Petition to the Oregon Department of Environmental Quality: Deny Air Quality Permit Renewal for the Covanta Marion Waste Incinerator
Please sign by November 17th, 2019 (deadline is November 18th and we need time to package up and submit comments). We welcome everyone, including health professionals and public health advocates with or without credentials.

The Oregon Department of Environmental Quality is considering a Title V air quality permit renewal for the Covanta Marion waste incinerator located in Brooks, OR halfway between Woodburn and Salem. The proposed permit is mostly the same as the one issued to the facility that expired in 2017, but with slight increases in allowed emissions of fine particulate matter.

Please add your name below to the following comments to the Oregon Department of Environmental Quality.


To: Gary Andes, State of Oregon Department of Environmental Quality, Western Region

Dear Mr. Andes,

We, the undersigned health professionals and public health advocates, urge you to deny the proposed Oregon Title V Operating Permit being considered for renewal for Covanta Marion, Inc.

The Covanta Marion waste incinerator is the single largest industrial emitter of Fine Particulate Matter (PM10/2.5), Carbon Monoxide (CO), Nitrogen Oxides (NOx), Sulfur Dioxides (SO2), and other air toxics in Marion County, and is the 20th single largest greenhouse gas emitter in the state of Oregon. The once annual stack testing that occurs at the facility is insufficient for determining whether the facility's air contaminants are in excess of current DEQ limits. Covanta Marion knows when stack testing occurs and is therefore capable of withholding their most toxic combustible waste materials during the time that stack emissions are monitored. Continuous monitoring and alternative means of testing for air contaminants including moss and soil testing are needed to determine whether Covanta Marion is exceeding the pollution levels outlined in this permit. We recommend that this permit be denied until more rigorous monitoring is required in order to obtain a sufficiently accurate understanding of the emissions created by the facility.

In addition, the permit proposes an increase in allowed emissions of Fine Particulate Matter (PM 2.5 and PM 10), a harmful air contaminant that is dangerous at any level of human exposure. PM 2.5 and PM 10 work their way into the deepest folds of lung tissue causing inflammation and increased risk of pulmonary disease, cardiovascular disease, cancers, and more. No permit allowing an increase in this contaminant should be granted to the facility in order to protect public health in the towns and communities who live, work, and play in the airshed of Covanta Marion, which include a higher than average population of people of color and low-income residents as well as a high population of outdoor farmworkers.

Additionally, major emitters of greenhouse gases like Covanta Marion must have decreasing amounts of permittable carbon dioxide equivalent emissions in order to align with the state of Oregon's goals of statewide carbon reduction. Global climate scientists have announced that worldwide carbon emissions must be decreased by 50% in order to prevent the worst-case scenarios of climate change, which has a myriad of harmful environmental and health impacts that Oregonians are already beginning to experience. A new permit for Covanta Marion must require the facility to decrease its overall carbon emissions in order to align with Oregon's necessary climate action objectives.

Covanta Marion was flagged as one of the first 20 facilities in Oregon who need to comply with the Cleaner Air Oregon program, which seeks to better understand the air quality impacts of major polluters in the state. The prioritization of Covanta Marion among a list of hundreds of major polluters in the state indicates that this permit should not be granted before conclusive results from the Cleaner Air Oregon process are obtained.

For all these reasons, we request that the Oregon Title V Operating Permit for Covanta Marion, Inc. be denied and the facility be required to comply with more rigorous air quality monitoring, reduce its air toxics and greenhouse gas emissions, and complete the Cleaner Air Oregon before a new permit is granted.

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