PCC Structurals facilities in Oregon use the best available control technology for control of metal dust emissions.  These controls are as good as, or better than, control systems used by PCC Structurals elsewhere.

“Best Available Control Technology” describes the technology that achieves the maximum degree of reduction, taking into account energy, environmental and economic impacts.

A cyclone filter is a unit that is typically used to capture larger size particulates.  It is similar in principle to a cyclone home vacuum, where air and particulates enter at the top of the unit, are swirled around, and then the particulates drop to the bottom of the unit and are captured there.  PCC Structurals uses cyclone units in combination with other filtration systems, and typically will place them ahead of a baghouse (defined below).

A baghouse is a filtration unit that passes dust-laden air through fabric filters to remove the dust.  The dust is then collected for proper recycling or disposal.  Baghouses are considered the best control device available for removing small particles such as metal dust.  PCC Structurals sometimes uses a baghouse in combination with other filtration units to augment their performance and/or increase filter life.  Baghouses can be placed either after a cyclone filter or before a HEPA filter (defined below).

HEPA stands for “High Efficiency Particulate Arresting” and is a high-performance filtration system that captures very small particles.  HEPA filters are typically used to supplement other filtration systems to remove additional particulates.  PCC Structurals places HEPA filters on the outlet of key baghouses handling fine metal dust.  This combination of baghouses and HEPA filters removes over 99.9% of the particulates that enter the treatment system.

PCC Structurals has completed, or is in the process of completing multiple upgrades to the pollution control equipment for its air emissions and stormwater discharges. We will update the information below as additional equipment is made operational.

FACILITY	PROJECT	STATUS
SSBO	Baghouse installation	Completed
SSBO	Route grinding cyclone filter exhaust through existing baghouse	Completed
Deer Creek	Baghouse installation	Completed
LPC Campus	Installation of HEPA filtration on four existing baghouses
	Steel grinding booths x2	Completed
	Grinding cell	Completed
	Robotic cell	Completed
LPC Campus	Cyclone pre-filter	Completed
LPC Campus	Baghouse with dual HEPA	Completed
Deer Creek	HEPA filtration on existing baghouse	Completed
LPC Campus	Stormwater filtration system	Completion expected late-June
LPC Campus	Baghouse installation	Completion expected early-July

PCC Structurals does not use arsenic or cadmium in the metal parts that it manufactures.  The metal recipe that we use for each part is strictly defined by our customers to meet their performance requirements.  No recipe at any of our facilities calls for either arsenic or cadmium.  Arsenic or cadmium is not identified by the manufacturer as present in any production materials that we use.

However, we do find low, but measurable levels of arsenic and cadmium in our baghouse dust.  Specifically, arsenic is present in our baghouse dust at levels at or below the naturally occurring level in soil in the Willamette Valley.

The cadmium levels in our baghouse dust are nearly 25 times lower than the level which DEQ considers safe in residential soil.  At current production rates the Large Parts Campus on Johnson Creek Boulevard would emit from its baghouses about 1/8th of an ounce of arsenic over the next 12 months and approximately 1/25th of an ounce of cadmium over the next 12 months.

If we were to use the EPA’s very conservative arsenic emission factor for combustion of natural gas, the Large Parts Campus emitted less than two ounces of arsenic in all of 2015 from natural gas, an amount so small that would be difficult for any monitoring system to detect.   We do not rely on the EPA natural gas emission factors in calculating our emissions, preferring to rely upon emission factors used in Southern California as we believe they are more accurate and up to date.

Toxicity of nickel is determined by the release of nickel ions in certain biological conditions. PCC Structurals uses high nickel content steel alloys to make its products.  Alloys are mixtures of two or more metals where the mixture can have different properties than the individual components.  One of the properties of the alloys that PCC Structurals uses is that the nickel is bound up in the alloy such that it has an extremely low ability to dissolve in biological conditions.  As a result, the nickel ions are generally not available for absorption or to cause adverse effects.  This very low toxicity of nickel alloys, such as that found in stainless steel, has been demonstrated in numerous scientific studies.  Also, studies consistently find that workers exposed to the type of nickel alloys used by PCC Structurals have no increased cancer risk.

The alloys that PCC Structurals uses are mixtures of several metals, including chromium. The chromium in our alloys is elemental chromium, not hexavalent chromium. While PCC Structurals’ alloys do not contain hexavalent chromium, some of our processes cause a small fraction of chromium to convert by oxidation to hexavalent chromium.

PCC Structurals has emissions controls in place to limit the amount of chromium, including hexavalent chromium, released from our facility. In addition, we recently completed installation of improved controls that will further reduce our chromium emissions.

PCC is doing extensive work to upgrade stormwater controls. Phase One involves installing an end-of-pipe filtration system designed to remove pollutants regulated under PCC’s general stormwater discharge permit, including total suspended solids and metals, to below benchmark standards established in that permit.  In addition, and as part of PCC’s cleanup efforts at the Large Parts Campus for legacy pollutants, the filtration system will also remove PCBs, TCE and PCE to concentrations below detectable levels.  These pollutants will be removed before stormwater is discharged into the city of Portland’s stormwater sewer system that discharges into Johnson Creek.  This system will cost $4 million and we expect installation to be complete by June 30, 2016.

Phase Two involves building a new and separate series of pumping stations and piping that will collect and divert pond and spring water that flow onto PCC property to the city storm sewer, thereby segregating stormwater that originates from the pond and springs from stormwater that falls within PCC’s operational areas.  Stormwater that falls within PCC’s operational areas will be treated by the new filtration system and segregation of the pond/spring water will make filtration more efficient.  This work is also expected to be completed by the end of this summer.

First, it is important to know that any industrial waste water generated at the plant site is not discharged into Johnson Creek.  Only stormwater from the site is discharged to the city of Portland’s storm drains that discharge into Johnson Creek.  As stated above, PCC continues to work with DEQ to assess our plant’s stormwater discharges.  Based on the presence of PCBs in storm lines under our plant site and due to other low levels of pollutants, PCC will install a stormwater filtration system that will be completed this summer.

PCC Structurals neither uses PCBs today, nor do any of its manufacturing processes generate PCBs.  However, electrical equipment, as well as some manufacturing materials, used several decades ago contained PCBs. 
PCC is addressing these legacy PCBs through DEQ’s Voluntary Cleanup Program.

PCC has not used TCE for many years.  We do know that TCE is a legacy contaminant in groundwater below our facility and PCC continues to work with DEQ to assess the extent of the issue.  However, based on current information we do not believe that the Large Parts Campus is a source of TCE in Milwaukie’s drinking water wells.

PCC Structurals has an extensive Contingency and Emergency Response Plan.  In the event of a disaster, our plan includes, but is not limited to:  shutting off all utilities to prevent fire potential and using backup generators to keep critical emissions controls operating.  Chemicals are stored within secondary containment (e.g., lined concrete vaults).  PCC also participates in quarterly meetings with the Local Emergency Planning Commission.

In 2011, a PGE power failure led to the release of an orange-colored plume of nitrogen oxide (NOx). No one was injured but it was a serious event.  Since then, the Large Parts Campus on Johnson Creek Boulevard has taken three steps designed to minimize the chance of recurrence.  First, the system controls for the specific manufacturing process have been relocated to outside the process area, allowing for control even in the case of limited access.  Second, remote monitoring for NOx was added to ensure we can determine the NOx level without entering the room.  Third, we upgraded the electrical systems to ensure an electrical spike won’t damage the control or system circuits.

We have engaged in a number of activities recently and are planning more. In April, we sent a letter to all of our neighbors addressing some of the issues raised in the media concerning Portland air toxics.  We have appeared before the Milwaukie City Council and had smaller meetings with neighborhood and elected leaders.  We have created a new website (pccstructuralscommunity.com) where we are posting fact sheets and information related to our permits and activities.  We are also planning to host a community meeting on May 25 and will post details about time and place as soon as we have them.

PCC Structurals was founded in Portland and has been part of this community for decades.  Today, our company has nearly 2,800 employees in the Portland area.  We support a variety of community organizations, including the Johnson Creek Watershed Council, Impact Northwest, the Boys & Girls Club of America, Clackamas Women’s Services, SMART (Start Making a Reader Today), and the American Red Cross.  PCC Structurals also supports students and programs at De La Salle High School, Clackamas Community College, Mt. Hood Community College, Oregon Institute of Technology, Portland State University, Oregon State University, University of Oregon, and University of Portland.