From: BARROWS Bob
Sent: Fri Aug 10 15:38:54 2012
To: BARROWS Bob; FULLER Brian; LUMPER Bruce; NUTTALL Christie; PICKERELL Loretta; RAWSON Stephanie; RHOADES Cathie; SPENDELOW Peter H; VANDEHEY Maggie
Subject: FW: conversion technology rulemaking
Importance: Normal
Attachments: conversion technology rules.doc; Comments of the draft rules from Jeanne Roy. I did acknowledge receipt of these comments. bb Bob Barrows | Waste Policy Coordinator Dept. of Environmental Quality 165 E. 7th Ave., Eugene, OR 97401 | barrows.bob@deq.state.or.us ( 541.687.7354 | 800.844.8467 x7354 (in Oregon) From: Jeanne Roy [mailto:jeanne@earthleaders.org] Sent: Friday, August 10, 2012 10:36 AM To: BARROWS Bob Subject: Re: conversion technology rulemaking Bob, Attached are my comments on the draft conversion technology rules. Please let me know you received this. Jeanne ----- Original Message ----- From: BARROWS Bob To: Jeanne Roy Cc: BARROWS Bob ; SPENDELOW Peter H Sent: Friday, July 20, 2012 12:37 PM Subject: RE: conversion technology rulemaking Hi Jeanne, I’ve inserted answers below. Bob Barrows | Waste Policy Coordinator Dept. of Environmental Quality 165 E. 7th Ave., Eugene, OR 97401 | barrows.bob@deq.state.or.us ( 541.687.7354 | 800.844.8467 x7354 (in Oregon) From: Jeanne Roy [mailto:jeanne@earthleaders.org] Sent: Thursday, July 19, 2012 3:01 PM To: BARROWS Bob Subject: Fw: conversion technology rulemaking Bob, Thank you. I still have a couple questions. See below. Jeanne Proposed Conversion Technology Rule Amendments, Div 96
[BBarrows] These rules are for management of solid waste at solid waste disposal sites. They are not air quality rules, where air emissions would be addressed.
So a facility would have to get a solid waste permit and an air quality permit? Are separate air quality rules being developed? Is your committee considering those? Or another committee?
[BBarrows] Yes, if a facility has air emissions from its activities it would need to submit a notification to the air quality program for evaluation as to the need for an air quality permit. The air quality program is not currently developing rules for conversion technology facilities but they have been tracking the progress of this rule making and we have consulted with them. Air Quality staff have attended several of the advisory committee meetings. In addition, someone from the EPAs Air Quality program has also attended advisory committee meetings by phone and has communicated with us by e-mail and phone. The advisory committee for this rulemaking is not considering the air quality rules. I do know that EPA is evaluating air emissions from various conversion technology facilities but I do not know if they will make new rules for permitting those facilities.
[BBarrows] That rule is focused specifically on the products produced by Conversion technology facilities. We are concerned that the facility might pose a risk and need a higher level of oversight if the products it produces pose a risk to the environment or human health. As I look at this, sections (a), (b), (c) and (e) address the risk the facility poses.
I see nothing under 096.0160 (5) or (6) that address risks to human health caused by the facility. Bullets address water, soil, odor, and cleanup risk.
[BBarrows] You’re right, I don’t see a direct reference to human health. Those factors are looking at the risks of pollution the facility may pose to those media directly. However, indirectly those media (water, soil, odor and contaminated site) can affect human health if polluted, as well as environmental health. Does that explain it?
Jeanne Roy | Co-Director
Center for Earth Leadership
319 SW Washington Street, Suite 400
Portland, Oregon 97204
(503) 244-0026; www.earthleaders.org
Forging citizen leadership to a sustainable future