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Integral Scientists Comment on New Framework for Air Quality Regulations in Oregon

As the Oregon Department of Environmental Quality (DEQ) seeks to develop new industrial air toxics regulations, Integral Consulting scientists are contributing to the discussion.  DEQ’s current regulations reflect a technology-based approach that sets limits on the emissions of air toxics at the source.  The Cleaner Air Oregon (CAO) program seeks to develop a new risk-based approach that focuses on the potential health impacts in the nearby communities from facility emissions.  DEQ’s goal for the new regulations is to provide greater protection for public health while being mindful of impacts on local economies and jobs.

The conversion from technology to risk-based air toxics regulations is a significant challenge, and DEQ is soliciting input from stakeholders on a draft framework for the new program.  In a May 15 letter to DEQ, Principal David Livermore, R.G., L.H.G., Senior Science Advisor James Lape, and Senior Consultant Jennifer Sampson provided comments on various aspects of the draft framework and posed questions intended to ensure a robust regulatory program.  The primary focus of the comments was on toxicological issues related to DEQ’s selection and application of the risk-based concentrations for use in evaluating facility impacts, and the metrics that would be used to judge the success of the new regulations in meeting the stated goals.  For example, DEQ is collecting toxicological data from numerous sources and will need to develop a sound approach for selecting the most appropriate chemical-specific values to use in developing the risk-based concentrations.  The draft framework also includes an assessment of impacts on a community from all nearby sources.  In Integral’s experience, a community-level risk assessment can be a valuable tool, but great care must be taken to ensure that risks are not overestimated when aggregating potential impacts from multiple facilities.  Furthermore, evaluating the success of the program in improving the overall quality of the air that Oregonians breathe is confounded by the multitude of air emission sources that are not subject to the proposed regulations.

The draft CAO regulations are expected to be published in August 2017.  There are also two upcoming meetings of the CAO Advisory Committee, one on July 28, which will focus on the implementation process for the CAO rule after it is adopted in about June 2018, and one in late August 2017, which will focus on initial review of and input on the draft rules.  Integral continues to closely track the technical elements and implications of this developing rule.

For more information about the CAO rulemaking or for assistance in understanding and reviewing the upcoming draft rules, contact Jim Lape at jlape@integral-corp.com or (410) 573-1982, David Livermore at dlivermore@integral-corp.com or (503) 943-3613, or Jennifer Sampson at jsampson@integral-corp.com or (206) 957-0351.

Visit Oregon DEQ web site.

Integral has provided air quality support to a wide variety of industries, including energy, waste management, mining, and manufacturing.

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