DEQ should deny the application by ORRCO for air quality and solid waste permits.

April 30, 2018
DEQ Air Quality Permit Coordinator,
The Bridgeton Neighborhood Association Green Team asks DEQ to deny the application by ORRCO for air quality and solid waste permits. We believe that health of our neighbors in the Bridgeton community and the natural environment surrounding us will be negatively impacted by the uncontrolled emissions and from ORRCO burning waste oil as fuel to run their processing plant. We also think that they are not carefully handling potential PCB’s that contaminate their collected waste fuel. 
DEQ has not been able to verify for certain what ORRCO emits. We want the oil refinery emissions to be monitored real-time, as they come out of the stacks and we want the full-spectrum results to be fully-disclosed and transparent. ORRCO should be required to install both a thermal oxidizer for the VOC gases and a Scrubber to contain all the Particulate Matter.
 
ORRCO’s system that allows for emissions self-reporting is not substantial enough for this dangerous type of industry. We think real-time monitoring technology has become readily available to verify exactly how much and exactly what hazardous agents are being emitted. There is evidence that refineries underestimate and underreport their true VOC emissions (like benzene, xylene and toluene which can cause headaches, dizziness and cancer) by 10-12 times. We want DEQ to stop allowing oil re-refiners to self-report their emissions and instead rely on quantifiable facts. 
 
DEQ should not grant a “used oil burning“ exemption to these oil refiners. It’s been misapplied. The original intent was for small space heaters in sheds as an “incidental process,” it should not apply to larger scale oil refining operations. By definition, it is not used oil by the time it hits their boilers because it’s already been processed into fuel. On one hand, DEQ calls it ‘used oil’ but on the other hand DEQ calls it “fuel” (i.e. on the proposed permit) However the two products are not the same thing and are not interchangeable. This mis-applied exemption causes the whole problem! We want DEQ do stop allowing this loophole as part of the ORRCO permit. 
 
Sincerely,
 
BNA Green Team Members
Bridget Bayer
Laura Miller
Ann Howell
Jon Peterson