Oregon Department of Environmental Quality (ODEQ) has been working to update their website with tools and background information related to toxic programs in Oregon. The toxic program has several websites relevant to industrial facilities including the Oregon Air Toxics Program (Oregon ATP) webpage, Cleaner Air Oregon (CAO) webpage, and Cleaner Air Oregon Permitting Requirements (CAO Permitting) webpage. Each of the websites provide useful content for implementation of the finalized CAO rules codified in Oregon Administrative Rules OAR 340-245 and background technical information to support risk assessment determinations and community engagement meetings. Trinity wrote an article summarizing the main components of the final rule here.
The Oregon ATP encompasses several programs and activities related to air toxics, including CAO. One of the newer posts is an Evaluation of Moss Sampling as a Methodology for Evaluating Air Toxics in December 2018. As many are aware, one of the catalysts to the CAO reform was detection of metals in moss located near a school in Southeast Portland. The report and supporting fact sheet include details on a 2017-2018 study of eight urban sites and two rural sites to determine if moss could be used as an indicator of air quality. Concentrations of metal in moss were higher in more industrialized urban areas, but the concentrations of metals varied greatly over a short distance and between samples. The conclusion of the study was that the exact relationship between levels of pollutants found in moss and atmospheric concentrations remains unknown. However, moss is a useful and cost effective way to identify areas to focus traditional or expanded air monitoring efforts. The Oregon ATP also has a link for Frequently Asked Questions (FAQ) About Air Toxics. Answers to the FAQs may be useful for background and supporting information in community engagement meetings and report submissions to ODEQ in the CAO program.
The CAO website includes a Plan for Community Engagement Protocols. Due to requirements in SB 1541, the final CAO rules require ODEQ to hold all community meetings. This document details the plan to hire a CAO Community Engagement Coordinator and determine an appropriate community engagement meeting protocol with this new hire. The plan also mentions developing a protocol in early 2019 with a final protocol ready for use by October 2019. A draft protocol outline is included in the document with titles including "How to Use this Document to Build an Engagement Plan." Based on conversations between Trinity and ODEQ, ODEQ is still in the process of hiring the coordinator.
The CAO permitting website is where most of the significant updates have occurred. ODEQ has posted CAO risk assessment flowcharts for new and existing facilities that may be useful in understanding requirements. The webpage notes that ODEQ will prioritize and call-in existing facilities in early 2019. Conversations between Trinity and ODEQ indicate the first facilities are expected to be called-in March 2019. Additionally pre-application fee (AQ100CAO) and emission inventory (AQ405CAO) forms are provided on this webpage. Recall that the first emission inventory under the new regulation will be due in 2020, with throughput information from the 2019 reporting year. AQ405CAO is an excel file that will be submitted electronically in 2020. The layout is very similar to the required submission in 2017 prior to the rule.
If you have any questions on the CAO process or resources, please contact Beth Ryder at (458) 206-6770.