Oregon's Department of Environmental Quality (DEQ) is completing its review of the emission inventories submitted under the Cleaner Air Oregon (CAO) program. If you submitted an inventory, it would be good to request the reviewed/final emission inventory from DEQ. The person at DEQ who entered the data, performed QA/QC and did the initial review is Jonathan “JR” Giska, at 503-229-5178. JR can turn a request around quickly. If you would like assistance contacting DEQ or requesting your final inventory, please feel free to contact us.
Once the reviewed/final inventory is available, DEQ changes to what you submitted may require follow up discussions with the agency. Major change information should be provided to DEQ; including the removal or addition of a process line, air emission control equipment, or air toxic pollutants, as examples. DEQ should also be made aware of any changes to your operations that have resulted in using less toxic materials. At a minimum, it would be wise to run a CAO Level-1 risk assessment, and potentially a CAO Level-2 or Level-3 risk assessment to identify which pollutants are the drivers at your site. CAO risk assessment methodology information is available from DEQ on-line. In some cases, it may make sense to investigate source testing now to better vet the inventory data as well.
In a recent conversation, JR did not indicate which facilities or industrial sectors will be prioritized for the first round of “call-ins”, however he said that eventually all facilities will be called into the program. Call-in will be an opportunity for discussion and refinement of emissions numbers. First quarter 2019 is the estimated timeline for the first 15-20 sites to be pulled into the process.
The CAO program will eventually require reporting; based on tracked throughput, emissions factors and other data that was used to develop emissions inventories for each facility. DEQ plans to align the reporting schedule with EPA’s National Emissions (NEI) requirements. We will continue to stay in the loop regarding new requirements. Please feel free to contact us to discuss how these requirements might impact your sites.