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ENTEK

Air Toxics Health Risk Assessment Status

DEQ called in ENTEK International LLC to the Cleaner Air Oregon program on March 4, 2019. ENTEK is currently working on its Emissions Inventory which is the first step of the Cleaner Air Oregon health risk assessment process. DEQ created Cleaner Air Oregon facility web pages as part of an ongoing commitment to communities to be transparent and provide access to a facility’s health risk assessment information. Facility correspondence and deliverables are provided below.
 

Air Toxics assessment process

process diagram

​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 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. 



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

Jonathan Giska

Entek Site Address

250 Hansard Avenue,
Lebanon, OR 97355


Current Air Permit

 

How to get involved