Comments on the Toxic Air Discharge permit for Hyundai E4 Wafer Fabrication
Facility
Dear LRAPA Board:
The permit you are writing for Hyundai presents an invaluable
opportunity to limit
the release of additional toxics into our air and to encourage Hyundai
to share vital chemical risk information with the public.
This permit should deal with:
I) not only Hyundai's routine emissions that occur as a result of
manufacturing chips, but also
II) the accidental releases of chemicals into the air, ie a worst case
analysis scenario that put the community at risk.
For routine emissions, I ask that Hyundai be directed to strive for a
NO Toxics
release agenda.
Failing that, insist that they use "state-of-the-art" techniques that
minimize the
release of toxics, and provide evidence that they are doing pollution
prevention research on various techniques to achieve that goal.
Hyundai should be required to report to the community all dangerous
substances that
are released by the plant, not just the ones required by EPA.
They should be willing to allow independent auditors to verify that
they are striving
towards these goals and their reports need to be made available to an
oversight committee
of regulatory officials, informed citizens and professionals.
This is not an outrageous request. Support for these types of action
comes from a
recent court case, as reported in New York Times, 2 May, A20,.
"Court Backs E.P.A.
Authority On Disclosure of Toxic Agents."
Judge Gladys Kessler of the U.S. District Court for the District of
Columbia ruled
EPA had not exceeded its legal authority when it greatly expanded
requirements for public disclosure of emissions
of an additional 286 chemicals that the Government listed in the Toxic
Release Inventory
(TRI) in November, 1994. EPA Administrator Carol M. Browner praised the
ruling stating:
"A community's right to know
about local releases of dangerous chemicals is vital to protecting
public health and the environment."
In addition, the permit should :
Put a cap on the amount of HAPs. Don't leave it unspecified.
Methyl chloroform: Insist that they not use it. It is toxic and an ozone
depleter.
It it so toxic that its manufacture and importation are banned in this
country.
Arsine and other similar deadly compounds: If they can't be discouraged
from using
them, at least require them to monitor it and account for where it all goes.
Acids: As some of acids released will fall back on site, ie on to the
protected wetlands, require them to monitor the effects of acid
precipitation the watershed. This would
include rainwater/pH monitoring, direct effects on plants as well as
effects on both terrestrial and aquatic biota. (Something along the
lines of an EIS...)
Frequent monitoring of the emissions should be required. Once a year is
not enough and once until the year 2,000 is absurd. We need to know what
and how much is coming out of the plant.
Reword the compliance assurance methodology as currently described in
the permit so that concerns and complaints can be readily dealt with.
Even though Hyundai emission levels are such that they are not required
to provide :
a)process hazard assessments of the most dangerous processes, or
b)evaluations of potential accident consequences for workers on-site and
and the nearby community,
it is in the best interest of the community for LRAPA to require them to
make such information available.
Hyundai should be required to provide a total mass balance accounting of
all chemicals that the plant uses. What toxics are not released into the
air can be washed into
the sanitary sewer where if they are not properly treated end up in our
water.
Fines for violations of the permit should be based on a percentage of
the Hyundai's
gross receipts and the corporate board members should be held personally
responsible for damage to personal health and to the environment.
I truly appreciate your efforts in this process as well as providing the
opportunity to comment on such an important matter.
Sincerely,
James P. Reed
1732 Long Island Dr.
Eugene, OR 97401
(541)687-1924