| A | B | C | D | E | F | G | H | I | J | K | L | M | N | O | P | Q | R | S | T | |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 1 | Subject | Body | From: (Name) | From: (Address) | From: (Type) | To: (Name) | To: (Address) | To: (Type) | CC: (Name) | CC: (Address) | CC: (Type) | BCC: (Name) | BCC: (Address) | BCC: (Type) | Billing Information | Categories | Importance | Mileage | Sensitivity | Attachments |
| 2 | Emissions from Glass Factories |
Jill,_x000D_ I ask that the state realize the immediate damage that the ruling to stop production would cause in our industry. The ripple will be nation wide, and reach globally as well. Uroborous and Bullseye are important assets in the stained glass world, loosing them would be like loosing a limb. We are a restoration studio in Ohio that depends on materials from both of these factories._x000D_ _x000D_ _x000D_ _x000D_ All the best,_x000D_ _x000D_ <https://docs.google.com/uc?id=0B60TSSDuTseLMUkxbWZaWXV3N2M&export=download> _x000D_ _x000D_ Andrea Killy-Knight_x000D_ Bigelow Glass_x000D_ 915 E. Bigelow_x000D_ Findlay, OH_x000D_ 45840_x000D_ 419-422-3523_x000D_ _x000D_ <https://docs.google.com/uc?id=0B60TSSDuTseLdUtXWm9DZ3JNNGk5VVF4NlA4ekJBOURlaXM4&export=download> _x000D_ _x000D_ _x000D_ **Artwork, if any, in this e-mail is property of Bigelow Glass**_x000D_ _x000D_ _x000D_ |
andreanightwithak@gmail.com | andreanightwithak@gmail.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 3 | regarding Portland air quality |
I find it strange to focus on small colored glass companies as
the source of air pollution in Portland Oregon. As a life-long
Oregonian I am dismayed how we ignore the Chem-Trails in our
skies, including Portland. I suggest researching the amount
of neuro-toxins being dropped on us by these planes now probably
drones. It will stager your mind: GeoEngineeringWatch.org
This is the real culprit of Oregon's awful air pollution. (commercial
airplanes do not have trails following them, they have a by-pass
engine to deal with condensation, which what you see in the sky,
is not.)_x000D_ _x000D_ Thank you for you service,_x000D_ _x000D_ Annie Ocean _x000D_ |
Annie Ocean | beloved@jeffnet.org | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 4 | FW: Bullseye Glass |
I think this is a comment on the rules._x000D_ _x000D_ _x000D_ _x000D_ From: ALSDORF William H On Behalf Of DEQINFO_x000D_ Sent: Friday, March 25, 2016 2:04 PM_x000D_ To: [AQ] Air Toxics_x000D_ Subject: FW: Bullseye Glass_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ From: John Malpass [mailto:jmalpass@bellsouth.net] _x000D_ Sent: Friday, March 25, 2016 2:00 PM_x000D_ To: DEQINFO_x000D_ Cc: questions@bullseyeglass.com <mailto:questions@bullseyeglass.com> _x000D_ Subject: Bullseye Glass_x000D_ _x000D_ _x000D_ _x000D_ Your attempt to shut down Bullseye Glass has not gone unnoticed by this artisan. I have used Bullseye’s products for almost 40 years. I am tired of DEQ/EPA’s liberal and unscientific attempts to squash another entrepreneur. Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. _x000D_ _x000D_ Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye’s furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules._x000D_ _x000D_ _x000D_ _x000D_ Regards,_x000D_ _x000D_ John_x000D_ _x000D_ _x000D_ _x000D_ John R. Malpass, Ph.D._x000D_ _x000D_ 910-420-2330_x000D_ _x000D_ Owner, Malpass Glass and Craft Studio, LLC_x000D_ _x000D_ jmalpass@bellsouth.net <mailto:jmalpass@bellsouth.net> _x000D_ _x000D_ _x000D_ _x000D_ |
ARMITAGE Sarah | /O=DEQ/OU=DEQHQ/CN=RECIPIENTS/CN=SARMITA | EX | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 5 | Media Contact - chromium 6 limit in temporary art glass rules |
Date and Time Contacted: 3/12/16 2 pm_x000D_ _x000D_ Publication/Station: Mercury_x000D_ _x000D_ Reporter’s Name and Phone Number: Dan Forbes 503-477-8888_x000D_ _x000D_ Topic Discussed: DEQ’s reasons for proposing 1.6 ng/m3 as chromium 6 limit in temp rules. See email below._x000D_ _x000D_ Reporter’s Deadline: COB 3/25_x000D_ _x000D_ Dan,_x000D_ You have asked for our thinking in setting the limit of 1.6 ng/m3 for chromium 6 in the proposed temporary rules for art glass facilities. As you know we consulted with OHA on this level because it pertains to exposures of less than a year and health effects that would be acute or intermediate, rather than chronic. DEQ’s risk based air toxics program is intended to manage potential chronic health effects from lifetime exposures, and our benchmarks are expressed as yearly averages and calculated with the assumption of a 70 year exposure. _x000D_ _x000D_ The art glass facility regulations are intended as a short term approach to emissions from specific facilities until DEQ develops a new comprehensive risk based permitting program where we will have a full process of public input and decision-making on fenceline emission limits and allowable risk._x000D_ _x000D_ In addition to what you heard from David Farrer at OHA about 1.6 ng/m3 being well below the ATSDR intermediate minimal risk level (MRL) value listed for chromium 6, we considered the following:_x000D_ _x000D_ - For long term cancer risk, 1.6 ng/m3 at 1 in 50,000 (assuming a 24 hour 70 year exposure) is well below the upper part of the range of 1 in 10,000 that EPA uses when setting industrial standards to control air toxics. _x000D_ _x000D_ - The proposed modeling to establish levels not to exceed 1.6 ng/m3 is for an adjacent receptor or nearest point of exposure, and levels of pollutants decrease with distance from that location. _x000D_ _x000D_ I hope this information helps clarify our thinking on the proposed limit._x000D_ _x000D_ Sarah_x000D_ _x000D_ _x000D_ Sarah Armitage_x000D_ DEQ Air Quality Planning_x000D_ 503-229-5186_x000D_ _x000D_ _x000D_ |
ARMITAGE Sarah | /O=DEQ/OU=DEQHQ/CN=RECIPIENTS/CN=SARMITA | EX | ALSDORF William H;DANAB Marcia;MCPHERSON Lee;SVELUND Greg;WHITE Brian;FLYNT Jennifer;ARMSTRONG Ken | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=WALSDOR;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=MDANAB;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=LMCPHER;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=Greg Svelunda68;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=BWHITE;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=FLYNT Jennifer3f3;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=ARMSTRONG Kenf07 | EX;EX;EX;EX;EX;EX;EX | CALDERA Stephanie;MANEY Ella;[All DEQ] Regional Solutions;PEDERSEN Dick;DECONCINI Nina;HAYES-GORMAN Linda;ANDERSEN Keith;HAMMOND Joni;EMER Lydia;WILES Wendy;FELDON Leah;DAVIS George;INAHARA Jill;MACMILLAN Susan;JOHNSON Keith;MODIE JONATHAN N;FARRER DAVID G | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=sclark;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=ecrumbl;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=[All DEQ] Regional Solutionsd01;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=DPEDERS;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=NDECONC;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=LHAYES;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=KANDERS;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=JHAMMON;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=EMER Lydiafdd;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=wwiles;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=lkoss;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=GDAVIS;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MACMILLAN Susanebb;keith.johnson@state.or.us;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=OR019592713b;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=OR0180882565 | EX;EX;EX;EX;EX;EX;EX;EX;EX;EX;EX;EX;EX;EX;SMTP;EX;EX | Normal | Normal | |||||||
| 6 | Bullseye Glass |
I find your making of these “special rules” for Bullseye Glass
to be absurd and politically motivated. _x000D_ _x000D_ " DEQ has concluded that uncontrolled furnaces used in such small art glass manufacturing are "more likely than not" to emit potentially unsafe levels of certain metals, including arsenic, cadmium, hexavalent chromium and nickel.” _x000D_ _x000D_ So there is no basis in reality for what you are doing and the rules you are proposing._x000D_ _x000D_ Professor Bruce Grudzinski_x000D_ Milwaukee Institute of Art and Design._x000D_ brucegrudzinski@miad.edu <mailto:brucegrudzinski@miad.edu> _x000D_ |
Bruce Grudzinski | brgrudski@att.net | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 7 | Bullseye Glass Company |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. _x000D_ _x000D_ Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye’s furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules._x000D_ _x000D_ _x000D_ _x000D_ Bullseye Glass has the most excellent programs and services of any other American glass company. They are five stars. This political issue, the news stories reporting the CRISIS caused, when that is all false._x000D_ _x000D_ _x000D_ Please find FACTS and not propaganda, pushing by the uneducated on the fact that Bullseye Glass is and has always been responsible. They are part of our community._x000D_ _x000D_ _x000D_ These over-the-top changes proposed will hamper many, MANY artists ability to access both high quality products, but the residual effect will be a reduction in community service events, top level educational opportunities and access to the basic services and products that artists in the art glass world require._x000D_ _x000D_ _x000D_ Imagine the price of a sheet of glass for your beautiful stained glass window being shipped from out of state, in a wood box, weighing who knows how much...you wouldn't be able to afford that stained glass window, nor the artist could afford to. No longer would there be the opportunity to see glass in person, touch the texture, see how the light hits it...instead ordering glass from a catalog._x000D_ _x000D_ _x000D_ This is extraordinarily ridiculous. Please listen to those of us that realize you are about to bend to the community's loud voices that are not based on the facts. Make your decision based on the facts that you know. Bullseye is doing more than enough to make it's community safe. There are bigger fish to fry in other business that have cancer-causing emissions._x000D_ _x000D_ _x000D_ Sincerely,_x000D_ Diane Nelson Cooper_x000D_ Glass Artist_x000D_ |
Diane Nelson Cooper | orcadolphin71@gmail.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 8 | FW: Bullseye Glass |
_x000D_ _x000D_ _x000D_ _x000D_ From: ALSDORF William H On Behalf Of DEQINFO_x000D_ Sent: Friday, March 25, 2016 2:04 PM_x000D_ To: [AQ] Air Toxics_x000D_ Subject: FW: Bullseye Glass_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ From: John Malpass [mailto:jmalpass@bellsouth.net] _x000D_ Sent: Friday, March 25, 2016 2:00 PM_x000D_ To: DEQINFO_x000D_ Cc: questions@bullseyeglass.com <mailto:questions@bullseyeglass.com> _x000D_ Subject: Bullseye Glass_x000D_ _x000D_ _x000D_ _x000D_ Your attempt to shut down Bullseye Glass has not gone unnoticed by this artisan. I have used Bullseye’s products for almost 40 years. I am tired of DEQ/EPA’s liberal and unscientific attempts to squash another entrepreneur. Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. _x000D_ _x000D_ Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye’s furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules._x000D_ _x000D_ _x000D_ _x000D_ Regards,_x000D_ _x000D_ John_x000D_ _x000D_ _x000D_ _x000D_ John R. Malpass, Ph.D._x000D_ _x000D_ 910-420-2330_x000D_ _x000D_ Owner, Malpass Glass and Craft Studio, LLC_x000D_ _x000D_ jmalpass@bellsouth.net <mailto:jmalpass@bellsouth.net> _x000D_ _x000D_ _x000D_ _x000D_ |
EBERSOLE Gerald | /O=DEQ/OU=DEQHQ/CN=RECIPIENTS/CN=GEBERSO | EX | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 9 | FW: Uroboros and Bullseye Glass |
_x000D_ _x000D_ _x000D_ _x000D_ From: ALSDORF William H On Behalf Of DEQINFO_x000D_ Sent: Monday, March 28, 2016 8:32 AM_x000D_ To: [AQ] Air Toxics_x000D_ Subject: FW: Uroboros and Bullseye Glass_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ From: Elizabeth Steinebach [mailto:esteinebach@statslog.com] _x000D_ Sent: Monday, March 28, 2016 8:03 AM_x000D_ To: DEQINFO_x000D_ Subject: Uroboros and Bullseye Glass_x000D_ _x000D_ _x000D_ _x000D_ Hello,_x000D_ _x000D_ _x000D_ _x000D_ I wanted to share some of my thoughts about the air and soil issues around the glass manufacturing plants, in Oregon, but couldn’t find where to submit this email specifically, so am sending it generally._x000D_ _x000D_ _x000D_ _x000D_ I love stained glass. I love both Bullseye and Uroboros glass. I want to be proud of the work I do with glass and want to know my sources are not being harmful to people or the environment. I’ve spent time reading your postings on your website and feel that there is much more you can do to help me and others, fully understand about this issue._x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ My name is Elizabeth Steinebach. I live in rural northern Ontario, Canada. I have been working with stained glass since 1979. This work included sales, repairs and custom work. I have been taught by some of the industries best and have gone on to teach, at a local level. I have worked in studios and privately, learned many advanced techniques and continue to love and learn from this medium._x000D_ _x000D_ _x000D_ _x000D_ I have been loosely tracking the news about air and land quality issues, in and around glass manufacturers on the west coast. It harkens back to the 1990’s when lead was the issue of the day. I wrote a short piece on the Artists in Stained Glass website and will share some further thoughts on this matter. _x000D_ _x000D_ _x000D_ _x000D_ When the news first broke that children were becoming ill and cadmium was a suspect source, possibly from a local glass manufacturer, I was spiritually ill. Was it possible that some of the glass that I use in my work, 1000’s of kilometers away, was having a harmful impact to the neighbors of this producer? _x000D_ _x000D_ _x000D_ _x000D_ Prior to the 1990’s studio work was very unencumbered. It was the cavalier time, coming out of the earlier generations when we believed we could do no harm, to others or ourselves. As a woman even then, working in a predominately male environment, it was seen as being weak to want a respirator or gloves. Since the Cincinnati Conference in 1990, our eyes were opened. We could no longer deny the health risks and things changed. Fume traps, safety gear of all sorts, proper disposal and education for clients became necessary. The industry had a huge transition. _x000D_ _x000D_ _x000D_ _x000D_ Some 25 years later, this current issue appears. Had we become complacent? It just didn’t sit well with me. In the AISG post I mention my time living in Toronto, Ontario. There was a huge metal manufacturer, who among other things made lead came. This was is the “poor” side of town, near the upper end of the dock area. They polluted for years. To believe otherwise is ridiculous. As the city of Toronto grew and demand for housing in new suburbs was needed, residential properties encroached the old metal plant. The human population, not keen to have a “stinky” plant in their back yard, soon forced the plant to leave. Some minor clean up policies were in place, on site, but the reality is that anything beyond the plant was not. To this day, when a new condominium, or some other serious disturbance of the soil occurs, all manner of heavy metal toxicity is revealed. _x000D_ _x000D_ _x000D_ _x000D_ Who now is to blame for this? The sins of the old company may reside as residue, but it was a different time. Did they deliberately pollute and by pass any kind of environmental safeguards? Perhaps, there is certainly anecdotal evidence of companies risking the health of their workers and their neighbors for maximizing profits. Could this be true of every glass manufacturer in the Portland area? Was there some kind of collusion among them? Personally I hope that this is not the case and that they remember they risk the health of their own workers, before it goes beyond their front doors._x000D_ _x000D_ _x000D_ _x000D_ When I left Toronto and moved north, it was for the fresh air and sunshine. Yet, since living here, I’ve found out that I’m about 10 km from an old silver mine and all the residues of it’s production. Naturally occurring uranium has a few “hot” spots. 100Km to the north of me, is Sudbury, one of Canada’s largest nickel mines. My geology is fraught with known and unknown dangers._x000D_ _x000D_ _x000D_ _x000D_ Nobody wants to see harm come to children or the environment. The stained glass industry has learned from past mistakes and has embraced change to better the industry. I do want to know what is going on in the Portland area. And I know that a safe knowledgeable outcome can be achieved that will protect the environment, neighbors of the glass manufacturers and not cause undo hardship on my industry. However fear mongering and wild accusations are not doing anyone service. Transparency is important. Please continue to do good work and keep me informed._x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ Questions that I would like to have answered are:_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ What is the health of the actual workers inside the manufacturing plants? _x000D_ _x000D_ _x000D_ _x000D_ What are the protocols for handling these specifically mentioned materials? At the plant? Disposal?_x000D_ _x000D_ What is the site history of the manufacturing plant? _x000D_ _x000D_ _x000D_ _x000D_ Could they have inherited a previous owners residue?_x000D_ _x000D_ _x000D_ _x000D_ I do not want to be mean spirited, however how thoroughly have the claims of the children, been researched? _x000D_ _x000D_ _x000D_ _x000D_ Could there be other sites of contamination – a school, or community facility or even locally occurring geological deposits?_x000D_ _x000D_ _x000D_ _x000D_ Are there going to be public information forums? _x000D_ _x000D_ _x000D_ _x000D_ Is there an organized local residential group, who might have a hidden agenda?_x000D_ _x000D_ _x000D_ _x000D_ What are the water samples in the area showing?_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ Your work has far reaching implications. The stained glass industry is a small one. In my experience we have always pulled together to do the right thing. Thank you._x000D_ _x000D_ _x000D_ _x000D_ Elizabeth Steinebach_x000D_ _x000D_ Stained Glass Artisan_x000D_ _x000D_ 2 Sugar Lake Road_x000D_ _x000D_ Seguin, Ontario_x000D_ _x000D_ Canada P2A0B6_x000D_ _x000D_ |
EBERSOLE Gerald | /O=DEQ/OU=DEQHQ/CN=RECIPIENTS/CN=GEBERSO | EX | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 10 | Temporary Rule, Colored Glass Manufacturing Plants in Multnomah, Washington Counties and whole State |
Hi Jill (Inahara),_x000D_ _x000D_ _x000D_ _x000D_ I have attached my Public Comment document titled ‘EQC colored glass Temporary Rule testimony March 30, 2016’ related to the Temporary Rules on the Colored Glass Manufacturing Plants. I also attached the document titled ‘Plaintiffs 21 Youth 8 to 19 years in color’ that I talk about in my comments._x000D_ _x000D_ _x000D_ _x000D_ Best regards,_x000D_ _x000D_ _x000D_ _x000D_ Dale_x000D_ _x000D_ cell: 503-504-5972 _x000D_ _x000D_ |
FEIK Dale | /O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=DALE FEIKEB6 | EX | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal |
    |
|||||||||
| 11 | portland air toxics interview with Dan Forbes of The Portland Mercury |
Date and Time Contacted: several times this week_x000D_ _x000D_ Publication/Station: The Portland Mercury_x000D_ _x000D_ Reporter’s Name and Phone Number: Dan Forbes 503-477-8888_x000D_ _x000D_ Topic Discussed: Uroboros and Bullseye agreements and temporary rules_x000D_ _x000D_ Reporter’s Deadline:_x000D_ _x000D_ Please see the attached email chain. In addition, I just did a phone interview. We discussed my email responses in further detail. I was able to correct some incorrect understandings he had about the agreement, which was good. Dan now understands that Uroboros may not use cadmium, chromium VI or arsenic (although they already don’t use this) in an furnace until there are controls. _x000D_ _x000D_ He did say that the agency has said they can’t use any chromium until there are controls. I clarified that they can use chromium III on an uncontrolled furnace, BUT NOT UNTIL they establish a maximum usage rate with the Department and that this must be done through source testing and modeling. He said it didn’t make sense that the agency doesn’t have the expertise to know that chromium III converts to chromium VI. I clarified that we do understand there is a conversion at certain heat levels and at certain oxidizing conditions, but that we don’t know the exact heat level and exact oxidizing or reducing conditions of the companies’ furnaces to know the conversion. I reiterated that was the point of requiring the source testing and modeling – to determine that conversion and protect the public._x000D_ _x000D_ _x000D_ Leah K. Feldon_x000D_ Manager, Office of Compliance and Enforcement_x000D_ Oregon Department of Environmental Quality_x000D_ 503.229.6408_x000D_ feldon.leah@deq.state.or.us_x000D_ _x000D_ _x000D_ |
FELDON Leah | /O=DEQ/OU=DEQHQ/CN=RECIPIENTS/CN=LKOSS | EX | ALSDORF William H;DANAB Marcia;MCPHERSON Lee;SVELUND Greg;WHITE Brian;FLYNT Jennifer;ARMSTRONG Ken;INAHARA Jill;ARMITAGE Sarah;GARRAHAN Paul;DAVIS George;STEVENS-SCHWENGER Joan;Stevens-Schwenger Joanie | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=WALSDOR;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=MDANAB;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=LMCPHER;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=Greg Svelunda68;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=BWHITE;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=FLYNT Jennifer3f3;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=ARMSTRONG Kenf07;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=SARMITA;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=Paul Garrahan0b6;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=GDAVIS;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=Joan Stevens-Schwenger81e;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=Stevens-Schwenger Joaniebd1 | EX;EX;EX;EX;EX;EX;EX;EX;EX;EX;EX;EX;EX | CALDERA Stephanie;MANEY Ella;[All DEQ] Regional Solutions;PEDERSEN Dick;DECONCINI Nina;HAYES-GORMAN Linda;ANDERSEN Keith;HAMMOND Joni;EMER Lydia;WILES Wendy | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=sclark;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=ecrumbl;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=[All DEQ] Regional Solutionsd01;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=DPEDERS;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=NDECONC;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=LHAYES;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=KANDERS;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=JHAMMON;/O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=EMER Lydiafdd;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=wwiles | EX;EX;EX;EX;EX;EX;EX;EX;EX;EX | Normal | Normal | |||||||
| 12 | FW: Bullseye Glass - 1 |
_x000D_ _x000D_ _x000D_ _x000D_ From: EBERSOLE Gerald _x000D_ Sent: Tuesday, March 29, 2016 1:26 PM_x000D_ To: INAHARA Jill_x000D_ Subject: FW: Bullseye Glass_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ From: ALSDORF William H On Behalf Of DEQINFO_x000D_ Sent: Friday, March 25, 2016 2:04 PM_x000D_ To: [AQ] Air Toxics_x000D_ Subject: FW: Bullseye Glass_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ From: John Malpass [mailto:jmalpass@bellsouth.net] _x000D_ Sent: Friday, March 25, 2016 2:00 PM_x000D_ To: DEQINFO_x000D_ Cc: questions@bullseyeglass.com <mailto:questions@bullseyeglass.com> _x000D_ Subject: Bullseye Glass_x000D_ _x000D_ _x000D_ _x000D_ Your attempt to shut down Bullseye Glass has not gone unnoticed by this artisan. I have used Bullseye’s products for almost 40 years. I am tired of DEQ/EPA’s liberal and unscientific attempts to squash another entrepreneur. Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. _x000D_ _x000D_ Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye’s furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules._x000D_ _x000D_ _x000D_ _x000D_ Regards,_x000D_ _x000D_ John_x000D_ _x000D_ _x000D_ _x000D_ John R. Malpass, Ph.D._x000D_ _x000D_ 910-420-2330_x000D_ _x000D_ Owner, Malpass Glass and Craft Studio, LLC_x000D_ _x000D_ jmalpass@bellsouth.net <mailto:jmalpass@bellsouth.net> _x000D_ _x000D_ _x000D_ _x000D_ |
INAHARA Jill | /O=DEQ/OU=DEQHQ/CN=RECIPIENTS/CN=JINAHAR | EX | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 13 | RE: Source test at Bullseye |
Forgot to talk about this yesterday….sorry! Mike, once you
know the dates of the source test, please work with Leah and
Jennifer Flynt on how to announce it to the public._x000D_ _x000D_ Thanks!_x000D_ _x000D_ Jill_x000D_ _x000D_ _x000D_ _x000D_ From: FELDON Leah _x000D_ Sent: Friday, March 25, 2016 12:03 PM_x000D_ To: INAHARA Jill; EISELE Michael; DAVIS George_x000D_ Subject: RE: Source test at Bullseye_x000D_ _x000D_ _x000D_ _x000D_ Yes – please add it to the list. Thanks._x000D_ _x000D_ _x000D_ _x000D_ From: INAHARA Jill _x000D_ Sent: Friday, March 25, 2016 11:57 AM_x000D_ To: EISELE Michael; FELDON Leah; DAVIS George_x000D_ Subject: Source test at Bullseye_x000D_ _x000D_ _x000D_ _x000D_ Hi Everyone,_x000D_ _x000D_ FYI - One commenter wanted to be notified of when the source test will be done. Maybe we can discuss this at the meeting/call on Monday. _x000D_ _x000D_ Thanks,_x000D_ _x000D_ Jill_x000D_ _x000D_ |
INAHARA Jill | /O=DEQ/OU=DEQHQ/CN=RECIPIENTS/CN=JINAHAR | EX | FELDON Leah;EISELE Michael;DAVIS George;LUDWICZAK Mark | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=lkoss;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=MEISELE;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=GDAVIS;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=mludwic | EX;EX;EX;EX | FLYNT Jennifer | /O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=FLYNT Jennifer3f3 | EX | Normal | Normal | |||||||
| 14 | Position on EPA ruling on glass manufacturers |
Jill,_x000D_ J Ring Glass Studio Inc. would like to voice its support of the position that Bullseye Glass Company, Uroboros Glass Company and the Stained Glass Association of America have taken in regards to the proposed temporary EPA rules which would stop production of 50% of the art glass colors available. These actions need to be based on science and proven fact._x000D_ I do believe that the proposed temporary EPA rules threaten the very existence of the supply of art glass used for the restoration and repair of tens of thousands of historic buildings, public as well as private. I believe this would be in violation of the U.S. National Preservation Act 1966. Under this law a Section 106 should be convened before any action can be taken._x000D_ _x000D_ Joseph W Ring_x000D_ _x000D_ President_x000D_ _x000D_ J. Ring Glass Studio Inc._x000D_ _x000D_ St. Paul, Minnesota_x000D_ _x000D_ |
Joe Ring | joe@jringglass.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 15 | RE: Bullseye Glass Testing |
Hi! I agree with the group that we should push for performing
three replicate tests (at the worst case operating condition).
Our Source Test Manual does allow for acceptance of two tests
in certain situations, but this is reserved for cases that are
‘beyond the control of the permittee’….for example, a sample
bottle is broken in shipment or extreme weather conditions.
We accept two tests when one of the three tests is invalidated
and can’t be repeated._x000D_ _x000D_ We don’t allow for two tests (only) during the planning stage of a test program. Of course, the manual applies to compliance testing projects. For ‘engineering’ or ‘informational’ testing (as this might be considered), we could probably rationalize an exception._x000D_ _x000D_ I went through this exercise (accepting two vs three tests) with the EPA on a PCWP MACT Rule (Federal) test a few years ago. Again, this situation (one sample invalidated) arose 1-2 weeks after the testing was completed. The MACT Rule spelled out specifically ‘when thou shall allow ‘less than three’ tests’. I talked with an EPA Region X rep about this case. He said that in practice, the EPA generally defers to the judgment of the local (ODEQ) governing body. They could certainly overturn our decision, but that would be very unusual ._x000D_ _x000D_ I accepted the two tests and it has not been challenged._x000D_ _x000D_ This is the MACT Rule language:_x000D_ Unless otherwise specified in a relevant standard or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the relevant standard. For the purpose of determining compliance with a relevant standard, the arithmetic mean of the results of the three runs shall apply. Upon receiving approval from the Administrator, results of a test run may be replaced with results of an additional test run in the event that— _x000D_ (i) A sample is accidentally lost after the testing team leaves the site; or_x000D_ (ii) Conditions occur in which one of the three runs must be discontinued because of forced shutdown; or_x000D_ (iii) Extreme meteorological conditions occur; or_x000D_ (iv) Other circumstances occur that are beyond the owner or operator’s control._x000D_ _x000D_ Again, this was for an EPA-mandated compliance test. The DEQ ‘rule’ on this allows a little more ‘wiggle’ room:_x000D_ _x000D_ (Section 2.5) Unless otherwise specified by permit, State rule, federal regulation, or Department letter, each_x000D_ source test must consist of at least three (3) test runs and the emission results reported as the_x000D_ arithmetic average of all valid test runs. If for reasons beyond the control of the permittee (e.g.,_x000D_ forced shutdown, extreme meteorological conditions, failure of an irreplaceable portion of the_x000D_ sample train) a test run is invalidated and cannot be replaced by a valid test run, DEQ may_x000D_ consider accepting two (2) test runs for demonstrating compliance with the emission limit or_x000D_ standard. However, all test runs, including those deemed invalid, are to be included in the test_x000D_ report._x000D_ _x000D_ --Mark_x000D_ _x000D_ -----Original Appointment-----_x000D_ From: EISELE Michael _x000D_ Sent: Friday, March 25, 2016 4:18 PM_x000D_ To: MONRO David; FELDON Leah; BOLING Brian; DAVIS George; INAHARA Jill; LUDWICZAK Mark_x000D_ Subject: Bullseye Glass Testing_x000D_ When: Monday, March 28, 2016 9:00 AM-9:30 AM (UTC-08:00) Pacific Time (US & Canada)._x000D_ Where: Call In Number: 888-398-2342 Particpate Code: 784770_x000D_ _x000D_ _x000D_ Agenda:_x000D_ _x000D_ *Bullseye has proposed to test one run over the duration of a batch cycle which will be approximately 16hrs. Testing will be for PM and total Cr & Cr+6 at both the inlet to and the exhaust of the baghouse._x000D_ Is this enough? We typically require 3 test runs._x000D_ _x000D_ *Bullseye is proposing to test a batch with the highest concentration of Cr they use. To make the glass they will be using a reducing flame (rich burn)._x000D_ Do we agree this is the worst case scenario or would a batch with less Cr, but with an oxidizing flame (lean burn) be the worst case scenario? _x000D_ _x000D_ *When will testing be._x000D_ _x000D_ *Difficult testing conditions._x000D_ _x000D_ Interesting fact:_x000D_ _x000D_ Cr turns the glass green with a reducing flame or yellow with an oxidizing flame. _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ ?????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????????? |
LUDWICZAK Mark | /O=DEQ/OU=DEQHQ/CN=RECIPIENTS/CN=MLUDWIC | EX | EISELE Michael;MONRO David;FELDON Leah;BOLING Brian;DAVIS George;INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=MEISELE;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=dmonro;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=lkoss;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=BBOLING;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=GDAVIS;/O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX;EX;EX;EX;EX;EX | Normal | Normal | ||||||||||
| 16 | Proposed Temporary Rules |
Hello Jill,_x000D_ _x000D_ After several failed attempts to submit and online statement, I am turning to you for help in getting my comment published. Thank You for your assistance in this very important matter. See statement below._x000D_ _x000D_ The Oregon Department of Environmental Quality (DEQ) is proposing a set of sweeping “temporary” regulations that will severely curtail Bullseye Galss Company’s production, without clear supporting scientific evidence or an understanding of how they make their glass. The Oregon Health Authority (OHA) and the Multnomah County Health Department have stated that there is no immediate health risk to our community. Nevertheless, DEQ is strongly considering adoption of temporary rules that are technically flawed, discriminate against two small companies unfairly, won’t improve Portland’s air quality, and aren’t necessary in the absence of acute health risks. Bullseye supports new regulations to improve air quality, but the temporary rules will not achieve that goal._x000D_ _x000D_ The DEQ’s latest statement is “Elevated and possibly unsafe levels of metals have been found in the air around two glass manufacturing facilities in Portland. Further study indicated these businesses were likely the source of metals air emissions._x000D_ _x000D_ Yet recent OHA studies found that there was no increased cancer risk in SE Portland attributed to Bullseye’s use of these materials. As the OHA states on its website, “it is unlikely that the level of metals detected in the air would cause any immediate health problems for people.”[1] OHA also concluded that current data shows “long-term health risks are relatively low.”[2]_x000D_ _x000D_ Further, DEQ found no health concerns due to cadmium, arsenic, total chromium or hexavalent chromium in the soil around Bullseye’s factory. Soil samples showed soil levels were generally below naturally occurring or “background” levels of heavy metals. Keith Johnson, manager for the DEQ’s Northwest Region Cleanup Program, stated, “[o]ngoing emissions from the Bullseye facility are not resulting in harmful impacts to soils around the facility.”[3]_x000D_ _x000D_ DEQ’s and OHA’s own statements provide that the rule is not needed to prevent “serious prejudice to the public interest.”_x000D_ _x000D_ I have worked with Bullseye Glass for over 30 years and there is no doubt in my mind that Bullseye understands the public interest and supports stronger environmental standards for our industry. To that effect, the company has already begun the process of installing 99% efficient baghouses on furnaces that melt glasses with chromium. Bullseye Glass and DEQ will test these filtration devices to make certain they operate correctly._x000D_ _x000D_ Instead of a hasty and discriminatory temporary rule, DEQ should focus on permanent rules, based on scientific investigation and a thoughtful process to address Portland’s air quality issues. Bullseye will support that effort. These rules should give clear directions to businesses and support the safety of the community. New regulations should cover all businesses, not just target minor specific industries._x000D_ _x000D_ With minor changes to correct scientific errors and omissions in the currently proposed rule, Bullseye Glass is willing to sign an agreement that achieves all of DEQ’s goals and allows DEQ and Bullseye to respond promptly to new factual information._x000D_ _x000D_ The haste to adopt technically flawed temporary rules makes it appear that Oregon is repressive to manufacturing businesses and does not care about jobs._x000D_ _x000D_ Oregon agencies should strive for proper and fair treatment of all parties, based on law, rather than responding to public concern resulting from sensational blog posts and test results with partial data and no peer review._x000D_ _x000D_ The health and safety of the community can be achieved without forcing these businesses to close._x000D_ _x000D_ These unthought out temporary rules that you are proposing for EQC adoption are a prime example of improper use of temporary rule making. The Oregon Environmental Quality Commission should only consider a temporary rule when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.” This is not the case here._x000D_ _x000D_ Hastily adopting temporary rules make it appear that agencies are being proactive, but these rules do not protect the public, and makes Bullseye a scapegoat. There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor that Bullseye’s 42 years of operation have resulted in areas of health concerns in the vicinity of the facility._x000D_ _x000D_ If the EQC were to implement this temporary rule, numerous significant sources of toxic air pollution will remain from many unregulated businesses. Thus, the temporary rule would not effectively protect the public._x000D_ _x000D_ These newly proposed regulations are based on politics and fear, not science and fact. They come right after DEQ’s executive director was forced to resign and the supervisor of the air quality department left the agency. _x000D_ _x000D_ If Bullseye is not allowed to use Cr (III), they can no longer make green glass. On top of their voluntary suspension of cadmium glass production until their baghouse is in place, this new limitation would eliminate 50% of their product line. It would result in employee layoffs, huge economic impacts to Bullseye and their worldwide customers, and could even drive them and tens of thousands of glass artists around the world of business. I myself could be one of them!_x000D_ _x000D_ If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. They have stated that they support an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information._x000D_ _x000D_ Bullseye Glass Co. has a payroll of $7.5 million dollars. 130 Portland families and 20 other Bullseye families depend on Bullseye for jobs. Hundreds of Oregon artists and craftspeople depend upon Bullseye products. Tens of thousands of artists across the United States and the world depend upon Bullseye products._x000D_ _x000D_ Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. _x000D_ _x000D_ Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye’s furnaces do not produce toxic chromium. I urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules._x000D_ _x000D_ _x000D_ _x000D_ Marily Badger_x000D_ _x000D_ Tropical Fusion Art Glass_x000D_ www.tropical-fusion-artglass.com <http://www.tropical-fusion-artglass.com/> _x000D_ _x000D_ _x000D_ <https://squareup.com/market/tropical-fusion-artglass> https://squareup.com/market/tropical-fusion-artglass_x000D_ _x000D_ |
Marily Badger | glasartist@gmail.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 17 | Temporary Rule Colored Art Glass Manufacturing |
Hello Jill,_x000D_ _x000D_ I tried to submit online but not sure if the comments made it through when I pushed the submit button_x000D_ _x000D_ _x000D_ Thank you for the opportunity to review and very briefly comment on the proposed temporary rule for colored art glass manufacturing facilities. _x000D_ _x000D_ Background. The release of toxic air pollutants is a widespread issue that has been under-addressed in some states. The National Emissions Standards for Hazardous Pollutants (NESHAPs) primarily address larger (major) sources. But not unlike criteria pollutant programs that simply target major sources, there remains an important gap that fails to protect human health and the environment from the impacts of the myriad of smaller sources. These sources, singularly and collectively, have the potential to adversely affect not only the local community but also more distant locations through environmental transport and deposition of toxic and criteria pollutants._x000D_ _x000D_ Current Situation. The Oregon Ambient Benchmarks for Air Toxics establish protective goals but it is not clear how and when these goals are translated into meaningful and enforceable protective measures. It is my observation that identification of the two small Colored Art Glass Manufacturing (CAGM) facilities in Portland as sources of heavy metal contaminants in their respective neighborhoods is not a unique situation. Many types of smaller sources of toxic air contaminants from currently unregulated industries, businesses, agricultural operations, and transportation exist that have the potential to adversely impact communities and residents across the state. Having to take each of these on individually is neither efficient nor protective. While many toxics programs focus on immediate needs, the potential for buildup of pollutants, especially heavy metals and other persistent toxics substances, is great both within the facility boundaries and in the surrounding environment. _x000D_ _x000D_ Recommendations. While I wholeheartedly agree with taking short-term temporary measures to protect the CAGM affected neighborhoods, it is my request that DEQ develop and implement a broader program for controlling releases from non-NESHAPs regulated sources of toxic air pollutants. There are a number of really good state programs across the country to draw on and simplify the process. In addition, the great work that has already begun on Ambient Benchmarks provides a good starting point. I, therefore, provisionally support a temporary rule with the caveat that it be tied to a high-priority, broader, definitive, and permanent toxic air pollutant rule for all sources of inorganic and organic airborne contaminants with a real potential to affect human health._x000D_ _x000D_ Respectfully,_x000D_ Marjorie MartzEmerson_x000D_ Joseph, Oregon_x000D_ _x000D_ _x000D_ _x000D_ |
marjorie | kaytehunt@gmail.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 18 | Re: Help! Unable to submit my comments on Air Toxics Temporary Rulemaking |
You made my day, thank you_x000D_ _x000D_ Sent from my iPhone_x000D_ _x000D_ On Mar 30, 2016, at 12:21 PM, INAHARA Jill <INAHARA.Jill@deq.state.or.us <mailto:INAHARA.Jill@deq.state.or.us> > wrote:_x000D_ _x000D_ _x000D_ _x000D_ Hi Michael,_x000D_ _x000D_ _x000D_ _x000D_ Sorry for the problems submitting comments online! I’ve got your comments and will enter them into the record._x000D_ _x000D_ _x000D_ _x000D_ Thanks for taking the time to comment,_x000D_ _x000D_ Jill_x000D_ _x000D_ _x000D_ _x000D_ From: Michael Aiello [mailto:redbarn.studio@live.com] _x000D_ Sent: Wednesday, March 30, 2016 11:43 AM_x000D_ To: INAHARA Jill_x000D_ Subject: Help! Unable to submit my comments on Air Toxics Temporary Rulemaking_x000D_ _x000D_ _x000D_ _x000D_ Hello Jill Inahara, thank you for receiving my comments through your email ._x000D_ _x000D_ I have attempted for days to submit online and have been unable to with the system reporting an error. I was given your email as a back up for submitting my comments. PLEASE, see to it that my comment is properly received and included. PLEASE contact me to confirm that my comments have been received. Thank you. Michael Aiello 503.929.3095_x000D_ _x000D_ My Comments:_x000D_ _x000D_ I live .4 miles from Bullseye Glass with my wife and my 6 year old daughter for the last 9 years. I work from home. so I am always being exposed to Bullseye's reckless practice of completely unfiltered carcinogenic heavy metals polluting. I am asking that the DEQ adopt the temporary rules that prohibit the uncontrolled emissions of HAPs from glassmaking facilities, Since moving into the neighborhood, we have developed the following symptoms, asthmatic episodes, hyper pigmentation, peripheral neuropathy, skin sensitivities, urinary and bladder conditions, demineralization and bone loss, as well as a heart murmur. All of these symptoms have been identified as being signatures of heavy metal exposure according to our physicians and the NHANES national toxicological report. I have 2 neighbors who have battled non genetic cancer and a third neighbor who ha 3 autoimmune diseases. The only difference between them asn us it that they have lived her throughout the duration of Bullseye's 42 years of unfiltered, unregulated carcinogenic pollution fallout._x000D_ _x000D_ I believe it to be criminal that Bullseye was alerted to regulations in2007 by the DEQ and then both parties worked together to craft exemptions from these regulations. It is not ethical that Bullseye and other small manufacturers should continue to be allowed to emit dozens of heavy metals and carcinogenic HAPs out of their furnaces, completely unfiltered. In is grossly unfair that our family now must pay out of pocket about $650 for extensive urine toxic tests which specialist recommend and that testing our soil will also cost us hundreds of dollars. Our family alone will spend about $1000 before any treatment plans! This expense ought to be Bullseye's expense on proper filtration. _x000D_ _x000D_ The public has lost trust in Bullseye, the DEQ and the EPA and we continue to pay the cost financially and to our health. Now is the time to usher in a new era of regulations which reflect a health based approach that places the public's wellbeing above the expedience and interests of any business. Clean, well regulated businesses ought to be encouraged in Oregon instead of enabling harmful polluters. The technologies exist for current polluters like Bullseye to transition towards environmentally considerate and socially responsible business models that all Oregonians can champion. It is the DEQ's job to demand this industry culture transformation through stricter regulations. This emphasis on clean air water and land is the only viable path towards sustainability; it must be championed to ensure wellbeing for all Oregonians. It is not 1970; it is 2016! The synergistic effects of population explosion, poor statewide diesel regulations an unfettered industry are rapidly taking their toll on the state and the health of it's citizens. It is appalling to think that Portland has some of the worst air quality in the nation!!?_x000D_ _x000D_ Bullseye must be mandated to install state of the art bag house filtration systems on ALL of their furnaces. Mandatory modern emissions equipment must be implemented and there should be mo allowances made through a technology-based approach in these temporary rules for facilities to emit chromium VI or any other HAPS such as cadmium, arsenic, nickel, lead, cobalt, uranium etc. from an uncontrolled furnace. The DEQ should honor these objectives from the temporary rule: To protect human health from emissions of metals from glassmaking facilities until a permanent rule can be put into place; to ensure effective public participation, transparency and accountability in any DEQ decisions that authorize emissions from regulated facilities and to ensure equal protection for all communities regardless of race, ethnicity and economic class._x000D_ _x000D_ The temporary rules should pave the way for permanent health based regulations which feature ongoing monitoring of businesses which use toxic materials and public transparency about those HAPs. The temporary rules ought to apply statewide and there should be no allowance for uncontrolled heavy metals emissions in other areas of the state. The temporary regulations ought to apply to all other glass manufacturers. The DEQ must look at the identified hotspot in the Cully neighborhood as well.through it's obligations under HB 420, Oregon's EJ Law, Tile VI of the Civil Rights Act. Both the temporary rules and the permanent rules must apply to the full suite of heavy metals utilized by the source category. _x000D_ _x000D_ The permanent rules must carry forward these technological standards and must also provide for the possibility of additional operating restrictions in the event that emissions continue to threaten public health. The rules must allow for adequate public participation and prohibit emissions of heavy metals from the source until the source obtains COMPLETE FILTRATION. The permit applications ought to include information on the proposed manufacturing processes, including identification of raw materials ant the rates at which they are used, emissions control equipment , source test plan, and air modeling information. The public should have a full and fair opportunity to review that information and to provide comments on the draft permit. Only then should the DEQ issue the permit, thereby authorizing emissions of heavy metals._x000D_ _x000D_ Emissions control equipment should include leak detection and automatic shut off controls. Source testing should be completed before standard operations commence and all source testing should be completed under 'representative operating conditions'. Record keeeping restrictions must apply. The DEQ must consider the synergistic effect of multiple heavy metal exposure on the most vulnerable in society from any continuous source such as Bullseye Glass._x000D_ _x000D_ Clean air ought not to be negotiable behind closed doors and at the price of a poorly regulated permit. Do the right thing and it will ultimately benefit not only the public, but also the success and longevity of businesses like Bullseye. _x000D_ _x000D_ Thank You, Michael Aiello_x000D_ _x000D_ |
Michael Aiello | redbarn.studio@live.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 19 | Help! Unable to submit my comments on Air Toxics Temporary Rulemaking |
Hello Jill Inahara, thank you for receiving my comments through
your email ._x000D_ _x000D_ I have attempted for days to submit online and have been unable to with the system reporting an error. I was given your email as a back up for submitting my comments. PLEASE, see to it that my comment is properly received and included. PLEASE contact me to confirm that my comments have been received. Thank you. Michael Aiello 503.929.3095_x000D_ _x000D_ My Comments:_x000D_ _x000D_ I live .4 miles from Bullseye Glass with my wife and my 6 year old daughter for the last 9 years. I work from home. so I am always being exposed to Bullseye's reckless practice of completely unfiltered carcinogenic heavy metals polluting. I am asking that the DEQ adopt the temporary rules that prohibit the uncontrolled emissions of HAPs from glassmaking facilities, Since moving into the neighborhood, we have developed the following symptoms, asthmatic episodes, hyper pigmentation, peripheral neuropathy, skin sensitivities, urinary and bladder conditions, demineralization and bone loss, as well as a heart murmur. All of these symptoms have been identified as being signatures of heavy metal exposure according to our physicians and the NHANES national toxicological report. I have 2 neighbors who have battled non genetic cancer and a third neighbor who ha 3 autoimmune diseases. The only difference between them asn us it that they have lived her throughout the duration of Bullseye's 42 years of unfiltered, unregulated carcinogenic pollution fallout._x000D_ _x000D_ I believe it to be criminal that Bullseye was alerted to regulations in2007 by the DEQ and then both parties worked together to craft exemptions from these regulations. It is not ethical that Bullseye and other small manufacturers should continue to be allowed to emit dozens of heavy metals and carcinogenic HAPs out of their furnaces, completely unfiltered. In is grossly unfair that our family now must pay out of pocket about $650 for extensive urine toxic tests which specialist recommend and that testing our soil will also cost us hundreds of dollars. Our family alone will spend about $1000 before any treatment plans! This expense ought to be Bullseye's expense on proper filtration. _x000D_ _x000D_ The public has lost trust in Bullseye, the DEQ and the EPA and we continue to pay the cost financially and to our health. Now is the time to usher in a new era of regulations which reflect a health based approach that places the public's wellbeing above the expedience and interests of any business. Clean, well regulated businesses ought to be encouraged in Oregon instead of enabling harmful polluters. The technologies exist for current polluters like Bullseye to transition towards environmentally considerate and socially responsible business models that all Oregonians can champion. It is the DEQ's job to demand this industry culture transformation through stricter regulations. This emphasis on clean air water and land is the only viable path towards sustainability; it must be championed to ensure wellbeing for all Oregonians. It is not 1970; it is 2016! The synergistic effects of population explosion, poor statewide diesel regulations an unfettered industry are rapidly taking their toll on the state and the health of it's citizens. It is appalling to think that Portland has some of the worst air quality in the nation!!?_x000D_ _x000D_ Bullseye must be mandated to install state of the art bag house filtration systems on ALL of their furnaces. Mandatory modern emissions equipment must be implemented and there should be mo allowances made through a technology-based approach in these temporary rules for facilities to emit chromium VI or any other HAPS such as cadmium, arsenic, nickel, lead, cobalt, uranium etc. from an uncontrolled furnace. The DEQ should honor these objectives from the temporary rule: To protect human health from emissions of metals from glassmaking facilities until a permanent rule can be put into place; to ensure effective public participation, transparency and accountability in any DEQ decisions that authorize emissions from regulated facilities and to ensure equal protection for all communities regardless of race, ethnicity and economic class._x000D_ _x000D_ The temporary rules should pave the way for permanent health based regulations which feature ongoing monitoring of businesses which use toxic materials and public transparency about those HAPs. The temporary rules ought to apply statewide and there should be no allowance for uncontrolled heavy metals emissions in other areas of the state. The temporary regulations ought to apply to all other glass manufacturers. The DEQ must look at the identified hotspot in the Cully neighborhood as well.through it's obligations under HB 420, Oregon's EJ Law, Tile VI of the Civil Rights Act. Both the temporary rules and the permanent rules must apply to the full suite of heavy metals utilized by the source category. _x000D_ _x000D_ The permanent rules must carry forward these technological standards and must also provide for the possibility of additional operating restrictions in the event that emissions continue to threaten public health. The rules must allow for adequate public participation and prohibit emissions of heavy metals from the source until the source obtains COMPLETE FILTRATION. The permit applications ought to include information on the proposed manufacturing processes, including identification of raw materials ant the rates at which they are used, emissions control equipment , source test plan, and air modeling information. The public should have a full and fair opportunity to review that information and to provide comments on the draft permit. Only then should the DEQ issue the permit, thereby authorizing emissions of heavy metals._x000D_ _x000D_ Emissions control equipment should include leak detection and automatic shut off controls. Source testing should be completed before standard operations commence and all source testing should be completed under 'representative operating conditions'. Record keeeping restrictions must apply. The DEQ must consider the synergistic effect of multiple heavy metal exposure on the most vulnerable in society from any continuous source such as Bullseye Glass._x000D_ _x000D_ Clean air ought not to be negotiable behind closed doors and at the price of a poorly regulated permit. Do the right thing and it will ultimately benefit not only the public, but also the success and longevity of businesses like Bullseye. _x000D_ _x000D_ Thank You, Michael Aiello_x000D_ _x000D_ |
Michael Aiello | redbarn.studio@live.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 20 | RE: Testimony on Proposed Colored Glass Temporary Rule |
Thank you. I have submitted the testimony_x000D_ _x000D_ _x000D_ _x000D_ Robert Le Chevallier _x000D_ _x000D_ Attorney, Shareholder_x000D_ _x000D_ _x000D_ _x000D_ <http://www.buckley-law.com/> _x000D_ t 503.620.8900 | f 503.620.4878_x000D_ _x000D_ 5300 Meadows Road, Suite 200 | Lake Oswego, OR 97035_x000D_ _x000D_ rlc@buckley-law.com <mailto:rlc@buckley-law.com> _x000D_ _x000D_ web: <http://www.buckley-law.com/> www.buckley-law.com_x000D_ _x000D_ Attorney-Client Privilege This e-mail message, including any attachments, may contain attorney privileged and/or confidential information. The review, disclosure, distribution, or copying of this message by or to anyone other than the named addressee(s) is strictly prohibited. If you have received this message in error, please immediately notify me by reply e-mail and destroy the original and all copies of the message. _x000D_ _x000D_ _x000D_ _x000D_ From: INAHARA Jill [mailto:INAHARA.Jill@deq.state.or.us] _x000D_ Sent: Friday, March 18, 2016 11:08 AM_x000D_ To: Rob LeChevallier_x000D_ Cc: abef@northstarglass.com_x000D_ Subject: RE: Testimony on Proposed Colored Glass Temporary Rule_x000D_ _x000D_ _x000D_ _x000D_ Hi Rob,_x000D_ _x000D_ _x000D_ _x000D_ Sorry to be so late in getting back to you! Can you please submit your comments <https://data.oregon.gov/dataset/Air-Toxics-2016-Temporary-Rulemaking/qgxk-k66w> here. That way they will be included with all the others and archived. That should also automatically put you on a list of people that are interested in this rulemaking so you’ll get updates. You can attach a file as part of your comments._x000D_ _x000D_ _x000D_ _x000D_ Thanks very much,_x000D_ _x000D_ Jill_x000D_ _x000D_ _x000D_ _x000D_ From: Rob LeChevallier [mailto:rlc@buckley-law.com] _x000D_ Sent: Tuesday, March 15, 2016 4:55 PM_x000D_ To: INAHARA Jill_x000D_ Cc: abef@northstarglass.com <mailto:abef@northstarglass.com> _x000D_ Subject: FW: Testimony on Proposed Colored Glass Temporary Rule_x000D_ _x000D_ _x000D_ _x000D_ Jill: I am resending with the correct email address._x000D_ _x000D_ From: Rob LeChevallier _x000D_ Sent: Tuesday, March 15, 2016 4:52 PM_x000D_ To: 'SWAB.Christopher@deq.state.or.us'_x000D_ Cc: 'INHARA.Jill@deq.state.or.us'; 'DAVIS.George@deq.state.or.us'; 'abef@northstarglass.com'_x000D_ Subject: Testimony on Proposed Colored Glass Temporary Rule_x000D_ _x000D_ _x000D_ _x000D_ Please find attached my client Northstar Glassworks, Inc’s testimony by Abe Fleishman, president on the proposed temporary rule for the manufacture of colored glass. Please include me on your contact list as their attorney for any revisions or comments on the proposed rule._x000D_ _x000D_ _x000D_ _x000D_ Sincerely,_x000D_ _x000D_ _x000D_ _x000D_ Rob LeChevallier_x000D_ _x000D_ _x000D_ _x000D_ Robert Le Chevallier _x000D_ _x000D_ Attorney, Shareholder_x000D_ _x000D_ _x000D_ _x000D_ <http://www.buckley-law.com/> _x000D_ t 503.620.8900 | f 503.620.4878_x000D_ _x000D_ 5300 Meadows Road, Suite 200 | Lake Oswego, OR 97035_x000D_ _x000D_ rlc@buckley-law.com <mailto:rlc@buckley-law.com> _x000D_ _x000D_ web: <http://www.buckley-law.com/> www.buckley-law.com_x000D_ _x000D_ Attorney-Client Privilege This e-mail message, including any attachments, may contain attorney privileged and/or confidential information. The review, disclosure, distribution, or copying of this message by or to anyone other than the named addressee(s) is strictly prohibited. If you have received this message in error, please immediately notify me by reply e-mail and destroy the original and all copies of the message. _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ |
Rob LeChevallier | rlc@buckley-law.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | abef@northstarglass.com | abef@northstarglass.com | SMTP | Normal | Normal | |||||||
| 21 | Re: Comment on Glass Making Temp Ruling |
Thank you Jill. I'm sure you have your hands full so I appreciate
you getting back to me._x000D_ _x000D_ Best,_x000D_ Shawn_x000D_ _x000D_ On Wednesday, March 30, 2016, INAHARA Jill <INAHARA.Jill@deq.state.or.us <mailto:INAHARA.Jill@deq.state.or.us> > wrote:_x000D_ _x000D_ _x000D_ Hi Shawn,_x000D_ _x000D_ _x000D_ _x000D_ Sorry for the problems submitting comments online! I’ve got your comments and will enter them into the record._x000D_ _x000D_ _x000D_ _x000D_ Thanks for taking the time to comment,_x000D_ _x000D_ Jill_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ From: Shawn Ingersoll [mailto:shawnwingersoll@gmail.com <javascript:_e(%7B%7D,'cvml','shawnwingersoll@gmail.com');> ] _x000D_ Sent: Wednesday, March 30, 2016 2:44 PM_x000D_ To: INAHARA Jill_x000D_ Subject: Comment on Glass Making Temp Ruling_x000D_ _x000D_ _x000D_ _x000D_ Got an error when I tried to submit my comment and could not find it at the last page (or the few in front). Would like for this to be added._x000D_ _x000D_ _x000D_ _x000D_ Thank you_x000D_ _x000D_ _x000D_ _x000D_ "I am a father of a boy who was at the daycare less than a 1/6 mile from Bullseye (where 100's of other children have/do attend, all breathing the same air). He has elevated cadmium levels (2.5x that of 6-11 yo). How this will impact his future is unknown and terrifying. He is only 4. His cancer risk is increased due to this exposure, let alone countless other diseases (kidney function, respiratory, neurological) and potential lifelong impacts that may take decades to surface as a result. I hold Bullseye and DEQ directly responsible for that exposure. We will unfortunately never know what his Arsenic or Chromium exposure was. We will forever wonder if any abnormal illnesses/diseases that arise or difficulties he faces in regards to his health resulted from Bullseyes glass making and environmental negligence. _x000D_ _x000D_ _x000D_ _x000D_ I'd like it noted how heavily Bullseye is pushing their customers/glass artists, including many outside Portland and Oregon, to weigh in on the temporary ruling. There have even been sponsored Facebook ads by Bullseye promoting comments on this ruling. Many unaware of how big of an issue this really is, especially due to the continually downplaying of exposure. 2 people with concerning levels of Cadmium seems grossly inaccurate considering my sons levels._x000D_ _x000D_ _x000D_ _x000D_ Please keep in mind that the majority of pro-glass/anti-pollution control posts are from these likely contributors. It is important that our future health/environment not be undermined by those merely concerned with glass availability or pollution control costs businesses will face. Health before profits. Make it so that it is more fiscally sensible to implement pollution control than to pollute unabated. This is the cost of doing business. We've done it before with industries, and we need to do it again. Have fines/penalties/closure notices incorporated into this ruling. So important! Otherwise whats the point. Expand this ruling beyond the simple few metals that have been included. Provide language that allows the addition of new metals/toxic material down the road. Require glass companies to list the material they use in their glass annually. Make it public. This is also just the beginning, as this goes so far beyond just glass. Dirty diesel, wood stoves, metal plating, PCC, McClure, schools next to freeways. DEQ has a lot to do, especially for those at risk._x000D_ _x000D_ _x000D_ _x000D_ There has been mention that Chromium 3 does not turn into Chromium 6 in a glass making environment. Maybe that is so, but we better be absolutely sure that is indeed the case before allowing glass makers to use this material again if it is allowed to leech into the air, water, or soil. We can not rely on a single individuals opinion no matter their experience. Doing so would be highly irresponsible._x000D_ _x000D_ _x000D_ _x000D_ We need to be a society that puts health over profits. There will be comments claiming how businesses will not be able to afford controlling the pollution they emit/potential job loss. These are tactics. Oregon can be a place for clean businesses. Polluters need to be responsible for the cost (health, environmental, and economic) that they force on their neighborhoods. There is no reason why they should not be responsible._x000D_ _x000D_ _x000D_ _x000D_ For every comment you receive from a concerned citizen advocating for these rules and/or expanding upon them, there are more likely hundreds of others that will not be able to share their voice. Many do not have the luxury of time, awareness, information access etc. Please do not let out of state customers of Bullseye drown out the voice of citizens who now face decades of unknown related to the exposure Bullseye has put us through._x000D_ _x000D_ _x000D_ _x000D_ Polluters claiming unawareness is negligence. Negligence is unacceptable. Businesses have a duty to ensure that what they do will not negatively impact the health and well being of those around them._x000D_ _x000D_ _x000D_ _x000D_ DEQ is not be in the business of economic development nor should industry be the hand of DEQ as they write regulation. Pollution control costs is not DEQ's concern. DEQ is environmental quality, and ensuring it does not put citizens, the environment, and the economy at risk. I have seen the community do much more than DEQ these past months. Do what your agency was created for. Protect us and implement the Precautionary Principle moving forward._x000D_ _x000D_ _x000D_ _x000D_ Thank you,_x000D_ _x000D_ Shawn"_x000D_ _x000D_ _x000D_ _x000D_ -- _x000D_ _x000D_ _x000D_ _x000D_ Shawn Ingersoll_x000D_ Phone: (503) 347-6594_x000D_ Email: shawnwingersoll@gmail.com <mailto:shawnwingersoll@gmail.com> _x000D_ Web: shawningersoll.com <http://shawningersoll.com/> & shawningersoll.com/studio <http://shawningersoll.com/studio> _x000D_ Add Me on LinkedIn: linkedin.com/in/shawningersoll <http://linkedin.com/in/shawningersoll> _x000D_ _x000D_ |
Shawn Ingersoll | shawnwingersoll@gmail.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 22 | Re: Comment on Glass Making Temp Ruling |
Hi Jill,_x000D_ _x000D_ Just wanted to follow up as I know the 5pm deadline is near. I was provided your email in regards to issues with submitting public comment on the Glass Making Temporary Rules. If you could let me know that you received the previous email and that it will be included, I would greatly appreciate it._x000D_ _x000D_ Thank you,_x000D_ Shawn_x000D_ _x000D_ _x000D_ _x000D_ Shawn Ingersoll_x000D_ Phone: (503) 347-6594_x000D_ Email: shawnwingersoll@gmail.com <mailto:shawnwingersoll@gmail.com> _x000D_ Web: shawningersoll.com <http://shawningersoll.com/> & shawningersoll.com/studio <http://shawningersoll.com/studio> _x000D_ Add Me on LinkedIn: linkedin.com/in/shawningersoll <http://linkedin.com/in/shawningersoll> _x000D_ _x000D_ On Wed, Mar 30, 2016 at 2:44 PM, Shawn Ingersoll <shawnwingersoll@gmail.com <mailto:shawnwingersoll@gmail.com> > wrote:_x000D_ _x000D_ _x000D_ Got an error when I tried to submit my comment and could not find it at the last page (or the few in front). Would like for this to be added._x000D_ _x000D_ Thank you_x000D_ _x000D_ "I am a father of a boy who was at the daycare less than a 1/6 mile from Bullseye (where 100's of other children have/do attend, all breathing the same air). He has elevated cadmium levels (2.5x that of 6-11 yo). How this will impact his future is unknown and terrifying. He is only 4. His cancer risk is increased due to this exposure, let alone countless other diseases (kidney function, respiratory, neurological) and potential lifelong impacts that may take decades to surface as a result. I hold Bullseye and DEQ directly responsible for that exposure. We will unfortunately never know what his Arsenic or Chromium exposure was. We will forever wonder if any abnormal illnesses/diseases that arise or difficulties he faces in regards to his health resulted from Bullseyes glass making and environmental negligence. _x000D_ _x000D_ I'd like it noted how heavily Bullseye is pushing their customers/glass artists, including many outside Portland and Oregon, to weigh in on the temporary ruling. There have even been sponsored Facebook ads by Bullseye promoting comments on this ruling. Many unaware of how big of an issue this really is, especially due to the continually downplaying of exposure. 2 people with concerning levels of Cadmium seems grossly inaccurate considering my sons levels._x000D_ _x000D_ Please keep in mind that the majority of pro-glass/anti-pollution control posts are from these likely contributors. It is important that our future health/environment not be undermined by those merely concerned with glass availability or pollution control costs businesses will face. Health before profits. Make it so that it is more fiscally sensible to implement pollution control than to pollute unabated. This is the cost of doing business. We've done it before with industries, and we need to do it again. Have fines/penalties/closure notices incorporated into this ruling. So important! Otherwise whats the point. Expand this ruling beyond the simple few metals that have been included. Provide language that allows the addition of new metals/toxic material down the road. Require glass companies to list the material they use in their glass annually. Make it public. This is also just the beginning, as this goes so far beyond just glass. Dirty diesel, wood stoves, metal plating, PCC, McClure, schools next to freeways. DEQ has a lot to do, especially for those at risk._x000D_ _x000D_ There has been mention that Chromium 3 does not turn into Chromium 6 in a glass making environment. Maybe that is so, but we better be absolutely sure that is indeed the case before allowing glass makers to use this material again if it is allowed to leech into the air, water, or soil. We can not rely on a single individuals opinion no matter their experience. Doing so would be highly irresponsible._x000D_ _x000D_ We need to be a society that puts health over profits. There will be comments claiming how businesses will not be able to afford controlling the pollution they emit/potential job loss. These are tactics. Oregon can be a place for clean businesses. Polluters need to be responsible for the cost (health, environmental, and economic) that they force on their neighborhoods. There is no reason why they should not be responsible._x000D_ _x000D_ For every comment you receive from a concerned citizen advocating for these rules and/or expanding upon them, there are more likely hundreds of others that will not be able to share their voice. Many do not have the luxury of time, awareness, information access etc. Please do not let out of state customers of Bullseye drown out the voice of citizens who now face decades of unknown related to the exposure Bullseye has put us through._x000D_ _x000D_ Polluters claiming unawareness is negligence. Negligence is unacceptable. Businesses have a duty to ensure that what they do will not negatively impact the health and well being of those around them._x000D_ _x000D_ DEQ is not be in the business of economic development nor should industry be the hand of DEQ as they write regulation. Pollution control costs is not DEQ's concern. DEQ is environmental quality, and ensuring it does not put citizens, the environment, and the economy at risk. I have seen the community do much more than DEQ these past months. Do what your agency was created for. Protect us and implement the Precautionary Principle moving forward._x000D_ _x000D_ Thank you,_x000D_ Shawn"_x000D_ _x000D_ _x000D_ |
Shawn Ingersoll | shawnwingersoll@gmail.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 23 | Comment on Glass Making Temp Ruling |
Got an error when I tried to submit my comment and could not find
it at the last page (or the few in front). Would like for this
to be added._x000D_ _x000D_ Thank you_x000D_ _x000D_ "I am a father of a boy who was at the daycare less than a 1/6 mile from Bullseye (where 100's of other children have/do attend, all breathing the same air). He has elevated cadmium levels (2.5x that of 6-11 yo). How this will impact his future is unknown and terrifying. He is only 4. His cancer risk is increased due to this exposure, let alone countless other diseases (kidney function, respiratory, neurological) and potential lifelong impacts that may take decades to surface as a result. I hold Bullseye and DEQ directly responsible for that exposure. We will unfortunately never know what his Arsenic or Chromium exposure was. We will forever wonder if any abnormal illnesses/diseases that arise or difficulties he faces in regards to his health resulted from Bullseyes glass making and environmental negligence. _x000D_ _x000D_ I'd like it noted how heavily Bullseye is pushing their customers/glass artists, including many outside Portland and Oregon, to weigh in on the temporary ruling. There have even been sponsored Facebook ads by Bullseye promoting comments on this ruling. Many unaware of how big of an issue this really is, especially due to the continually downplaying of exposure. 2 people with concerning levels of Cadmium seems grossly inaccurate considering my sons levels._x000D_ _x000D_ Please keep in mind that the majority of pro-glass/anti-pollution control posts are from these likely contributors. It is important that our future health/environment not be undermined by those merely concerned with glass availability or pollution control costs businesses will face. Health before profits. Make it so that it is more fiscally sensible to implement pollution control than to pollute unabated. This is the cost of doing business. We've done it before with industries, and we need to do it again. Have fines/penalties/closure notices incorporated into this ruling. So important! Otherwise whats the point. Expand this ruling beyond the simple few metals that have been included. Provide language that allows the addition of new metals/toxic material down the road. Require glass companies to list the material they use in their glass annually. Make it public. This is also just the beginning, as this goes so far beyond just glass. Dirty diesel, wood stoves, metal plating, PCC, McClure, schools next to freeways. DEQ has a lot to do, especially for those at risk._x000D_ _x000D_ There has been mention that Chromium 3 does not turn into Chromium 6 in a glass making environment. Maybe that is so, but we better be absolutely sure that is indeed the case before allowing glass makers to use this material again if it is allowed to leech into the air, water, or soil. We can not rely on a single individuals opinion no matter their experience. Doing so would be highly irresponsible._x000D_ _x000D_ We need to be a society that puts health over profits. There will be comments claiming how businesses will not be able to afford controlling the pollution they emit/potential job loss. These are tactics. Oregon can be a place for clean businesses. Polluters need to be responsible for the cost (health, environmental, and economic) that they force on their neighborhoods. There is no reason why they should not be responsible._x000D_ _x000D_ For every comment you receive from a concerned citizen advocating for these rules and/or expanding upon them, there are more likely hundreds of others that will not be able to share their voice. Many do not have the luxury of time, awareness, information access etc. Please do not let out of state customers of Bullseye drown out the voice of citizens who now face decades of unknown related to the exposure Bullseye has put us through._x000D_ _x000D_ Polluters claiming unawareness is negligence. Negligence is unacceptable. Businesses have a duty to ensure that what they do will not negatively impact the health and well being of those around them._x000D_ _x000D_ DEQ is not be in the business of economic development nor should industry be the hand of DEQ as they write regulation. Pollution control costs is not DEQ's concern. DEQ is environmental quality, and ensuring it does not put citizens, the environment, and the economy at risk. I have seen the community do much more than DEQ these past months. Do what your agency was created for. Protect us and implement the Precautionary Principle moving forward._x000D_ _x000D_ Thank you,_x000D_ Shawn"_x000D_ |
Shawn Ingersoll | shawnwingersoll@gmail.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||
| 24 | Re: Comments on Glass-Making Proposed Rules |
Jill, _x000D_ _x000D_ You and your colleagues are in a tough spot. I just read through the many, many comments on the DEQ website. They are predominantly comments from employees or customers who are parroting the Bullseye post in which Dr. LaCourse is cited for the proposition that trivalent chromium does not convert to hexavalent chromium in Bullseye's furnaces. At least one commenter besides me has noted that its what happens in the combustion gasses that is at issue (not in the glass melt). And as I point out in my written comments, the question is not whether Bullseye emits hexavalent chromium (and other toxic and carcinogenic metals) but at what rate._x000D_ _x000D_ I have spent the last week researching and thinking about these issues even though I am only "interested" as an impacted citizen of Portland. When I left the Texas Water Commission in September 1989 I had just testified in support of a proposed hazardous waste incinerator in Port Arthur, Texas (Chemical Waste Management). I had taken over for Joe Gingerich as permit writer when he left TWC to come to work for DEQ (he works on solid waste landfills for DEQ now). On my last day, the attorney who had represented the surrounding community found me standing at the elevator and said to me "Have you rubber stamped any more hazardous waste incinerators lately?" Without answering I got on the elevator and came to Oregon to go to law school. The sting of that comment has never gone away. As I have become more experienced I am more and more embarrassed at how unprepared I and my colleagues were during that initial period of HW facility permitting 1984-1989. Joe and I, and our fellow permit writers, were just out of university with our bachelors degrees in Mechanical and Chemical Engineering, and Geology. We were thrown on the front lines without any real support and we did our best. But we failed, by today's standards. So if I offended you this morning with my questions and criticisms please accept my apology. I don't know how much experience you have in this area but I have to believe that we all still have a steep learning curve ahead of us (even for me, 25 years into this.)_x000D_ _x000D_ Here is a copy of the written comments I just submitted. You please call me if you see anything I need to be corrected on._x000D_ _x000D_ _x000D_ Regards,_x000D_ TRB_x000D_ _x000D_ _x000D_ _x000D_ On Mar 28, 2016, at 5:28 PM, INAHARA Jill wrote:_x000D_ _x000D_ _x000D_ Hi Thomas,_x000D_ Thank you very much for this follow-up email along with the attachments you sent regarding the partitioning of heavy metals in a combustion chamber and the need for wet scrubbers to control volatilized metals. I have forwarded your emails on to the permit engineer who is reviewed the Notice of Intent to Construct for Bullseye. I’m not sure how much contact he has had with the company that is installing the baghouse. I apologize for not having enough time to talk with you this morning. I may be available to talk Tuesday afternoon so please call if you have further questions._x000D_ Thank you,_x000D_ Jill Inahara_x000D_ _x000D_ _x000D_ _x000D_ From: Thomas Benke [mailto:trbenke@environmental-compliance.com] _x000D_ Sent: Monday, March 28, 2016 10:48 AM_x000D_ To: INAHARA Jill_x000D_ Cc: PALERMO Jaclyn_x000D_ Subject: Comments on Glass-Making Proposed Rules_x000D_ _x000D_ Ms. Inahara,_x000D_ _x000D_ This is Thomas Benke. Thank you for taking a few minutes to talk to me this morning. I was disappointed that you could not make time to talk to me when I could be at my desk with my notes at hand (you called at 8:36 am) and that you could only talk to me for about 11 minutes. I was disappointed that you did not have the proposed rules at hand yourself when you called me. I was disappointed that you could not answer my question about the Department's objective in allowing the two "options" included in the rule. I was particularly disappointed to hear from you that the Department was relying solely on representations by the glass-making facilities that installation of an emissions control device designed to remove 99% of particulate would likely remove most of the heavy metals from the facility's glass-making furnaces. (I am paraphrasing here and I would appreciate being corrected as necessary.) I asked if you had called the manufacturer of the proposed device to confirm that representation and you responded that you had not, and did not indicate that you would. _x000D_ _x000D_ As I told you, I struggled with these same technical problems when I drafted Part B permits for commercial hazardous waste incinerators in 1989. The following year, as a result of what we had learned in Texas and other permitting states, the USEPA proposed new rules for Hazardous Waste incinerators. In its April 27, 1990 proposal (55 FR 17862, 17868) (attached) USEPA wrote:_x000D_ _x000D_ _x000D_ The existing regulations control metal and some organic emissions through the performance standard for particulates. Metals can be contained in particulates or condense out onto particulates and are then captured by air pollution control devices. The present particulate standard of 180 milligrams per dry standard cubic meter may not provide adequate protection if a substantial percentage of the particulate is composed of toxic metals. Further, in the case of volatile metals such as arsenic, mercury, and chlorides of lead and cadmium, the particulate standard may provide little control._x000D_ _x000D_ _x000D_ I urge you to study that rules proposal thoroughly. In the case of the Portland glass-making facilities, which use natural gas to fire the furnaces, I assume that there is little or no particulate matter, and so very little metal associated with particulate. In any event, the heavy metals that are emitted will be predominantly in the gaseous phase, volatilized, and so a standard that requires removal of particulate will do nothing to reduce emissions of toxic metals from Bullseye and Uroboros. I will send you in a following email two technical articles that support this contention. _x000D_ _x000D_ Putting a baghouse on the Bullseye and Uroboros stacks will do little or nothing to inhibit the discharge of toxic metals from the those facilities, so adoption of the proposed rule is tantamount to a declaration by the State that Bullseye and Uroboros can return to business as usual while the Department plays catchup with the science of combustion and adoption of new, efficacious rules. If the EQC adopts the proposed temporary rules then I anticipate that those rules will remain in effect for at least a year, and perhaps longer if the regulated facilities oppose new permanent rules that will undoubtedly require limits on how much heavy metal they can use in their formulations and that will require the facilities to install expensive wet scrubbers or other devices specifically designed to capture volatile metals._x000D_ _x000D_ I understand that the Department's lawyers and administrators may prefer a compromise with Bullseye and Uroboros rather than a fight over whether the Department's existing authority is sufficient to regulate emissions of toxic metals from those facilities. In my view, given the moss, air and soil samples available to date, DEQ has ample justification and authority to shut those facilities down unless and until they prove through actual testing and dispersion modeling that their operations are not causing, or substantially contributing to, nuisance conditions in the surrounding neighborhood. I urge the Department to rewrite the rules so that glass-makers are required to prove through stack testing and dispersion modeling that their operations are safe for the neighborhood before they are allowed to continue using toxic metals in their formulations._x000D_ _x000D_ I will be following up with more carefully written comments, but please consider this email as a formal submission of comments with regard to the proposed rulemaking._x000D_ _x000D_ TRB_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ |
Thomas Benke | trbenke@environmental-compliance.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal |
  |
|||||||||
| 25 | Technical documents re heavy metals emissions |
Jill,_x000D_ _x000D_ The attached technical documents are just "for example" regarding the partitioning of heavy metals in a combustion chamber and regarding the need for wet scrubbers to control volatilized metals._x000D_ _x000D_ TRB_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ |
Thomas Benke | trbenke@environmental-compliance.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal |
    |
|||||||||
| 26 | Comments on Glass-Making Proposed Rules |
Ms. Inahara, _x000D_ _x000D_ This is Thomas Benke. Thank you for taking a few minutes to talk to me this morning. I was disappointed that you could not make time to talk to me when I could be at my desk with my notes at hand (you called at 8:36 am) and that you could only talk to me for about 11 minutes. I was disappointed that you did not have the proposed rules at hand yourself when you called me. I was disappointed that you could not answer my question about the Department's objective in allowing the two "options" included in the rule. I was particularly disappointed to hear from you that the Department was relying solely on representations by the glass-making facilities that installation of an emissions control device designed to remove 99% of particulate would likely remove most of the heavy metals from the facility's glass-making furnaces. (I am paraphrasing here and I would appreciate being corrected as necessary.) I asked if you had called the manufacturer of the proposed device to confirm that representation and you responded that you had not, and did not indicate that you would. _x000D_ _x000D_ As I told you, I struggled with these same technical problems when I drafted Part B permits for commercial hazardous waste incinerators in 1989. The following year, as a result of what we had learned in Texas and other permitting states, the USEPA proposed new rules for Hazardous Waste incinerators. In its April 27, 1990 proposal (55 FR 17862, 17868) (attached) USEPA wrote:_x000D_ _x000D_ _x000D_ The existing regulations control metal and some organic emissions through the performance standard for particulates. Metals can be contained in particulates or condense out onto particulates and are then captured by air pollution control devices. The present particulate standard of 180 milligrams per dry standard cubic meter may not provide adequate protection if a substantial percentage of the particulate is composed of toxic metals. Further, in the case of volatile metals such as arsenic, mercury, and chlorides of lead and cadmium, the particulate standard may provide little control._x000D_ _x000D_ _x000D_ I urge you to study that rules proposal thoroughly. In the case of the Portland glass-making facilities, which use natural gas to fire the furnaces, I assume that there is little or no particulate matter, and so very little metal associated with particulate. In any event, the heavy metals that are emitted will be predominantly in the gaseous phase, volatilized, and so a standard that requires removal of particulate will do nothing to reduce emissions of toxic metals from Bullseye and Uroboros. I will send you in a following email two technical articles that support this contention. _x000D_ _x000D_ Putting a baghouse on the Bullseye and Uroboros stacks will do little or nothing to inhibit the discharge of toxic metals from the those facilities, so adoption of the proposed rule is tantamount to a declaration by the State that Bullseye and Uroboros can return to business as usual while the Department plays catchup with the science of combustion and adoption of new, efficacious rules. If the EQC adopts the proposed temporary rules then I anticipate that those rules will remain in effect for at least a year, and perhaps longer if the regulated facilities oppose new permanent rules that will undoubtedly require limits on how much heavy metal they can use in their formulations and that will require the facilities to install expensive wet scrubbers or other devices specifically designed to capture volatile metals._x000D_ _x000D_ I understand that the Department's lawyers and administrators may prefer a compromise with Bullseye and Uroboros rather than a fight over whether the Department's existing authority is sufficient to regulate emissions of toxic metals from those facilities. In my view, given the moss, air and soil samples available to date, DEQ has ample justification and authority to shut those facilities down unless and until they prove through actual testing and dispersion modeling that their operations are not causing, or substantially contributing to, nuisance conditions in the surrounding neighborhood. I urge the Department to rewrite the rules so that glass-makers are required to prove through stack testing and dispersion modeling that their operations are safe for the neighborhood before they are allowed to continue using toxic metals in their formulations._x000D_ _x000D_ I will be following up with more carefully written comments, but please consider this email as a formal submission of comments with regard to the proposed rulemaking._x000D_ _x000D_ TRB_x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ _x000D_ |
Thomas Benke | trbenke@environmental-compliance.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | PALERMO Jaclyn | /O=DEQ/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=PALERMO Jaclynef5 | EX | Normal | Normal |
  |
||||||
| 27 | Position on EPA ruling on glass manufacturers |
Jill,_x000D_ J Ring Glass Studio Inc. would like to voice its support of the position that Bullseye Glass Company, Uroboros Glass Company and the Stained Glass Association of America have taken in regards to the proposed temporary EPA rules which would stop production of 50% of the art glass colors available. These actions need to be based on science and proven fact._x000D_ I do believe that the proposed temporary EPA rules threaten the very existence of the supply of art glass used for the restoration and repair of tens of thousands of historic buildings, public as well as private. I believe this would be in violation of the U.S. National Preservation Act 1966. Under this law a Section 106 should be convened before any action can be taken._x000D_ _x000D_ Joseph W Ring_x000D_ _x000D_ President_x000D_ _x000D_ J. Ring Glass Studio Inc._x000D_ _x000D_ St. Paul, Minnesota_x000D_ _x000D_ |
vendor- J Ring Glass | vendor@jringglass.com | SMTP | INAHARA Jill | /O=DEQ/OU=DEQHQ/cn=Recipients/cn=jinahar | EX | Normal | Normal | ||||||||||