From: Andrew Berna-Hicks <This email address is being protected from spambots. You need JavaScript enabled to view it.>
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Sent: Sunday, January 15, 2017
Subject: Comments: Pacific Steel Casting, 1333 2nd Street, Berkeley, CA. Operating Permit Revision BAAQMD
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Sent: Sunday, January 15, 2017
Subject: Comments: Pacific Steel Casting, 1333 2nd Street, Berkeley, CA. Operating Permit Revision BAAQMD
To Mr. Nicholas Maiden, Bay Area Air Quality Management District (BAAQMD):
The following comments are submitted regarding the public notice and public comment period for the Operating Permit Revision for Pacific Steel Casting in Berkeley, CA. Comments refer to the draft permit revision dated June, 2016 accessed online at the following location: http://www.baaqmd.gov/~/media/files/engineering/title-v-permits/e2605-smop/e2605_12_2016_smop_revision_proposed_eval_2nd-pdf.pdf?la=en
1) Page 12 indicates that the minimum Control Efficiency Requirement for VOCs is 90%. As a result the plant is allowed to emit 90 tons of pollutants into the surrounding atmosphere every year. In view of the fact that the control efficiency requirement for hazardous waste incinerators is 99.99%, why is Pacific Casting held to such a low standard? What is the legal basis for this Control Efficiency? In view of the fact that this plant operates upwind from a high density residential community, there is ample need to impose a higher control efficiency on the plants emission control systems.
2) Page 5, 3rd full paragraph discusses carbon monoxide as a newly discovered pollutant however at p. 13 Table 7 shows that it is only required to be monitored every 2 or 5 years; shouldn't some baseline testing be conducted for this newly discovered source?
3) P. 11 shows that excess cancer risk from the plant is 31 in a million and that any exceedence of 10 in a million requires public noticing. A map of the plant should be included in the report with isopleths showing where the 10, 20, and 30 in a million risk isopleths are located. The plant should be required to notify those residences or businesses of the excess risk.
3) P. 11 shows that excess cancer risk from the plant is 31 in a million and that any exceedence of 10 in a million requires public noticing. A map of the plant should be included in the report with isopleths showing where the 10, 20, and 30 in a million risk isopleths are located. The plant should be required to notify those residences or businesses of the excess risk.
4) Why is this plant allowed to impose such a high cancer risk on the public?
5) The Health Risk Assessment (HRA) is a crucial part of the decision making process. I could not locate the HRA for this facility online. It should be made available and the public comment period extended so that commenters may evaluate the permit along side the HRA. The HRA was created in 2008 and needs to be checked to see if it corresponds to current operations at the plant.
5) Appendix A calculations have been left out based on "confidential" information. What is the basis for leaving this information out? It should be included.
5) The Health Risk Assessment (HRA) is a crucial part of the decision making process. I could not locate the HRA for this facility online. It should be made available and the public comment period extended so that commenters may evaluate the permit along side the HRA. The HRA was created in 2008 and needs to be checked to see if it corresponds to current operations at the plant.
5) Appendix A calculations have been left out based on "confidential" information. What is the basis for leaving this information out? It should be included.
I request that the public comment period be extended and that another public hearing be held regarding this permit because the last hearing and public notice were inadequately noticed. Notices of the public hearing should be sent to the homes all residents and businesses and schools in the vicinity who potential could be impacted by this plant (5 mile radius minimum) and to all historical commenters.
Respectfully, Andrew Berna-Hicks