What is the issue?
Beginning in late August 2015, DEQ and its partner agencies began investigating odors in the Portland North Harbor area in response to numerous citizen complaints. Based on these investigations, DEQ identified two used oil re-refineries, American Petroleum Environmental Services and Oil Re-refining Company, as sources contributing to the odors. The recycling process begins with the used oil heated to a high temperature to remove water and impurities. After the heating process, the oil is further refined to remove additional pollutants and sold as a fuel product.
Air quality permits for APES and ORRCO require updates that will include additional testing, monitoring, and recordkeeping requirements.
In response to community concerns, EPA, in support of DEQ’s investigation into odors, conducted air monitoring at two locations near the oil re-refiners from September 2015 to January 2016. While the pollution levels measured did not pose an imminent health risk and were generally consistent with levels found in an urban environment, several days over the two months showed intermittent elevated levels of specific odorous gases.
DEQ conducted follow-up monitoring around the North Portland harbor area in an effort to better understand the specific pollutants of concern identified by EPA. Results from DEQ monitors showed levels of air pollutants similar to those found in urban air and do not pose an imminent health risk. However, people with asthma or other respiratory conditions may experience increased frequency of symptoms.
What are DEQ and other agencies doing about it?
DEQ issues Air Quality and Solid Waste permits
On Sept 20, 2017, DEQ received notification from EcoLube Recovery, LLC, a subsidiary of Clear Lube Re Refining Co., that it had acquired and taken ownership of the American Petroleum Environmental Services Inc. oil re-refining facility.
On Sept 27, 2017 DEQ issued a modified and renewed air contaminant discharge permit and a new solid waste permit to EcoLube Recovery LLC dba American Petroleum Environmental Services, Inc. DEQ considered comments received during the public comment period and made adjustments to the permits based on regulatory authority. See the two issued permits and supporting documents below.
Solid Waste Permit
Update on Communications with APES on MAO Deadline
On September 15, 2017, DEQ issued an Order and Demand for Payment of Stipulated Civil Penalty to APES/CLRR regarding failure to meet the deadline in the Mutual Agreement and Final order to install the thermal oxidizer.
Update on Communications with APES on MAO Deadline:
On August 4, 2017, DEQ issued an Order and Demand for Payment of Stipulated Civil Penalty to APES and CLRR regarding failure to meet the deadline in the Mutual Agreement and Final Order to install the thermal oxidizer.
See APES and CLRR's communication to DEQ and DEQ's response letter and Order and Demand for Payment of Stipulated Civil Penalty below:
Communication with APES on MAO Deadline:
On July 24, 2017, DEQ provided written notification to APES that DEQ currently plans to enforce the existing deadlines in the Mutual Agreement and Final Order signed with DEQ on December 27, 2016. This letter is in response to APES’ request for an extension of the deadline to install the thermal oxidizer.
See APES and CLRR's communication to DEQ and DEQ's response below:
Updated Hayden Island Laboratory Monitoring Report:
DEQ has finalized its report for monitoring completed near Hayden Island in the fall of 2016.
See the report below for more information:
DEQ has entered into a Mutual Agreement and Final Order with Oil Re Refining Company to expedite the installation of controls for solid waste and air quality.
Public hearing for APES permits
DEQ is holding a public hearing and beginning the comment period for American Petroleum Environmental Services, Inc. proposed renewed and modified air quality permit and a proposed solid waste transfer permit.
See the proposed renewed and modified air quality permit below:
See the proposed solid transfer permit below:
DEQ is holding an information meeting for a complex air quality permit modification application and a solid waste transfer permit application for Oil Re-Refining Company.
DEQ and EPA required APES to submit records on its plans for the disposal of the contents of Tank 12.
DEQ has approved the removal of the Kiln and Evaporator at ORRCO and the transition of the facility’s oil process from batch to continuous flow. Both the Kiln and Evaporator units were known sources of emissions and odors at the ORRCO facility.
DEQ worked with EPA to post infrared
videos taken during an on-site inspection of APES and ORRCO in September
of 2015. These videos helped DEQ and EPA identify APES and ORRCO as
contributors to odors and emissions.
Infrared videos of APES and ORRCO
FLIR is a company that sells infrared imaging technology used by industry and regulators to visually observe the release of specific pollutants. During an off-site inspection of APES and ORRCO on Sept. 24, 2015, DEQ and EPA used a FLIR GF320 to help pinpoint sources of odors and emissions from the two facilities. Below are videos collected during the offsite inspections with DEQ and EPA’s explanation of what the videos show: APES – Video #1
This video shows the exhaust stack of the “Back Plant Burner” at APES. The majority of what is shown exiting the stack in the video consists of hot exhaust gasses, primarily carbon dioxide and water. In this infrared video, the exhaust plume appears to quickly dissipate as the hot exhaust gasses cool. As the plume moves away from the stack, the video shows a faint residual plume indicating that some unburned Volatile Organic Compounds are likely present in the burner exhaust.
As required by the Mutual Agreement and Final Order, APES will install a thermal oxidizer to control emissions from the “Back Plant Burner” no later than June 25, 2017. APES – Video #2
This video shows emissions from the condenser stack attached to “Cook Tank 4” at APES. Emissions from all four cook tanks are routed to a unit that condenses the vapors and reduces volatile organic compound emissions. This process is also known as the “Front Plant.” DEQ and EPA are confident that the plume of gasses visible in the infrared video are primarily Volatile Organic Compounds.
As required by the Mutual Agreement and Final Order, APES will be decommissioning the four of the cook tanks by no later than May 26, 2017. ORRCO – Video #1
This video shows the exhaust stack of “Burner #9” at ORRCO. The majority of what is shown exiting the stack in the video consists of hot exhaust gasses, primarily carbon dioxide and water. In the infrared video, the exhaust plume appears to quickly dissipate as the hot exhaust gasses cool. As the plume moves away from the stack, the video shows a faint residual plume indicating that some unburned Volatile Organic Compounds are likely present in the burner exhaust. ORRCO – Video #2
This video shows emissions from the “Thumper Tank” at ORRCO. The stack vents gasses that have passed through a condensing unit at the facility. DEQ and EPA are confident that the emissions visible in the infrared video are primarily Volatile Organic Compounds.
While the video footage shows emissions that are otherwise invisible to the naked eye and helps identify potential sources of emissions, the infrared technology does not quantify the amount of emissions. DEQ has required APES to conduct stack testing as part of a Mutual Agreement and Final Order (MAO) with specified timeframes for installation of additional control equipment. Stack testing allows DEQ to determine the amount of actual emissions from processes and will verify that control technology is effectively controlling emissions. Modified and renewed air quality permits for both facilities will include additional language that requires emission controls to be operated and maintained following equipment manufacturer specifications to ensure emissions reductions are maintained into the future.Visit our YouTube channel.
DEQ is holding an information meeting for a complex air quality permit modification application and a solid waste transfer station permit application for American Petroleum Environmental Services. See the notice below for more information:
EPA recently communicated with APES about the company's plans to remove the contents of Tank 12. See the letter below for more information.
The following documents provide information regarding correspondence and reporting for American Petroleum Environmental Services and Oil Re-Refining Company that DEQ has received or originated May through August 2016, as well as a Fact Sheet updated February 6, 2017.
On Dec. 27, 2016, DEQ entered into a Mutual Agreement and Final Order with APES that requires for the installation of control technology at the facility. A compliance schedule for the implementation of the additional controls is documented in the MAO.
View the Mutual Agreement and Final Order
The following documents provide information regarding correspondence and reporting for American Petroleum Environmental Services and Oil Re-Refining Company that DEQ has received or originated through November 2016.
Information about planned shutdown at APES, Sept. 27, 2016
DEQ has determined that the air pollution control technology that American Petroleum Environmental Services proposes to install will appropriately control gaseous emissions from facility operations.
In a Sept. 3 letter
sent to DEQ, Oil Re-refining Company proposed improvements and modifications to the facility to reduce air emissions and nuisance odors.
On Aug. 23, APES provided information DEQ required so DEQ can complete a technology analysis to ensure that the facility has appropriate controls for controlling gaseous emissions.
Since late August 2015, DEQ has been investigating odors in response to numerous complaints in the Jantzen Beach area on Hayden Island. Based on these investigations, some of which were in partnership with EPA, DEQ identified American Petroleum Environmental Services as one source of odors and continues to investigate other possible sources including Oil Re-refining Company. Both facilities recycle oil.
DEQ encourages people to continue documenting and filing odor complaints through the DEQ Complaints Hotline or online complaint form. DEQ will compare complaint information to meteorological data and facility operation information to determine if there are other sources of odors in the area.
DEQ may or may not be able to pinpoint other odor sources. Also, a business may be in compliance with its air quality permit but still may emit odors. In that case, DEQ uses the nuisance odor strategy which outlines DEQ’s process for addressing potential nuisance odor sources.
Air quality monitoring
EPA assisted DEQ in the odors and air emissions investigation by conducting limited short term air testing in the area from September 2015 through January 2016. The results are included in the following report:
DEQ conducted additional sampling and monitoring on Jantzen Beach and near APES and ORRCO to identify the pollutants, conditions and sources contributing to the odors and emissions.