Portland North Harbor Air Quality

DEQ proposes to issue two permits, and air quality permit renewal and a solid waste permit, for Oil Re-Refining Company Inc., or ORRCO, and invites the public to submit comments on the proposed permits.

Attend a public hearing Tuesday, April 24 at 6 p.m. at Red Lion Hotel on Hayden Island to comment in person, or submit written comments by 5 p.m. May 1. View the public notice and proposed permits below.

​DEQ issued a warning letter to EcoLube on Dec. 13, 2017 for accepting used oil containing PCBs. DEQ directed EcoLube to work with EPA to address proper storage, management and disposal of the PCB containing oil. In response, EPA issued a warning letter in February 2018 directing EcoLube to comply with the federal Toxic Substances Control Act and requested that EcoLube meet with EPA to discuss the requirements for managing PCB containing oil.

​Investigation into Odors
Between July 25, 2017, and Oct. 12, 2017, DEQ received 11 complaints identifying EcoLube Recovery, doing business as American Petroleum Environmental Services, and Oil Re-Refining Company as sources of odors and emissions in North Portland. DEQ used this information, along with meteorological data from nearby weather stations, to confirm that APES and ORRCO are possible sources of odors and emissions.

 

DEQ sent complaint information to both companies and requested they provide information about their operations during the times reported in the complaints and three-hours prior to those times. DEQ evaluated the operational data and determined that both companies were in compliance with the requirements of their air quality permits. DEQ also confirmed that the thermal oxidizer at APES, which the company installed to reduce emissions and odors, was in use during all operating hours. The thermal oxidizer controls the majority of odors and emissions from the facility, however, it is not a practical means of controlling every emission and odor point.

 

DEQ is in the process of communicating with both companies about ways they can further reduce odors and emissions. Any additional action by the companies would be above and beyond what current environmental law requires.

 

DEQ asks that community members continue to file pollution complaints when they detect odors and emissions. Complaints filed through DEQ’s complaint system are permanent records of pollution occurrences and are DEQ’s primary means of ensuring the agency collects the necessary information to conduct timely and thorough investigations into community concerns about pollution.

 

Emissions Testing at APES
In September 2017, DEQ reviewed and approved APES’ plan to complete its required emissions “stack test” to determine whether the facility’s thermal oxidizer, which it installed in August 2017 to reduce emissions and odors, was operating properly, and to gather information on the facility’s emissions of volatile organic compounds, nitrogen oxides, carbon monoxide and sulfur dioxide. 

 

On Oct. 5, 2017, a third-party contractor completed the required testing. DEQ received the results of the test on Nov. 20, 2017, and is currently conducting a review to validate the results. DEQ anticipates completing this review in the first quarter of 2018, and will post its analysis on this webpage at that time.

 

Preliminary results indicate that the thermal oxidizer is functioning properly and is an effective means of controlling emissions of volatile organic compounds. DEQ is using the stack test emissions data to determine if the company is in full compliance with its air quality permit.

 

Solid Waste Violation Warning
On Dec. 13, 2017, DEQ issued a warning letter to EcoLube Recovery, doing business as American Petroleum Environmental Services, that identified a solid waste permit violation for receiving used oil that contained detectable amounts of Polychlorinated Biphenyls (PCBs) at its North Portland facility. APES is to correct the violation by working closely with EPA to make sure the oil is removed from the site and properly transported and disposed.

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.

Air Quality Permit

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:

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 Dec. 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:

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. 

DEQ held a public hearing and collected comments 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.

• Approval by DEQ to remove a kiln and evaporator at ORRCO
  

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. 

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.

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​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 through November 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.

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. 

​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.