The Emissions Inventory provides information on all the Toxic Air Contaminant emissions from a facility, and includes information on a facility’s operations and activities, as well as fuel and material usage rates. This is often the longest step in the CAO risk assessment process as DEQ needs to verify that all activities have been accounted for, and that the most representative emissions data available are used. In some cases, DEQ will require a facility to perform source testing at this stage if insufficient data is available to estimate emissions.
For an introduction to emissions inventories and why they matter, please see EPA’s
Fact Sheet. DEQ is currently finalizing a fact sheet specific to our Cleaner Air Oregon program. A facility-specific emissions inventory timeline and associated documents are linked below.
March 4, 2019: DEQ calls AmeriTies into the program
June 3, 2019: AmeriTies submits Emissions Inventory and Categorically Insignificant Activities Form for DEQ review
- Cover letter for Emissions Inventory submittal
- Emissions Inventory: An Emissions Inventory is a list of each toxic air contaminant regulated under the Cleaner Air Oregon rules that a facility emits in a given year. The Emissions Inventory includes the amount of each toxic air contaminant emitted from each individual emissions-producing activity.
- Categorically Insignificant Activities (Form ED601): Categorically Insignificant Activities are activities that are likely to have insignificant emissions that are not part of a facility’s primary production process. Categorically Insignificant Activities are defined in OAR 340-200-0020.
Aug. 8, 2019: DEQ requests supporting Emissions Inventory information
- DEQ’s response letter: DEQ requests supporting information to verify emissions reported in original Emissions Inventory submittal
Aug. 28, 2019: AmeriTies Response to DEQ Comments
Aug. 30, 2019: AmeriTies provides supplemental Emissions Inventory information in response to DEQ’s request
March 11, 2020: DEQ Response to AmeriTies Request for Additional Information
April 10, 2020: AmeriTies Response to DEQ Comments
May 14, 2020: Facility submitted a Notice of Intent to Construct Form AQ104 in order to install and operate a Regenerative Thermal Oxidizer to control emissions from the Retort Building operations.
June 3, 2020: DEQ approved the Notice of Intent to Construct (NC# 32340) to install and operate the RTO control system, including requirements to perform source testing requested by DEQ for the purposes of the CAO program.
Sept. 25, 2020: Facility submits comment letter on the source testing requirements for the CAO program.
Jan. 22, 2021: DEQ provides response to the April 10, 2020, and September 25, 2020, facility letters. DEQ addressed source testing requirements for the RTO, Storage Yard, Boiler #2, and Diesel Scrubber, as well as the inclusion of emissions from ties stored in on-site in railcars prior to shipping.
March 15, 2021: Facility submits source-testing protocol for the RTO testing.
June 4, 2021: Facility submits revised source testing protocol for the RTO testing.
June 22, 2021 DEQ requests revisions to the source test plan.
June 23, 2021: Facility submits revised source testing protocol for the RTO testing.
June 29, 2021: DEQ approves the source-testing plan for the RTO testing.
July 20-22, 2021: Facility performs source testing on RTO.
July 23, 2021: DEQ issues Warning Letter with Opportunity to Correct requiring that the facility source test Treated Tie Storage, address data insufficiency related to the control efficiency of the Diesel Scrubber, and provide fugitive emission estimates from loading and unloading of retorts. DEQ provided the facility with 90 days to address these corrective actions.