Professional Documents
Culture Documents
April28, 2016
The Honorable Kate Brown
Governor, State of Oregon
254 State Capitol
Salem, OR 97301-4047
Dear Govemor Brown:
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. It represents our
cunent 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 shape 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.
April28, 2016
Page 2 ofS
List of Oregon 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 of metals 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.
Types and volume of metals 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 of metals.
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 inspections 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 of our 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 in 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
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 of moss 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 Air 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 yearlong 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 at1d to collect and transfer samples to our lab. We are also adding one data
specialist to analyze and prepme 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.
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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.
The additional resources will allow OI-IA to work with communities around the state to evaluate
environmental factors that affect the health of people, 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 of Oregon 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
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Oregon air permitted facilities that emit metals or have the potential to emit metals
Facility Name
Aarons Custom Metal Fab, Inc.
Ace Car Reconditioning , LLC
ACME Welding , Inc.
ACP Auto Body LLC
Advanced R.V. Painting and Repair LLC
Aero Air, LLC
AGC Heat Transfer, Inc.
Aggregate Machinery, Inc.
Akies', Inc.
Allied Systems Company
Allweather Wood, LLC
Allweather Wood , LLC
Amalgamated Sugar Company*
American Laminators*
American Metal Products Company
Ammcon Corp.
Anodex Anodizing, Inc.
Anodizing Solutions, LLC
Apex Anodizing, Inc.
Arc Terminals Holdings, LLC
Ardin Surfaces, Inc.*
Armstrong World Industries Inc.
Ash Grove Cement Company
Austen's Body Shop, Inc.
Auto Body Specialties (Quad Investments)
Automotive Innovation Inc
Bear Mountain Forest Products , Inc.*
Beaverton Auto Body & Paint LLC
Bend Plating, Inc.
Biomass One, L.P.*
Blue Mt. Lumber Products, LLC*
Bob Thomas Auto Body
Boeing Company (The)
Boise Cascade Wood Products, L.L.C.*
Boise Cascade Wood Products, L.L.C.*
Boise Cascade Wood Products, L.L.C.* (31-0002)
Boise Cascade Wood Products, L.L.C.*
Boise Cascade Wood Products, L.L.C.* (31-0011)
Boise Cascade Wood Products, L.L.C.*
Boise Cascade Wood Products, L.L.C.*
Boman Industries, Inc.
BP West Coast Products, LLC
Brasher's Auto and Truck Collision Repair
Bright Wood Corporation
Brotherton Pipeline, Inc.
Bullseye Glass Co.
Bushwacker, Inc.
C. G. Industries, Inc.
Facility City
PORTLAND
TIGARD
PORTLAND
PORTLAND
SALEM
HILLSBORO
PORTLAND
SALEM
SALEM
SHERWOOD
NORTH BEND
WHITE CITY
NYSSA
SWISSHOME
PORTLAND
HILLSBORO
MEDFORD
TUALATIN
PORTLAND
PORTLAND
PORTLAND
SAINT HELENS
DURKEE
CANBY
SPRINGFIELD
CLACKAMAS
BROWNSVILLE
BEAVERTON
BEND
WHITE CITY
PENDLETON
PORTLAND
PORTLAND
MEDFORD
PILOT ROCK
LA GRANDE
ELGIN
LA GRANDE
SHERIDAN
WHITE CITY
SALEM
PORTLAND
WOOD VILLAGE
MADRAS
GOLD HILL
PORTLAND
PORTLAND
ALBANY
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
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
SPRING FIELD
CLATSKANIE
TOLEDO
EUGENE
CHARLESTON
PORTLAND
PORTLAND
HALFWAY
TILLAMOOK
WARRENTON
ESTACADA
NEWBERG
TUALATIN
HERMISTON
HERMISTON
VENETA
WINSTON
PORTLAND
BEAVERTON
EUGENE
- -
- -- - - - - - -- - - - - -- - - -- - - - .
NEWBERG
MOLALLA
GILCHRIST
SPRINGFIELD
MCMINNVILLE
MEDFORD
CANBY
EUGENE
JASPER
STAYTON
KLAMATH FALLS
TUALATIN
CANBY
EUGENE
PORTLAND
PORTLAND
GRANTS PASS
EUGENE
PORTLAND
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
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
RUSCO, Inc
Russ Auto Sales & Service, Inc.
S.R. Smith, LLC*
Sandy Auto Body, Inc.
Sanipac Inc.
Sapa Extrusions, Inc.
Sapa Profiles, Inc.
Sause Bros., Inc.
S-Aute Collision LLC
Seneca Sustainable Energy*
Shaw's Fiberglass and Plastics, Inc.*
Shore Terminals LLC*
Silver Eagle Manufacturing Co.
Silverton Foundry
South Coast Lumber Co.*
Stangel Industries, LLC
Steel Tech Enterprises Inc.
Steelhead Metal & Fab, LLC
Stimson Lumber Company*
Strategic Printing and Manufacturing Solutions, Inc.
Sulzer Pumps (US) , Inc.
Sunstone Circuits, LLC
Swanson Group Mfg. LLC
Swanson Group Mfg. LLC*
Swanson Group*
TOY Industries, LLC dba ATI Wah Chang
Technical Finishes & Coatings Inc.
Technical Plating, Inc.
The Lynch Company, Inc.
Thompson Auto Body, Inc.
Tillamook County Creamery Association*
Timber Products Co. Limited Partnership*
Timby's Too LLC
Toby Murry Motors, Inc.
Todd's Autobody, Inc.
Top Service Body Shop, Inc.
TP Grants Pass, LLC
TP Trucking, LLC
Transco Industries, Inc.
T ri m Auto Body, Inc.
TTC-The T rading Company dba The Trading Company
Two C Enterprises Incorporated dba Salem Auto Body & Paint Works
U-Haul Repair Center
Ulven Forging Inc.
United States Gypsum (USG)
Uroboros Glass
US Crane & Hoist, Inc.
Vanquish Investment Group
Vigor Industrial, LLC
Viper Northwest, Inc.
West Linn Paper Company*
PORTLAND
TIGARD
CANBY
SANDY
EUGENE
THE DALLES
PORTLAND
COOS BAY
SALEM
EUGENE
DAMASCUS
PORTLAND
PORTLAND
SILVERTON
BROOKINGS
ENTERPRISE
CANBY
SALEM
GASTON
TUALATIN
PORTLAND
MULINO
GLENDALE
ROSEBURG
SPRINGFIELD
ALBANY
PORTLAND
WHITE CITY
PORTLAND
PORTLAND
TILLAMOOK
MEDFORD
PORTLAND
NEWPORT
SPRINGFIELD
COOS BAY
GRANTS PASS
CENTRAL POINT
PORTLAND
NORTH BEND
WOODBURN
SALEM
PORTLAND
HUBBARD
RAINIER
PORTLAND
WILSONVILLE
PORTLAND
PORTLAND
ALBANY
WEST LINN