Letter to Bay
Area Air Quality Management District (BAAQMD)
Regarding Pacific Steel
From West Berkeley Alliance for Clean Air and Safe Jobs
December 30, 2005
Jack Broadbent, APCO
Bay Area Air Quality Management District (BAAQMD)*
939 Ellis St.
San Francisco, CA 94109
Dear Mr. Broadbent:
As you know, The West Berkeley Alliance for Clean Air and Safe Jobs has been extremely concerned about toxic air emissions from Pacific Steel Casting in Berkeley. Our West Berkeley community believes these emissions are not just an "odor problem" but rather a very serious health threat--the toxic pollutants Pacific Steel emits are associated with cancer, reproductive, respiratory, neurotoxic and other adverse health effects.
We support a multi-pronged approach to cleaning up Pacific Steel: installing new pollution control equipment and upgrading existing equipment; substituting non-toxic materials for toxic materials in the production process; re-engineering processes to reduce waste and pollution and to properly ventilate operations to funnel emissions to abatement devices; and improving housekeeping to eliminate such problems as fugitive emissions from open doors and casts left to cool outside.
We are pleased to see that the recently announced settlement agreement between BAAQMD and Pacific Steel contains many of these elements. Unfortunately, it does not go far enough. We oppose any notion of increasing Pacific Steel’s permit to allow increased POC emissions from the plant-- this is completely counter to resolving the issues. We would like to see the following elements added to the agreement or drafted into a new agreement:
1. Pacific Steel must achieve significant reductions in POC emissions not only through proper mitigation and abatement steps, but also by substitution of non-toxic binders for the binders currently used. As part of its mitigation, Pacific Steel should be required to adhere to a firm schedule for replacing their POC emitting binders with non-toxic alternative binders. As you know, the existing binders are a major cause of "odor" complaints to BAAQMD. Identifying and using non-toxic binders should not be difficult as the metal casting industry did research on non-toxic binders decades ago, aware at that time that binders contributed to serious pollution problems.
2. All doors on the plant—including Plant 1 (which is not mentioned in the agreement)—must be closed during operations to ensure a negative air flow allowing pollution control equipment to work as intended and to prevent fugitive emissions not only from casting, but also from pollution-producing metal grinding and finishing operations.
3. Metal grinding and finishing operations should be connected to existing or planned carbon adsorption and baghouse air pollution control devices to mitigate odors, POCs (grinding wheel resin burn from friction), and particulates generated from the grinding process.
4. The sand recycling incinerator in Plant 2 should be connected into the existing or planned carbon adsorption and baghouse air pollution control devices to control emissions from the burn off of binder from the sand, especially to control the permitted temperature fluctuating events below 1400 C, the temperature below which the BAAQMD has stated in the record would result in chemical hydrocarbon emissions out of the stack. These events should be eliminated or properly mitigated.
5. Mold release operations should be connected into the existing or planned carbon adsorption and baghouse air pollution control devices to eliminate or significantly reduce emissions from these operations.
Finally, the community, with the assistance of the West Berkeley Alliance for Clean Air and Safe Jobs, has assumed the burden of making complaint after complaint to BAAQMD regarding these toxic odors. The West Berkeley Alliance for Clean Air and Safe Jobs has conducted unpaid community outreach to educate the community on the BAAQMD complaint "process" since it is far from user friendly. We therefore request that the penalties assessed against Pacific Steel be reserved to pay for: (1) Independent air monitoring and testing by the community: Community members have paid for recent independent air monitoring, which suggests that there may be unhealthy levels of formaldehyde in the community. The Alliance, together with the city of Berkeley, has consistently asked for additional and more comprehensive sampling and monitoring. Continued independent testing and monitoring are needed to ensure that the measures described in the agreement are effective in protecting the public health.
(2) Continued educational outreach to, among other things, inform our community about the potential health and environmental risks identified by the HRA process and how to place odor complaints to the District.
We look forward to meeting with you on January 31, 2006, to discuss these and other matters of concern to the community, including the schedule for Pacific Steel’s Title V permit under The Clean Air Act. In addition to responding to this letter, we would like you to explain how the Title V process will allow for more community involvement and more rigorous future controls to address the serious problems posed by Pacific Steel.
The West Berkeley Alliance for Clean Air and Safe Jobs
cc: Peter Hess, Deputy APCO
*Bay Area Air Quality Management District (BAAQMD) is the regional, government agency that regulates sources of air pollution within the nine San Francisco Bay Area Counties.