DEQ Public Hearing summary / need written public comments by 8/4

[Jeremy Monroe]

Hello neighbors-

I'm just sending out some takeaways from last Thursday's DEQ hearing on the draft H&V air permit, for those who couldn't attend, and a reminder for written comments by the August 4th deadline.

Notes from hearing

-Even though the citizen land use (LUBA) appeals could pause or halt the DEQ permitting process, DEQ is proceeding with the Public Hearing & Comment Period because there is an Oregon Administrative Rule that allows them to

-The increased CO levels are the trigger for the higher class EPA Title V permit that H&V must apply for. DEQ reported that measured/modeled CO levels near the plant were below public health safety thresholds

-There is still a lot of uncertainty about the fine particulates, PM <2.5, that are being emitted from H&V. There is some averaging of particulate sizes and possible shell-gaming between plants that may hide the true emissions of fine particulates that are among the highest concern for public health. EPA classifies glass microfibers as a Hazardous Air Pollutant (HAP) when <1.0 micron in diameter, which is the size produced at the Glass Fiber 1 plant (near Crystal Lake park entrance). However, because DEQ allows the both H&V plants to be considered one facility, the average size emitted is larger than 1.0, and so escapes additional regulation.  DEQ allows H&V to keep the details of the fiber size of their glass fiber emissions confidential.

-The Cleaner Air Oregon program that H&V has been called into will be doing testing on fine particulates, and results are anticipated in a year or so

-Several neighbors had thoughtful questions and comments on the historical context of neighborhood concerns and zoning history, conflicts with the City's land use approval, and the need to slow down the permitting process

Given the pending citizen land use appeal, the unknowns with particulate levels, and the forthcoming Cleaner Air Oregon testing, we see a stronger argument to postpone this public comment period to allow critical information to come to light and allow for some community trust in this process. Postponement would not limit H&V's ability to operate in the meantime (they have been on a temporary permit since 2016).

Written comments can be submitted through 5pm, August 4th and made to:

Suzy Luttrell
Email: suzy.l...@deq.oregon.gov

Here is an updated list of potential talking points to add to your comments. Demanding detailed test results for particulates may be the most important appeal we can make:

• H&V recently installed a completely different filtration technology to capture particulates. This equipment change and the public health risks associated with fine particulates, especially PM < 2.5, demand rigorous testing before approval of any new permit. H&V is too close to neighborhoods, businesses, parks, and natural areas to proceed with estimates and formulas.
  

• After all the community has been through with H&V and DEQ in the last 6 years, we deserve to see more emissions testing from both plants 1 and 2 to feel comfortable with any permitting process. The continued use of estimates/formulas without testing is not acceptable, and averaging / combining emissions - especially particulates - from the plants misrepresents actual pollutant risk for the community.
  

• H&V's proximity to sensitive neighbors and land uses, along with their persistent air permit violation (that was in part due to an overreliance on incorrect formulas), are why H&V is called into DEQ's Cleaner Air Oregon program. The CAO program has planned particulate testing for H&V, so why don't we just let CAO complete their testing/reporting before proceeding with this permit process?

• The regulated pollutant levels in the draft permit are 3 times higher than in the previous permit. This pollution increase is unacceptable by our local land use code, and unacceptable for a polluter with a history of negligence.

• It is not prudent for DEQ to proceed with a public comment period while two citizen LUBA appeals are pending. There is no need to rush this public comment period, and doing so is not protective of public interest or health and safety.
  

• The community has seen no accurate emissions information from DEQ or H&V in the last 7 years. Even DEQ's published reports contain erroneous/old formulas, how can we trust DEQ when it has not been diligent with testing or transparent with reporting?

• H&V's negligence and old infrastructure continue to pose harm and risks to our community and environment. H&V has had two river spills in the last ten years, and they are also responsible for TCE soil contamination clean-up.

• H&V has demonstrated irresponsibility and negligence, while DEQ seems to be continuing with its 'honor system' of pollution enforcement. If it wasn't for citizen outcry, DEQ would have never discovered the gross persistent violation in 2015. This pattern does not foster public trust.
  

• The draft permit requests 74,000 tons/year of greenhouse gas emissions, an enormous amount that conflicts with our City's Climate Action Plan

Please take some time to add your voice to this important issue for our neighborhood.

Jeremy Monroe

[meditati...@gmail.com]

Testing ( we as the neighbors ) will have to test for very fine particulate matter by our self because the D E Q will not!!

   The cost of having professional testing is not expensive (resently the cost  has become affordable and the accuracy is excellent)

    The D E Q (by law must come and meet with the neighbors)!  All we need is 50 people to sign a request and they must come.

      Any person can call the D E Q  And speak to the officials in charge of this project.

   Mike Eidele, PE

   ENVIRONMENTAL ENGINEER 

   ODEQ-WR-Salem

    503 378 5070

Sent from my iPhone

On Jul 29, 2022, at 9:12 AM, Jeremy Monroe <jer...@freshwatersillustrated.org> wrote:



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[Denis White]

Thanks for your comments and suggestions.

I will sign a request for DEQ to come to South Corvallis to meet with us. 

How do we initiate the fine particulate testing?

Denis White
Crystal Circle

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