Response to Comments to Public Notice for the Proposed New Solid Waste Disposal Site Permit Number 1592 for Thermo Fluids
DEQ issued a public notice on August 22, 2017 requesting public comment on the draft DEQ solid waste permit for the Thermo Fluids transfer station and material recovery facility. DEQ mailed the notice to property owners within at least one quarter mile of the facility, provided public notice through email, and placed public notice ads in local newspapers including the Oregonian and the Oregon City News and Clackamas Review. Subscribers of DEQ’s email notification list received a message about the proposed permit issuance and the chance to comment. The comment period closed at 5 p.m. on October 2, 2017.
DEQ received four comments from one commenter on the draft solid waste permit. DEQ has listed the comments and DEQs responses below. Based on these comments, DEQ did not make any modifications to the draft permit.
DEQ received the following comments from Jungho Ahn of Environmental Review, Inc:
Comment 1:
Solid Waste Disposal Facilities have Financial Responsibilities requirements (insurance, bonding, etc.). What are the minimum Financial Requirements for this facility? Shouldn’t financial responsibility requirements be specified in the permit?
DEQ Response 1:
Transfer Stations and Material Recovery Facilities are only required to obtain financial assurance if DEQ determines they are not a low risk facility. Due primarily to the tank associated with the oil filter crusher, DEQ has determined that Thermo Fluids must maintain financial assurance for costs associated with closure of the facility and accidental releases. DEQ reviews the proposed closure and accidental release cost estimates during the annual financial assurance submittal and review period. Financial assurance requirements are detailed in Section 7 of the permit. The types of financial assurance mechanisms allowed are detailed in Oregon Administrative Rules OAR 340-095-0090.
Comment 2:
Shouldn’t Spill Containment and Countermeasure Control (SPCC) plan requirement be specified? Shouldn’t DEQ review and renew that the annually?
DEQ Response 2:
DEQ Materials Management Program requires spill response measures to be addressed in the site Operations Plan. The permittee may satisfy this requirement by submitting the SPCC.
Comment 3:
Chapter 10.2: When the prohibited waste is to be arrived to the facility, what is the procedure to prevent it from contaminating other regular waste? The public notice should clarify that.
DEQ Response 3:
Per permit section 6.3, prohibited wastes must not be accepted. If the facility discovers prohibited wastes at the facility; the permittee must manage the waste in accordance with the site’s Operations Plan.
Comment 4:
The public notice does not discuss the possible contamination of groundwater due to a release of liquid waste or wastewater; add discussion for that.
DEQ Response 4:
The facility provides secondary containment of liquid waste and wastewater. Based on this and other site conditions, DEQ does not consider there to be a significant risk of groundwater contamination from onsite releases.
Solid Waste Permit Coordinator
Department of Environmental Quality (DEQ)- Northwest Region Environmental Partnerships
700 NE Multnomah St., Suite 600
Portland, Oregon 97232-4100
To Whom It May Concern:
Environmental Review, Inc. has reviewed the document and has the following comments:
1. Solid Waste Disposal Facilities have Financial Responsibilities requirements (insurance, bonding, etc.). What are the minimum Financial Requirements for this facility? Shouldn’t financial responsibility requirements should be specified in the permit?
2. Shouldn’t Spill Containment and Countermeasure Control (SPCC) plan requirement be specified? Shouldn’t DEQ review and renew that the annually?
3. Chapter 10.2: When the prohibited waste is to be arrived at the facility, what is the procedure to prevent it from contaminating other regular waste? The public notice should clarify that.
4. The public notice does not discuss the possible contamination of groundwater due to a release of liquid waste or wastewater; add a discussion for that.
Sincerely yours,
Jungho Ahn - Project Manager,
ENVIRONMENTAL REVIEW, INC.,
P.O. Box 2756, Berkeley, CA 94702