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Oregon Department of Environmental Quality (DEQ) continues to update its website with information surrounding the Cleaner Air Oregon (CAO) regulations finalized in November 2018. Recently, DEQ posted "Draft Recommended Procedures for Conducting Toxic Contaminant Health Risk Assessments." This document should be used as support for decisions regarding DEQ CAO submittals, and provides background and procedural information including:

  • Risk assessment basics,
  • Conducting varying levels of risk assessment,
  • Screening examples of Level 1-3 risk assessments, and
  • Development of the risk-based concentrations.

This document was previously released during the rulemaking process and is included as part of the 2017 and 2018 Public Notice Documents on DEQs website. Since the previously released version, major changes include guidance on non-detect values (Appendix G) and inclusion of fugitive emission sources.

DEQ is requesting informal comments on the Draft Recommended Procedures until April 15, 2019. DEQ has specified on its website that this is not a formal rulemaking process and does not represent any binding requirements for DEQ or facilities. However, if there is something in the document that does not align with your facility or you would like additional clarification, Trinity would suggest making a comment during this period to address any concerns.

Some clients are concerned with anonymity with comments like these. So, if you'd like Trinity to assist with reviewing this document, assessing how it may affect your specific facility, or submitting any comments on your behalf, please contact Trinity's Portland office at (503) 906-7833 or email Beth Ryder at or Jesse Gonzalez at