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Comment on the Selmet Delisting 2018 Rulemaking

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Michele
Thompson
ODEQ
OR
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Frances
Dunham
Oregon
This delisting proposal is not in the public interest, nor is it justified under RCRA. DEQ was correct in its 2017 determination that Selmet must handle its chemical etching and milling waste (both currently generated and older stockpiled waste) as F006 hazardous waste. Cadmium, hexavalent chromium, nickel and complexed cyanide are highly toxic wastes, and they should be treated as such to protect public health and the environment. This delisting would be a dangerous precedent, likely to be employed by other generators of hazardous waste. The proposed rule change cites only this single “need”: shielding Selmet from the costs of proper treatment and disposal. Besides the pollution threats, there is the issue of rewarding a company that seems to have no plans for pollution prevention. This slants the playing field to the advantage of polluters and irrationally punishes companies that implement sustainable production processes.
Allan
Peterson
OR
Selmet’s milling wastes containing, among other things, cadmium, hexavalent chromium, nickel and complexed cyanide are all well-known toxics that should remain as DEQ determined, F006 hazardous waste. It is an affront that the company should seek an exemption on the basis of merelybeing costly. Such a delisting would put the risk to public health as secondary to profit, and encourage others to avoid their responsibility to handle hazardous waste responsibly, a dangerous precedent. I appreciate and support the 2017 review decision. Proper protection has its costs; Selmet should be denied an easy out. Thank you for the opportunity to comment.

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