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ENTEK

Entek public meeting

DEQ and OHA held a public meeting on Nov. 30, 2023 to discuss Entek’s CAO Risk Assessment.

Background

Cleaner Air Oregon is a health-based permitting program that regulates emissions of toxic air contaminants from facilities based on risk to nearby communities. CAO requires facilities to report toxic air contaminant emissions, assess potential health risks to people nearby and reduce toxic air contaminant risk if it exceeds legal limits.

As part of the Cleaner Air Oregon process, each facility has a dedicated web page to provide communities access to facility information and updates on where it is involved in the process.

  • Each step of the CAO risk assessment process has a section that includes DEQ's communications and deliverables from the facility.
  • The graphic below shows where a facility is in the Cleaner Air Oregon Process.

For additional information and history of the program, visit the Cleaner Air Oregon website. 

Green Arrow pointing to the right with 4 enclosed boxes labeled, from left to right, Emissions Inventory, Modeling Protocol, Ris

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. ​
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​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 ENTEK into the program

June 3, 2019: ENTEK 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
Sept. 6, 2019: ENTEK provides a revised Emissions Inventory and supplemental information in response to DEQ’s request
Oct. 8, 2019: Based on DEQ’s review of the revised Emissions Inventory, DEQ sends ENTEK a Warning Letter with Opportunity to Correct.
 
Oct. 16, 2019: DEQ and ENTEK meet to discuss Emissions Inventory
 

Oct. 24, 2019: ENTEK sends DEQ a letter as a follow-up to the Oct. 16, 2019 meeting, including an extension request for responding to the warning letter.

Nov. 5, 2019: ENTEK cover letter submitted along with requested Continuous Emissions Monitoring System (CEMS) data.

Nov. 6, 2019: DEQ approves an extension request for responding to the warning letter.

Nov. 20, 2019: DEQ visits ENTEK to better understand the facility's activities and emissions.

Nov. 25, 2019: ENTEK requests extension to meet the Corrective Actions in the warning letter. 

Nov. 27, 2019: DEQ approves ENTEK's extension request to complete compilation of TCE service components and fugitive emissions by Feb. 7, 2020. 

Feb. 7, 2020: ENTEK submits letter and requested TCE service components and fugitive emissions data.

July 10, 2020: DEQ sends ENTEK an Amended Warning Letter with Opportunity to Correct outlining final corrective actions and timelines required for completing Emissions Inventory.

Aug. 7, 2020: ENTEK response to DEQ's amended Warning Letter – Public version​.

Jan. 11, 2021: DEQ issues ENTEK a Pre-Enforcement Notice for violations related to failing to meet the Corrective Actions required in the Amended Warning Letter with Opportunity to Correct.

Feb. 3, 2021: DEQ issues ENTEK a Notice of Civil Penalty and Order for violations related to failing to meet the Corrective Actions required in the Amended Warning Letter with Opportunity to Correct​.

Feb. 23, 2021: ENTEK requests a contested case hearing to appeal the Notice of Civil Penalty and Order​. 
Jan. 18, 2022: After reaching a settlement, ENTEK enters a Mutual Agreement and Order to complete Emissions Inventory. 

April 20, 2022: DEQ issues letter requiring ENTEK to provide information on previously Exempt Toxics Emissions Units after rule revisions. 
June 24, 2022: ENTEK submits a revised Emissions Inventory including activities removed from the Categorically Exempt Toxics Emissions Units list. 

The Modeling Protocol provides information on how the facility plans to accurately model the concentrations of Toxic Air Contaminants (TACs) that community members may be exposed to based on the TAC emissions data from the approved Emissions Inventory. A Risk Assessment Work Plan is required for more complex Risk Assessments (Level 3 or Level 4) and provides more detailed information about locations where people live or normally congregate around the facility and how risk to these community members will be evaluated.​

Feb. 17, 2022: ENTEK submits Modeling Protocol and accompanying information for DEQ review. 
March 3, 2022: ENTEK submits Risk Assessment Work Plan for DEQ review. 
May 26, 2022: DEQ issues comment letter requesting revisions to the Modeling Protocol. 
June 24, 2022: ENTEK submits revised Modeling Protocol and accompanying information. 
Aug. 2, 2022: DEQ issues another comment letter requesting revisions to both the Modeling Protocol and Risk Assessment Work Plan. 

Aug. 17, 2022: ENTEK submits revised Modeling Protocol and Risk Assessment Work Plan. 

Aug. 26, 2022: DEQ issues approval letter for Modeling Protocol and Risk Assessment Work Plan. 


The Risk Assessment provides the summary of findings on potential risks to the surrounding community from emissions of Toxic Air Contaminants from this facility. The assessment indicates the exposure location(s) in the community with the highest potential Cancer and Noncancer health risk, and DEQ uses this information to regulate TAC emissions from the facility. In some cases, the risk may be very low and no further action may be required, or the risk may exceed health-based standards where DEQ can require risk reductions. In most cases, permit conditions will be developed and included in a facility's air quality permit to regulate TAC emissions based on the results of the risk assessment.

Dec. 14, 2022: ENTEK submits Risk Assessment. 

Jan. 10, 2023: DEQ meets with ENTEK to discuss minor revisions to the Risk Assessment. 

Jan. 18, 2023: ENTEK submits a revised Risk Assessment. 

Feb. 3, 2023: DEQ issues approval letter for ENTEK's Risk Assessment. The Acute (24-hour) Noncancer Risk requires community engagement under the CAO program rules. At this risk level state law prohibits DEQ from requiring any reduction in emissions. DEQ will convene a public meeting to discuss the results of the risk assessment with the community. To be notified about upcoming community engagement activities, sign up to receive emails under the 'How to get involved' link on this page. 


About the Facility

ENTEK is a battery separator manufacturing facility that has operated in Lebanon since 1984. The facility manufactures lead acid separator material using a mix of oil and product specific additives such as polyethylene and silica. Lithium ion separator materials are manufactured using the same method without the use of silica. The mixture is extruded at an elevated temperature into desired shapes, and the oil is extracted from the microporous plastic product using a trichloroethylene bath.



Contact

JR Giska, Project Manager
503-229-5178

Entek Site Address

250 Hansard Avenue,
Lebanon, OR 97355


Current Air Permit

 

How to get involved