Category Archives: Pollutants

Descriptions of toxins and pollutants.

CAAT Written Testimony on CAO Risk Hazard Assessments

Owens-Brockway, Portland, OR.

Updated July 2019, original April 14, 2019 

Cully Air Action Telemetry (CAAT)

Regarding Section 7.1.b of SB 1541 of CAO

Severe human health effects should comprise individual as well as additive effects.

‘Severe’ should be an indication that is a causative for any negative health effects

Since these toxins, many of which are synthetic and do not exist in the natural environment, affect the human system in negative ways, causing potentially permanent injury, they should all be considered severe. The bee sting analogy (OHA) does not really work for me. No one willingly seeks to be stung, even if bee venom is a non-synthetic irritant for which the majority of the population is only going to receive a minor irritation. The sting is still severe in its delivery, and of course one can literally be stung to death. Yellow jackets? Killer Bees? What about yellowish airstreams and killer polluters? Are both acute instances and chronic exposure ‘severe’? I think so. And who knows what the emissions are, at what levels and how concentrated, and any potential densities of exposure? Polluters are, after all, allowed to self-report emission inventories and releases. Are they always being honest? Ever hear of Sapa defrauding NASA for the last 20 years? 

Human sensitivity is not the same as acute physical injury. Severe should be construed as a causative for any negative health effects. In the same way, hydrogen fluoride may be a different hazard than selenium, and have a different TRV, but chronic exposure to selenium will have a severe effect on human system including vision loss, paralysis, cardiovascular, hepatic and renal effects.

The State must protect the health of the community. At least, that is what I say to myself each November when I pay my property taxes. And, when someone moves into a community, they may not even be aware that different emissions from polluting industries will have a severe effect on their health and the health of the wider community, or have the base knowledge that something is wrong with that smokestack across the street. The headaches and coughing, the kids nightmares and bloody noses, may not be severe in some peoples views, but over time….

So, Option 1, the choice that offers widest protection statute for the health and well-being of the local community, and the adjacent communities is the only choice.

And, industry should not be allowed to slow this process down. The people of Oregon have already decided they want to live in cleaner and healthier environment.

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Comments on the Draft Recommended Procedures for Conducting Toxic Air Containment Health Risk Assessments (TACHRA)

Overall, the TACHRA document provides a comprehensive and detailed framework for Oregon-based polluting industries to perform a series of tasks that will allow them to continue to pollute and endanger local residents and fauna, and poison flora, waterways, and land.

These areas of concern came up for me as I read though this document:

1: Allowing industries to self-assess with little or no oversight from DEQ, or any other State Agencies, is an open invitation for fraud, and for unscrupulous companies to provide skewed data.

2: Public involvement in both this process and the process of determining RAL’s and Adjusted RAL’s is virtually non-existent (post-SB 1541), and so removes the affected population from joining the debate to protect their own health, lands, and air.

3: Many determinative effects and resultative actions remain undefined or unclear, including what, if any, penalties exist for providing false data, for operating illegal un-permitted sites, and for polluters who repeatedly break the law and violate health standards.

4: Are any businesses or industries or other entities that release dangerous pollutants into the air exempt from RAL’s?

5: Why are so few actions and solutions being implemented to actually reduce health risks to the public?

If self-assessment by polluters remains the only reporting mechanism, Level Three and Four Risk Assessments should be required when community complaints reach a threshold of consistency over time and scope. For example, if DEQ or other State Agencies receive a set number of complaints over a six-month time period for a particular and unique nuisance, the local polluter must do a verifiable Level There or Level Four Risk Assessment within a reasonable period of time. Verification can be conducted by the State or an independent and reputable third-party. Because of the immediacy of complaints from the public, a venue for public input needs to be implemented so both the State and the polluter hear from the community on the effects of the pollution. The resolution of pollution problems must rely on public participation as much as, if not more than, industry self-assessment since the likelihood of under-reporting of toxin release by polluters is well established, historically and locally. In the case of invisible or unnoticeable toxins, local health effects should also be considered as a determinate factor in assessment using local epidemiological reporting by clinics, schools, and others. 

Again, the result of self-assessment leaves the pollution, and resultant health burden, on the public and is not a verifiable quantification of pollutant releases. To be equitable, the public must be made aware of, and be included in the process of determining, the dangers of living and raising children near polluting industries and businesses. 

Going through the TACHRA document:

In section 2.1, page three, paragraph five, regarding the final sentence: Are cancer burdens assumed, or are they statistical from OHA and other Agencies data, or other sources? If polluters are clustered together, as they are in the Cully neighborhood in Portland, statistical data from OHA, health providers, and schools would be more relevant than assumed cancer rates.

In Section 2.2.1, page five: For polluters within 2 km of a school, Level 3 or Level 4 Screening Risk Assessments should be mandated given the susceptibility of young people to pollution related chronic and other illnesses. In general, ELAF should be prioritized.

In Section 2.2.2, and in general: While Mutlipathway Factors already include agricultural land and bodies of water where fishing takes place, wetlands need to also be considered as they are incubator zones for many species, including endangered species. Given methane outgassing from wetlands, another method should be established for monitoring wetlands habitats, perhaps tissue sampling of indicator species.

Section 2.3: The Risk Assessment Process needs to be more community inclusive with the public more engaged. Perhaps a community complaint designation for the polluter of ‘high complaint level’ (many complaints) or ‘low complaint level’ (few or no complaints) for areas zoned for residential use in the vicinity of the polluter needs to be designed. The public should be informed of this ‘complaint level’ during the Risk Assessment Process.

Section 2.4.1: Under Modeling Protocol, page nine, bullet point one, include ‘sensitive wildlife areas.’

Section 3.1.1: Polluters estimating pollutant emission rates compounds the main problem with the Draft TACHRA regarding the dangers of industry self-assessment, as stated previously. Polluters have made a mockery of self-assessment and fostered corrupt practices at the State level, and this has all been well documented by media outlets, independent scholars, and environmental activists over decades of research and investigation. Allowing polluters to “assess toxic air contamination emission at the capacity to emit” (3.1.1, bullet point 2) just provides one more level of distortion for unscrupulous operators. A better way may exist in examining chemical intake manifests and determining where toxic compounds, and elements, go after being processed by the industry. For example, if a company is receiving 1000 .lbs of methyl chloride a mechanism should be created to account for the use, synthesis, and release of the dangerous chemical emissions or byproducts into the local environment. Needless to say, any hazardous residues must be disposed of properly. This is a more responsive methodology to local health concerns and contamination than relying on the ‘capacity to emit’ method. 

In terms of Adjusted Hazard Index RAL’s (page 14), public participation and community inclusion with EQC Advisory is crucial. Developmental effects from pollutants are recognized in the Draft TACRA but need to be prioritized, especially for mutagenic contaminants [e.g Cr(VI)]. There is a critical need for verifiable assessment and containment of mutagenic pollutants. Marginalized and other frontline communities deserve special protection, outreach, and inclusion given neonatal care concerns (access, affordability, education, language, etc.) Any development of higher index numbers should necessitate more robust pollution containment procedures. 

Section 3.2, page 16, paragraph two: Why does ‘Fugitive Emissions at Stage One’ not include on-site truck transportation emissions and spillage?

Section 3.3, page 17, paragraph three: Simple modeling for one hour extrapolated to a 24-hour emission footprint is an invitation to provide skewed data and perpetuate fraud. A more reasonable approach would include either Level 3/4 Screening Risk Assessment, or on-site 24-hour modeling for a multi-month long sampling period.

Section 3.4, page 17, paragraph seven: The public needs to be informed of, and invited to, any and all meetings between DEQ and the polluter.

Section 3.5: Title V facilities and industries that use or produce criteria pollutants, or highly toxic PBT’s, should be mandated to perform Level Four Screening Risk Assessments. PBT emitting, or production, facilities and industries should have mandated TBACT to eliminate or minimize toxin releases into the environment. Public notice and inclusion here are crucial. 

The State has spent considerable time and resources defining explicit Risk Action Levels. However, communities should not be forced to trade or relinquish their health safety, or the health safety of their animals, lands, agricultural products and consumable garden foods, or the health of local flora and fauna for any increased risk that comes from CAO Risk Action Level permitting. Unless enforcement of environmental quality regulations and clear consequences for pollution violations are codified within the TACHRA, including enforceable sanctions, mandatory retrofits and filtering using TBACT (e.g. thermal oxidizers, scrubbers, containment housing, and electrostatic filters), substantial monetary penalties, or shut-downs, then TACHRA will not be a sufficient protection for the people and environs of Oregon. As mentioned earlier, the States’ and Agencies reliance on unsubstantiated and unverifiable self-assessments from polluters may very well allow for a return to past practices where DEQ functioned more as a bystander, aware that something was going on with some toxic pollution release and contamination, but unable or unwilling to take any action, rather than a functioning regulatory agency charged with protecting the health of the people of Oregon, or the Oregon environment.

CAAT testifies on SB 792 (NW Metals)

NorthWest Metals, 7600 NE Killingsworth St Portland OR 97218

Senate Bill 792 was designed to address the NW Metals fire 2018. CAAT submitted this written testimony:

Written Comments to Oregon Legislative Assembly regarding

Senate Bill 792

March 12, 2019

The NW Metals catastrophic fire one year ago on March 12, 2018 caused physical and psychological harm, and property destruction, and led to a mandatory evacuation of residents in the Cully community. Hazardous wastes, from burning solid-waste stored haphazardly on-site, became airborne and settled over a wide area to the west of the facility, including public schools, community and individual local agricultural gardens, private yards, and public parks. Hazardous waste and fire extinguishing fluids from the site were not contained and most likely entered into the local watershed, already compromised by decades of under-regulated industrial contamination. 

The Cully community and the outlying environs have a number of unregulated solid waste storage facilities and auto-dismantlers, also known as ‘chop shops’. No one is sure of the actual number since it seems many of these polluters are not regulated. These unregulated polluters continue to negatively affect the health of the community and diminish property values. These unregulated polluters are also negatively affecting the health of local wildlife populations and continue to complicate the clean-up of existing polluted waterways, including the Columbia Slough watershed, by improperly storing and containing solid wastes and hazardous wastes, spills, catastrophic releases, and illegal dumping. 

As the community suffered through the NW Metals catastrophic fire and airborne toxic event, we turned for relief to Oregon DEQ and to our Oregon state legislators. We have asked state Agencies to regulate these facilities and perform investigatory actions, levy fines, and aggressively pursue polluters and shut them down if they refuse to implement protective practices to stop public exposure to hazardous wastes. We have asked legislators to impose conditions on the permitting of polluters to provide a buffer zone between them and community households. As a frontline community with many low-income neighbors, families with children, elderly residents on fixed incomes, first-time homeowners, new immigrant/refugee families, and a vibrant new housing development economy, the community expressed frustration with the existing state apparatus for protecting our health and well-being and expressed an alacrity for implementation of changes that would allow existing laws and regulations to be acted upon. We are, a year plus later, still waiting for state relief from these known dangers, created by under-regulated and unregulated solid-waste storage companies, auto-dismantlers, and chop shops. 

The Amendments to SB 792 begin to address some of these concerns but not to  address the existing problem. In other words, members of the community are well aware of the problems that exist and still await action from the State Agency’s to insure the health and well-being of local residents and the health of the local wildlife and ground water supplies. Furthermore, as environmental contamination and resultant health maladies become more evident, due to past regulatory and Agency failures, CAAT (Cully Air Action Telemetry) and CAN (Cully Association of Neighbors) encourage the state to revisit this piece of legislation and improve it to create an enforceable SB that serves the people and communities of Oregon, including protecting their health from existing and future toxic contamination, rather than create a ‘paper tiger’ that maintains the same levels of past inadequacy, or worse, that reflects the well-documented influence of industries financial contributions rather than the well-being of the people.

In regards to the particular language designations and constraints of SB 792 (2019) Amendments CAAT (Cully Air Action Telemetry), and CAN (Cully Association of Neighbors), urge legislators to correct the following, and to insert the additional items, described below:

Proposed Amendments to SB 792 requested by Representative KOTEK (v. 3.11.2019)

Section 1 (1) Line 7 Insert

…ORS 822.110, except for ORS 822.110 Section (2) (a) and (b),…

Section 1 (2) Line 13 Insert

…of Transportation, after public notice and consultation with community groups, tribal groups, and other affected parties. Public Notice will be financed in toto by company or individuals requesting site expansion.

Section 1 (d) Page 2, Line 15. Change 

(d) Maintains a current bond that meets the requirements under ORS 822.120. 

to

(d) Increase the current bond by amending ORS  822.120 written guarantee to $500,000.00

Section 1  New Item. Insert after (d) Page 2, Line 15.

(e) Maintain verifiable environmental liability insurance.

(d- The existing $500 ‘written guarantee’ is a joke, right? It has to be. It is merely a signal to polluters that it is cheaper to create toxic plumes and illegal solid-waste dumps, pay the fine, and walk away than be a responsible neighbor to local communities. Oregon DEQ has repeatedly stated to the community that they do not have the resources to do their job, so increasing the ‘written guarantee’ within OSR 822.120 becomes a priority, or,

e- Mandatory, verifiable environmental liability insurance needs to be codified within existing regulatory framework, just the same as any Oregon resident is required to have auto liability insurance if they choose to drive an automobile, because industry has proven over and over again that ‘gaming the system’ at taxpayers expense is an acceptable part of a business model in the State of Oregon. Prior incompetence by state Agencies has also allowed polluting industries to create and exploit loopholes, or flat-out ignore environmental responsibilities with little of no consequence.)

Section 4 New Item(s) (9) and (10) page 5 Line 11. Insert

(9) Either enter into a Prospective Purchaser Agreements (PPAs) with DEQ, publicly noticed to adjacent communities for public  comment before implementation, or, 

(10) Earmark not less than 5% of company’s total gross receipts to an Orphan Sites Account (OSA) Contaminated Site cleanup fund.

(These two items may be combined, but it is crucial that the State allows and directs Agency’s to create a framework for responsible practices for polluting industries, and to allow public participation in the design of PPA’s. The OSA, if it still exists in Oregon’s state framework, should be pre-loaded by polluting industries rather than rely on future taxpayer revenue. IF OSA has sunset, then a new Orphan Fund for solid-waste auto dismantles and storage facility needs to be created.)

Section 7 (h) (4) Page 6, Line 13. Change

Change “may” to “shall”

Please make these changes and alert CAAT, and the constituency that you have done so.

Cully Air Action Telemetry – CAAT (formerly Cully Air Action Team)

Cully Association of Neighbors – CAN

DEQ full spectrum air monitor up and running

Here is the DEQ factsheet on the Air Monitor. It is worth looking over. Thanks to Oregon DEQ for listening to the community.

DEQ has set up a full spectrum monitor between Thomas Cully Park and 205 freeway. This is good timing because Thomas Cully Park has it’s Grand Opening this Saturday, June 30th! The new park is a great accomplishment for the people of Cully who advocated for it for so long. We need to insure that the kids playing there, the families picnicking, the lovers strolling, and the flora and fauna have a healthy airshed to breathe in this new park.

The air monitor will record VOCs, as well as lead and PM.  Results should be available by the end of the year, if not sooner.

PSU Ambient Metal Study for Cully released

PSU  has released their study of ambient (airborne) metal pollutants in the Cully neighborhood from testing done last summer. The good news is that lead levels are low, as are cadmium and nickel.  There are elevated arsenic levels, but we have a good bit of native arsenic in our soil environment already.

Thank you to the neighbors who so graciously housed the monitoring equipment, the student scientists at PSU, Dr. Linda George, and Neighbors for Clean Air for making this happen.

To anyone who has lived in or visited the Cully neighborhood, the strange odors are still here: sulfur compounds and diesel PM and other fuel odors.

Next Wednesday, June 27, from 6-7 pm., we will be meeting to discuss how we want to work with DEQ regarding re-permiting the  pollution releases from Owens-Brockway.  Drop me a line if you want the meeting location.

Step-by-step, the air quality is improving, but we have a ways to go.  In the meantime, please look over the attached file.

CullyPSUReport

CAAT and OEC to monitor diesel Air Pollution Particulate Matter (PM) in Cully

There is a great deal of focus on Particulate Matter, or PM, these days. PM is a pollutant that comes primarily from soot and smoke. Diesel trucks and aircraft are major sources of PM pollutants. The Cully, Sumner and Parkrose neighborhoods are affected by heavy diesel truck traffic, PDX airport, the rail lines and the 205 freeway. In addition to industrial polluters, these sources contribute large amounts of oil and diesel PM pollution to our neighborhoods. Especially during a temperature inversion, these exhaust and soot fumes can create a dangerous local airborne stink event.

CAAT is teaming up with the Oregon Environmental Council-OEC, to create a monitoring project to determine diesel related PM pollution levels. This project will involve local community members taking measurements in the areas they frequent and walk through. It is an exciting opportunity to get involved and help the local airshed. If you want to participate in this study please contact us and attend our next meeting.

Tuesday, December 6, 2016 at 6:00 -7:00 pm
Villas de Mariposas Community Room,
5205 NE Killingsworth St., Portland, OR 97218

Particulate Matter is a pollutant where the size of the particle matters. This has to do with how our lungs function while breathing as absorbers of atmospheric oxygen. With smaller PM there is more penetration into sensitive lung tissue. But even the larger PMs can cause difficulties in our lungs, throats and nasal cavities. Premature mortality incidence is associated with this pollutant. Other PM-related health impacts include chronic bronchitis, non-fatal heart attacks, respiratory and cardiovascular illnesses. In the chart below you can see the how the sizes of PM are related along the top and bottom horizontals. Current areas of regulatory focus are on PM 2.5 (size in microns) and PM 10.

https://en.wikipedia.org/wiki/Particulates#/media/File:Airborne-particulate-size-chart.svg
https://en.wikipedia.org/wiki/Particulates#/media/File:Airborne-particulate-size-chart.svg

While there are many kinds of PM, the ones of most import for air pollution monitoring and remedy are Black Carbon PMs. CAAT, OEC, Oregon DEQ and OHC are all beginning to work together to address these issues and to increase protective Oregon state regulations on diesel trucks. Currently Oregon has relatively lax laws regulating diesel trucks, much more permissive of pollutant and PM release than neighboring states. Oregon is far behind both California and Washington state in terms of upgrading diesel engines to meet healthy standards. Large trucking companies have taken advantage of that by dumping their dirtiest trucks here in our state. We will be working together in 2017 to find ways to reduce diesel pollution where it matters most for our health and our community. If you would like to be a part of this discussion please contact us and come to our next few meetings.

Additional Resources:

>>> On-Road Measurement of Emissions from Heavy-Duty Diesel Trucks

>>> Oregon Environment Council Protecting Oregon from Dirty Diesel

>>> Physicians for Social Responsibility (PSR): Airborne Particulate Matter and Public Health

>>> Oregon DEQ: Particulate Matter

Monday Air Quality Update

The Cully Air Action Team has been extremely busy and involved in air quality issues over the past few months. This is the first weekly posting spree, split into several topic-based posts, serving to bring readers up to speed on CAAT’s activism and issues that exist with air quality in Cully, in addition to listing important upcoming meetings and events that people should attend. We all breathe air from the same airshed!

July saw the establishment of a weekly, 30-minute call-in conversation with representatives of the Department of Environmental Quality (DEQ), Oregon Health Authority (OHA), Multnomah County, to discuss the many air quality issues that affect us, in Cully: Heavy industry with little or no air filtration; several high-use transportation corridors; the Port of Portland; Forest Service moss results;  Air Quality informational meetings; specific polluters I will mention, below.

The United States Forest Service (USFS) moss samples indicated that Cully is the most polluted neighborhood in all of Portland. From this data, DEQ decided to establish two air monitors in Cully. One air monitor was located on 1 Sep at Parkrose Deliverance Tabernacle on NE 57th & Portland Highway, while the second is at a BES Pumping Station on about NE 62nd, north of Columbia Highway, placed 19 Sep. Both air monitors are functioning, with data collected daily by DEQ. To complement these monitors, a meteorological data station has been mounted atop Living Cully Plaza. On 1 Oct, DEQ will begin to analyze 30 days’ worth of data from the first monitor, in addition to corresponding meteorological data, and we are told to expect results sometime mid-Oct. These results will indicate what has been in the air for 30 days, but unfortunately will not pinpoint the source of the heavy metals. If the results show that there is a level of heavy metals that exceeds state health benchmarks, OHA will take some form of action to alert public.

As to why DEQ is spending so much time, effort and outreach on Cully:

  1. Cully is a historically underserved community, the largest and most diverse neighborhood in Portland. There are issues of environmental justice and unheard voices that need to be immediately addressed.
  2. From the Moss Samples we can see that Cully is off the chartsregarding aluminum, chromium and cobalt (highest in Portland for all three), iron; very high in arsenic, lead, copper, zinc, and molybdenum. http://www.fs.fed.us/pnw/pubs/pnw_gtr938.pdf

This is a fantastic document, listing all the moss sample sites throughout the city, and the corresponding metals found in each sample. Although I knew Cully was bad, I hadn’t considered all the metals measured in the samples, as Bullseye and Uruboros were gathering attention for Chromium, Cobalt, and Arsenic. Thus, when I looked at the sample from two blocks away, I was astounded to see the aluminium measured the worst in the city. Everyone should look at their closest moss samples to see what was collected. It is difficult to envision air pollution amidst blue skies and gorgeous days.

 

 

 

 

 

 

The problem with sulfur dioxide

map_pollution_sulfar_dioxidHave you noticed a smell of burnt matches in the air recently, in the morning when you are getting up and watering the tomatoes or getting ready for a morning jog?

Chances are you are smelling the potent industrial pollutant sulfur dioxide, SO2. The pollutant comes from the combustion of tar sands fuel, coal, and petrochemicals. Throughout the Cully air-shed this past summer the smell of SO2 was prevalent and noticeable as a recurrent nuisance. Numerous complaints to the Oregon DEQ have been met with responses ranging from “We don’t know where the SO2 is coming from” to blaming it on asphalt laying and road maintenance taking place in distant down-wind locations. Through inquires to DEQ in the past and careful research of existing permits the Cully Air Action Team does know that Owen-Illinois Brockway (O-I) and Porter Yett both produce SO2 as part of their industrial processes. Control technology does exist to capture and neutralize SO2 yet O-I has been fined by the EPA in the past for lying about installing and using that technology. Porter Yett does have a control unit to capture SO2 although it is unclear if it is operating at all times. The state leaves it to the industry to report any toxic air releases or breakdowns in capture equipment.

Aside from the states inability to determine the source of the pollutant there are other problems with SO2 too. Here is a CDC/ATSDR fact sheet about the health effects of SO2 on humans.

SO2 is primarily associated with acid rain as an environmental pollutant.  There are indications that SO2 is also an indirect greenhouse gas, creating sulphate aerosols that contribute to localized climate change.

The acrid smell comes from the sulfur element and as the aerosol  SO2 disperses it becomes acidic and can damage invertebrates and aquatic life.  SO2 is a known danger. The mystery of where it is coming from needs to be addressed. 

Portland as a municipality likes to portray itself as a leader in being responsive to community members environmental concerns. The Portland Climate Plan mentions our regions “high incidence of respiratory illnesses” and sets an objective for Community Resilience (16B, page 116) to respond to this ‘high incidence of respiratory illness’, but neglects to inform that that diesel pollution levels are exacerbated by other aerial pollutants, such as SO2 and NOX (nitrous oxide.)

I’ll explore the impact of NOX as a pollutant in another article, but if you are smelling burnt matches, that is probably SO2, from a local polluter. It is always important to file a complaint with the DEQ. Right now though, it may be best to close your windows and stay inside awhile to avoid breathing the irritating pollutants. Exercise and garden time may have to wait until the SO2 aerosol cloud dissipates.

New Moss study released for Cully in June 2016

mossample57thtext

These heavy metal concentrations are from the corner of NE 57th and Portland Highway.

 

mossamplecornfoot

These heavy metal concentrations are from NE Cornfoot Road adjacent to Oregon National Air Guard.

The USFS maps are located here.

What these photographs and maps show are elevated concentrations of heavy metals in our Cully neighborhood. These concentrations may come for a variety of sources including industrial polluters such as Porter Yett, Owens Brockway (just east of map edge), and others.

These monitoring results do not include VOCs, which are a major pollutant from Porter Yett and other industries. The Cully Air Action Team is working to get VOC monitoring up for Summer 2016.

Thanks to our friends at Living Cully/Verde for help with this page.

The Porter W. Yett asphalt stench

Asphalt heaters and dryers at Porter Yett
Asphalt heaters and dryers at Porter Yett

While community members have made numerous complaints to the Oregon DEQ regarding foul and chemical odors in Cully, we have seen little real progress in addressing the mediation of such odors. Neither have we seen an accounting of the origin or monitoring of such odors. We, as residents of the Cully neighborhood of Portland, Oregon, are concerned that unregulated chemical releases may affect our long term health in a negative way as well as our short-term comfort. This is of special concern given our high population of children and elderly.

Perhaps the DEQ is unaware of the amount and nature of the chemicals being used. If so, please send them a message and document below on asphalt pollutants, (from http://www.ncair.org/toxics/asphalt/) Granted, this document only addresses toxic air pollutants related to the Porter Yett facility (5949 NE Cully Blvd.) but we hope it may spur on the DEQ to take a more responsive and transparent approach to protect the health of Cully residents. Other industries may be using similar TAPs, toluene and other PAHs yet there seems to be little information about how these TAPs are being addressed.

Cully, as a community within Oregon, is home to a very diverse and economically vulnerable population. We strongly believe that our complaints and concerns have systematically been ignored. Because of this, many of our residents may have become resigned to the fact that the air around us may be laced with known carcinogens. We are compelled to demand that the Oregon DEQ restrict Porter Yett and other TAP industries from polluting our air and endangering our health. We would further request increased monitoring and a listing of all known TAPs being used in industrial processes within 1000 feet of the Cully neighborhood boundaries. It is our deepest hope that DEQ will now focus its attention to protecting the people it is meant to serve. Please respond to this letter, and our health concerns, within 30 days.

from http://www.ncair.org/toxics/asphalt/
from http://www.ncair.org/toxics/asphalt/