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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.
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
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.
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
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
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
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.
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
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
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
6/12
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
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)
East Side Plating, Inc. (26-0171)
East Side Plating, Inc. (26-3036)
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
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
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*
Gas Transmission Northwest LLC*
Gas Transmission Northwest LLC*
Gas Transmission Northwest LLC*
Gas Transmission Northwest LLC*
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
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
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*
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
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
10/12
Northwest Pipeline LLC*
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.*
Roseburg Forest Products Co.* (10-0078)
Roseburg Forest Products Co.*
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
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
11/12
8/17/2019 DEQ Letter to Governor Brown on Metal-Emitting Facilities
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