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Incident Category
Time Critical Removal Action
Background
The JH Baxter Facility is wood treatment facility in Eugene, Oregon. The facility stopped operations "moth balling" the facility in 2022. Prior to closure, operations consisted of treating wood in any of five retorts using Creosote, Pentahlorophenol (PCP), Ammoniacal Copper Zinc Arsenate (ACZA). The main treatment area includes four retorts (Retorts 81, 82, 83, and 84), and multiple work, process, and storage tanks. Another area used for PCP treatment (Retort 85) includes one retort and several process and storage tanks. The ground surface beneath all retorts and tanks is currently concrete with secondary containment sidewalls averaging 2 feet in height. In 1992, in response to new regulations at 40 C.F.R. Part 264 Subpart W, all the retort areas had concrete drip pads with roofs installed. Approximately 80 percent of the remaining areas within the facility are unpaved.
The process and chemical storage area is broken into 2 primary tank farms, south and north, which are connected by underground piping. According to the facility Spill Prevention, Control, and Countermeasure Plan (SPCC), the total storage capacity exceeds 1 million gallons and contains materials such as PCP-based oil, creosote/bunker fuel oil, creosote, ACZA, 50/50 recovery, diesel, recovery water, PCP-a recovery, Arsenic Acid, and Aqua Ammonia.
The wood-treating facility portion of the Site is approximately 32 acres and has several areas of interest. The areas of interest have been divided into the following decision units (DU).
• The Main Treatment Area:
o North Retort and surrounding tanks – DU01
o North Tank Farm – DU02
o South Tank Farm – DU03
o Boiler room and surrounding area – DU04
o Hazardous Materials Shed and Drum Storage Area – DU05
• Drip pad sheds, storage, and drying areas – DU06
• Stormwater and Groundwater treatment systems – DU07
• Laboratory – DU08
The primary focus area of this TCRA will be DU01 thru DU05 (The Main Treatment Area) and DU08 (Laboratory). All these DUs contain large quantities of hazardous substances such as dioxins/furans, heavy metals, Volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs).
Description of Threat
During September 2023, EPA conducted a Removal Site Evaluation (RSE) to assess and sample all large containers, drums, totes, and tanks, within the south and north tank farms. EPA discovered greater than 500,000 gallons of hazardous substances in both liquid and solid phases. These hazardous substances have been evaluated to contain high levels of dioxins/furans, metals, VOCs, and SVOCs, and have been assigned potential Resource Conservation and Recovery Act (RCRA) hazardous waste codes including F032, FO33, F034, F035, D001, D002, D004, D018, and K001. Due to the aging infrastructure, the current mothballed status of the facility, the periodic vandalism and theft, and the lack of funding and plans by the owner to remove any of these wastes, there is a high threat of release from one or more of the tanks which would directly impact the neighboring residential community and the adjacent commercial area.
Removal Assessment Results
A combined total of over 750,000 gallons (or greater than 6,000,000 pounds) of various hazardous substance waste streams have been identified.
