by Wanda Ballentine

However, actual emissions will not be monitored. A one-time source testing measures actual stack emissions to ensure they are under the limits; then equipment controls are calibrated by a consulting firm hired by Hyundai. Regular emission monitoring is then based on reading the controls. In at least one instance where source testing was repeated in six months, emissions were found to be 50% higher than the previous test. Control monitoring will be done by Hyundai, with LRAPA making periodic, sometimes unannounced spot-checks. Monitoring records will not be available to the public. Cole asserted that the consulting firm, CH2M3, has a national reputation to uphold and could be counted on to provide accurate data no matter who was paying the bill.

Cole assured the audience that while she, too, would prefer zero emissions, Hyundai's projected emissions are low, particularly compared to the 6000 tons of VOCs emitted annually by autos in the region. Audience members were not impressed that a large amount in one area justified increasing emissions in another. Hyundai spokesman John Lively stated that the VOCs will be burned at high temperatures and converted to water vapor and carbon dioxide. The latter is a greenhouse gas. O'Brien expressed doubts that these were the only residuals.

The emergency rule had banned incineration of chlorinated hydrocarbons, which produces dioxin, furans, and other chlorinated toxins, most of which are carcinogens and cause genetic mutations and deformations in many species. Hyundai claims the ban is unnecessary as they no longer use these substances. O'Brien asked why, if the company is not using them, it would object to the ban. Change is the name of the game in the wildly competitive arena of chip production, with constant changes in the processes and chemicals used.

Under the emergency rule, chemical use was estimated by the number of wafers produced, with a production cap of 30,000 monthly. The new permit proposes limiting the amounts of chemicals coming into the plant, which Lively called a more conservative standard. This could be an improvement if the amount of chemicals is not greater than that required to produce 30,000 wafers, and would be an incentive to produce more with less. However, there may be other reasons for the change. Tying emission limits to wafer production is standard in DEQ's air pollution permits. Hyundai has been pushing LRAPA to emulate DEQ policy -- except on this one point. For the last four years, Hyundai has been charged with "chip dumping," selling imported chips at below cost [see "Hyundai woes"]. Wafer production limits would make production numbers public and prevent the company from expanding domestic sales of low-priced chips.

The emission limits of volatile acids hydrochloric [HCl] and hydrofluoric [HF] will increase 50%, while limits on sulfuric acid will remain the same. Source testing revealed that Hyundai overestimated the amount of its sulfuric acid emissions but underestimated HF [40% of acid emissions] and HCl emissions [50%]. Currently these two acids are reacting with ammonia in the acid stacks, forming ammonium salts, seen as blue haze above the plant. These salts are acidic and could precipitate in the wetlands.

A full year's operation at this emission level would violate both Hyundai's current permit and proposed permit. Hyundai plans to remove ammonia from the acid stacks and to add an ammonia scrubber in 1999. LRAPA is thus relaxing the limits on HCl and HF, which will then be wind-dispersed across Eugene. However, limits on two smog-producers, particulates and nitrogen oxides will be stricter to help meet national air quality standards.

The question raised by a few people as to whether the monitoring equipment was "Y2K" compliant was dismissed as irrelevant.

This Public Forum was conducted jointly by LRAPA and Hyundai as an experiment with new permit application processes for projects of high public interest. The agency wanted to hear public concerns earlier in the process in order to address them when the final draft permit is written. Bern Johnson, of Citizens for Public Accountability, liked the approach, but suggested that future forums should include a public interest representative as well.

Summary of differences in original and proposed permits