Ron Walters, President, NWDA Board
I will cc this cover letter and our Work Plan draft No 10 to all the members of the Board. Today we posted our minutes for our meeting last night.
At last night’s meeting the Committee asked me to write a cover letter from our Committee to you and all Board members to remind you that our work on the committee is voluntary and unpaid. We are finding many of the suggestions offered to change our work plan overly broad and ambitious. In fact some of the suggestions are for a work plan suitable for the DEQ at a cost beyond what we can realistically hope to fund.
During the over fifteen years of our operation as a Board committee, we have acquired a list of air quality controls that Esco put on the two plants since 1994, when we began working on neighborhood air pollution issues. And in addition to the work already accomplished at Esco, we were instrumental in getting DEQ to adopt a rule requiring capture equipment when loading and unloading fuels along the riverfront. This prevented tons of benzene and other contaminants going into the neighborhoods (CA & WA states already had this rule at the time). We were instrumental in getting Faulkner on 28th & Thurman to drastically reduce emissions of Styrene. A pregnant woman lived directly across the street.
These are some of our accomplishments. But during the last two years of writing this work plan (our one pager had been good for years) we have been able to do little else than respond to demands for rewrites, attend meetings etc.
We are now wanting to get back to the work of the Committee. In addition to passing the work plan 10, which responds to many of the demands made to us,
we are asking you to place on the agenda a motion from our Committee to change the website to reflect our name change to the NWDA Air Quality Committee. Please remove Health & Environment from the website, as there is no functioning H & E
Sharon Genasci, Chair, NWDA Air Quality Committee
2012 Work Plan (draft 10)
NWDA Air Quality Committee
March 13, 2012
The protection of public health and environment in the Northwest District encompasses a number of needs as outlined in the Northwest District Plan. The greatest health and environment concern for the neighborhood, however, remains the quality of air in our urban neighborhood due to:
- The neighborhood’s adjacency to the Northwest industrial district,
- The neighborhood being surrounded on two sides by an urban freeway, and
- The concentrations of emissions from the great mix of activities associated with an urban community – traffic, construction, household emissions, etc.
The density of Northwest populations, the concentrations of children, senior citizens and those with health concerns focuses these air quality concerns. NWDA Air Quality Committee is dedicated to monitoring and promoting a clean and healthy air shed in which Northwest neighbors can live and work. The Committee evaluates health and environmental issues affecting Northwest District air quality, communicates with neighbors about air pollution and health impacts, promotes public health and works with the community, DEQ, legislature and other public officials to improve the quality of NW neighborhood air.
The committee will continue to focus energies and resources on the reduction of toxic air pollutants, including volatile organic compounds (VOCs) and particulate matter (dust) that settles on neighbor’s homes and gardens.
This dense, mixed use, residential neighborhood, next to an historic industrial area along the Willamette River, is bounded by I-405, West Burnside Street, the West Hills and Highway 30. Its northern edge abuts the Northwest Industrial Neighborhood, an industrial zone characterized by factories and distribution centers, some old and not up to modern standards that potentially emit air pollution. There is no buffer zone; the industrial sanctuary is directly adjacent to Northwest’s dense, residential neighborhood. On the east and northeast side the northwest district lies next to the I-405 freeway. Heavy car and truck travel have historically emitted high levels of air pollution into the neighborhood.
Air shed pollutants include heavy metals, particulate matter and VOCs from many large industrial sources and emissions from mobile sources such as trucks, cars and buses. These pollution sources impact the quality of life in the NW neighborhood. Potential health impacts of the known pollutants are of particular concern for young children, the elderly and anyone with respiratory health problems. Health concerns for some of the known pollutants include cancer, asthma, Parkinson’s disease, and other neurological ailments. Several of the known pollutants such as manganese and lead are neurological toxins. The NWDA tracks odor complaints, which support these concerns.
2012 Work Plan:
- on industrial pollutants, which historically and continue to pose the greatest concern for neighborhood health.
- Promote with the City and ODEQ the adoption of the Precautionary Principle, requiring that permitted polluters prove their emissions are safe for a residential neighborhood. For many years it has been the role of the neighborhood to ask for protective regulatory help to clean up the air shed. Enough is known now about the types of emissions and emitting industries that the Precautionary Principle should be in place statewide.
Outreach, Education and Awareness:
• Continue air pollution educational outreach to neighbors, schools, other organizations and neighborhoods through meetings and events.
• Continue to improve the NWDA odor complaint form and website and utilize the submittals to improve an understanding for the Committee, the Board and for the Oregon DEQ of air shed problems in the NW neighborhood.
- Track odor complaints received from the NWDA website. Continue to investigate and work with neighbors to identify the source of potentially harmful emissions, odors and particulates that come into the neighborhood and work with suspected sources on the elimination or reduction of those pollutants.
- Work with the Planning Committee’s Conway planning project on including a clean diesel proposal in the Leeds agreement of the Master Plan. This would propose that a portion of the total construction cost go to upgrading exhaust controls on construction vehicles, generators and other construction equipment to reduce diesel emissions.
- The NWDA Air Quality Committee will work with the NAC (Neighborhood Advisory Committee of the GNA) to monitor neighborhood air pollution, and will also continue to do community monitoring when possible to watch for changes and increases in neighborhood air pollutants from all sources.
ESCO Good Neighbor Agreement:
- Work with ESCO and other groups to fulfill the commitments contained in the recently signed Good Neighbor Agreement (GNA), that promises to reduce overall air emissions by about 20 per cent over the five years of their new permit, which was issued by DEQ on March 1, 2012.
- Actively participate on the Neighborhood Advisory Committee (NAC). Report on Committee activities and seek feedback from the Air Quality Committee and the NWDA Board.
Enforcement & Support:
• Seek opportunities to work with the Mayor’s Office to promote awareness of air pollution problems in NW Portland, and where possible, strengthen enforcement.
• Seek opportunities to work with the legislature to develop new air quality related legislation.
• Continue to testify at ODEQ and other hearings and legislative committee meetings on air pollution.
• Fundraise where necessary, (i.e. from health directed foundations) in support of the Committee’s activities.
Organization and Conduct of Committee:
• As a standing NWDA committee, the Air Quality Committee shall recruit members, not less than 3 and not more than 15.
• Shall provide notice of all meetings and shall post both agendas and minutes.
• Shall review membership and the chairperson annually for reporting to the NWDA Board.
• Shall provide updates on a monthly basis at the NWDA Board meeting.
• Shall hold meetings at a public and ADA accessible location.
Committee Work to Date on Air Quality Problems:
Under the direction of Dr. Robert Amundson the Health & Environment Committee (as it was then named) in 1997 began conducting neighborhood air monitoring studies. Dr. Amundson has conducted air quality monitoring since 1969 and has specialized in quantifying effects of air pollution on managed and unmanaged ecosystems. Under Dr. Amundson’s guidance, northwest neighbors monitored the air at their homes and at sites throughout the neighborhood. Funding came from various grants, including an EPA grant and a legal settlement (Chevron vs. Genasci). Some studies were conducted in conjunction with the Oregon Department of Environmental Quality (ODEQ), while others were independent neighborhood efforts. Particulates (dust), metals and toxic gases were monitored.
The following data compiled over the years yielded results that clearly indicate a serious air pollution problem in Northwest Portland:
• Over 70 toxic compounds were found to be in the air, including compounds known to cause cancer, respiratory and endocrine problems. The aggregate health effect of such a mix of toxic substances is unknown.
• Dust samples collected in the neighborhood contained concentrations of lead that far exceeded the EPA’s indoor standard of 40 micrograms per square foot. (see http://www.nchh.org/Media/Press-Releases/Lead-Dust-Standard.aspx which recommends a standard of 10 micrograms per square foot).
• Many heavy metals such as lead, manganese, nickel, and chromium 6 (hexavalent chrome) were found in particulates. These metals can cause serious health problems. Studies have consistently shown the level of lead and other heavy metals to be higher in locations closer to the NW industrial area, indicating a “hot spot” for industrial sources of pollution.
• The most recent monitoring showed concentrations of three VOCs – benzene (a Class A carcinogen), butadiene, and acrolein – high enough to be of concern. All three compounds exceeded EPA and California health benchmarks. Benzene concentrations, for instance, varied from 16 to 73 times the EPA cancer benchmark and from 67 to 293 times the California benchmark. (See H & E air monitoring data at the NWDA Office)
• Fuel & diesel emissions. Fuel odors are a priority because benzene, a known carcinogen, is a component of fuel. The Committee worked with the Oregon Department of Environmental Quality (ODEQ), the Environmental Protection Agency (EPA), city officials, some state legislators and a few industrial polluters. The Committee performed community outreach through neighborhood events, meetings, mailings and leaflet distribution to increase awareness of the problem and organize the efforts of concerned community members.
The Committee’s online odor complaint form (www.portlandair.org) supplements the NWDA’s new general-purpose form and allows neighbors to report odors that may be associated with toxic air borne pollutants. Complaints go to the Committee Chair and Oregon DEQ. The Committee uses the complaints to work with ODEQ to identify the source of problem odors, which are not only irritants, but may also indicate dangerous air pollutants. From June 2, 2005 through February 3, 2012 the Committee received 1050 odor complaints. Of these, there were 775 complaints submitted by approximately 120 people, that mentioned Esco Corporation as the source (73 per cent).
Major Sources of Air Pollution:
ESCO, a multinational steel foundry is located at NW Vaughn and 25th with a second plant on NW Brewer. Part of the concern is their location near Wallace Park, Chapman Elementary School and other schools. Built in 1913, the buildings are old and not air-tight. ESCO emits a suite of heavy metals and toxic gases, as well as particulate matter in the form of black dust. It is thought that the distinctive, noxious odors from the plant come from the binders used in the molding process at ESCO. Following a USA Today article (http://content.usatoday.com/news/nation/environment/smokestack/search/OR/), parents were concerned about a possible link to health problems in the schools’ communities near industrial air pollution. Children are especially vulnerable to harmful effects of these air pollutants. The 775 complaints or 73 percent of odor complaints received by the Committee are attributed to ESCO Corporation’s two plants in NW Portland.
The other major source of odors that neighbors complained of in recent years was very strong fuel smells that came into people’s homes and gardens, sometimes over a several day period. Eight oil companies operating in Portland use above ground fuel storage tanks, some at least fifty years old. These are located in a “tank farm” near the Willamette River. Fuel is transferred from ship-to-port and from ship-to-ship. ODEQ requires the use of capture equipment during the on shore transfers, but not the transfers from ship-to-ship. More work is needed to document the sources of these odors.
The proposed 2011 Health and Environment Committee Workplan can be downloaded here: