimum temperature = 70.2 °F, and total pr ecipitation = 20.7 inches (52.6 cm), while the same averages for Hilo (Hawaii) are maximum temperature = 81.2 °F, minimum temperature = 66.3 °F, and total precipitation = 128.2 inches (3.25 m) (Western Regional Climate Center, 2007).Hawaiian baled MSW to OR 2 22 Gilliam County lies in rain

shadow

Climate is arid and cold in comparison to Hawaii

Local agriculture: Wheat predominate crop in the

area

Climate of Rainier based on Longview, WA,

Annual precipitation at

Rainier is similar to that

of Hawaii Gilliam County lies in the easte rn rain shadow of the coastal Cascade Mountains (Department of Assessment and GIS, 2003). Mean annual precipitation is onl y about 15 inches (38 cm), and most falls during the winter (Taylor et al. , 2005). The mean (annual) daily maximum temperat ure in the county is 58.7 °F, and the mean daily minimum is 35.7 °F. That is about 20 °F less than the mean maximum temperat ures in Hawaii, and about 30

°F less than the mean minimum temperatures. In addition, mean annual snowfall in the central part of Gilliam County is about 18 inches (45.7 cm; equal to approximately 4.6 cm of rainfall). Thus, Gilliam County is drier and much colder than most municipalities in Hawaii. Most of the transport route (Fig. 1) is

also in the rain shadow of the coastal range, and therefore would also be significantly drier and colder.

Gilliam County is in the main wheat-producing area of Oregon. Most acreage in the county is devoted to wheat, followed by forage and barley (National Agri cultural Statistics Service, 2004). Apples, grapes and other ir rigated crops are found in the northern part of the county.

Rainier is in Columbia County, OR. We used weather information for Longview, WA, which is directly across the Columbia River from Rainier. Rainier and Longview have

climates which are more moist a nd mild than that of Arlington (Western Regional Climate Cent er, 2007). The annual climatic averages for Longview range from an average maximum temperature of 61.7 °F to an av erage minimum temperature of 41.8 °F (Western Regional Clim ate Center, 2007). The total annual precipitation averages 46.3 inches (18.2 cm), with an annual average snowfall of 4.9 inches (1.9 cm) (Western Regional Climate Center, 2007).

Though much colder than Hawaii, annual precipitation in Rainier is between the averages record ed for Honolulu and Hilo. Thus, compared to Arlington, the Rain ier area poses a greater pest establishment risk. The proximity of Rainier to several protected wetlands and wildlife refuges also increases the potential environmental risk from hitchhikers from this route (EPA, 2007).

Potential plant pests

We expect a low incidence of pests in

baled MSW Quarantine plant pests from Hawa ii include pathogens, mollusks, insects, and invasive plants (CPHST, 2006). We expect an extremely low incidence of thes e pests in Hawaiian municipalHawaiian baled MSW to OR 2 23 solid waste (CPHST, 2006). In addition to federal quarantines, Oregon has state plant pest quara ntines in Gilliam County for apple maggot (603-052-0121), small broomrape (603-052-1025) and noxious weeds (603-052-1200).

Insects Insects are highly unlikely to survive in

bales Of the insect pests of concern to the Oregon nursery industry,

two, Popillia japonica (Japanese beetle) and Homalodisca coagulata (Say) (glassy winged shar pshooter), are present in Hawaii (Table 1). Some insects in Hawaii are Federal quarantine pests (Table 2). We do not discus s insects further since they are highly unlikely to survive in the bales (CPHST, 2006).

Invasive plants Definition of category A noxious plant

Four category A noxious weeds present in Hawaii

Aquatic weed, Hydrilla

Two other noxious weeds produce seed with low viability In Oregon, Category “A” noxious plant species are defined as “Weeds of known economic importance which occur in the state in small enough infestations to make eradication or containment possible; or which are not known to occur, but their presence in neighboring states makes future occurrence in Oregon seem imminent” (Oregon Department of Agriculture, 2005). Only four of these Category “A” species are present in Hawaii, according to USDA NRCS (2004), Imada et al . (2007), Bishop Museum (2004), and Wagner et al. (1999). Those species are Cyperus

rotundus L. (purple nutsedge), Hydrilla verticillata (hydrilla),

Pueraria lobata (Willd.) Ohwi (kudzu), and Solanum elaeagnifolium Cav. (silverleaf nightshade).

Hydrilla, an aquatic species, ma y present a risk to the Rainer, Oregon, area, but the arid condi tions in Gilliam County would greatly mitigate the risk. Furthe rmore, hydrilla relies greatly on reproduction from leaf fragments (Kay and Hoyle, 2007), which would not be possible via this pathway because plant material

would not survive in the bales.

Weed seed viability may be unaffected by bale conditions in general, but the seeds are highly unlikely to escape and contact a suitable growth environment. In addition, the kudzu (Susko et
al. , 2001) and Cyperus rotundus (Justice and Whitehead, 1946) seeds only have about 10 percent viability. The vegetative nutlets

of C. rotundus are produced in the soil, and therefore, are much less likely than seeds to be present in MSW. As in the PRA for Washington state (CPHST, 2005), the risk from invasive plants

in baled MSW is Low.Hawaiian baled MSW to OR 22 4 Mollusks

Mollusks present concern

as hitchhikers

Suitability of climate

C. aspersum already

present in California

Proper staging and certification mitigates risk

from mollusks Federal quarantine phytophagous snails occur in Hawaii (Robinson, 2006; Table 3) and may be a risk to hitchhike on bales. Mollusks have been detected in pre-departure and permitted cargo from Hawaii headed by air to the continental United States (AQAS, 2007), but not in maritime shipments, for which less inspection data is avai lable. Smith and Fowler (2003)

rated the risk for movement of A. fulica by cargo and empty containers as Low, partly because the large size of the snail

facilitates detection. Contact of bales with moist substrates (Robinson, 2006), such as soil or mulch, increases the likelihood

that mollusks can become established.

The climate in Oregon is suita ble for at least one species, Achatina fulica (Smith and Fowler, 2003). We do not know if the climate is suitable for other species such as C. aspersum , but that species has been a problem pest in California for many years (Grafton-Cardwell et al. , 2005). Dispersal from there probably poses a greater risk.

Staging bales on impermeable su rfaces away from vegetation sources, and certification of bales by the company as molluskfree (CPHST, 2006; Robinson, 2006) should make them Low

Risk.

Plant pathogens Some quarantine plant

pathogens present in

Hawaii Some bacterial, fungal, and viral diseases of plants under Federal or Oregon quarantine are presen t in Hawaii and the pathogens could be transported (Tables 4 a nd 5). Oregon has a general pest quarantine against grapes ( Vitis spp.) (excluding table grapes, V.

labrusca ), but we found no pathogens of grapes in Hawaii. For various reasons, the plant pathogens listed in Tables 4 and 5 are very unlikely to establish in Or egon via this pathway (Table 6).Hawaiian baled MSW to OR 22 5 Table 1. List of insect species of quarantine conc ern to the Oregon nursery industry (Oregon Department of Agriculture, 2006) with record ed presence in Hawaii (HDOA, 2004; Nishida (ed.), 2002).

Scientific Name Common Name Present in HI? Conotrachelus nenuphar Plum Curculio No Homalodisca coagulata Glassy Winged Sharpshooter Yes

Ostrinia nubilalis European Corn Borer No Oulema melanopus Cereal Leaf Beetle No Popillia japonica Japanese Beetle Yes Rhagoletis mendax Blueberry Maggot No Rhyacionia buoliana European Pine Shoot Moth No Tomicus piniperda Pine Shoot Beetle No Yponomeuta malinellus Apple Ermine Moth No

Table 2 . Selected Federal quarantined insects presen t in Hawaii relevant to Oregon ecosystems.
Scientific name (Order: Family) Common name Reference 1

Adoretus sinicus (Coleoptera: Scarabaeidae) Chinese rose beetle 7 CFR§318.13

Adoretus sp. – 7 CFR§318.60

Bactrocera cucurbitae (Diptera: Tephritidae) melon fly 7 CFR§318.13

Bactrocera dorsalis (Diptera: Tephritidae) Oriental fruit fly 7 CFR§318.13

Cactoblastis cactorum (Lepidoptera: Pyralidae) cactus borer 7 CFR§318.13
Ceratitis capitata (Diptera: Tephritidae) Mediterranean fruit fly 7 CFR§318.13

Coccus viridis (Hemiptera: Coccidae) green scale 7 CFR§318.13 Chilo suppressalis (Lepidoptera: Crambidae) Asiatic rice borer 7 CFR§318.13 Eriophyes gossypii (Acarina: Eriophyidae) cotton blister mite 7 CFR§318.47 Euscepes postfasciatus (Coleoptera: Curculionidae) sweet potato scarabee 7 CFR§318.30 Lampides boeticus (Lepidoptera: Lycaenidae) bean butterfly 7 CFR§318.13

Maruca testulalis (Lepidoptera: Pyralidae) bean pod borer 7 CFR§318.13 Omphisa anastomosalis (Lepidoptera: Pyralidae) sweet potato stem borer 7 CFR§318.30 Pectinophora gossypiella (Lepidoptera: Gelechiidae) pink bollworm 7 CFR§318.47 Phyllophaga spp. (Coleoptera : Scarabaeidae) white grubs 7 CFR§318.60 Phytalus sp. (Coleoptera : Scarabaeidae) white grubs 7 CFR§318.60 Sternochetus mangiferae (Coleoptera: Curculionidae)

synonym: Cryptorhynchus mangiferae mango seed weevil 7 CFR§318.13

1 CFR = Code of Federal RegulationsHawaiian baled MSW to OR 22 6 Table 3 . Federal quarantined and regul ated mollusks present in Hawaii that are relevant to Oregon ecosystems.

Scientific name (Type: Family) Common name Reference Achatina fulica Bowdich (Mollusca:Achatinidae) giant African land snail Cowie (1977; 2002b); Robinson, (2006) Cornu aspersum (Müller)

(Mollusca:Helicidae) [Syn. Cryptomphalus aspersus

(Müller); Helix aspersa Müller] brown garden snail Cowie (1977; 2002b); Robinson (2006)

Laevicaulis alte (Férussac) (Mollusca:Veronicellidae) tropical leatherleaf – thrives in arid biotopes Cowie (1977; 2002b)

Meghimatium striatum (Hasselt) (Mollusca:Philomycidae) a terrestial snail Cowie (2002a); Robinson (2006)

Parmarion cf. martensi (Simroth) [tentative identification] (Mollusca:Helicarionidae) a semi-slug; Carrier of the human parasitic nematode, Angiostrongylus cantonensis Robinson (2006)

Paropeas achatinaceum (Pfeiffer) (Mollusca:Sublinidae) a snail Robinson (2006)

Pila ampullacea (Linné) (Mollusca:Ampullaridae) “apple snail” Robinson (2006)

Pila conica (Wood) (Mollusca:Ampullaridae) “apple snail” Robinson (2006)

Pila sp. (Mollusca:Ampullaridae) “apple snail” Robinson (2006)

Pomacea canaliculata (Lamarck) 1
(Mollusca:Ampullaridae) channelled apple snail Cowie (1977; 2002b); Robinson (2006)

Veroncella cubensis (Pfeiffer) (Mollusca:Veronicellidae) two striped slug or Cuban slug Cowie (1977; 2002b); Robinson (2006)

1 Three other species occur in Hawaii, but this is the worst pest in that genus.Hawaiian baled MSW to OR 22 7 Table 4 . Federal quarantined and regul ated pathogens and nematodes present in Hawaii that are relevant to Oregon ecosystems. Scientific name (Type: Family or Order) 1 Common name Reference

Meloidogyne konaensis (Nematoda: Meloidogynidae) root-knot nematode Zhang and Schmitt, (1994)

Xanthomonas albilineans (Ashby)

Dowson (Bacterium: Xanthomonadales sugarcane leaf scald USDA-APHIS-PPQ, (2003)

X. axonopodis pv vasculorum (Cobb 1894) Vauterin, Hoste, Kersters & Swings Synonym: X. vasculorum (Bacterium: Xanthomonadales) sugarcane gumming disease USDA-APHIS-PPQ, (2003)

1 Family is listed for nematodes; Order is listed for bacteria.

Table 5 . Plant pathogens and parasitic nematodes of concern in Oregon (Division of Plant Industries, 2005), and present in Hawaii (CABI, 2005; Raabe et al. , 1981; University of Hawaii and Hawaii Department of Agri culture, 2004; USDA-APHIS-PPQ, 2003).

Scientific name Common name

Bean common mosaic virus (strain US-6) 2,4 bean common mosaic virus

Colletotrichum truncatum 4 lentil anthracnose

Colletotrichum lindemuthianum 1,3,4 bean anthracnose Curtobacterium flaccumfaciens pv flaccumfaciens 2,3,4 bacterial wilt of beans Ditylenchus dipsaci (onion race) 5 onion stem and bulb nematode
Fusarium graminearum 2,5 wheat scab Phakopsora pachyrhizi 4 soybean rust Phytophthora infestans 5 potato late blight

Pseudomonas savastanoi pv phaseolicola 2,3,4

synonym: P. syringae pv phaseolicola halo blight of beans

Pseudomonas syringae pv syringae 2,3,5 bacterial brown spot of beans Sclerotium cepivorum 2,3,5 onion white rot Xanthomonas axonopodis pv phaseoli 3,4

synonym: X. campestris pv phaseoli common blight of beans

1 Reported present in Hawaii (CABI, 2005) a nd under control in Ma lheur County by Oregon

Department of Agriculture ((2007) (Ore gon Revised Statutes (ORS) 570.405 to 570.435).

2 Reported present in Oregon by CABI (2005). B ean diseases are under control in Malheur

County by Oregon Department of Agriculture (2007) (ORS 570.405 to 570.435).

3 Pests of moderate to high concern.

4 Not known to occur or not detected in Oregon.

5 Limited distribution or newly established.Hawaiian baled MSW to OR 22 8 Table 6. Rationales for pathogens being low risk for introduction and establishment in Oregon

via baled solid waste from Hawaii.

Common/scientific name Rati onale for low risk rating
bacterial brown spot of beans

bacterial wilt of beans common blight of beans halo blight of beans sugarcane gumming disease sugarcane leaf scald ▪ Aerobic bacteria need oxygen (Wener, 2005) and are unlikely to survive in bales

bean anthracnose

lentil anthracnose ▪ Primarily seedborne (CABI, 2005) , so unlikely to be present

in the bale or to di sperse after escape

▪ Dormant agents may require oxygen

bean common mosaic virus

(strain US-6) ▪ Seedborne and aphid-vectored (CABI, 2005); aphids cannot survive and infected seeds are unlikely to be present

▪ Only multiplies in living cel ls ((Agrios, 2005)) and suitable host plants would either not en ter or survive in the bales

onion stem and bulb nematode ▪ Needs oxygen for survival

▪ Seedborne (CABI, 2005), so un likely to be present or to disperse after escape

▪ Most stages need host material for survival (CABI, 2005)

▪ Fourth stage juveniles surviv e for years without a host, but populations decline rapidly (CAB I, 2005) and are not likely to survive other bale conditions (e.g., compression, anoxia)

onion white rot ▪ Fungus is unlikely to survive anoxic conditions in the bale

▪ Dormant sclerotia germinate only in the presence in soil of specific root exudates from Allium spp. (CABI, 2005) potato late blight ▪ Dormant agents may need oxygen for survival

▪ Except for oospores, a living host or crop debris is required for survival (CABI, 2005), whic h are unlikely to be present

or to survive in the bales

▪ The asexual stage only occurs in contact with living host material (Agrios, 2005; CABI, 2005), which is unlikely to be present in the pathway

root-knot nematode ▪ Dormant agents may need oxygen for survival

▪ Cool temperatures are expect ed to kill eggs (Schmitt, 2002)

▪ Nematode has limited tolerance to changes in temperature (prefers 75±10 °F), so clima tic conditions in Oregon would probably prevent long-term establishment (Schmitt, 2002)

▪ Dispersal is primarily via ro ots and tubers, or by field equipment (Agrios, 2005), whic h are both unlikely to occur soybean rust ▪ Obligate parasite can only survive on live plant material,

which would not survive in the bales

wheat scab ▪ Seedborne; requires host material for survival (CABI, 2005), which is very unlikely to be present

▪ Needs oxygen for survivalHawaiian baled MSW to OR 22 9 Conclusions

We found no exceptional pest risks

Three notable mitigating

factors

Overall Low Risk of pest

establishment

Both routes with conveyances were Low

risk for bale-rupturing

accidents

This assessment only

dealt with pest risks

The pathway may be

disallowed for other

reasons We found no significant exceptiona l pest risks related to the WMDSO proposal to take baled MS W to the CRL that justified a

conclusion different from th at given in CPHST (2006).

A few mitigating factors seemed particularly noteworthy:

• The climate in Gilliam County is very different from that of Hawaii;

• Very few relevant invasive plant species in Oregon are present in Hawaii; and

• The risks from relevant diseas es and pathogens seem likely to be effectively mitigated by the bale technology and other

factors.

Overall, transportation of urban solid waste from Hawaii to the CRL in Oregon by WMDSO in plas tic-wrapped, airtight bales

poses a Low risk of pest establishment. Perhaps the greatest pest risk is from hitchhikers, so we strongly recommend that bales be certified mollusk-free by the co mpany (subject to audit by USDA APHIS).

The two routes proposed, barge pl us truck or barge plus rail, were both Low risk for accidents. However, in the alternate route the unloading site of Rainier, Oregon, has a milder climate and represents an increased possi bility of establishment by hitchhiking mollusks and other pests.

Last, we only addressed the pest ri sk associated with the proposal by WMDSO to move baled MSW from Hawaii to Oregon. Complete approval of the propos al (pathway) or particular procedures should not be inferre d. The pathway and proposal in question may still be subject to denial or modification, in whole or in part, based upon other constrai nts (pest or non-pest related),

such as available resources or ot her State or Federal regulations.Hawaiian baled MSW to OR 2 30 References

Agrios, G. N. 2005. Plant Pathology (5th Ed.). El sevier Academic Press, New York, NY. 922 pp. AQAS. 2007. Pest Interception Data for Mollusk s from Hawaii. . Agricultural Quarantine Activity Systems, United States Department of Agriculture Animal and Plant Health Inspection Service, Plant Protection a nd Quarantine. Last accessed April 19, 2007, Bishop Museum. 2004. Bishop Museum--Hawaiian Flowering Plant Chec klist. The State

Museum of Natural and Cultural History. Last accessed June 1, http://www.bishopmuseum.org/resear ch/natsci/botany/ botdbhome.html. CABI. 2005. Crop Protection Co mpendium. CAB International (CABI), Wallingford, UK. Cowie, R. H. 1977. Catalog and bibliography of the nonindigenous nonmarine snails and slugs of the Hawaiian Islands. Bishop Museum Press, Honolulu, HI. 66 pp. Cowie, R. H. 2002a. Invertebrate invasions on Pacific Islands and th e replacement of unique native faunas: a synthesis of the land and fr eshwater snails. Biological Invasions 3:119-136. Cowie, R. H. 2002b. List of potential pest mo llusks in the USA (Interim Report to USDA).

Center for Conservation Resear ch and Training, University of Hawaii, Honolulu, HI. 8 pp.

CPHST. 2005. The Risk of Introduction of Pest s to Washington State via Plastic-Baled Municipal Solid Waste from Hawaii. Center for Plant Health Science and Technology (CPHST), Plant Protection and Quaran tine, USDA-APHIS, Raleigh, NC. 10 pp.

CPHST. 2006. The Risk of Introduction of Pests to the Continental United States via PlasticBaled Municipal Solid Waste from Hawaii. Ce nter for Plant Health Science and Technology (CPHST), Plant Protection and Quaran tine, USDA-APHIS, Raleigh, NC. 36 pp. CPHST. 2007. The Risk of Introducing Pests to Elmore County, Idaho via Plastic-Baled Municipal Solid Waste from Hawaii. Appendix A. (Draft). Center for Plant Health Science and Technology (CPHST), Plant Protection an d Quarantine, USDA-A PHIS, Raleigh, NC. 29

pp. Department of Assessment and GIS. 2003. 2003 Population and Econom ic Handbook: Klickitat County. Clark County Department of Assessm ent and GIS, Clark County. Last accessed March 24, 2005, http://gis.clar k.wa.gov/applications/gishom e/publications/popecon_docs/27- klecon.pdf.

Division of Plant Industries. 2005. Recommended Plant Pest Watch List . Division of Plant Industries, Idaho State Department of Agriculture. Last accessed August 22, http://www.agri.state.id.us/Categories/Plants Insects/PlantDiseasesAndOtherPests/Documents

/ISDA%20Division%20of%20Plant%20Industi es%20Plant%20Pest%20Watch%20List.pdf. EPA. 1993. Safer Disposal For So lid Waste: The Federal Regu lations for Landfills (EPA/530 SW-91 092,). Environmental Protection Agency (EPA), Washington, DC. 18 pp. EPA. 2007. National Estuary Program Coastal C ondition Report. Chapter 6: West Coast National Estuary Program Coastal Condition, Lo wer Columbia River Estuary Partnership.

United States Environmental Protecti on Agency (EPA), Washington, DC. 11 pp. Grafton-Cardwell, E. E., J. G. Morse, N. V. O’Connell, P. A. Phillips, C. E. Kallsen, and D. R. Haviland. 2005. Citrus, Brown Gard en Snail, Scientific Name: Helix aspersa . Statewide IPM Program, Agriculture and Natural Resources, University of California. Last accessed September 25, 2007, http://www.ipm.ucdavis.edu/PMG/r107500111.html.

HDOA. 2004. New Plant Pest Discovered In L eeward Oahu. Hawaii Department of Agriculture (HDOA).Hawaiian baled MSW to OR 2 31 Imada, C. T., G. W. Staples, and D. R. Herbst . 2007. Annotated Checklist of Cultivated Plants of Hawai‘i. Bishop Museum, Honolulu, Hawaii. Last accessed July 24, 2007, http://www2.bishopmuseum.org/HBS/bot any/cultivatedplants/default.asp. Justice, O. L., and M. D. Whitehead. 1946. S eed production, viability, and dormancy in the
nutgrasses Cyperus rotundus and C. esculentus . Journal of Agricultural Research 73(9/10):303-318. Kay, S., and S. Hoyle. 2007. Aquatic Weed Fact Sheet: Hydrilla, Hydril la verticillata. Crop Science Department, College of Agricultu re and Life Sciences, Raleigh, NC. 1 pp.

Merriam-Webster. 2004. Merriam-Webster Online Dictionary. Merriam-Webster Inc. Last accessed June 1, 2004, http://www.m-w.com/. National Agricultural Statistic s Service. 2004. 2002 Census of Agriculture County Profile: Gilliam, Oregon. Oregon Agricultural Statistics Service, National Agricultural Statistics Service, U.S. Department of Agri culture. Last accessed August 17, 2005, http://www.nass.usda.gov/census/cen sus02/profiles/wa/cp53039.PDF. Nishida (ed.), G. M. 2002. Hawaiian Terrestrial Arthropod Checklist, 4th ed. Bishop Museum Press. Last accessed March 30, 2006, http://www2.bishopmuseum.org/HBS/ checklist/query.asp ?grp=Arthropod. Oregon Department of Agriculture. 2005. 2005 Noxi ous Weed Policy and Classification System. Noxious Weed Control Program, Oregon Depart ment of Agriculture, Salem, Oregon. 9 pp. Oregon Department of Agriculture. 2006. Oregon De partment of Agriculture Pathogen and Pest Lists. Plant Division, Oregon Department of Agriculture. Last accessed March 30, 2006, http://egov.oregon.gov/ODA/PLANT/ docs/word/nurs_ppwlists.doc. Oregon Department of Agriculture. 2007. Bean Disease Control Area- Malheur County. Oregon Department of Agriculture. Last accessed September 19, 2007, http://www.oregon.gov/ODA/PLANT/603_052_0385.shtml. Raabe, R. D., I. L. Conners, and A. P. Mar tinez. 1981. Checklist of Plant Diseases in Hawaii: Including Records of Microorganisms, Principa lly Fungi, Found in the State. Hawaii Institute of Tropical Agriculture and Hu man Resources, College of Tr opical Agriculture and Human Resources, University of Hawaii, Manoa, Hawaii. 313 pp. Robinson, D. G. 2006. Questions about mollusk pe sts. Personal communication to B. RandallSchadel on March 08 and 17, 2006, from D. G. Robinson (National Mollusk Specialist, USDA APHIS. PPQ P&RA NIS and Departme nt of Malacology, Academy of Natural Sciences). Archived in th e PERAL Library, Raleigh, NC. Schmitt, D. P. 2002. Evaluation of the risk of Kona coffee nematode to US agriculture (an email confirmation of phone conversation). Persona l communication to E. Sutker on April 21, 2002, from Dr. D. P. Schmitt (Department of Pl ant and Environmental Protection, University of Hawaii). Archived at th e PERAL library, Raleigh NC. Smith, J. W., and G. F. Fowler. 2003. Pathway risk assessment for Achatinidae with emphasis on the giant African land snail Achatina fulica (Bowdich) and Limicolaria aurora from the

Caribbean and Brazil with comments on related taxa Achatina achatina (Linne), Archachatina marginata (Swainson) intercepted by PPQ . Plant Epidemiology and Risk Analysis Laboratory. USDA–AP HIS–PPQ–CPHST, Raleigh, NC. Susko, D. J., J. P. Mueller, and J. F. Spears. 2001. An evaluation of methods for breaking seed dormancy in kudzu ( Pueraria lobata ). Canadian Journal of Botany 79:197-203.Hawaiian baled MSW to OR 2 32 Taylor, G., C. Hale, and S. Joos. 2005. Climate of Gilliam County. Oregon Climate Service. Last accessed August 18, 2005, http://www.ocs.oregonstate.edu/count y_climate/Gilliam_files/Gilliam.html. University of Hawaii, and Hawaii Department of Agriculture. 2004. Crop Knowledge Master. College of Tropical Agriculture and Human Resources, University of Hawaii, and Hawaii Department of Agriculture. Last accessed May 19, 2004, http://www.extento.hawaii.edu/kbase/crop/crop.htm. USDA-APHIS-PPQ. 2003. Hawaii Nonpropagative Manual: Regulation and clearance of carriers, mail, passengers, plants, plant produc ts, sand, soil and earth from Hawaii to other parts of the United States. USDA- APHIS-PPQ, Riverdale, MD. 26 pp. USDA NRCS. 2004. The PLANTS Database, Versi on 3.5. National Plant Data Center, National Resources Conservation Service (NRCS), U.S. Department of Agriculture (USDA). Last accessed June 1, http://plants.usda.gov. Wagner, W. L., D. R. Herbst, and S. H. So hmer. 1999. Manual of the Flowering Plants of Hawai'i (Rev.). University of Hawaii Pre ss, Bishop Museum Press, Honolulu, HI. 1919 pp. Waste Management. 2005. Transportation and Dis posal of Municipal Solid Waste from Hawaii: Operations Brief. Waste Management Dispos al Services of Oregon, Inc., Portland, Oregon, Portland, Oregon. 11 pp. Wener, K. 2005. Aerobic Bacteria. Definition. Medline Plus. U.S. National Library of Medicine and the National Insititutes of Health. Last accessed March 7, 2007, http://www.nlm.nih.gov/medlineplus/ency/article/003437.htm. Western Regional Climate Center. 2007. Climate Summaries: Arlington, Oregon (350265); Hilo WSO AP 87, Hawaii (511492); Honolulu WB Airport 703, Hawaii (511919); Mikkalo Larson Rance, Oregon (355545); Portland WS FO, Oregon (356751), Longview, Washington (454769). Western Regional Climate Center, Di vision of Atmospheric Sciences, Desert Research Institute. Last accessed April 24, 2007, http://wrcc@dri.edu. Willmann, F. 2005. Follow-up on Poly Bags Waste Management. Personal communication to B. P. Caton on October 31, 2005, from F. Willmann (Waste Management). Archived at the PERAL library, Raleigh, NC. Willmann, F. 2007. Response Requested: Clarification on Waste Volumes Hawaii waste. Personal communication to D. Alontaga on June 25, 2007, from F. Willmann (Waste Management). Archived at th e PERAL library, Raleigh, NC. Zhang, F., and D. P. Schmitt. 1994. Host status of 32 plant species to Meloidogyne konaensis

. Supp. J. Nematol. 26(4S):744-748.

Contacts

Center for Plant Health Science and Technology 1730 Varsity Drive, Suite 300 Raleigh, NC 27606 919-855-7595 (fax)

Barney P. Caton, Ph.D. Ecologist/Pest Risk Analyst barney.p.caton@aphis.usda.gov

919-855-7504 Betsy Randall-Schadel, Ph.D. Plant Pathologist/Risk Analyst betsy.randall-schadel@aphis.usda.gov

919-855-75442 33 

### Appendix F. Risk of Introduction of Pests to Idaho via GRG from

Hawaii.

### United States Department of Agriculture

Animal and Plant Health Inspection

Service

September 2007 

## The Risk of Introducing Pests to Elmore County, Idaho, via Plastic-Baled Municipal

Solid Waste from Hawaii

Agency Contact : Barney P. Caton

Authors : Barney P. Caton, Andrea Lemay, and Betsy

Randall-Schadel

Plant Epidemiology and Risk Analysis Laboratory

Center for Plant Health Science and Technology Plant Protection and Quarantine 1730 Varsity Drive, Suite 300 Raleigh, NC 27606Version 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 2 35 Executive Summary

Proposals to move waste to mainland landfills in airtight

bales

This assessment is for proposed transport to

Idaho

Description of transport

means and route

Unsuitable climate

No exceptional factors favoring pest establishment

Risk rating different than Low Risk not justified Companies are proposing to trans port large volumes of Hawaiian municipal solid waste (MSW) in airtight bales to landfills in the continental United States. In a previ ous general pest risk assessment,

CPHST found that the risk of intr oducing pests from Hawaii via this pathway was insignificant. The following is an assessment of a proposal by Idaho Waste Systems, Inc. to transport baled MSW to the Simco Road Regional Landfill in Elmore County, Idaho. The landfill is a modern facility that complies with all relevant federal regulations. Our objective was to de termine if the proposal entails any exceptional risks, due to diffe rent procedures or the specific transport route or location of the land fill, that would justify a different recommendation than was made for the general pathway.

This proposal closely follows the procedures for waste processing, bale creation, monitoring, and trans port outlined in the general pest risk assessment. The company propos es to barge the baled MSW to the mainland for unloading at Rainier, Oregon. Bales will be transported directly to the landfil l by rail. The transportation methods

to be used are low risk for accid ents that might rupture bales.

In addition, the climate in Elmore County is much drier and colder than that in Oahu, which will mitigate against many possible introductions of subtropical Hawaiian pests.

We found 44 Federal or State quaran tine plant pests relevant to this pathway. These included 19 insects, 16 pathogens and nematodes, two mollusks, and nine invasive plants. None of them posed an exceptional threat—i.e., factors enab ling special means of escaping or dispersing, or an enhanced lik elihood of establishment—of introduction and establishment via this pathway.

In conclusion, we found no factors that justified a different pest risk finding than the Low Risk rating given in the general risk assessment. The transportation of baled MSW from Hawaii to Elmore County, Idaho, poses an insignificant risk of pest establishment

. We recommend that the pathway be monitored to ensure that procedures and compliance do not differ significantly from what was

described in this document and in the general pest risk assessment.Version 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 23 6 Introduction

General pest risk

assessment done in 2005

High-density, airtight bales

Previous finding was insignificant pest risk

Factors contributing to low risk for the pathway

Low Risk ratings given to pest introductions

New proposal for Idaho

Objective is to find exceptional risk factors

Site-specific factors

considered A general pest risk assessment was done by the Center for Plant Health Science and Technology (CPHST ) at the request of Hawaii to

assess the likelihood of introduction of pests into the continental United States via the transport of Hawaiian plastic-baled municipal solid waste (MSW) (CPHST, 2005a). In the baling process MSW is compressed and wrapped in adhesive-backed, plastic film barriers made of low density polyethylene (L DPE), creating airtight packages. Bales are then transported by barg e to a receiving facility on the mainland, taken to landfills by rail or truck, and buried (intact) in accordance with solid waste dispos al regulations (40CFR§258; EPA (1993). The assessment dealt with parts of the pathway applicable to all companies proposing to transport baled MSW. A pest risk assessment was necessary because garbage from Hawaii cannot enter

the continental U.S. under current fe deral regulations for plant pests (7CFR§330.400).

CPHST concluded that, if the gene ral procedures described were followed, the transportation of ba led MSW from Hawaii posed an insignificant risk of pest introdu ction and establishment (CPHST, 2005a) for the following reasons:

● the exclusion of most yard and ag ricultural waste from the pathway would reduce the presence of potenti al plant pests or propagules in

the bales

● insects and some pathogens are unlikely to survive in the bales

● other pathway procedures ( e.g ., monitoring during transport) would adequately protect against escapes via accidental ruptures and punctures during handling and transport Qualitative risk analysis indicated th at the cumulative risk ratings for the introduction of insects, pa thogens, and weeds were Low.

Idaho Waste Systems, Inc. has proposed moving baled MSW from Hawaii to the Simco Road Regional Landfill in Elmore County, Idaho. Bales will be transported by barge to Rainier, Oregon, and then by rail to the landfill. The obj ective of this assessment is to evaluate the proposal by Idaho Wast e Systems to determine if any exceptional risk factors exist to wa rrant a risk rating greater than Low. Although a specific baling t echnology provider has not been designated by Idaho Waste Systems, the proposed procedures for baling and transporting the MSW (Idaho Waste Systems, 2005) closely follow those evaluated by CPHST (2005a). Specific items considered include the destination landfill, Federal and State quarantine pests of concern, the t ype(s) of transpor tation used to

move bales after reachin g the mainland, and other notable factors in the proposal.Version 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 23 7 Definitions of key terms

Definition of ‘garbage’

Definition of ‘spill’

Other definitions Garbage is defined (CPHST, 2005a) as urban (commercial and residential) solid waste from muni cipalities in Hawaii (e.g., Honolulu, Hilo). Based on proposals to move baled waste, we assumed in this analysis that the company will actively exclude yard and agricultural

waste from the waste stream.

A spill is defined as the escape of waste material from a bale, and contact with the ground, tr uck, tractor, barge, or other terrestrial

features.

Other important terms are defined as follows (Merriam-Webster, 2004):

Anoxia : Hypoxia especially of such severi ty as to result in permanent damage

Anoxic : Greatly deficient in oxygen

Hypoxia : A deficiency of oxygen reac hing the tissues of the body

Anaerobic : Living, active, occurring, or existing in the absence of free oxygen. The term applies to living organisms, not those that are non-living, like bales, or the conditions within them

Proposal review

Eleven important details from the proposal

Diversion of some waste

Volume will increase in

time

Baling system details

Staging and storage

Transportation route Idaho Waste Systems (2005) indicated the following important details in their proposal:

1) Agricultural and yard waste will be diverted to other disposal sites or separated from conveyors belts as it enters processing so that yard waste does not enter the pathway: the goal will be to achieve 3 percent or less yard waste entering the waste stream 2) The company plans to start tran sporting about 5,000 tons of baled MSW monthly, or 60,000 tons annuall y, but to increase that over time to the full barge capacity available, which would mean 30,000 tons monthly, or 360,000 tons annually (Gauthier, 2006) 3) The waste compression and baling system (Macpresse solid waste baler, model MAC 112; Idaho Waste Systems, 2005) will create rectangular bales weighing about 1.7 tons, with densities from about 1,000 to 1,500 lbs to per cu bic yard (approx. 640 to 880 kg/m 3 ) (Harris, 2005). Total thrust produced is equal to 440,000 pounds, or 235 psi, which 4) Any imperfectly sealed bales found during staging in Hawaii will be rewrapped and re-staged. 5) Any stored bales will be kept on hard, impervious surfaces, at least 100 ft from any vegetation or agricultural product 6) Bales will be moved to the mainland and up the Columbia RiverVersion 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 23 8

Direct loading onto railcars

Manifesting system

Company inspections

Bale repairs

Bales monofilled at the

landfill

Use of vapor meters could be an improvement

Restaging repaired bales is not necessary

Bales palletized from Hawaii to Oregon

Forklifts may reduce the drop rate but increase the likelihood of punctures by barge to a facility near Ra inier, Oregon (Columbia County) (Fig. 1), unloaded, and then moved to the landfill by rail, a distance of 550 miles (distance es timated as Longview, WA, to Simco, ID) (Union Pacific Railroad Corp., 2006) 7) The company plans to move bales from the barge directly onto rail cars, to reduce handling 8) Bales will be tracked with an electronic (“chain-of-custody”) manifesting system 9) Bales will be inspected by the company for ruptures and punctures at each handling point. An organic vapor analyzer/meter will be used to detect waste decompositi on gases that would escape if a puncture or rupture allowed oxygen to re-enter the bale 10) Broken or ruptured bales will be patched or repaired when and where found. Bales will be repaired if ruptures are 6 inches long or less; otherwise they will be rewrapped at a mainland baling facility 11) Bales will be segregated, or “m onofilled,” in the landfill to allow careful handling and to avoid wa ste compacting operations used for daily deliveries of regular MSW

In regard to item (5), we could not fully evaluate the effectiveness of the organic vapor meter; however, if it is sufficiently sensitive and properly used it could improve visual detection of small breaches.

Also note that for item (10) above, restaging is not necessary since the initial staging in Hawaii would have met the requirement. At this point, getting the bale to the landfill quickly is proper.

The company will handle the bales on pallets in Hawaii and while barging them to the mainland. The pallets are the type used for newsprint, wooden, with featur es (e.g., rounded edges, sanded planks) designed to avoid snagging or tearing (Gauthier, 2007). One pallet has the capacity for four bales, which will minimize the number of handling operations required, bu t expose four bales to a single accident. Furthermore, the use of st andard forks will expose bales to accidental punctures and rips. If ne cessary, the company will strap the bales together or to the pallets. Palletized bales probably will be handled using lift trucks with st andard forks, or cranes, which

increases the likelihood for bale punctures. After off-loading in Oregon, bales will be separated from the pallets and handled using lift trucks with clamp-type arms.Version 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 23 9 Destination landfill

Proposed landfill

Alternate landfill Simco Road Regional Landfill (http://www.idahowaste.com/ simco.html) is in Elmore County, about 30 miles southeast of Boise. It is a modern facility that meet s regulations and EPA guidelines for design and operation (e.g., EPA, 199 3). We have no reason to believe that bales will not be properly landf illed at this site; therefore, the mitigation likely to come from landfilling (CPHST, 2005a) is valid.

Rail travel to Idaho from the we st may sometimes close during the winter . In that case, the company has proposed to deliver the bales to the Columbia Ridge Solid Waste Landfill in Gilliam County, Oregon (http://www.wmnorthwest.com/landfill/landfillcities/ columbia.html), near the town of Arlington. As above , it is a modern facility meeting all regulations and EPA guidelines. The environment of the alternate landfill poses no exceptional pest risks (CPHST, 2007).

Transportation of bales

Bales moved 60 miles by barge

1,429 years to the first bale-rupturing barge

accident

550 miles by rail to Idaho

385 years to the first balerupturing rail accident

Only 180 rail miles to

alternate landfill site Bales will be barged 60 miles up th e Columbia River, and off-loaded onto railcars at Rainier, OR. Based on data on the number of freight barge accidents from 2000 to 2005, and estimates of the mean number of miles freight was moved, the mean barge accident rate was 0.000575 per mile (Appendix A). The mean annual probability of a bale-rupturing barge accident was 0.0007 (0.07 percent). This gave a mean of 1,429 years to the first ba le-rupturing accident, with only a 5 percent chance of happening within 74 years.

The trip by rail to the landfill is 550 miles. Like barges, rail transport has a very low accident rate: th e mean rate from 1996 to 2006 was 3.92 accidents per million rail miles (Appendix A). From that rate and other parameters, the annual prob ability of a bale-rupturing train accident was 0.0005 at the beginning of service, and 0.0026 (0.26 percent) after the anticipated incr ease in volume. Accordingly, the estimated means for years to the first bale-rupturing accident were 2000 years at the beginning, and 385 years after the increase. In addition, even in the latter case, th ere is only a 5 pe rcent chance of that accident happening within 20 years.

If transported by rail to the Columbia Ridge Landfill from Rainier, the barge miles would not change, wh ile rail distance would decrease

to 180 miles. We assumed this woul d only affect trips 25 percent of the time (3 mos. out of 12). Given this, the risk of any bale-rupturing

rail accident was 0.035 percent under the star ting MSW amounts, and 0.235 percent for future amounts. M ean years to the first balerupturing accident for trains was 2,8 57 at start, and 426 in the future.Version 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 2 40

426 years to the first balerupturing rail accident We found a 95 percent chance that the first train accident would occur only after 147 years at star t, and after 22 years with the increased amounts. Using the landfi ll in Oregon would decrease the risk somewhat, because fewer rail miles would be traveled.

Local environment

Elmore County is very arid

Major crops are livestock and pasture/forage Northern Elmore County is mountainous, while the southern portion—where the landfill is located—slopes down to the Snake River. The area is “a relatively pa rched environment” (Schlosser, 2004) that supports drought-tolerant sagebrush and grasses (Fig. 2).

Elmore County is primarily a livestock and pasture/forage area (National Agricultural Statistics Service, 2002). Other crops grown include sugar beets, potatoes, wh eat, and fresh market vegetables.

Climate

Hawaii: Mild climate, no freezing

Idaho is much drier and

much colder

Short growing season

Transport route mostly has

climate like SW Idaho Hawaii’s tropical climate is char acterized by relatively uniform day lengths and temperatures (Nati onal Weather Service, 1983). Annual climatic averages for Honolulu (Island of Oahu) are maximum temperature = 88.0 oF, minimum temperature = 74.4 oF, and total precipitation = 20.75 ′′ (Western Regional Climate Center, 2005a).

Elmore County is significantly drier and colder than Oahu. Mean annual precipitation is only about 10 ′′ , most of which falls as snow from November to February (Western Regional Climate Center, 2005b). Mean daily minimum temperat ure in the county is 36.7 °F, and the mean daily maximum is 64.8 °F. Mountain Home, near the landfill, has about 150 days a year in which the temperature drops below freezing, 32 deg F. The growing season is only about 135 days.

Most of the transport route (Fig. 1) is also in the rain shadow of the coastal range, and would be significantly drier than Oahu, and colder

as well.

Potential plant pests

Very low pest incidence in

MSW Quarantine plant pests fo r Idaho include insects, pathogens, mollusks, and invasive plants. We expect an extremely low incidence of these pests in typical MSW.

Insects Only species of concern are

federal quarantine insects No insects of concern for Idaho (http://www.agri.state.id.us/ Categories/PlantsInsects/Re gulatedAndInvasiveInsects/ Insectpestwatchlist.php) are presen t in Hawaii except for federallyVersion 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 2 41 quarantined pests (Table 1). Inse cts are Low Risk because they

cannot survive inside the bales (CPHST, 2005a); we do not discuss

them further here.

Pathogens

Risk from both federal and state quarantine pests Bacterial, fungal, nematode and vira l diseases of plants under Federal or Idaho quarantine are present in Hawaii and can be transported (Tables 2 and 3). For various reasons , these organisms are unlikely to

establish in Idaho via th is pathway (Table 4).

Invasive plants

Many Idaho noxious weeds are already present and widespread

Three relevant noxious weeds are present in HI

Risk mitigating factors include aquatic habit and

unsuitable means of reproduction The state list of noxious weed speci es for Idaho includes species that are often already widespread (Divis ion of Plant Industries, 2007a). Consequently, few of the listed spec ies have limited distributions and

would be a concern. Nine noxious weed species categorized as ‘Early Detection-Rapid Response’ represent the most risk (Table 5). Only three are reported as presen t or cultivated in Hawaii: Egeria densa (Brazilian elodea), Eichhornia crassipes (water hyacinth), and Hydrilla verticillata (hydrilla) (Bishop Museum, 2002; Imada et al.

, 2007). All three species are aquatic , and the arid conditions in southwest Idaho would greatly mitigat e the risk from all three species. Furthermore, two of them—el odea and hydrilla—rely greatly on reproduction from leaf fragments (Kay and Hoyle, 2007a, 2007b), which would not be possible via this pathway because plant material

would not survive in the bales. As in the PRA for Washington state (CPHST, 2005b), the risk from invasi ve plants in baled MSW is Low.

Mollusks

No risk in baled MSW, but potential risk as hitchhikers

Pallets increase the

likelihood of hitchhikers

Four of six Idaho-regulated

species are not present in

Hawaii

Risk mitigating factors Generally, mollusks in baled MSW pose no risk because they would be killed by either compression or hypoxia. They may pose risks as

hitchhikers on the outside of bales, however (CPHST, 2006; Robinson, 2006). Unfortunately, in th is proposal the planned use of pallets to transport the bales incr eases the likelihood that hitchhiking mollusks could follow the pathway. Pa llets provide better cover and will be more difficult to inspect than the plain surfaces of the bales.

The regulated list of mollusks for Idaho has six species (Division of Plant Industries, 2007b). Four are not present in Hawaii, but the

others— Achatina fulica (giant African snail), and Cornu aspersum (brown garden snail) (Bishop Museum, 2004b)—are among several Federal quarantine phytophagous sn ails that occur in Hawaii (Robinson, 2006) and might hitchhike on bale exteriors (Table 6).

Smith and Fowler (2003) rated the risk for movement of A. fulica , by cargo and empty containers as low, partly because its large size

would facilitate detection. Moreove r, except for the off-loading pointVersion 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 242 Unsuitable climate for giant

African snails in Idaho

C. aspersum already present in nearby California

Inspection and proper staging should

reduce the risk in Oregon, weather-based mapping i ndicated that Idaho and eastern Oregon are not suitable for A. fulica establishment (Smith and Fowler, 2003). We do not know if the climate is suitable for other species such as C. aspersum , but that species has been a problem pest in California for many y ears (Grafton-Cardwell et al. , 2005). Dispersal from there probab ly poses a greater risk.

If bales are inspected and certified to be mollusk-free, and if they do not contact moist substrates, such as soil or mulch, before departure from Hawaii, the pathway should be low risk (Robinson, 2006). We strongly recommend that this inspection and cert ification be required and implemented. Likewise, the st aging area for bales in Hawaii should always be on an impervious surface, and should be appropriately distant from vegeta tion to reduce th e likelihood of snails being present (CPHST, 2006).

Figure 1 . Map showing barge (light blue) and rail (yellow) transport route for baled MSW to the Simco Road Regional Landfill in Idaho.

Figure 2. Sagebrush-dominated plant co mmunity typical of Southwest Idaho

©BLMVersion 1, September 26, 2007PRA for Hawaiian Baled MSW to ID243Table 1. Federally quarantined insects present in Hawaii and potentially relevant to Idaho ecosystems.Scientific name (Order: Family) Common nameReference1Aceria litchi(Acarina: Eriophyidae)synonym:Eriophyes litchilitchi rust mite, litchi gall mite Chia et al. (1997), USDA-APHIS (2005)Adoretus sinicus(Coleoptera: Scarabaeidae)Chinese rose beetle7 CFR§318.13Adoretussp.– 7 CFR§318.60Bactrocera cucurbitae(Diptera: Tephritidae)melon fly7 CFR§318.13Bactrocera dorsalis(Diptera: Tephritidae) Oriental fruit fly 7 CFR§318.13Cactoblastis cactorum(Lepidoptera: Pyralidae)cactus borer7 CFR§318.13Ceratitis capitata(Diptera: Tephritidae) Mediterranean fruit fly 7 CFR§318.13Coccus viridis(Hemiptera: Coccidae)green scale7 CFR§318.13Chilo suppressalis(Lepidoptera: Crambidae) Asiatic rice borer 7 CFR§318.13Eriophyes gossypii(Acarina: Eriophyidae)cotton blister mite7 CFR§318.47Euscepes postfasciatus(Coleoptera: Curculionidae)sweet potato scarabee 7 CFR§318.30Lampides boeticus(Lepidoptera: Lycaenidae)bean butterfly7 CFR§318.13Maconellicoccus hirsutus2(Hemiptera: Pseudococcidae)pink hibiscus mealybug CABI(2005), USDA-APHIS-PPQ (1996)Maruca testulalis(Lepidoptera: Pyralidae)bean pod borer7 CFR§318.13Omphisa anastomosalis(Lepidoptera: Pyralidae) sweetpotato stem borer 7 CFR§318.30Pectinophora gossypiella(Lepidoptera: Gelechiidae)pink bollworm7 CFR§318.47Phyllophagaspp.white grubs 7 CFR§318.60Phytalussp.white grubs7 CFR§318.60Sternochetus mangiferae(Coleoptera: Curculionidae)synonym:Cryptorhynchus mangiferaemango seed weevil 7 CFR§318.131CFR = Code of Federal Regulations2This pest is established in California, Florida and Hawaii and is under biological control (Meyerdirk, 2004), but not officialcontrol. (Official control is defined as “theactive enforcement of mandatory phytosanitary regulationsand the application of mandatory phytosanitary procedureswith the objective of eradication or containmentof quarantine pests” (IPPC, 2001).) Thus, it does not fit the IPPCdefinition of a quarantine pest: “A pest of potential economic importance to the area endangeredthereby and not yet present there, or present but not widely distributed and being officially controlled” (IPPC, 2001).Version 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 24 4 Table 2

. Federally quarantined pathogens in Hawaii that are relevant to Idaho ecosystems.

Scientific name (Order: Family) Common name Reference Meloidogyne konaensis (Nematoda:

Meloidogynidae) root-knot nematode Zhang and Schmitt (1994)

Phakopsora pachyrhizi (Uredinales:

Phakopsoraceae) soybean rust USDA-APHIS-PPQ,2003; USDA-APHISPPQ, 2005

Xanthomonas albilineans

(Xanthomonadales: Xanthomonadaceae) sugarcane leaf scald USDA-APHIS-PPQ, 2003

X. axonopodis pv vasculorum

(Xanthomonadales: Xanthomonadaceae) Synonym: X. vasculorum sugarcane gumming

disease USDA-APHIS-PPQ, 2003

Table 3

. Plant pathogens and parasitic nematodes of concern in Idaho (Division of Plant Industries, 2005), and that are present in Hawaii (CABI, 2005; Raabe et al., 1981; University of Hawaii and Hawaii Department of Ag riculture, 2004; USDA-APHIS-PPQ, 2003).

Category Scientific name Common name

Not known to occur or not detected in the state

Bean common mosaic virus 1 (strain US-6) bean common mosaic virus

Colletotrichum truncatum lentil anthracnose

Colletotrichum lindemuthianum 1 bean anthracnose Curtobacterium flaccumfaciens pv flaccumfaciens 1 bacterial wilt of beans Phakopsora pachyrhizi soybean rust

Pseudomonas savastanoi pv phaseolicola 1

synonym: P. syringae pv phaseolicola halo blight of beans

Xanthomonas axonopodis pv phaseoli

synonym: X. campestris pv phaseoli common blight of beans

Limited distribution or newly established Ditylenchus dipsaci (onion race) onion stem and bulb nematode
Fusarium graminearum wheat scab Phytophthora infestans potato late blight Pseudomonas syringae pv syringae bacterial brown spot of beans Sclerotium cepivorum 2 onion white rot

1 Reported as present in Idaho (CABI, 2005).

2 Pests of moderate to high concern.Version 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 24 5 Table 4. Rationales for pathogens being Low Risk for introduction a nd establishment in Idaho via

baled solid waste from Hawaii.

Common/scientific name Rationale for Low Risk rating

▪ bacterial brown spot of beans

▪ bacterial wilt of beans

▪ common blight of beans

▪ halo blight of beans

▪ sugarcane gumming disease

▪ sugarcane leaf scald ▪ Aerobic bacteria need oxygen and are unlikely to survive in

bales

▪ Free bacteria have lower surviv al rates, i.e., when not in

contact with suitable host material (Agrios, 2005)

▪ bean anthracnose

▪ lentil anthracnose ▪ Primarily seedborne (CABI, 2005), so it is unlikely to be present in the bale or to disperse after escape

▪ Dormant agents may require oxygen

▪ bean common mosaic virus

(strain US-6) ▪ Seedborne and aphid-vectored (CABI, 2005); aphids cannot survive and infected seeds are unlikely to be present

▪ Only multiplies in living cells (Agrios, 1997) and suitable host plants; would not enter or survive in the bales

▪ onion stem and bulb

nematode ▪ Needs oxygen for survival

▪ Seedborne (CABI, 2005), so it is unlikely to be present or to disperse after escape

▪ Most stages need host material for survival (CABI, 2005)

▪ Fourth stage juveniles surviv e for years without a host, but populations decline rapidly (CAB I, 2005) and are not likely to survive other bale conditions (e.g., compression, anoxia)

▪ onion white rot ▪ Fungus is unlikely to survive anoxic conditions in the bale

▪ Dormant sclerotia germinate only in soil in the presence of specific root exudates from Allium spp. (CABI, 2005)

▪ potato late blight ▪ Dormant agents may need oxygen for survival

▪ Except for oospores, a living host or crop debris is required for survival (CABI, 2005), whic h are unlikely to be present

or to survive in the bales

▪ The asexual stage only occurs with contact to living host material (Agrios, 2005; CABI, 2005), which is unlikely to be present in the pathway

▪ root-knot nematode ▪ Dormant agents may need oxygen for survival

▪ Cool temperatures are expect ed to kill eggs (Schmitt, 2002)

▪ The nematode has limited tolerance to temperature change (prefers 75±10 °F), so clima tic conditions in Idaho would probably prevent long-term establishment (Schmitt, 2002)

▪ Dispersal is primarily via ro ots and tubers, or by field equipment (Agrios, 2005), whic h are both unlikely to occur

▪ wheat scab ▪ Seedborne; requires host material for survival (CABI, 2005), which is both unlikely to be present and to survive

▪ Needs oxygen for survivalVersion 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 24 6 Table 5. Idaho noxious weeds classified as ‘Early Detection-Rapid Response’, with scientific and common names and reported presence or cultivation in Hawaii.

Scientific Name Common Name Present 1 Cultivated 2

Centaurea squarrosa squarrose knapweed No No
Eichhornia crassipes water hyacinth Yes Yes Egeria densa Brazilian elodea Yes Yes Heracleum mantegazzianum giant hogweed No No Hieracium glomeratum yellow devil hawkweed No No
Hieracium piloselloides tall hawkweed No No Hydrilla verticillata hydrilla No Yes Impatiens glandulifera policeman's helmet No No Zygophyllum fabago Syrian beancaper No No

1 Bishop Museum (2004a)

2 Imada et al . (2007)

Table 6

. Federal quarantined and regulated mollusks pr esent in Hawaii that may be relevant to Idaho ecosystems. Scientific name (Type: Family) Common name Reference
Achatina fulica Bowdich (Mollusca: Achatinidae) giant African land snail Cowie (1977; 2002b); Robinson (2006)
Cornu aspersum (Müller) (Mollusca:

Helicidae) [Syns. Cryptomphalus aspersus (Müller);

Helix aspersa Müller] brown garden snail Cowie (1977; 2002b); Robinson (2006)

Laevicaulis alte (Férussac) (Mollusca: Veronicellidae) tropical leatherleaf Cowie (1977; 2002b)

Meghimatium striatum van Hasselt (Phylomicidae) a terrestial snail Cowie (2002a); Robinson (2006)

Parmarion cf. martensi (Simroth) [identification tentative] a semi-slug 1 Robinson (2006)

Paropeas achatinaceum (Pfeiffer) a snail Robinson (2006)
Pila ampullacea (Linné) “apple snail” Robinson (2006)

Pila conica (Wood) “apple snail” Robinson (2006)

Pomacea canaliculata (Lamarck) 2 channelled apple snail Cowie (1977; 2002b); Robinson (2006)

Veroncella cubensis (Pfeiffer) (Mollusca: Veronicellidae) two striped slug or Cuban slug Cowie (1977; 2002b); Robinson (2006)

1 Carrier of human parasitic nematode, Angiostrongylus cantonensis

2 This is the worst of four Pomacea species in HIVersion 1, September 26, 2007

PRA for Hawaiian Baled MSW to ID 24 7 Conclusions

No exceptional risks found for Idaho proposal

Three notable mitigation

factors

Overall conclusion is an insignificant risk of plant pest establishment

This assessment only dealt with pest risks

The pathway may be

disallowed for other

reasons We found no exceptional risks rela ted to the Idaho Waste Systems proposal that justified a finding differe nt from that given in the earlier document by CPHST (2005a). Three risk mitigating factors seemed particularly noteworthy: • The climate in Elmore County is ve ry different from that of Oahu; • Very few invasive plant species of concern in Idaho are present in

Hawaii • The risks from potentially invasive diseases and pathogens are likely to be mitigated by the bale tec hnology, climate, and other factors

Overall, Idaho Waste Systems transporting MSW from Hawaii to Simco Road Regional Landfill in plastic-wrapped, airtight bales poses an insignificant risk of pl ant pest establishment.

Finally, we note that we have onl y addressed the plant pest risks associated with the proposal by Id aho Waste Systems to move baled MSW from Hawaii to Idaho. Comple te approval of the proposal (pathway) or particular proce dures should not be inferred. The pathway and proposal in question may still be subject to denial or modification, in whole or in part, based upon other issues or constraints (pest or non-pest related) , such as available resources or other State or Federal regulations.

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PRA for Hawaiian Baled MSW to ID 2 50 USDA-APHIS. 2005. Regulated Pest List Project. USDA-APHIS. Last accessed September 30, http://www.invasivespecies .org/PestListResults.CFM. Western Regional Climate Center. 2005a. Hawaii Climate Summaries: Honolulu WB Airport 703, Hawaii (511919). Western Regional Climate Center, Division of Atmospheric Sciences, Desert

Research Institute. Last accesse d October 3, http://www.wrcc.dri.ed u/cgi-bin/cliMAIN.pl?hihono. Western Regional Climate Center . 2005b. Mountain Home, Idaho (10617 4): Period of Record Monthly Climate Summary. Western Regional Climate Cent er, Division Of Atmosphe ric Sciences, Desert

Research Institute. Last accesse d August 22, http://www.wrcc.dri.ed u/cgi-bin/cliMAIN.pl?idmoun. Zhang, F., and D. P. Schmitt. 1994. Host status of 32 plant species to Meloidogyne konaensis . Supp. J. Nematol. 26(4S):744-748.

Contacts

Plant Epidemiology and Risk Analysis Laboratory Center for Plant Health Science and Technology 1730 Varsity Drive, Suite 300 Raleigh, NC 27606

Barney P. Caton, Ph.D., Ecologist/Pest Risk Analyst barney.p.caton@aphis.usda.gov

919-855-7504 919-855-7595 (fax)

Betsy Randall-Schadel, Ph.D., Plant Pathologist/Risk Analyst betsy.randall-schadel@aphis.usda.gov

919-855-7544Appendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 2 51 

### Appendix A . Updating the models fo r the likelihood of bale-rupturing accidents during transport of baled municipal solid wa ste (MSW) by truck, rail, or barge.

I. Introduction

This appendix describes updates and changes to the previous model version

Only relevant sections

included here

Also report effects on previous model results In 2006, we released a description of the models used to estimate the likelihoods of bale-ruptur ing accidents occurring during transport of baled MSW to landfills on the U.S. mainland by either truck, rail, or barge. Since then, more data on accident rates has become available, and we have changed the way barg e accidents are predicted, so we discuss below the changes and updates to the accident models.

Only the relevant sections are included below. For full model details and descriptions, see Appe ndix B in CPHST (2006a).

For completeness, though, we have also included the effects these changes would have on the results of previous models, for the generic situation (CPHST, 2006a) and for th e Washington state PRA (CPHST, 2006b).

II. Updated accident-related distributions

A. Barges

1. Total accidents

Barge accident rates were

in ton-miles before

Changed to a rate based

on miles, not ton-miles

“Average haul” statistic provided necessary

conversion factor

Mean annual barge miles

on the Columbia was
110,000 miles The first change made was in the way we calculated the barge accident

rate. That rate used to be based on ton-miles, because that is how waterborne freight is commonly re ported (e.g., U.S. Army Corps of Engineers, 2003). In contrast, the acc ident rates for trucks and trains

are based on vehicle miles traveled (VMT). That had the unfortunate effect, however, of increasing risk if the tonnage transported increased,

even if total distance traveled wa s unchanged. Therefore, we changed the barge accident rate to match th e others, calculating it in terms of

miles rather than ton-miles.

To do this, we needed to estimate annual miles traveled from annual

ton-miles. We converted ton-miles to miles using the national “average haul”, or the mean number of miles a ton of freight travels by water. For internal (inland) barge traffic, this value has been relatively constant over the years at about 465 miles per ton (U.S. Army Corps of Engineers, 2006b). Using these va lues, and total annual ton-miles for the Columbia River system (U.S. Army Corps of Engineers, 2006a), we calculated mean annual miles traveled, which was about 110,000 miles.

The accident rate was calculated from statistics for 2000 to 2005 forAppendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 2 52 Fewer accidents in 2003 and 2005 than other years

Model rate was a triangular

distribution numbers of accidents on the Columbia River (U.S. Coast Guard, 2007). The previous estimate was ba sed on just two years of data, 2000 and 2001. The number of accidents per year was often about 80 to 85, in years 2000, 2001, 2002, and 2004. But in 2003 it was only 29,

and in 2005 it was 36. The accident rate was annual accidents divided by miles, and these values ranged from 0.00028 in 2003, up to 0.00088

in 2002. The mean value was 0.00061. We estimated the model rate as a triangular distribution (F ig. A1) with most likely value = mean value, and the minimum and maximum values from the 99 percent

confidence limits around the mean. Ninety percent of the sampled

values from the distribution were between 0.00032 and 0.00090.

2. Relevant accidents Data unchanged Accident reporting to the level of type of vessel has apparently stopped since the last work was done, and so it was not possible to include more information. Even in the prev ious PRA we only had data on this

from 2000 and 2001.

3. Bale-rupturing accidents Updated release rate

No change from previous

estimate We updated the estimate of the pr oportion of barges in serious hazardous waste accidents (1990-1997 data) with data from 1998 to 2006 (Hazardous Materials Information System, 2007a, 2007b). The updated data had 6 serious incident s out of 216 total incidents (2.8 percent). When combined with the previous data, the new beta distribution had a mean of 0.046, a nd 90 percent of sampled values were between 0.028 and 0.069 (Fig. A2). The updated mean value was about half of the previous mean.Appendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 2 53 Fig. A1 . The distribution for the barge accident rate, number per miles traveled, based on data from

2000 to 2005. Lines are the 5th and 95th percentiles, so 90 percent of samples fall between the lines.

0 0.2 0.4 0.6 0.8

1 1.2 1.4 1.6

0.0002 0.0003 0.0004 0.0005 0.0006 0.0007 0.0008 0.0009 0.001

Probability of a barge accidentProbability density function

Fig. A2 . The distribution for the likelihood of a barge accident causing bale rupture, based on data from

1990 to 2006. Lines are the 5t h and 95th percentiles.

0 5 10 15 20 25 30 35

0 0.015 0.03 0.045 0.06 0.075 0.09 Likelihood of bale-rupturing accidentProbability density functionAppendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 25 4 B. Trucks

1. Total accidents Updated estimate with

2005 data We updated the data to include 2005 accidents. The new mean rate was 1.89 accidents per million VMT, a decrease from the previous mean of 1.96. The pert distribution had minimum = 1.56, and maximum = 2.23, with 90 percent of sampled values between 1.68 and 2.10 (Fig. A3).

2. Relevant accidents

Overall probability is based

on two likelihoods

Likelihood of an accident to

an intrastate truck

Likelihood of an accident to

a flat-bed truck The likelihood of an accident bei ng relevant is the product of two likelihoods: 1) the probabili ty of an accident dur ing intrastate travel, and 2) the probability of an accident occurring to a flat bed truck.

Before, the distribution for the likeli hood of an accident to an intrastate truck was based on data from 2003 to 2004 only. We updated that data

here to include 2002 to 2005 data (Federal Motor Carrier Safety Administration, 2007). The likelihood was estimated as the proportion

of accidents to intrastate trucks , which had a mean of 0.148, with 99 percent confidence limits of 0.124 to 0.172 (Fig. A4). Ninety percent of the sampled values were between 0.133 and 0.163.

Before, the likelihood of an accident being for a flat bed truck was based only on 2004 data. Here we sp ecified the distribution based on 2002 to 2005 data (Federal Motor Carrier Safety Administration, 2007). The mean proportion of accidents to flat bed trucks was 0.178, with 99 percent confidence limits of 0.152 to 0.204 (Fig. A5). In the model distribution 90 percent of th e sampled values were between

0.162 and 0.194.Appendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 25 5 Figure A3. The distribution for the truck accident rate, number per million miles traveled, based on data

from 2000 to 2005. Lines are the 5th and 95th percentiles.

0 0.5

1 1.5

2 2.5

3

1.5 1.6 1.7 1.8 1.9 2 2.1 2.2 2.3

Truck accident rate (no. per million miles)Probability density function

Figure A4. The distribution for the likelihood of an accident being for intrastate transport, based on data

from 2002 to 2005. Lines are the 5th and 95th percentiles.

0 10 20 30 40

0.12 0.13 0.14 0.15 0.16 0.17 0.18

Proportion of intrastate truck accidentsProbability density functionAppendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 25

Figure A5. The distribution for the likelihood of an accident being for a flat-bed truck, based on data

from 2002 to 2005. Lines are the 5th and 95th percentiles.

0 10 20 30 40

0.15 0.16 0.17 0.18 0.19 0.2 0.21

Proportion of accidents to flat bed trucksProbability density function

C. Trains

1. Total accidents Updated accident rate by including 2005 data

Very little change from previous estimate For trains, we estimated the national accident rate from ten years of data, 1996 to 2005 (Office of Safety Analysis, 2006b). The overall mean was 3.92 accidents per million VMT, for all companies and all modes (e.g., yards and main lines). The distribution based on the 99 percent confidence limits of the me an was a pert with minimum = 3.645, and maximum = 4.186 (Fig. A6). Ninety percent of the sampled

values were between 3.75 and 4.08. Compared to the previous estimate, the values and distribut ion changed only very slightly.

2. Relevant accidents Updated main line freight

accident numbers

Number of freight train

accidents We updated the numbers of accidents to freight trains on main lines. The overall probability of an accide nt being relevant was the product of the two probabilities for fr eight and main line accidents.

Using data from 2000 to 2005, 9,893 out of 21,485 accidents were to freight trains (Office of Sa fety Analysis, 2001, 2003, 2004, 2005a, 2005b, 2006a). We summarized this with 99 percent confidence intervals for the annual proportion, whic h gave a pert distribution with mean = 0.462, minimum = 0.412, a nd maximum = 0.512 (Fig. A7).Appendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 25 7 Number of main line

accidents

Little change from previous

estimates Ninety percent of the sampled values were between 0.431 and 0.493. Out of the 9,893 freight accidents, 5,488 were main line accidents. This data gave a pert distri bution with mean = 0.555, minimum = 0.522, and maximum = 0.588 (Fig. A8). Ninety percent of the sampled

values were between 0.534 and 0.576.

Compared to the previous values (data only through 2004), the mean proportion of freight accidents declin ed only slightly, from 0.47 to 0.462, and the mean proportion of main line freight accidents was basically unchanged: 0.55 then and 0.555 now.

3. Bale-rupturing accidents Updated release rate

No change from previous

estimate We updated the estimate of the proportion of trains in accidents releasing hazardous materials with data from 2005 and 2006 (Office of Safety Analysis, 2006a, 2007). The ne w mean proportion of accidents releasing waste was 0.039. The pert minimum was 0.031 and the maximum was 0.048, with 90 percent of sampled values between 0.034 and 0.045 (Fig. A9). These values were almost unchanged from the previous parameters.

Figure A6. The distribution for the train accident rate, number per million miles traveled, based on data

from 1996 to 2005. Lines are the 5th and 95th percentiles.

0 0.5

1 1.5

2 2.5

3 3.5

3.6 3.7 3.8 3.9 4 4.1 4.2

Train accident rate (no. per million miles)Probability density functionAppendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 25 8 Figure A7. The distribution for the likelihood of a train acc ident being for a freight train, based on data

from 2000 to 2005. Lines are the 5th and 95th percentiles.

0 4 8 12 16 20

0.41 0.43 0.45 0.47 0.49 0.51

Proportion of freight train:all other train accidentsProbability density function

Figure A8. The distribution for the likelihood of a train accident being for a main line freight train,

based on data from 2000 to 2005. Line s are the 5th and 95th percentiles.

0 5 10 15 20 25 30

0.52 0.53 0.54 0.55 0.56 0.57 0.58 0.59

Proportion of main line:other freight accidentsProbability density functionAppendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 25 9 Figure A9. The distribution for the likelihood of a train accident releasing hazardous materials, based on data from 2005 and 2006. Lines are the 5th and 95th percentiles.

0 0.2 0.4 0.6 0.8

1 1.2

30 32 34 36 38 40 42 44 46 48

Proportion of accidents re leasing hazmat (thousandths)Probability density function

II. Updated results from previous models

A. Generic model

Updated estimates not greatly different

Barge transport was

riskiest of the three

conveyances Estimates of risk declined for train transport and increased for transport by barge or truck (Table 1) . Still, the differences were not particularly great. For example, the annual probability of a balerupturing accident for barge transpor t more than doubled, but the mean years to first occurrence was still 308 years. Likewise, the mean number of years to the first bale-r upturing accident for truck transport decreased to 161 years. The same re sponse variable for train transport increased by about 400 years, to 181 8 years. The riskiest conveyance in the generic situation, therefore, was still by barge, which had a 95 percent chance that the first bale-r upturing accident would not happen for at least 7 years.

B. Washington state model

Risk of truck transport

increased four-fold Risk estimates increased by a factor of four for truck transport in the Washington state model, with the m ean annual probability of a balerupturing accident changing to 0.001 1 from 0.0003 (Table 2). Despite this, the annual probability was still very low: mean years to the firstAppendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 2 60

Only a 5 percent chance of happening within 49 years

Risk during barge transport

also increased occurrence was 952 years. In this case, there was only a 5 percent chance of that happening within 49 years.

The annual probability of a bale -rupturing accident during barge transport increased from 0.0037 to 0.0065 (+76 percent). Still, mean years to first occurrence was still 155, with a 5 perc ent chance of happening within 4 years.

Table 1. Comparison of results from the previous gene ric accident model with results from the updated

model.

Response variable Truck Train Barge
Updated Previous Updated Previous Updated Previous

p (any bale-rupturing accident) 0.0062 0.0035 0.0006 0.0007 0.0033 0.0029

Years to 1st bale-rupturing accident 161 285 1818 1429 308 344 5th percentiles 9 15 94 74 16 18

Table 2. Comparison of results from the previous accident model for transport to Washington state with results from the updated model.

Response variable Truck Barge
Updated Previous Updated Previous

p (any bale-rupturing accident) 0.0011 0.0003 0.0065 0.0037

Years to 1st bale-rupturing accident 952 3333 155 130 5th percentiles 49 171 8 7

Contact/Author

Barney P. Caton Plant Epidemiology and Risk Analysis Laboratory

Center for Plant Health Sc ience and Technology (CPHST Plant Protection and Quarantine, Animal and Plant Health Inspection Service U. S. Department of Agriculture 1730 Varsity Drive, Suite 300 Raleigh, NC 27606 barney.p.caton@aphis.usda.gov (919) 855-7504; (919) 855-7595 (fax)

CPHST. 2006a. The Risk of Introduc tion of Pests to the Continental United States vi a Plastic-Baled Municipal Solid Waste from Hawaii. Center for Plant Health Science and Technology (CPHST), Plant Protection and Quarantine , USDA-APHIS, Raleigh, NC. 45 pp.Appendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 261 CPHST. 2006b. The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal

Solid Waste from Hawaii. Center for Plant H ealth Science and Technology (CPHST), Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. 8 pp. Federal Motor Carrier Safety Administration. 2007. Crash Statistics. Federa l Motor Carrier Safety Administration (FMCSA), U.S. Department of Transportation. Last accessed July 06, http://ai.fmcsa.dot.gov/CrashProf ile/StateCrashProfileMain.asp. Hazardous Materials Information System. 2007a. Hazardou s Materials Safety: Serious incidents. Office of Hazardous Materials Safety, U.S. Department of Transportation. Last accessed July 26, 2007, http://hazmat.dot.gov/pubs/inc/ data/tenyr_orig_serious.pdf. Hazardous Materials Information Syst em. 2007b. Hazardous Materials Safety : Total incidents. Office of Hazardous Materials Safety, U.S. Department of Transportation. Last accessed July 26, 2007, http://hazmat.dot.gov/pubs/inc/data/tenyr.pdf. Office of Safety Analysis. 2001. Railroad Safety Statistics: Final Report 2000. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 150 pp. Office of Safety Analysis. 2003. Railroad Safety Statistics: Final Report 2001. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 158 pp. Office of Safety Analysis. 2004. Railroad Safety Statistics: Final Report 2002. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 150 pp. Office of Safety Analysis. 2005a. Railroad Safety Statistics: Final Report 2003. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 159 pp. Office of Safety Analysis. 2005b. Railroad Safety Statistics: Final Report 2004. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 161 pp. Office of Safety Analysis. 2006a. Railroad Safety Statistics: Final Report 2005. Office of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 150 pp. Office of Safety Analysis. 2006b. Thr ee-year accident rate trends. Office of Safe ty Analysis, Federal Railroad Administration. Last accessed July 27, http://safetydata.fra.dot. gov/OfficeofSafety/Query/Defa ult.asp?page=inctally2.asp. Office of Safety Analysis. 2007. 3.07 A ccidents By State/Railroad. Offi ce of Safety Analysis, Federal Railroad Administration, U.S. Department of Transportation. Last accessed July 3, 2007, http://safetydata.fra.dot. gov/OfficeofSafety/Query/defa ult.asp?page=incabbr.asp. U.S. Army Corps of Engineers. 2003. Waterborne Commerce of the United States: Calendar Year 2001, Part 5. Corps of Engineers, United St ates Army, Washington, D.C. 98 pp. U.S. Army Corps of Engineers. 2006a. Waterbor ne Commerce of the United States, Calendar Year 2005: Part 4–Waterways and Harbors; Pacific Co ast, Alaska and Hawaii. Institute for Water Resources, U.S. Army Corps of Engineers, Washington, D.C. 207 pp. U.S. Army Corps of Engineers. 2006b. Waterborne Commerce of the United States, Calendar Year

2005: Part 5–National Summaries. Institute for Wa ter Resources, U.S. Army Corps of Engineers, Washington, D.C. 99 pp.Appendix Version 1, August 2007

PRA for Hawaiian Baled MSW to Idaho 2 62261 U.S. Coast Guard. 2007. Marine Casualty and Polluti on Investigations. Security and Environmental Protection Database Administration Branch (G-P RI-1), U.S. Coast Guard Office of Marine Safety. Last accessed June 20, 2007, http:// www.iwr.usace.army.mil/ndc/db/uscg/data/.