NE Neighbors for Clean Air provided us with some additional information related to Boeing’s application to discharge contaminants at their Portland Airport painting facility. Click the link below for the complete text (with minor edits for length/style). You can also check out previous stories posted on the CNA website related to this issue.
Boeing wants to emit 99 tons per year (tpy) of volatile organic compounds (VOCs) and between 10 tpy of any single hazardous air pollutant (as defined by the EPA) and 25 tpy aggregate. It’s important to note that if Boeing had asked for a permit to emit 100 or more tons per year of VOCs (or more) they would have been required to obtain a Title V permit from the EPA, which would have required additional monitoring.
Q. Motorized vehicles are the predominant source of VOCs not industry; why is this a big deal?
A. People in our neighborhoods already bear higher health risks and costs from pollution than many other neighborhoods in the Portland metro area due to higher concentrations of mobile pollution due to our proximity to the airport, the I-5 and I-205 freeways and two heavily trafficked four-lane roads (Columbia Blvd. and Lombard St.). Added together these pollution levels probably exceed EPA limits, but levels in our neighborhoods are not directly measured.
Q. The Portland airshed (basically the Portland metro area) is below the EPA limit for VOCs by approximately 700 tons – doesn’t that leave us plenty of room for more pollution before anyone’s health is damaged?
A. EPA levels are crude averages over large metropolitan areas. There are only four sites in the city and only one monitors VOCs. Our neighborhoods are not measured to determine whether levels of criteria pollutants are excessive.
Q. Is it within Oregon DEQ’s power to stop Boeing’s proposed increase in emissions?
A. DEQ has the authority to require Boeing to install control technology which would remove 95% or more of the proposed 99 tons per year of VOCs emitted from the facility. If Boeing wanted to paint more planes, thereby having the potential to emit over 99 tpy, they would be required to obtain a Title V permit from the EPA with all of the requirements associated with that designation including monitoring and modeling. Because Boeing wants to avoid those requirements, they have requested a Plant Site Emission Limit for VOCs of 99 tons per year. Unless Boeing applies for a permit to emit over 100 tons of VOCs each year, DEQ has the discretion to require installation of technology that would, in effect, limit VOC emissions from the facility to approximately 5 tons or less annually.
Q. What technology is available to control VOC emissions from this facility. Can DEQ require Boeing to install it?
A. There are several proven VOC control technologies which could be installed at the Boeing facility, such as Regenerative Thermal Oxidizers (RTOs) or carbon adsorption technology. These and other technologies can achieve a removal efficiency between 90% and 99%. DEQ has the authority to require Boeing to install any of these control technologies, including the Kono Kogs Equipment RTO, which Boeing identified in its permit application as having 98% removal efficiency.
Q. Aren’t the levels of 2.5 micron particles that Boeing proposes to emit much lower than the EPA considers safe?
A. In December 2006 EPA revised the PM2.5 daily standards (for a 24 hour period) from 65 to 35 ug/m3 . EPA is expected to modify the Air Quality Index (AQI) to match this new standard in Spring 2008. The more we learn about air pollution the more we realize we have underestimated the health effects. Even Stephen Johnson, EPA administrator, states that pollution and smog standards are “too weak to protect people from the air they breathe.” (June 21, 2007).
Q. What does the EPA’s National Air Toxics Assessment of (NATA) say about Multnomah county?
A. Multnomah county ranks the highest state-wide in terms of both cancer (12th out of 3,222 counties nationwide) and non-cancer health threats (16th nationwide).
Q. Isn’t the main problem with VOCs that they create ground level ozone , which is only a problem during hot summer months?
A. Ground level ozone is apparently only a problem when the sun shines, but it is highly oxidative and causes tissue damage so more ozone during summer is a serious health risk. It penetrates deeper into parts of our lungs that are most vulnerable to injury. According to EPA, one in three Americans are at higher risk of problems from ozone. People with asthma or other pulmonary diseases are vulnerable to adverse health effects such as acute attacks or increased infections at lower levels. Even some healthy people are unusually sensitive to ozone. Ozone can make it difficult to breathe deeply and vigorously thereby restricting normal outdoor activities vital to good health. Long term exposure may reduce lung function and quality of life. Children and elderly are at particular risk.
But temperature inversions during winter months can trap and concentrate pollutants near ground. Carbon dioxide (CO2) reduces the oxygen carrying capacity of blood. Symptoms include dizziness, fatigue, headaches, nausea, memory and visual impairment, decreased muscular control and reduced ability to exercise. Nitrogen dioxide (NO2) and nitric oxide (NO) may cause lung damage and acute episodes for people with bronchial problems (asthma, COPD). Sulfur dioxide (SO2) may cause breathing problems and permanent lung damage; it’s an ingredient in acid rain that can damage vegetation, lakes and metals. Particulate matter (PM) causes nose and throat irritation, lung damage, bronchitis, and possibly premature death. Children, elderly and people with heart and lung diseases are at higher risk.
Q. Boeing’s proposed increase in hazardous air pollutants would be within the EPA guidelines of 10 tons per year for any single pollutant and 25 tons combined – is there really a danger to people in surrounding neighborhoods?
A. The Clean Air Act does not establish air quality standards that define legally acceptable concentrations of these pollutants in ambient air. No one knows how much exposure it takes to which pollutant or collection of pollutants to cause cancer or other serious health effect, indeed because each person’s genome is different each person’s risk will vary in unknown ways. Toxicology studies lack means to consider genomic differences. What is known is that mutations that eventually lead to cancer usually take years to manifest. That makes it difficult to pin down what source caused your cancer or other health problem. It’s prudent to conclude that more pollutants are probably worse for health.