DEQ Letter to Governor Brown on Metal-Emitting Facilities

8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities

1/12

r gon

Kate Brown, Governor

April28, 2016

The Honorable Kate Brown

Governor, State

of

Oregon

254 State Capitol

Salem,

OR

97301-4047

Dear Govemor Brown:

ep

artment of nvironmental Quality

gency H eadquarters

811 SW Sixth venue

Portland, OR 97204-1390

(503) 229-5696

F X

(503) 229-6124

T Y

7

In a letter to you dated Febmary 14, 2016, we committed to send you a list

of

facilities that that

are authorized to release chromium and other metals under conditions specified in permits we

have issued to them. Enclosed is an initial list

of

316 facilities statewide.

t

represents our

cun·ent best judgment as to the facilities most likely to be users and emitters

of

the specified

metals. This is a good start toward our overhaul

of

regulation

of

industrial air emissions. We

will refine and, as necessary, add to or subtract from this list as we develop new information.

The list is the first

of

its kind to have been produced in Oregon. Developing this list is one

of

several steps DEQ and OHA are taking under your direction and as part

of

the Cleaner Air

Oregon regulatory refmm project.

• DEQ will conduct surprise inspections

of

a prioritized subset of the enclosed list to

gather more information about metals that may

be

present at each inspected site;

• DEQ will undertake an array

of

monitoring activities to cany out rapid pollutant-specific

monitoring and longer-te1m monitoring -- all

of

which will help infmm our understanding

of

the potential long te1m health effects;

• While focusing on metals now, DEQ is also building capacity to address a wider variety

of

industrial and other air toxics. DEQ will begin to expand monitoring capabilities to

high priority areas in Portland and across the state, using a portion

of

the $2.5 million

appropriated by the Legislature at your request;

• DEQ will use its findings to provide the public with greater access to emissions

information about facilities that will be subject to Cleaner Air Oregon initiative; and,

• DEQ will actively engage OHA' s public health expertise to help sha

pe

our next steps and

infmm our joint regulatory refmm effmi. OHA will analyze DEQ' s monitoring data to

infmm communities about potential human health impacts.


2/12

Governor Kate rown

April28, 2016

Page 2 ofS

List ofOregon facilities permitted to emit or have the potential to emit metals

We began with a list of the types of sources covered under National Emission Standards for

Hazardous Air Pollutants (NESHAPs) and all sources listed under the Title V program. We then

compiled a list

of

316 facilities statewide that are authorized to emit metal compounds. In

developing the list, DEQ worked closely with partners at Lane Regional Air Protection Agency

(LRAPA). We consulted additional sources to help develop the list: EPA

's

Urban Air Toxics

Strategy, the Toxic Release Inventory, the Oregon State Fire Marshal's database, and the Eugene

Toxics Right to Know database.

The list focuses on nine metals listed under

EPA's

Urban Air Toxics Strategy. These nine

metals are: arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel and

selenium.

As a result

of

these research and review efforts,

we

now have better infmmation about the

number and types of sources with the potential to emit metal compounds in Oregon. When

reviewing the list, please consider the following:

• While we know the companies identified

on

this list of facilities are authorized to emit

metals, we do not yet know whether these companies are producing metal emissions or

whether any emissions actually are being produced at levels posing any health risks to the

public.

• There is wide variation in the amount ofmetals these facilities are pennitted to emit, from

potentially large amounts to potentially very small amounts.

We

ru ·e

unable to provide at this time a list

of

hexavalent cluomium users. DEQ currently lacks a

statewide, health

or

risk-based petmitting program for air taxies. The existing air permitting

program mirrors federal requirements that focus only on specific industry activities (refetTed to

as the National Emission Standru ·ds for Hazardous Air Pollutants, or NESHAPs). The existing

program applies to sources such as chrome plating, and also to lru ·ge emitters of hazardous air

pollutants such as metal foundries. Federal and current state air petmitting programs do not

address metal emissions from facilities that are exempt, are not regulated by a NESHAP,

or

that

ru ·e not

lru ·ge

emitters. This is

pru i

of the regulatory

gap we

will address with the Cleaner Air

Oregon regulatory reform.

A second problem we encountered is that the information we do have about metals does not

differentiate between the different types

of

chromium, e.g., trivalent

or

hexavalent chromium.

Rather, these are refeiTed to generically as chromium.

Working in collaboration with OHA and local pru.iners (such as counties), DEQ is taking the

following additional specific steps.


3/12

Governor Kate rown

April 28, 2016

Page 3 ofS

Information requests from facilities and prioritized inspections

On May 16, 2016, DEQ will send letters to all 316 companies on the enclosed list. We will

require the companies to provide us with infmmation known to them about the particular metals

that they use, whether and how they are emitted, and their emission rates. Permittees are requiTed

to provide such information to

us

by the te1ms

of

their permits. The information collected will

infmm the Cleaner ir Oregon regulatory reform process and help us identify where our limited

monitoring capability should be deployed. The deadline for submission

of the information will

be June 1, 2016.

We will require each permittee to supply us with the following information:

• Types and volume ofmetals or metal containing fuels used at the facilities.

• Material Safety Data Sheets for materials used in production.

• Operating hours, days, and whether production is continuous or periodic.

• Repmis

of

the most recent facility emissions testing commissioned by the facility.

•

Cunent

air pollution control measures or equipment in use.

• Existing results of any efforts to model ambient air concentrations ofmetals.

In addition to the infmmation DEQ will be requiring of the facilities, DEQ and

ORA

will also

determine the proximity of these facilities to residences, schools, daycare, long-term health care

centers, health care facilities and cotTectional facilities. Starting in June, DEQ and LRAP A will

launch facility in

spections

of

prioritized sites around the state. While DEQ will eventually

inspect all 316 sources, DEQ is committing to inspect 100 of the listed facilities over a six week

period.

In

addition, as part

of

the Cleaner Air Oregon regulatory reform, DEQ will inspect

additional facilities that are potential sources of air toxics.

As noted above, all ofour permittees know that they must adhere to the terms of their respective

permits. Alllmow that they are subject to inspection.

We

will not, however, give advance

notice of our intended inspections to any individual pe1mittee whose facility we will inspect.

DEQ will provide the .results of the requests for infonnation from the facilities and inspections to

the Cleaner Air Oregon Teclmical Work Group as it works toward the comprehensive refmm of

DEQ

s

air pe1mitting program for industrial facilities.

Expanding our ability to monitor in more communities

We deeply appreciate your assistance n securing the additional 2.5 million during this recent

legislative session. That your initiative found bi-partisan support in the legislative session is

suggestive to us of the continued existence of a broad consensus in support of regulatory reform

that will focus our future work on the application of science to the protection of human health. A


4/12

Govemor Kate Brown

Ap

ril

28, 2016

Page 4

of

portion of these funds will be used to support expanded monitoring, which includes three

different components as outlined below.

First, DEQ will utilize data derived from the analysis ofmoss to inf01m the placement of

monitors in the P01iland area. DEQ, 01-IA, Multnomah County Health Depatiment and the US

Forest Service (USFS) have developed a prioritization process for locating monitoring

equipment. We will utilize new information from the most recent publication of data from the

USPS moss study, information about the proximity

of

permittees ' facilities to children and other

vulnerable populations, and information obtained from permittees to help determine where to

conduct monitoring. Follow-up monitoring will use a combination of additional moss

monitoring and air sampling as equipment becomes available. As DEQ expands its ability to

monitor at more locations, we will continue to consult with OHA to provide health inf01mation

to the public and to Cleaner

ir

Oregon.

Second, DEQ will develop a plan and deploy two new air toxics monitors. These monitors test

for a wide range

of

air toxics, both metals and non-metals. These units will be dedicated to year

long studies, which generate data to help detetmine the potential likelihood of longer tetm health

effects. The data collected will directly support the health-based regulatory overhaul that will

eventually be realized from Cleaner Air Oregon.

Third, DEQ is diversifying our monitoring strategy by purchasing equipment that can be focused

on specific pollutants. This equipment is less expensive than monitors testing for a broader range

of air toxics. It can produce inf01mation in a shmier period of time, and can be focused on

pollutants of high community concem

Better Data: Greater access to information

To increase the speed

of

our monitoring and analysis we are hiring two chemists to analyze and

review monitoring samples. We are also hiring two field technicians to deploy and maintain

monitoring equipment

at d

to collect and transfer samples to our lab. We are also adding one data

specialist to analyze and prepm·e monitoring results in accessible fonnats for the public.

The public has seen the P01iland-area moss maps revealing elevated concentrations for cetiain

metals. We anticipate more such maps for other metals from USPS

in

coming months. With the

development of the enclosed list of facilities , we will now have the ability to overlay these two

types of data to show the location

of

permitted facilities

in

conjunction with concentrations

of

metals in moss. We will

be

working to use moss and other innovative passive sampling

techniques (since moss does not grow in all pmis

of

the state) to develop similar overlay maps

for other communities in Oregon for metals and other pollutants.


5/12

Governor Kate Brown

April 28, 2016

Page 5 o

f

OI-IA community resources

-

-

- -

Currently,

we

understand that OI-IA staff are conducting environmental health assessments for

neighborhoods near glass factories in Pmiland and 8 other statewide sites. OHA would need

additional resources to expand to other prioritized sites. Our colleagues at

OI-IA

report taking the

following steps to strengthen OHA s capacity to address concerns from Oregon residents about

industrial emissions:

• OI-IA is in process of hiring an additional public health toxicologist to add to the capacity

to conduct environment public health assessments as monitoring data becomes available

and more infmmation about the prioritized sites is known.

• OHA is pursuing additional resources for analysts to expand environmental assessment

capacity for the Cleaner Air Oregon effmi. This includes additional program analysts to

identify health strategies, provide additional program coordination for the additional sites

and add capacity to engage the public and develop the additional site specific public

education materials and talking points.

The additional resources will allow

OI-IA

to work with communities around the state to evaluate

environmental factors that affect the health ofpeople, families and their sunounding

neighborhoods. This environmental health information will also be used

by

state and local

policy makers

on

strategies to improve individual and community health.

Our commitment

DEQ will continue to work with partners at the

OI-IA

, county health departments, and LRAPA

in

order to further protect the people ofOregon fi om air toxics in line with your Cleaner Air

Oregon vision. As new findings and information become available, we remain committed to

sharing that information with the public.

We

will continue to encourage continued public input

as we develop and implement Cleaner Air Oregon.

Thank you for your ongoing support

of

this effort to protect public health and the environment.

Please let me know if

we

can frniher describe our plans going forward.

Sine ·ely Yours,

Interim Director

Enclosure


6/12


7/12

Canron Western Constructors, In

c

Capital Grinding Corporation dba Capital Chrome and Precision Grinding

Cardinal Aluminum Oregon LLC

Ca

restream Health, Inc.*

Cascade Pacific Pulp, LLC

Cascade Plating and Machine

Cascade Steel Rolling Mills, Inc.

Cascades Tissue Group-Oregon

Central Auto Body LLC

CEW

, Inc. dba Newberg Ford

CH Murphy/Clark-Ulman, Inc.

Champion Collision Inc.

Chevron Products Company*

Clarke's Sheet Metal

Clint Newell Motors, Inc dba Clint Newell Motors

Co-Gen Co. LLC*

Co-GenII

LLC

Collins Pine Company*

Collins Products LLC

Collision Rebuilders, Inc.

Columbia Body Manufacturing

Columbia Forest Products, Inc.*

Columbia Helicopters, Inc.

Columbia Sales and Service, Inc.

Commercial Collision Paint Inc.

Conrad Wood Preserving Co.

Contact Industries, Inc.

Conveyco Mfg, Co.

Covanta Marion, Inc.*

Cruisin Classics

CSC, Inc. dba Medford Fabrication

Curtis L Livingston dba Curt's Body Shop

Custon Concepts

D. B. Western, Inc.

Daimler Trucks North America LLC

Dan Enterprises, Inc.

Dave Hunter Company, Inc.

Davis Body Shop, Inc.

Davis Tool, Inc.

Dirk Johnson dba DJ's Bump Paint Parlor

DMH, Inc.*

Do It Now Inc dba Advanced Truck Body Equi

pment

Co

.

Donaldson Landry Machine Shop

Double A Metal Fabrication, Inc.

Douglas County, Inc. dba Douglas County Forest Products*

Eagle Carriage Machine, Inc.

East Side Plating, Inc. (26-0018)



Ektron Industries, Inc.

Elite Collisi

on

LLC

PORTLAND

SALEM

PORTLAND

WHITE

CITY

HALSEY

EUGENE

MCMINNVILLE

SAINT HELENS

PORTLAND

NEWBERG

PORTLAND

SANDY

PORTLAND

EUGENE

ROSEBURG

PRAIRIE CITY

RIDDLE

LAKEVIEW

KLAMATH FALLS

PORTLAND

CLACKAMAS

KLAMATH FALLS

AURORA

PORTLAND

CENTRAL POINT

RAINIER

PRINEVILLE

CLACKAMAS

BROOKS

SALEM

MEDFORD

WOODBURN

JUNCTION CITY

NORTH BEND

PORTLAND

OREGON CITY

ALBANY

ENTERPRISE

HILLSBORO

GRANTS PASS

FOREST GROVE

CENTRAL POINT

PORTLAND

ROSEBURG

WINCHESTER

LA GRANDE

PORTLAND

PORTLAND

PORTLAND

AUMSVILLE

GRESHAM


8/12

Elkay Wood Products Company*

Elliot Specialty Metal

Emerald Forest Products, Inc.*

Emerald Steel Fabricators

Entek International LLC*

EP Minerals, LLC

Erickson Air-Crane Incorporated

ESCO Corporation

Evers Auto Body and Painting

EVRAZ Inc, NA

Express Auto Body, Inc.

FCC Commercial Furniture Inc.*

Finishing First, Inc.

Fix Auto Express Gresham

Flakeboard America Limited

Flakeboard America*

Fought Company, Inc.

Frank Lumber Co. Inc.*

Fred Wahl Marine Construction, Inc.

Freebird, Inc.

Freeman Marine Equipment, Inc.

Freres Lumber

Co.

Inc.*

G R Body Shop, L.L.C.

G.T.E. Metal Fabricators, Inc.

Gas Transmission Northwest LLC*






Gateway Body Shop, Inc.

General Trailer Parts

Georgia-Pacific Consumer Products LP

Georgia-Pacific Toledo LLC

Gibson Steel Fab

Giddings Boat Works, Inc.

Graphic Packaging International, Inc*

Gunderson LLC

Halfway Carriage Autobody Repair

Hampton Lumber Mills, Inc. dba Tillamook Lumber Company*

Hampton Lumber Mills, Inc.*

Hardchrome, Inc.

Harris Thermal Transfer Products, Inc.

Helser Industries, Inc.

Hermiston Generating Company, L.P.*

Hermiston Power LLC*

Holte Manufacturing

Hoover Treated Wood Products , Inc.

Horizon Air Industries

Hurford Industries, Inc.

Image King

INDEPENDENCE

EUGENE

DRAIN

EUGENE

LEBANON

VALE

CENTRAL POINT

PORTLAND

HILLSBORO

PORTLAND

PORTLAND

ROSEBURG

TIGARD

GRESHAM

ALBANY

EUGENE

TIGARD

LYONS

REEDSPORT

CORVALLIS

GOLD BEACH

LYONS

PHILOMATH

CANBY

BEND

MADRAS

BONANZA

CHEMULT

lONE

KENT

PORTLAND

SPRI

NG

FIELD

CLATSKANIE

TOLEDO

EUGENE

CHARLESTON

PORTLAND

PORTLAND

HALFWAY

TILLAMOOK

WARRENTON

ESTACADA

NEWBERG

TUALATIN

HERMISTON

HERMISTON

VENETA

WINSTON

PORTLAND

BEAVERTON

EUGENE


9/12

Integrity Auto Body Inc

lnterfor US Inc. *

lnterfor US Inc.*

International Paper

J W Auto Body, Inc. dba J W Carstar Collision Repair Center

J. B. Steel Inc.

J.

V.

Northwest, Inc.

J.H. Baxter and Co

Jasper Wood Products*

Jeld-Wen, Inc.

Jeld-Wen, Inc. dba Jeld-Wen*

Jewell Attachments, LLC

Johnson Controls Battery Group, Inc.

Johnson Crushers International

Jose Sanchez

K W Auto Body, Inc.

Katanacraft LLC dba Katanacraft

Kendall Auto Group

Kinder Morgan Liquids Terminals LLC*

Kindred Son, Inc.

Kingsford Manufacturing Company

Klamath Energy LLC*

Kohler Company

Kramer's Auto Body Car Stereo

Lamping Enterprises, LLC

Landmark Ford, Inc.

Larsen Motor Co . Inc.

Leader Technologies, Inc.

Maaco

Main Auto Body, Inc. dba Lovegrove Collision Centre

Manheim Portland

Marion Ag. Service, Inc.

Marquis Corp

MasterBrand Cabinets, Inc.*

M-B Companies, Inc.

McCiister, Inc.

Metal Enterprises, Inc.

Metal Finishers, Inc.

Meyer Sign Co. of Oregon

Micro-Trains Line Co.

Miller Manufacturing

Mohawk Metal

Murphy Plywood*

Neil's Body Shop, In

c.

Noble Pane ls and Gates, Inc.

Norpac Foods, Inc.*

Northwest Copper Works, Inc.

Northwest Hardwoods*

Northwest Pipe Company

Northwest Pipeline LLC*


NEWBERG

MOLALLA

GILCHRIST

SPRINGFIELD

MCMINNVILLE

MEDFORD

CANBY

EUGENE

JASPER

STAYTON

KLAMATH FALLS

TUALATIN

CANBY

EUGENE

PORTLAND

PORTLAND

GRANTS PASS

EUGENE

P TLAND

WILSONVILLE

SPRINGFIELD

KLAMATH FALLS

PORTLAND

FOREST GROVE

WARRENTON

TIGARD

MCMINNVILLE

WILSONVILLE

EUGENE

SALEM

PORTLAND

ST. PAUL

INDEPENDENCE

GRANTS PASS

SALEM

TUALATIN

PORTLAND

GRANTS PASS

TIGARD

TALENT

HEPPNER

EUGENE

EUGENE

ENTERPRISE

MILTON-FREEWATER

STAYTON

PORTLAND

EUGENE

PORTLAND

BAKER CITY

MEACHAM


10/12


Northwest Structural Services, Inc.

NSA

Northwest Superbrasives (Advanced Diamond)

NW Bend Boats, LLC dba North River Boats

Oak

Street Tank Steel Inc.

Ochoco Lumber Company*

Ochoco Manufacturing Corp.

Orchid Orthopedic Solutions Oregon, Inc

Oregon Collision Center

Oregon Cutting Systems

Oregon

Door

Company*

Oregon Health Science University (OHSU)*

Oregon Industrial Lumber*

Oregon Pacific Metal Fabrication, LLC

Oregon Sandblasting Coating, Inc

Owens Corning Foam Insulation, LLC*

Owens Corning Roofing and Asphalt, LLC*

Owens-Brockway Glass Container Inc.

Pacific Cast Technologies, Inc. dba ATI Cast Products*

Pacific Truck Colors, Inc.

Pacific

Wood

Laminates, Inc.*

PCC Structurals, Inc.

PCC Structurals, Inc.

PECO, Inc,

Perlenfein, Inc. dba B R Auto Body

Pesznecker Brothers, Inc.

Pierce Pacific Manufacturing

Pioneer Metal Finishing (34-0099)

Pioneer Metal Finishing, LLC (34-01 07)

PiRod Inc. dba Valmont Structures

Portland Auto LLC

Portland General Electric (PGE) Beaver plant (oil)*

Portland General Electric Company (25-0016)

Portland General Electric Company* (25-0031 )

Power Motors, Inc. dba Power Collision Center

Pratt and Larson Ceramics

Precision Equipment, Inc.

Quality Industrial Refinishers Co .

Quality Metal Finishing

Quality

Tank

Construction Co. , Inc.

R M Fiberglass Inc

Rawebody Collision Center, Inc.

Rears Manufacturing Co., Inc.

Rikar Enterprises Inc.

Rosboro Springfield*

Roseburg Forest Products Co.*

Roseburg Forest Products Co.* (10-0013)


Roseburg Forest Products Co.* (10-0078)


Rough Ready Lumber LLC*

OREGON CITY

PORTLAND

EUGENE

ROSEBURG

ASHLAND

JOHN DAY

PRINEVILLE

OREGON CITY

FOREST

GROVE

MILWAUKIE

DILLARD

PORTLAND

SPRINGFIELD

MULINO

TUALATIN

GRESHAM

PORTLAND

PORTLAND

ALBANY

TUALATIN

BROOKINGS

CLACKAMAS

PORTLAND

CLACKAMAS

CORVALLIS

CLACKAMAS

PORTLAND

TUALATIN

TUALATIN

SALEM

PORTLAND

CLATSKANIE

BOARDMAN

BOARDMAN

NEWPORT

PORTLAND

PORTLAND

PORTLAND

EUGENE

SANDY

TURNER

TILLAMOOK

COBURG

PORTLAND

SPRINGFIELD

COQUILLE

RIDDLE

DILLARD

RIDDLE

MEDFORD

CAVE JUNCTION


11/12


12/12

West Salem Machinery Company SALEM

Westak o Oregon, Inc. FOREST GROVE

Western Pneumatics EUGENE

WestRock Northwest, LLC* (formerly SP Newsprint) NEWBERG

Weyerhaeuser NR Company* FOSTER

White's Collision Service,

Inc

INDEPENDENCE

White's Collision Service, Inc. (27-0020) DALLAS

White's Collision Service, Inc. (27-0022) DALLAS

Winnebago JUNCTION CITY

Wishart Welding General Fabrication, Inc. CLACKAMAS

Wolf Steel Foundry, Inc. HUBBARD

Wright Manufacturing, LLC PORTLAND

Zieman Manufacturing Company MCMINNVILLE

*Indicates these facilities do not use raw materials containing metals in their production and only

produce minimal metal emissions from fuel combustion for energy purposes.

4/26/2016

Documents

DEQ Letter to Governor Brown on Metal-Emitting Facilities