USD Clean Fuels Facility

The next community meeting will be held on Saturday, October 19 at 3:00pm at the Barber Shop on the corner of Bethel Drive and Pershing Street. We look forward to when the representatives of the USD Facility visit us - date/time to be determined, but it will most likely be in November.

The meeting on October 7 attracted almost 100 people and produced a great article by Hannarose McGuinness, Eugene Register-Guard: Pollution concerns reignited as Eugene residents raise alarm over planned fuel facility

and another by Nathan Wilk, KLCC & OPB:

Beyond Toxics Challenges a Proposed Fuel Transfer Facility in West Eugene

WHAT IS THIS PROJECT: A Texas corporation, USD Clean Fuels LLC (USDCF), announced its intention to build a biofuels terminal in the Trainsong Neighborhood located along Bethel Drive in West Eugene. The location is across the street from homes and parks. This facility will transload renewable diesel, biodiesel, ethanol and sustainable aviation fuel (SAF) from rail cars to tanker trucks.  These fuels will be delivered to the Eugene railyard by rail, then transloaded (transferred) from railcar to truck without storage. USDCF stated that the transfer station will result in 40 individual tanker truck trips daily (24 hours/day) which is 80 roundtrips. 

POLLUTION: The U.S. Energy and Administration states that ethanol and ethanol-gasoline mixtures burn cleaner and have higher octane levels than gasoline that does not contain ethanol, but they also have higher evaporative emissions from fuel tanks and dispensing equipment. These evaporative emissions contribute to the formation of harmful, ground-level ozone and smog. This may mean an additional burden of harmful air pollution for residents of Trainsong. There will be a significant increase in neighborhood exposure to diesel particulate and dangerous air toxics pollution from the truck tailpipes, additional locomotive activity and leakage from the fuel tank valves and pipes. 

TRAFFIC: Bethel Drive is a small and unimproved access street for residents of Trainsong and is not constructed to accommodate 40 heavy tanker truck trips per day. Despite this strain on transportation resources as well as the impacts of noise, vibrations, lack of safety and a significant increase in diesel particulate pollution from truck emissions,, the City of Eugene is not planning to do a traffic impact analysis. According to USD Clean Fuels, LLC, “the City of Eugene has not identified any traffic safety, operations, or pedestrian/bike issues that would warrant additional levels of service.”

TRAINSONG NEIGHBORHOOD: Trainsong is a residential neighborhood that has been impacted time and again by industrial pollution. Currently Trainsong Park, which serves children in the neighborhood, is being rebuilt after the Oregon Dept of Environmental Quality found very high levels of dioxin contamination. The neighborhood is also exposed to diesel particulate from idling trains, a history of noxious fumes from nearby industries (including the former J.H. Baxter plant), contaminated groundwater, leaking rail cars, and other historic pollution sources.

RIVER ROAD NEIGHBORHOOD: Wind patterns in the area predominantly blow north and south. This means that there is a high probability that River Road residents in the southern end of the neighborhood will experience an increase in diesel particulate, air toxics, loud noises from running tanker trucks and locomotives in the area 24-7, and light pollution.

WHAT: COMMUNITY MEETING to discuss plans of the proposed unsuitable siting of a biofuels transfer station in the Trainsong neighborhood, hosted by Beyond Toxics and the Active Bethel Community Neighborhood Association (ABC)

We encouraged residents of West Eugene, including Bethel, Trainsong and River Road, to attend the Community Forum on Monday, October 7 to learn more and ask questions. Mayor Lucy Vinis and City Councilor Lyndsie Leech, Ward 7, were on hand to discuss the project with Eugene residents. Beyond Toxics had an impressive PowerPoint program they shared with us. Approximately 60 people attended this meeting and all are unhappy with this facility attempting to locate in their residential area.

ABC received answers to the three questions we emailed:

1. How many trucks per day will go there?

"We anticipate up to 40 trucks per day will travel to the Eugene Clean Fuels Facility. Trucks would avoid peak commuting hours in the morning and evening. According to City of Eugene guidance, this volume is low enough for the current transportation system to accommodate without changes."

2. Is it 100% renewable fuel or a blend with traditional fuels?

"This facility will be permitted to receive biodiesel, renewable diesel, ethanol, and sustainable aviation fuel, all of which will be 100% renewable fuels. The fuel products that would travel through this proposed facility are made from agricultural, food waste, and forestry materials. These fuels are incentivized by the Oregon Clean Fuels Programs to help reduce greenhouse gas emissions in energy sectors that are more challenging to electrify, such as heavy construction and aviation.

You can find more information about the types of fuels we handle at the Clean Fuels Alliance America website: https://cleanfuels.org/our-fuels/"

3. Do the "best practices" you state you will follow actually protect against vapor emissions?

"The vapor emissions are in compliance with all applicable regulations, and the vapor emission recovery system is approved by Oregon Department of Environmental Quality."

They said:

"If you have more specific questions about this topic, we will schedule time for a specialist to follow up with you."

Please email bethelneighbors@gmail.com with any specific questions and we will compile for a future call.

UPDATE: https://www.kezi.com/news/bethel-area-residents-angry-and-frustrated-over-proposed-fuel-facility-project/article_862bd76c-6bee-11ef-91df-f74361e54633.html

KEZI reported (September 5) that they had met with ABC and Beyond Toxics and it sounded like we were okay with the proposed location. That is false. I sent them an email and they added a paragraph at the bottom of their posted article. We did meet with them and asked them many questions that we have yet to hear back on. I will be posting the answers here as soon as we hear back. Some of the questions were:

• Have you been in contact with the fire department?

• How will the vapors be captured?

• Will the trucks have a "no idling" requirement?

• Will the streets be improved prior to operation?

• How is this project funded? Will public tax dollars help pay for the new facility?

• How was this site selected? Could the facility be located in another location?

• Is the site facility contaminated? Will the developed area be cleaned up?

• Can Bethel Drive accommodate the new truck traffic in its current condition?

• Will facility operations contaminate the soil? Will the facility have storage tanks that may leak?

• What safety measures are in place to address the possibility of spills?

• What will happen at the Eugene Clean Fuels Facility? Will fuel be refined or stored on site?

• What is USD Clean Fuels doing to communicate with the community about the proposed Eugene Clean Fuels Facility?

• Is this facility "another JH Baxter"?

Question	USD Clean Fuels Response
How is this project funded? Will public tax dollars help pay for the new facility?	This project is 100% privately funded.
How was this site selected? Could the facility be located in another location?	Alternative sites that could potentially serve this market were evaluated. The site selected is uniquely able to offer service to the Eugene market on an existing railroad property - a working railyard with historic railroad operations - in a location that will be able to serve potential customers and the rail operator. Compared to other potential locations, this site will have the greatest reduction of truck miles from what it currently takes to deliver the fuels used today to the Eugene market. The proposed Eugene location is the only site matching all these criteria while maximizing the reduction in long haul truck traffic.
Is the site facility contaminated? Will the developed area be cleaned up?	USD Clean Fuels is not aware of any existing contamination or need for cleanup within the footprint of the proposed project. If any contamination is discovered, USD Clean Fuels will follow all applicable regulations.
Can Bethel Drive accommodate the new truck traffic in its current condition?	The additional truck traffic would be below the significance thresholds required for further analysis. The City of Eugene has not identified any traffic safety, operations, or pedestrian/bike issues that would warrant additional levels of service.
1.      Will facility operations create more pollution in the area? 2.      Will the facility contaminate the soil? 3.      Will the facility have storage tanks that may leak?	1.      The Eugene Clean Fuels Facility will be designed and operated in compliance with all applicable pollution regulations. 2.      Facility design and operational plans will be developed to minimize the likelihood of spills and contamination. 3.      There will be no storage associated with this facility, and there will not be any storage tanks on the site.
Will the facility create odors that neighbors can smell?	USD Clean Fuels does not anticipate odors associated with this facility. The company will ensure compliance with Eugene and Oregon Nuisance Odor requirements.
What safety measures are in place to address the possibility of spills?	The USD Clean Fuels team has operated fuels transloading facilities with zero reportable releases and zero recordable injuries since 2008. A spill of a reportable quantity is unlikely, and the facility will be designed and operated to minimize the likelihood of any such release and any adverse consequences. The facility will install a spill containment and drainage system as a protection method. Containment areas under railcars, tank trucks, and pumps will be piped to a containment basin on-site. This containment system will ensure that spills are prevented from entering sewers and waterways. A spill of any significant quantity is highly unlikely due to safeguards and emergency shut-off capabilities.
1.      What will happen at the Eugene Clean Fuels Facility? 2.      Will fuel be refined or stored on-site?	1.      The Eugene area will receive the benefits of cleaner air through cleaner fuels, with approximately 2,000,000 fewer truck-miles per year compared to the current delivery of fuels to the same area. Ethanol, renewable diesel, biodiesel, and sustainable aviation fuel (as they become commercially available for this market) will be delivered by rail, then transloaded (transferred) directly from railcar to truck without storage. The trucks will then depart for deliveries to the local market. 2.      No refining or storing of fuel will occur at the facility.
What is USD Clean Fuels doing to communicate with the community about the proposed Eugene Clean Fuels Facility?	The company initiated community outreach activities in late August 2024, including conversations with local groups (Active Bethel Community and Beyond Toxics), and distributing informational brochures to businesses and residents along Bethel Drive. For more information, residents can visit usdcleanfuels.com, call 832-991-8579, or email infoeugene@usdcleanfuels.com.
Is this facility "another JH Baxter"?	No. USD Clean Fuels has no relation to JH Baxter. The Eugene Clean Fuels facility will not treat lumber. There will be no processing or storage of fuels at the facility. The clean fuels intended for this facility are the type intended by the State of Oregon to be cleaner and renewable versions of the motor fuels that currently move in and through the Eugene market.
What air permits are required for this facility?	The Eugene Facility has applied for a Simple Air Contaminant Discharge Permit through Lane County Air Protection Agency.
What air emissions are expected from operations? Including truck operations?	Products to be transferred at the facility will be renewable diesel, biodiesel, ethanol, and sustainable aviation fuel (as they become commercially available for this market). Any emissions from these products will be small, in compliance with applicable regulations, and classified as volatile organic compounds. Truck idling emissions will be minimized, in accordance with ORS 825.605, as commercial vehicles cannot idle their primary engine for more than five minutes in any 60-minute period while on the facility grounds.
What kind of vapors will be emitted?	Products to be transferred at the facility will be renewable diesel, biodiesel, ethanol, and sustainable aviation fuel (as they become commercially available for this market). Any emissions from these products will be small, in compliance with applicable regulations, and classified as volatile organic compounds. Vapor control will comply with applicable laws and regulations. Vapor control will be a closed-loop system between railcars and tank trucks, designed and operated to comply with air permitting requirements.
1.      Will dust maintenance be needed? 2.      What kind of surface will the trucks drive on?	1.      Should any road dust occur, roads will be maintained with a watering truck, as needed for dust control and in compliance with applicable regulations. 2.      The trucks will drive on an asphalt driveway and concrete containment pads.
1.      What further information can you provide about the vapor containment system? 2.      Can you provide an online resource that describes the mechanism?	1.      Vapor balancing is a closed-loop system that is permitted under the design outlined in EPA’s AP-42 section 5.2 "Transportation and Marketing of Petroleum Liquids", page 6. Similar applications are stage 1 vapor recovery systems often used by local gas stations in Oregon and across the country. 2.      Additional Resources: •         Oregon DEQ 2022 Air Quality Compliance Calendar https://www.oregon.gov/deq/aq/Documents/GDFCalendar2022.pdf •         EPA’s website: Vapor balance systems in EPA AP-42 Section 5.2 https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-fifth-edition-volume-i-chapter-5-petroleum-1
What is the flammability hazard of facility operations?	While the renewable fuels that will be handled on-site are considered flammable, there are numerous safety precautions to help ensure the safe handling of these fuels. These precautions include the use of non-sparking tools, fittings, equipment, and a strict no smoking or open flame policy on-site. Additionally, all railcars, pipes, pumps, and trucks will be fully bonded and grounded so that sparks will not occur from operation. The facility will also have intrinsically safe electronics, as required, and emergency stop shutoffs throughout the facility. The facility will have extensive firefighting suppression on-site as well. Also note that the flammability of renewable fuels is lower than traditional gasoline type fuels. Motor fuels are already handled daily and consistently in these markets, in a safe and efficient manner.
What Fire Marshal safety precautions are you required to follow? Are you required to have an evacuation plan in place?	The Fire Marshal has stated that all applicable codes and standards must be followed. As such, the following will apply to this facility: Applicable Codes, Standards, and References •         2022 Oregon Structural Specialty Code (OSSC), as amended by the City of Eugene •         2022 Oregon Fire Code (OFC), as amended by the City of Eugene •         2022 Oregon Electrical Code (OEC), as amended by the City of Eugene The following NFPA standards are applicable as referenced by the OSSC, OFC, and OES: •         NFPA 10, Standard for Portable Fire Extinguishers, 2018 Edition •         NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, •         2019 Edition •         NFPA 30, Flammable and Combustible Liquids Code, 2021 Edition •         NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2013 Edition •         NFPA 69, Standard on Explosion Prevention Systems, 2019 Edition •         NFPA 77, Recommended Practice on Static Electricity, 2024 Edition •         NFPA 385, Standard for Tank Vehicles for Flammable and Combustible Liquids, 2017 Edition The facility will have an Emergency Response Action Plan and a Spill Prevention Countermeasures and Control Plan. The facility will work with local first responders regularly and hold drills to ensure everyone understands the process to respond to an emergency, in the unlikely event one should occur.
Will trucks be idling on the facility property?	The facility will follow ORS 825.605 regulations. Per Oregon law, commercial vehicles cannot idle their primary engine for more than five minutes in any 60-minute period while on the terminal grounds. (ORS 825.605)
What is the truck idling policy? Will you consider a no-idling policy for trucks?	The facility will follow ORS 825.605 regulations. Per Oregon law, commercial vehicles cannot idle their primary engine for more than five minutes in any 60-minute period while on the terminal grounds. (ORS 825.605)
Will USD share the Land Use Compatibility Statement?	Yes, please find attached the Land Use Compatibility Statements.
Will you share more details about the vegetation buffer planned between the road and the facility?	The existing trees along Bethel Drive will remain in place. The current gaps between the existing trees will be planted with trees approved by the City of Eugene to encourage a continuous canopy along the southern property boundary. In addition to the street trees, a continuous row of cedars will be planted adjacent to the street trees just across from Morse St and will continue to the eastern property boundary.

Question	USD Clean Fuels Response
Please send us:  1.      Air Quality Discharge Permit applications filed with LRAPA, including air emission capture technology you plan to deploy  2.      Any environmental permits filed with the DEQ, including permits for underground storage tanks  3.      A list of sites USD considered for this project, and then rejected; and why you settled on the Trainsong Neighborhood	1.      An Air application was submitted to LRAPA and assigned permit application number 202566 (still under review by LRAPA). 2.      No permits with DEQ have been filed to date. There will be no storage associated with this facility, and there will not be any storage tanks on the site. We anticipate filing permits with DEQ for construction and industrial stormwater compliance.   3.      Alternative sites that could potentially serve this market were evaluated. The site selected is uniquely able to offer service to the Eugene market on an existing railroad property - a working railyard with historic railroad operations - in a location that will be able to serve potential customers and the rail operator. Compared to other potential locations, this site will have the greatest reduction of truck miles from what it currently takes to deliver the fuels used today to the Eugene market. The proposed Eugene location is the only site matching all these criteria while maximizing the reduction in long haul truck traffic.
Would there be any reason USD would not accommodate these recommendations, and if that is USD's position, why not?  1.                  All trucks that will be entering the Trainsong neighborhood must run on biofuels and NOT diesel (or be electric). The USD company cannot morally make a profit off running a clean fuels transfer station while poisoning the residential community with diesel exhaust pollution. That would be unconscionable.	The likelihood of trucks running on biofuels significantly increases once those fuels are widely available in the market. This facility's purpose is to make biofuels widely available for both trucks servicing this facility and motor vehicles in the Eugene area.   Contracts and trucking requirements are determined by the shippers of the biofuels to the facility, and not by USD Clean Fuels.
Would there be any reason USD would not accommodate these recommendations, and if that is USD's position, why not?  2.                  No idling of trucks whatsoever, for the sake of reducing air pollution and reducing noise pollution.  If a truck must be running an engine/idling to onload fuel, then USD must invest in electric charging technology to enable battery-powered operations while docked/parked/waiting in the Trainsong neighborhood.	The facility will follow ORS 825.605 regulations. Per Oregon law, commercial vehicles cannot idle their primary engine for more than five minutes in any 60-minute period while on the terminal grounds. (ORS 825.605). Trucks will not idle while loading.
Would there be any reason USD would not accommodate these recommendations, and if that is USD's position, why not?  3.                  Financial support to the City of Eugene to upgrade Bethel Drive, including paving and reflective traffic lines and to plant and maintain trees as a buffer between the project property and the neighborhood	USD Clean Fuels is open to considering financial support for Bethel Drive upgrades.  The existing trees along Bethel Drive will remain in place. The current gaps between the existing trees will be planted with trees approved by the City of Eugene to encourage a continuous canopy along the southern property boundary. In addition to the street trees, a continuous row of cedars will be planted adjacent to the street trees just across from Morse Street and will continue to the eastern property boundary.
Would there be any reason USD would not accommodate these recommendations, and if that is USD's position, why not?  4.                  No truck traffic during school bus route hours.	USD Clean Fuels can look into this accommodation. Can you share the local school bus route hours with us?
Would there be any reason USD would not accommodate these recommendations, and if that is USD's position, why not?  5.                  Installation of maximum available vapor control technology to control fugitive emissions, non-permeable hoses, spill control and capture	·         Hoses: Hoses at the Eugene Clean Fuels facility will be non-permeable; dry break fittings that attach the hoses to the rail cars and trucks will be used for spill prevention purposes. ·         Spill control and capture: The USD Clean Fuels team has operated fuels transloading facilities with zero reportable releases and zero recordable injuries since 2008. A spill of a reportable quantity is unlikely, and the facility will be designed and operated to minimize the likelihood of any such release and any adverse consequences. The facility will install a spill containment and drainage system as a protection method. Containment areas under railcars, tank trucks, and pumps will be piped to a containment basin on-site. This containment system will ensure that spills are prevented from entering sewers and waterways. A spill of any significant quantity is highly unlikely due to safeguards and emergency shut-off capabilities. ·         Vapor control: Vapor control will comply with applicable laws and regulations. Vapor control will be a closed-loop system between railcars and tank trucks, designed and operated to comply with air permitting requirements.   o   Additional Resources:  §  Oregon DEQ 2022 Air Quality Compliance Calendar  https://www.oregon.gov/deq/aq/Documents/GDFCalendar2022.pdf  §  EPA’s website: Vapor balance systems in EPA AP-42 Section 5.2  https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-fifth-edition-volume-i-chapter-5-petroleum-1
Would there be any reason USD would not accommodate these recommendations, and if that is USD's position, why not?  6.                  Working with the Eugene-Springfield Fire Marshall and Eugene Transportation Department to establish emergency evacuation routes for Trainsong neighbors in the event of an emergency.	The Fire Marshal has stated that all applicable codes and standards must be followed. As such, the following will apply to this facility:   Applicable Codes, Standards, and References  ·         2022 Oregon Structural Specialty Code (OSSC), as amended by the City of Eugene  ·         2022 Oregon Fire Code (OFC), as amended by the City of Eugene  ·         2022 Oregon Electrical Code (OEC), as amended by the City of Eugene  The following NFPA standards are applicable as referenced by the OSSC, OFC, and OES:  ·         NFPA 10, Standard for Portable Fire Extinguishers, 2018 Edition  ·         NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, 2019 Edition  ·         NFPA 30, Flammable and Combustible Liquids Code, 2021 Edition  ·         NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2013 Edition  ·         NFPA 69, Standard on Explosion Prevention Systems, 2019 Edition  ·         NFPA 77, Recommended Practice on Static Electricity, 2024 Edition  ·         NFPA 385, Standard for Tank Vehicles for Flammable and Combustible Liquids, 2017 Edition  The facility will have an Emergency Response Action Plan (ERAP) and a Spill Prevention Countermeasures and Control Plan. A shut down plan is one of the scenarios included in the ERAP.     The facility will work with local first responders regularly and hold drills to ensure everyone understands the process to respond to an emergency, in the unlikely event one should occur.
Would there be any reason USD would not accommodate these recommendations, and if that is USD's position, why not?  7.                  Have an emergency shutdown plan and educate workers on procedures	The facility will have an Emergency Response Action Plan (ERAP) and a Spill Prevention Countermeasures and Control Plan. A shut down plan is one of the scenarios included in the ERAP.   The facility will work with local first responders regularly and hold drills to ensure everyone understands the process to respond to an emergency, in the unlikely event one should occur.

Question	USD Clean Fuels Response
It is stated that the facility will follow ORS 825.605 regulations. However, that law does not prevent idling if it is needed to run an auxiliary power unit, a generator of heat and cooling or to provide electrical power.  Is there any situation when one of the trucks using the facility would run an engine at any point in the fueling process while at the facility?  ORS 825.605 (2)  (2)  For purposes of this section, a person is not idling a primary engine if the person:   (a)  Operates an auxiliary power unit, generator set or other idle reduction technology as a means to heat, air condition or provide electrical power.	We do not anticipate a situation when trucks would run an engine during the process of transloading fuel from train cars to trucks at the facility.
In the Land Use Compatibility Statement, it is stated that the facility will run 24 hours/day and 7 days/week. This contradicts what residents have been told, specifically, that the facility would only operate during a normal working day of 8:00am-5:00pm Our question is: which statement is correct. Will trucks be arriving and leaving the site before 8:00AM or after 5:00PM.	The facility will be operational 24 hours per day, 7 days per week.  USD Clean Fuels is unaware of any information provided by the company stating the facility would only operate from 8:00am-5:00pm.    We anticipate trucks would arrive outside of peak local traffic hours.  The facility layout will be designed to hold the delivery trucks within the property to reduce potential impacts to existing traffic on Bethel Drive.
What trucking company will be hauling the biofuels?  Will trucks traveling through Trainsong neighborhood be equipped with diesel emission reduction technology?	Contracts and trucking requirements are determined by the shippers of the biofuels to the facility, and not by USD Clean Fuels.
Will trucks be running on petroleum diesel or biofuels?	The likelihood of trucks running on biofuels significantly increases once those fuels are widely available in the market. This facility's purpose is to make biofuels widely available for both trucks servicing this facility and motor vehicles in the Eugene area.   Contracts and trucking requirements are determined by the shippers of the biofuels to the facility, and not by USD Clean Fuels.
How much noise will this facility create?	USD Clean Fuels will comply with all regulations applicable to this facility, including noise. The company does not anticipate any actionable noise levels, including both onsite for its operators and offsite.