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<p class="header"><i>PRA for Baled Hawaiian Municipal Solid Waste to WA: Updated HWS Proposal</i></p>
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<p>United States Department of Agriculture</p>
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<p>Animal and Plant Health Inspection Service</p>
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<p>December 15, 2009</p>
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<p><a name="OLE_LINK2"></a><b>The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal Solid Waste in Shipping Containers from Hawaii </b></p>
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<p><b>Proposal: Hawaiian Waste Systems</b></p>
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<p><b>Executive Summary</b></p>
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<p>Hawaii Waste Systems (HWS) has proposed transporting large volumes of municipal solid waste (MSW) in airtight bales from Hawaii to landfills in the Continental United States. In previous general and specific pest risk assessments, we found that the risk of introduction of pests from Hawaii via this pathway was insignificant. Here we focus on a revised proposal to transport baled MSW inside shipping containers to a landfill in Klickitat County, Washington State. We assessed whether any exceptional risks associated with the changes to the original proposal would justify a different recommendation than was made for the previous pathway.</p>
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<p>HWS proposes transporting the baled MSW in shipping containers. This may be safer than previous proposals because containers are handled routinely in ports and at rail stations, and because the containers provide extra protection for the bales in the event of an accident.</p>
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<p>P proposes to move baled MSW by sea barge to ports in either Rainier, OR, Longview, WA, or Portland, OR. The containers will be transported by rail to Roosevelt Regional Landfill in Roosevelt, WA. Those locations are somewhat wetter than Klickitat County, but average temperatures are much colder than most Hawaiian cities, and would not be very suitable for pest establishment. Thus, the transportation methods involved are still low risk, and the local environment and climate do not pose exceptional risks. </p>
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<p>In conclusion, the new features of the proposal did not justify a different recommendation. Thus, transportation of baled MSW in shipping containers from Hawaii to Klickitat County, Washington, continues to pose 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 previous pest risk assessment.</p>
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<p class="footer">2</p>
<p class="footer"><i>Risk Assessment: ASR from Japan </i></p>
<table><tbody><tr>	<td><p><b>Introduction</b></p>
</td>	<td><p>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 pests into the Continental United States via the transport of plastic-baled municipal solid waste (MSW) from Hawaii (CPHST, 2006a). That system has been completely described before and assessed both generically (CPHST, 2006a) and for a specific proposal by Hawaiian Waste Systems, LLC (HWS) (CPHST, 2006b) [including the company, Pacific Rim Environmental Resources]. We have also evaluated other different or updated company-specific proposals (CPHST, 2007, 2008, 2009). We concluded in each case that if the proposed procedures were followed, transportation of baled Hawaiian MSW posed an insignificant risk of pest establishment. Some reasons for our conclusion were that the exclusion of most yard and agricultural 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 transport in the bales; and other pathway procedures (e.g. proper staging, mollusk-free certification, monitoring during transport) would adequately protect against introductions of pests. A qualitative risk analysis indicated that the cumulative risk ratings for the introduction of insects, mollusks, pathogens, and pest plants in baled MSW were each Low.</p>
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<p>Now, HWS has proposed changes to the previously assessed protocols (Hawaiian Waste Systems, 2009a). The first is that bales will be placed in shipping containers. The second is that bales will no longer be barged upriver to Roosevelt. HWS plans to take the containers by sea-going barge to one of three ports on the Columbia River (see below). Accordingly, the objective of this assessment is to evaluate the revised proposal to assess whether any exceptional risk factors warrant a recommendation other than the Low risk ratings given previously.</p>
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<tr>	<td><p><b>Review of changes to the proposal</b></p>
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</td>	<td><p>The details of the HWS  proposal are in Hawaiian Waste Systems (2009a). As mentioned above, the general procedures mostly follow those used in the previous assessment, the major changes are the placement of bales within shipping containers during transport as opposed open-air transport, and the destination not being Roosevelt, WA (CPHST, 2006a). The three proposed ports are as follows (no particular order): 1) Teevin Brothers Terminal in Rainier, OR, 2) the Port of Portland, OR, or 3) the Port of Longview, WA (Hawaiian Waste Systems, 2009b). Some important details include the following:</p>
<p>1) Prior to shipment, the bales will be placed inside shipping containers that are sealed and remain so until arrival at the Roosevelt Regional Landfill.</p>
<p>2) Once arriving in Washington, containers will be transported in the following manner: shipments will dock at whichever port, be transferred to rail, and then be transported to the landfill. </p>
<p>3) Containers will be offloaded and moved to a transload facility on landfill property, where bales will be removed from the containers, and then trucked four miles to the working face of the landfill for burial (Regional Disposal Company, 2009).</p>
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<p>All other protocols previously agreed-to by HWS (e.g., bale staging and storage, hitchhiker free certification) are unchanged.</p>
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<tr>	<td><p><i>Use of shipping containers </i></p>
</td>	<td><p>This was fully assessed in a recent company-specific proposal (CPHST, 2009). We concluded that movement of baled Hawaiian MSW in shipping containers may be less risky than previous methods because they are handled routinely in ports and at rail stations, and because the containers provide extra protection for the bales against photodegradation (sunlight damage), and rupture or ejection of waste in the event of an accident. The protection from photodegradation is complete, so time spent by bales inside containers should not count toward the compliance agreement deadline of burial within 75 days.  </p>
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<tr>	<td><p><i>Pallets and Flatracks</i></p>
</td>	<td><p>In addition to standard enclosed shipping containers, HWS has proposed using pallets and flatracks. Pallets would presumably each bear a single bale (possibly strapped), and could be loaded on any flat surface on the barge or flatbed rail car, but likely cannot be not stacked. Using pallets would decrease the risk of bale rupture because bales would not be grabbed directly by loading equipment. In an accident, however, pallets would provide little additional security.</p>
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<p>Flatracks are essentially three-sided containers (bottom, front, and back), and the (typically) solid, vertical end pieces allow them to be stacked like other containers (Transportation Information Service, 2009). Using flatracks would, as above, protect the bales from direct handling ruptures. They might also better protect bales in an accident, especially if bales are strapped down, but not to the same extent as a solid-paneled container.</p>
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<p>Neither system would protect bales from photodegradation.</p>
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<tr>	<td><p><i>Transportation of bales</i></p>
</td>	<td><p>At each possible port, containers will arrive and be offloaded using standard container-handling equipment (e.g., forklifts, toppicks, gantry cranes). Containers will be placed directly on railcars in the facilities; no trucking operations are necessary. Then they will be transported to Roosevelt, and handled as described above. These means of transport are low risk for potential bale-rupturing accidents (CPHST, 2006a). </p>
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<p>The furthest the bales could possibly travel, from Rainier to Roosevelt, is 187 rail miles (BNSF Railway, 2009) [Longview = 174, Portland = 149]. Thus, adapting the generic quantitative risk analysis for bale-rupturing accidents to transport of bales to Roosevelt Regional Landfill required a decrease in (river) barge miles to zero, a decrease in truck miles from 25 to 0, and a decrease in rail miles from 500 to 187. When these changes were made, the risk of any bale-rupturing accident for barges and trucks was zero, and that for rail decreased from 0.00070 to 0.0002. Mean years to the first bale-rupturing accident for rail was 2500. We found a 95 percent chance that the first rail accident would occur only after 129 years. The risk of catastrophic rupture of bales while they are being transported by truck or rail to Roosevelt Regional Landfill is therefore very low.</p>
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<tr>	<td><p><b>Local environment: geography and climate</b></p>
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</td>	<td><p>Because containers will spend a short time in either Longview, Rainier, or Portland while they are transferred to rail cars, we briefly describe climate here. The main difference between these climates and that of Klickitat County is the average annual precipitation. Portland receives much more precipitation than Klickitat County, with mean annual precipitation of about 36 inches (U.S. Census Bureau, 2009). The wetter climate of Tacoma offers a more favorable environment than Klickitat County for Hawaiian pests, but the much colder temperatures would limit the ability of these pests to become established.</p>
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<tr>	<td><p><b>Conclusions</b></p>
</td>	<td><p>Compared to the previous assessment (CPHST, 2006a), we found no exceptional risks related to the new proposal that justified a different conclusion. The use of shipping containers seems likely to decrease the risk of rupture and spill of baled MSW. The changes to the transportation routes and conveyances used also reduced the plant pest risk associated with this pathway. Overall, transportation of urban MSW from Hawaii to Roosevelt Regional Landfill in Washington State by HWS in airtight bales within shipping containers continues to pose an insignificant risk of pest establishment. </p>
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<p>Last, we note that only the pest risk associated with the proposal by HWS to move baled MSW in shipping containers from Hawaii to Washington State were addressed here. Complete approval of the proposal (pathway) or particular procedures 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 constraints (pest or non-pest related), such as available resources or other Federal regulations.</p>
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<tr>	<td><p><b>References</b></p>
</td>	<td><p>BNSF Railway. 2009. BSNF 6003 Rail Miles Inquiry. BNSF Railway Company, Fort Worth, Texas. http://www.bnsf.com/bnsf.was6/RailMiles/RMCentralController.</p>
<p>CPHST. 2006a. 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, USDA-APHIS, Raleigh, NC. 45 pp.</p>
<p>CPHST. 2006b. The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal Solid Waste from Hawaii. Center for Plant Health Science and Technology (CPHST), Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. 8 pp.</p>
<p>CPHST. 2007. The Risk of Introducing Pests to Elmore County, Idaho, via Plastic-Baled Municipal Solid Waste from Hawaii (Rev. 00). Center for Plant Health Science and Technology (CPHST), Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. 17 pp.</p>
<p>CPHST. 2008. The Risk of Introducing Pests to Gilliam County, Oregon via Hawaiian Plastic-Baled Municipal Solid Waste (Rev. 03). Center for Plant Health Science and Technology (CPHST), Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. 17 pp.</p>
<p>CPHST. 2009. The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal Solid Waste in Shipping Containers from Hawaii. Proposal: Pacific Rim Environmental Resources. Center for Plant Health Science and Technology (CPHST), Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. 6 pp.</p>
<p>Hawaiian Waste Systems. 2009a. Letter Re: Hawaiian Waste Systems Handling and Export Protocol. Hawaiian Waste Systems, LLC, Seattle, Washington. 7 pp.</p>
<p>Hawaiian Waste Systems. 2009b. Letter Re: HWS Questions From APHIS 11-25-09. Hawaiian Waste Systems, LLC, Seattle, Washington. 7 pp.</p>
<p>Regional Disposal Company. 2009. Modified Plan of Operation for the Roosevelt Regional Landfill. Regional Disposal Company, Seattle, WA. 49 pp.</p>
<p>U.S. Census Bureau. 2009. 411. Normal Monthly and Annual Precipitation -- Selected Cities. U.S. Census Bureau, Washington, D.C. http://www.allcountries.org/uscensus/411_normal_monthly_and_annual_precipitation_selected.html.</p>
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<tr>	<td><p><b>Agency Contacts</b></p>
</td>	<td><p>Barney P. Caton, Ecologist/Pest Risk Analysta</p>
<p>barney.p.caton@aphis.usda.gov</p>
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<p>Ashley F. Hiser, Program Analysta</p>
<p>ashley.hiser@aphis.usda.gov</p>
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<p>a Plant Epidemiology and Risk Analysis Laboratory</p>
<p>Center for Plant Health Science and Technology</p>
<p>1730 Varsity Drive, Suite 300</p>
<p>Raleigh, NC 27606</p>
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<p>BNSF Railway. 2009. BSNF 6003 Rail Miles Inquiry. BNSF Railway Company, Fort Worth, Texas. Last accessed http://www.bnsf.com/bnsf.was6/RailMiles/RMCentralController.</p>
<p>CPHST. 2006a. 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, USDA-APHIS, Raleigh, NC. 45 pp.</p>
<p>CPHST. 2006b. The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal Solid Waste from Hawaii. Center for Plant Health Science and Technology (CPHST), Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. 8 pp.</p>
<p>CPHST. 2007. The Risk of Introducing Pests to Elmore County, Idaho, via Plastic-Baled Municipal Solid Waste from Hawaii (Rev. 00). Center for Plant Health Science and Technology (CPHST), Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. 17 pp.</p>
<p>CPHST. 2008. The Risk of Introducing Pests to Gilliam County, Oregon via Hawaiian Plastic-Baled Municipal Solid Waste (Rev. 03). Center for Plant Health Science and Technology (CPHST), Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. 17 pp.</p>
<p>CPHST. 2009. The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal Solid Waste in Shipping Containers from Hawaii. Proposal: Pacific Rim Environmental Resources. Center for Plant Health Science and Technology (CPHST), Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. 6 pp.</p>
<p>Hawaiian Waste Systems. 2009a. Letter Re: Hawaiian Waste Systems Handling and Export Protocol. Hawaiian Waste Systems, LLC, Seattle, Washington. 7 pp.</p>
<p>Hawaiian Waste Systems. 2009b. Letter Re: HWS Questions From APHIS 11-25-09. Hawaiian Waste Systems, LLC, Seattle, Washington. 7 pp.</p>
<p>Regional Disposal Company. 2009. Modified Plan of Operation for the Roosevelt Regional Landfill. Regional Disposal Company, Seattle, WA. 49 pp.</p>
<p>Transportation Information Service. 2009. Container types: Flatracks (Ver. 1.1.0.05). Gesamtverband der Deutschen Versicherungswirtschaft e.V. (GDV), Berlin, Germany. Last accessed http://www.tis-gdv.de/tis_e/containe/arten/flat/flat.htm.</p>
<p>U.S. Census Bureau. 2009. 411. Normal Monthly and Annual Precipitation -- Selected Cities. U.S. Census Bureau, Washington, D.C. Last accessed http://www.allcountries.org/uscensus/411_normal_monthly_and_annual_precipitation_selected.html.</p>
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<p class="footer">3</p>
<p class="footer">Rev. Original	December 15, 2009</p>
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