

Oregon Records Management Solution
Shawn Ingersoll comment 7-21-2016
Received an error message when trying to submit, my comment is below: - Health based regulation that incorporate the Precautionary Principle. - Clause to allow for the future addition of other materials from glass manufacturing if found to exceed either short and/or long term health standards for air shed quality. - Choose limits based on those most at risk, not normal average healthy adults (i.e., children, elders, and those with medical issues). Many of the facilities are near schools and parks, so there are large populations of children that cannot tolerate the same level of pollution as a full grown adult. - Assume the EPA view that all Cr III converts to Cr 6 in glass production. - Require filters that are rated to remove 99.9% of emissions. - Require all furnaces to have said filters if they use HAP. - Create facility limits, not furnace limits. If you limit based on furnaces, their is the likelihood that the accumulative pollution for all furnaces would be above health based standards. - Heavy fines for violations and a plan for repeat offenders. The ability to shut facility down if it poses an immediate risk to the public and environment. - Incorporate full health and environmental costs into account. Both long and short term. - Health before profits. The cost of pollution will always outweigh any benefits a facility brings to the economy. We can get new jobs, develop new ways to make glass, yet we can't prevent the damage that has already been done to our bodies. Damage that may take years to surface. - Ensure their coldshops (where they cut the glass) and resulting wastewater are safe. Incorporate direction/regulation/fines to ensure their coldshops do not result in environmental damage (i.e., fine glass particulates making their way into the water system). - Incorporate direction/regulation/fines related to the fine glass particulates that have the ability to become airborne, as well as the glass fragments that litter the perimeter of their facility (particularly near their scrap collection bins). - Incorporate an accumulative pollution approach to permitting (multiple industrial polluters in a small vicinity). There may be health based limits, but if two polluters are hitting both of their limits in a small geographical area, it will double the health/environmental impact of said pollutant and cause damage to people and the environment. In addition look at how pollution interacts, for example there was a study that showed higher rates of autism when a population was exposed to both styrene and chromium. - Do not delay implementation beyond the defined timeline. - Continue to involve the public in the process with transparent decision making and public input. - Continue to monitor the air quality near these facilities. Beyond just these rules: - A public notification system for the permitting process (new and renewals). DEQ has a responsibility to ensure homeowners, businesses, and schools are aware of the pollution that is being permitted in their area. Currently there is no system in place that provides transparent and easy to access information for the public. We have a right to know who permits what, and we have a right to as a community, refuse to allow a polluter into our neighborhoods if they cannot do business responsibly or if their business puts the public or environment at unnecessary risk. We need in-person mailers to all homes, businesses, and schools within a determined radius of the facility (i.e., a mile) with information on the permit, other polluters nearby (so we can have an understanding of the addition of pollution being made to the area). In addition, an accessible online mapping system that identifies all facilities, all hazardous materials used/on site, the health effects (long and short) on the specific materials, permitting allowances for their facility, when a permit ends/begins, and air/water/soil monitoring data etc. - DEQ needs to start collecting all info on all hazardous materials used on all sites, not just a lump sum of pollution. - DEQ needs to advocate for funding. Show the public why you need it and what it is for. The DEQ is severely underfunded. - DEQ should have informed the public of the high levels of cadmium when they first knew. DEQ needs to start notifying the public immediately to instances such as these. - DEQ needs source and ambient air monitoring. The ability for DEQ to do source testing needs to be included in all permits moving forward. - DEQ needs to do statewide moss sampling. - Realize that for all the out of state glass artists that Bullseye has recruited to contribute their comments, their numbers pale in comparison to the affected families around these facilities. Be aware that many working families that are impacted by this pollution do not have the luxury to comment on these rules; be it time, access to the internet, or even being aware of this issue. Our air, water, and soil is community based. We all need it to be clean and healthy for generations to come. A facility does not have the right to put others at risk simply by paying a small fee and all the while the public is none the wiser. Bullseye is the catalyst. It is my sincere hope that DEQ does not stop here because the public sure won't. Thank you, Shawn