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Facts about Toluene

Oregon Administrative Rules (OAR) 340-246-0090(3)(rr) establishes a benchmark of 400 ug/m3 (micrograms per cubic meter) or 106 ppb (parts per billion) for toluene. This benchmark is based on being exposed to toluene at 106 ppb for 70 years. At this level and duration of exposure there is a one in one million risk of becoming ill and/or developing cancer. The link to this rule is provided below.

Useful Websites for Toxicity Information:

· DEQ Oregon Administrative Rules (See OAR 340 Division 246 for Toluene benchmark value):

http://www.deq.state.or.us/regulations/rules.htm

· USEPA’s Air Toxic Website:

http://www.epa.gov/ttn/atw/allabout.html

· USEPA’s Integrated Risk Information System (IRIS):

http://www.epa.gov/ncea/iris/

· California’s Office of Environmental Health Hazard Assessment(OEHHA)::

http://www.oehha.ca.gov/

How does the proposed emissions from Suterra LLC compare in specific terms to other industry in Deschutes County?

Plant Site Emission Limits in Tons/Year

Air Pollutant	Suterra LLC (proposed)	Fuqua Homes, Inc	Knott Landfill	JELD-WEN Bend Millwork	Texaco Gas Station (No Limits)	Gas Transmission Northwest Corporation
Particulate Matter	NA	24	24	24	NA	24
Particulate Matter less than 10 microns	NA	14	14	14	NA	14
Sulfur dioxide	NA	NA	NA	39	NA	39
Nitrogen oxide	39		39	39	NA	503
Carbon Monoxide	NA		99	99	NA	381
Volatile organic Compounds	39	39	39	348	5.6	39
Hazardous Air Pollutants
Toluene	2.05	2.55	0.98	0.0042	unknown	0.0769
Benzene	NA	NA	0.04	NA	unknown	0.0284
Xylene	NA	0.01	0.35	2.74	unknown	0.0379
Cumene	NA	NA	NA	1.17	unknown	NA
Ethylene glycol	NA	7.11	NA	1.2	unknown	NA
Formaldehyde	NA	NA	NA	0.18	unknown	4.48
Methylene diphenyl diisocynate	NA	NA	NA	2.74	unknown	NA

NA – Not Applicable to this facility

Fuqua Homes, Inc., 20495 Murray Road, has a Simple Air Contaminate Discharge Permit:

This facility is located approximately 1mile south from BANA. The facility has a Plant Site Emission Limit of 39 tons per year for Volatile organic compounds. 11.3 tons per year of the permitted volatile organic compounds are identified as hazardous air pollutants. The facility’s ability to emit toluene is 2.55 tons/year. There are 11 different hazardous air pollutants emitted from this facility. The volumes of the higher annual hazardous air pollutants emissions are included in the table above.

Knott Landfill, Deschutes County Department of Solid Waste, 6100 SE 27th Street has a Simple Air Contaminate Discharge Permit:

The Knott Landfill is located directly across the street from High Desert Middle School. The landfill has Plant Site Emission Limit of 39 tons per year for volatile organic compounds. 4.30 tons per year of the permitted volatile organic compounds are identified as hazardous air pollutants. The facilityhas the potential to emit toluene is 0.98 tons/year. There are 24 other hazardous air pollutants emitted from this facility. The volume of their higher annual hazardous air pollutants emissions are included in the table above.

JELD-WEN, Inc., 62845 Boyd Acres Road, has a Title V Air Contaminate Discharge Permit:

This facility is located a half mile north of a school located on Studio Road and approximately 1mile south from BANA. 10.6 tons/year of the 348 tons/year of volatile organic compounds are identified as hazardous air pollutants. There are 14 different hazardous air pollutants emitted from this facility. The volume of their toluene emissions is low, however, at 0.0042 tons/year. Some of the higher annual hazardous air pollutants emissions are included in the table above.

Texaco Gas Station on the corner of Butler Market and NE 27th, an air permit is currently not required:

This gas station has a potential business throughput of 40,000 gallons per month. USEPA has developed volatile organic compound emission factors for gas stations (see website at http://www.epa.gov/ttn/chief/ap42/ch05/final/c05s02.pdf). A gasoline tanker filling an underground storage tank has an emission factor of 11.5 pounds of volatile organic compound for every 1000 gallons of fuel delivered. Fueling of vehicles has an emission factor of 11.0 pounds of volatile organic compounds occurring when dispensing fuels. A third source of volatile organic compound emissions come from underground tank venting or “breathing”. Breathing losses occur daily and are attributable to gasoline evaporation and barometric pressure changes. An average volatile organic compound breathing emission rate is 120 mg/L (1.0 lb/1000 gal) of throughput.

A gas station with a potential throughput of 40,000 gallons per month has approximately 11,300 pounds or 5.6 tons of volatile organic compounds per year. Toluene is one component of the vapor loss. This gas station is directly across the street from one school and less then a ¼ mile from two other schools. Plus there are businesses, homes, and neighborhoods within 100 feet of this gas station. DEQ is in the process of regulating volatile organic compound losses from gasoline stations. See http://www.deq.state.or.us/aq/permit/vapor/vapor.htm.

Gas Transmission Northwest Corporation located 19 miles south of Bend on Hwy 97S has a Title V Air Operating Permit with the Plant Site Emission Limits provided above. Their toluene emission is estimated to be at 153 pounds per year. Their largest hazardous air pollutant emission is formaldehyde at approximately 4.84 tons per year.

At what levels and distances should residents be concerned about emissions coming from an industrial park?

The permitted levels emitted by industrial sources are allowed by federal and state regulation. DEQ does perform ambient air quality monitoring and would start evaluating capping emissions when ambient air quality monitoring shows signs of being adversely impacted from industrial emissions.

What other environmental hazards should residents be concerned about as industry grows in the neighborhood?

DEQ does not have additional information to add to the group discussion on this matter. The group discussed transportation of materials and products out of Juniper Ridge. There was discussion on adequate access for the fire department and other services in and out of the Juniper Ridge. City of Bend Councilor Jodi Barram provided helpful information on these topics.

Is monitoring of pollutants at a site such as Lava Ridge School a reasonable (cost versus effect) strategy?

Monitoring at Lava Ridge School could be performed to evaluate air quality but the monitoring may not be able to identify the source of pollutants detected. DEQ is currently discussing the option of performing air quality monitoring at the schools and in the Juniper Ridge industrial park.

DEQ is also considering modeling the emissions from Suterra LLC to determine what levels of pollutants would be anticipated in the areas surrounding Juniper Ridge.

What resources do you know about to keep abreast of environmental concerns in our neighborhood?

· City of Bend

Stay in contact with the City of Bend Planning Department. An industry wanting to move into the Juniper Ridge Industrial Park must go through the City’s local land use approval. You may want to let City Counsel members and City Planning Department know that you are interested in being included in these discussions and would like to have the ability to ask questions and participate in the process. The City of Bend does have a website just for Juniper Ridge. http://www.ci.bend.or.us/depts/urban_renewal_economic_development/juniper_ridge/index.html.

· DEQ

Any resident or group can sign up to be on the DEQ mailing list to be notified of proposed DEQ actions. Go to: http://www.deq.state.or.us/news/publicnotices/PN.asp and click on the green envelop in the upper left hand corner that reads, “Sign up to get DEQ info by e-mail”. DEQ has an established mailing list for Suterra LLC. DEQ can use this list to contact residences of future public notices and/or hearings on proposed permits within Juniper Ridge.

Can you summarize the public comments you received and what proportion came from BANA residents?

The DEQ received comments from 36 individuals and 1 group. All comments received were opposed to the issuance of the Simple Air Contaminant Discharge Permit. Only a handful of the commenter’s mentioned or identified that they were associated with BANA.

A majority of the comments received stated opposition of the permit based on the proximity of the Suterra facility to local schools and the toxicity of their emissions. Others commented that they received no notification on the public notice period for the proposed permit or the informational meeting. A few of the commenter’s requested additional time and information before allowing the facility to be permitted.

I am working through the comments received and hope to address all comments soon. The comments and Response to Comments will be added to the Review Report as an addendum and will be made available to everyone who is on the DEQ mailing list. Action on the permit will likely occur shortly after the Response to Comments is complete.