HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD—REVIEW

COVER SHEET

J. H. BAXTER
September 2024

Stephen Nguyen (206) 553-1073
U.S. Environmental Protection Agency
Seattle, WA

Region 10 START
Weston Solutions, Inc.

Seattle, WA

Documentation Record: Brandon Perkins (206) 553-6396

U.S. Environmental Protection Agency
Seattle, WA

Christina Marquis
Weston Solutions, Inc.

Seattle, WA

Pathways, Components, or Threats Not Scored

Name of Site:

Date Prepared:
Site Investigation:

The ground water, surface water, subsurface intrusion component, and air migration pathways
were not scored, as their inclusion would not have impacted the overall site score.


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HRS DOCUMENTATION RECORD

Name of Site:
EPA ID#:
EPA Region:

Date Prepared:

Street Address of Site:

J. H. BAXTER

ORD009032400

10

September 2024

3494 Roosevelt Boulevard

City, County, State, Zip Code: Eugene, Lane County, Oregon 97402

Topographic Map:

Eugene West, Oregon, U.S. Geological Survey (USGS) 7.5-Minute
Quadrangle (Reference [Ref.] 3)

Latitude: 44° 3' 43.3872" North Longitude: 123° 9' 10.0584" West (Ref. 3; Ref. 4, p. 10)

Latitude/Longitude Reference Point: The latitude and longitude correspond to sample location

JHB-S05 in the approximate center of the J. H. Baxter facility in the
tank farm area (Ref. 4, pp. 269-270).

SCORES

Ground Water1 Pathway

=

Not scored

Surface Water Pathway

=

Not scored

Soil Exposure and Subsurface
Intrusion Pathway

=

63.40

Air Pathway

=

Not scored

HRS SITE SCORE

=

31.70

*The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the
general area where the Site is located. They represent one or more locations the United States Environmental
Protection Agency (EPA) considers to be part of the Site based on the screening information EPA used to evaluate the
Site for National Priorities List (NPL) listing. EPA lists national priorities among the known "releases or threatened
releases" of hazardous substances; thus, the focus is on the release, not precisely delineated boundaries. A Site is
defined as where a hazardous substance has been "deposited, stored, disposed, or placed, or has otherwise come to be
located." Generally, HRS scoring and the subsequent listing of a release merely represent the initial determination that
a certain area may need to be addressed under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA). Accordingly, EPA contemplates that the preliminary description of facility boundaries at
the time of scoring will be refined as more information is developed as to where the contamination has come to be
located.

1 "Ground water" and "groundwater" are synonymous; the spelling is different due to "ground water" being codified
as part of the HRS, while "groundwater" is the modern spelling.

1


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HRS SUMMARY SCORESHEETS
SITE NAME: J.H.BAXTER

CITY/COUNTY/STATE: Eugene. Lane County. Oregon
EPA ID#: ORD00903240Q

EVALUATOR: Christina Marquis	DATE: September 2024

LATITUDE: 44° 3'43.3872" N	LONGITUDE: 123° 9' 10.0584" W



s

s2

Ground Water Migration Pathway Score (Sgw)

Not scored

Not scored

Surface Water Migration Pathway Score (Ssw)

Not scored

Not scored

Soil Exposure and Subsurface Intrusion Pathway

Score (Ssessi)

63.40

4,019.56

Air Migration Pathway Score (Sa)

Not scored

Not scored

Sgw2 +Ssw2 + Ssessi2 + Sa2

xxxxxxx

4,019.56

(Sgw2 +Ssw2 + Ssessi2 + Sa2) / 4

xxxxxxx

1,004.89

SQRT ((Sgw2 +Ssw2 + Ssessi2 + Sa2) / 4)

xxxxxxx

31.70

2


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HRS Table 5-1	Soil Exposure Component Scoresheet

Factor Categories and Factors

Maximum
Value

Value
Assigned

Resident Population Threat





Likelihood of Exposure





1. Likelihood of Exposure

550

550

Waste Characteristics:





2. Toxicity

(a)

10,000

3. Hazardous Waste Quantity

(a)

10

4. Waste Characteristics

100

18

Targets:





5. Resident Individual

50

50

6. Resident Population:





6a. Level I Concentrations

(b)

405

6b. Level II Concentrations

(b)

68.35

6c. Resident Population (lines 6a + 6b)

(b)

473.35

7. Workers

15

5

8. Resources

5



9. Terrestrial Sensitive Environments

(c)



10. Targets (lines 5 +6c+ 7 + 8 +9)

(b)

528.35

Resident Population Threat Score:





11. Resident Population Threat (lines 1x4x10)

(b)

5,230,665

Nearby Population Threat





Likelihood of Exposure:





12. Attractiveness/Accessibility

100

NS

13. Area of Contamination

100

NS

14. Likelihood of Exposure

500

NS

Waste Characteristics:





15. Toxicity

(a)

NS

16. Hazardous Waste Quantity

(a)

NS

17. Waste Characteristics

100

NS

Targets:





18. Nearby Individual

1

NS

19. Population Within 1 Mile

(b)

NS

20. Targets (lines 18 + 19)

(b)

NS

Nearby Population Threat Score:





21. Nearby Population Threat (lines 14 x 17 x 20)

(b)

NS

Soil Exposure Pathway Score





22. Soil Exposure Pathway Scored (Ss), (lines [11 +21]/82,500,
subject to a maximum of 100)

100

63.40

aMaximum value applies to waste characteristics category.
bMaximum value not applicable.

cNo specific maximum value applies to factor. However, pathway score based solely on terrestrial-sensitive
environments is limited to maximum of 60.
dDo not round to nearest integer.

NS: Not Scored

3


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4


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~L8

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IT

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10


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ACRONYM LIST

l-ig/kg

micrograms per kilogram

^g/L

micrograms per liter

ACZA

ammoniacal copper zinc arsenate

AOC

Area of Observed Contamination

bgs

below ground surface

CEA

copper ethanolamine

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CFR

Code of Federal Regulations

cfs

cubic feet per second

CLP

Contract Laboratory Program

CRQL

Contract Required Quantitation Limit

dioxin

dibenzo-p-dioxins

DU

Decision Unit

EPA

United States Environmental Protection Agency

ERT

Environmental Response Team

ESU

Evolutionary Significant Unit

FR

Federal Register

furans

dibenzofurans

HpCDD

heptachlorodibenzo-p-dioxin

HpCDF

heptachl orodib enzofuran

HRS

Hazard Ranking System

HxCDD

hexachl orodib enzo-p-di oxin

HxCDF

hexachl orodib enzofuran

IA

Integrated Assessment

ID

identification number

ISM

Incremental Sampling Methodology

Keystone

Keystone Environmental Resources Ltd.

LRAPA

Lane Regional Air Protection Agency

MDL

Method Detection Limit

mg/kg

milligrams per kilogram

mg/L

milligrams per liter

ng/kg

nanograms per kilogram

No.

Number

NOV

Notice of Violation

NPL

National Priorities List

NS

Not Scored

NWI

National Wetlands Inventory

NWS

National Weather Service

OCDD

octachl orodib enzo-p-di oxin

OCDF

octachl orodib enzofuran

ODEQ

Oregon Department of Environmental Quality

PAH

polycyclic aromatic hydrocarbon

PCB

polychlorinated biphenyl

PCP

pentachlorophenol

PeCDD

pentachlorodibenzo-p-dioxin

11


-------
ACRONYM LIST (cont'd)

PeCDF

pentachl orodib enzofuran

PPE

Probable Point of Entry

ppt

parts per trillion

PRP

Potentially Responsible Party

RCRA

Resource Conservation and Recovery Act

REAC

Response Engineering and Analytical Contract

Ref.

Reference

RSE

Removal Site Evaluation

ROD

Record of Decision

SAP

Sampling and Analysis Plan

SCDM

Superfund Chemical Data Matrix

SOW

Statement of Work

SQL

Sample Quantitation Limit

START

Superfund Technical Assessment and Response Team

SVOC

semivolatile organic compound

TAL

Target Analyte List

TDL

Target Distance Limit

TO

Task Order

TOC

total organic carbon

USFWS

U.S. Fish and Wildlife Service

USGS

U.S. Geological Survey

VOC

volatile organic compound

Weston

Weston Solutions, Inc.

12


-------
NOTES TO HI! READER

Page numbers have been added to the references in the lower right corner. For reference citations,
please refer to the page numbers in this location.

13


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Oregon

Coordinate System:

WGS 1984 Web Mercator Auxiliary Sphere
Source:

Background: ESRI World Street Map*

Inset Background: ESRI Ocean Basemap*
Task Order No,:

68HE0722F0059

©

1.25

2.5

Legend:

(•) Site Location

*The source of this map
image is ESRI, used by the
EPA with ESRI's
c permission. Ref. 4, pp.
¦ Miles 269"270

EPA Region 10



Weston Solutions Inc.
START V

FIGURE 1

SITE LOCATION MAP

J. H. BAXTER
EUGENE, LANE COUNTY, OR

August 2024

14


-------
I _ „

k

. Outfall 002rTreated Groundwater

-Oji .

fWfW

Coordinate System:

WGS 1984 Web Mercator Auxiliary Sphere
Source:

Background: Nearmap 2022/07/10*

Task Order No.:

68HE0722F0059

125	250

500

¦ Feet

Legend:

[¦1 Surface Wiater Outfall

—	Site Drainage

—	— Underground Channel

Wood Storage Area
¦ i Facility Boundary
'The source of this map image is
Nearmap, used by the EPA with
Nearmap's permission. Site
features are from Ref. 4, p. 75

AF-'

EPA Region 10



Weston Solutions Inc.
START V

FIGURE 2

SITE FEATURES MAP

J. H. BAXTER
EUGENE, LANE COUNTY, OR

August 2024

15


-------
Coordinate System:

WGS 1984 Web Mercator Auxiliary Sphere
Source:

Background: NearMap 2023/05/29*

Task Order No.:

6SHE0722F0059

©

*The source of this map image is
Nearmap, used by the EPA with
Nearmap's permission. Site
features are from Ref. 4, pp. 79,
113. Sample locations collected
by Weston

Legend

0

Total Area of Observed Contamination

in facility = 714,744 sq ft.

Estimated Permeable Surfaces

Within Facility Area of Contamination = 595,515 sq ft.

EPA IA Surface Soil
Sample Location

Facility Boundary

"i AOC A - Facility

-•—J Contaminated Soil

75 150

300

¦ Feet

EPA Region 10



Weston Solutions Inc.
START V

FIGURE 3A

FACILITY

CONTAMINATED SOIL

J. H. BAXTER
EUGENE, LANE COUNTY, OR

August 2024

16


-------
Coordinate System:

WGS 1984 Web Mercator Auxiliary Sphere
Source:

Background: NearlVlap 2022/07/10*

Task Order No.:

68HE0722F0059

0

*The source of this map image is Le9end
Nearmap, used by the EPA with
Nearmap's permission. Site
features are from Ref. 4, pp. ~

30-32, 78, 81, 86, 113; Ref. 118, 			

p. 32. Sample locations collected I	1

Total Area of Observed Contamination by Weston and GSI
in residential neighborhood = 454,604 sq ft.

Estimated Permeable Surfaces ~
Within Residential Area of Contamination = 291,324 sq ft.	j	1

75	150	300

^^¦Feet

^ EPA IA Surface Soil Sample Location
EPA IA 2023 RSE ISM Sample Location
EPA IA 2022 RSE ISM Sample Location
ODEQ 2021 ISM Sample Location
Residential Parcels
AOC B - Residential Contaminate Soil

EPA Region 10



Weston Solutions Inc.
START V

FIGURE 3B

RESIDENTIAL
CONTAMINATED SOIL

J. H. BAXTER
EUGENE, LANE COUNTY, OR

July 2024

17


-------
West Eugene

jODEQ-BKGD-08

ODEQ-BKGBIQa!

¦MMMM

Legend

EPA IA Background Surface Soil

Sample Location

ODEQ ISM Background Sample

Location

EPA 2022 RSE ISM Background

Sample Location

EPA 2023 RSE ISM Background

Sample Location

Facility Boundary

Residential Parcels

,0DEQ-BKGIDI09

*The source of this map image is
ESRI, used by the EPA with
ESRI's permission.

**The source of this map image
is Nearmap, used by the EPA
with Nearmap's permission. Site
features are from Ref. 4 p. 78,
Ref. 4, pp. 30-32, 78, 80-81, 86,
113; Ref. 39, p. 34; Ref. 118, p.
32. Sample locations collected
by Weston and GSI

2

Miles

Coordinate System:

WGS 1984 Web Mercator Auxiliary Sphere
Source:

Background: ESRI World Imagery*

Inset Background: NearMap 2022/07/10**
Task Order No.:

68HE0722F0059

18


-------
sSS

f* IT/ 11

mSl

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» *J

IrvlngtonDr

W 11th Av*

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Coordinate System:

WGS 1984 Web Mercator Auxiliary Sphere
Source:

Background: ESRI World Topographic Map*

Inset Background: ESRI World Imagery*

Task Order No.:	ril .	.

-Qucn^ooimncn The source of this map image is ESRI,
joiilu / zzruuoy , , .. i—1-,« *ii

used by the EPA with ESRI s

©permission. Site features are from Ref.
4 p. 78. Site flowpath features are from
Ref. 4 p. 79, Ref. 4, pp. 76-77.

0.5

1

iMiles

Legend:

© JH Baxter Facility
—Flow Direction
Canal/Ditch

	Stream/River

Lake/Pond

EPA Region 10

prGS^

Weston Solutions Inc.
START V

FIGURE 5

SURFACE WATER
FEATURES

J. H. BAXTER
EUGENE, LANE COUNTY, OR

August 2024

19


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SITE DESCRIPTION

J. H. Baxter is a former wood-processing and treatment facility located at 3494 Roosevelt
Boulevard, formerly 85 Baxter Street, in southwest Eugene, Lane County, Oregon (Figure 1 and
Figure 2 of this HRS documentation record; Ref. 5, p. 10; Ref. 18, p. 6). For HRS scoring purposes,
the Site consists of the release of hazardous substances from wood-processing operations to two
areas of observed contamination (AOCs).

Hazardous substances associated with the AOCs include dibenzo-p-dioxin (dioxin) and
dibenzofuran (furan) congeners, polycyclic aromatic hydrocarbons (PAHs), phenols, including
pentachlorophenol (PCP), and metals, including cadmium, lead, and zinc (see Section 5.1 of this
HRS documentation record, General Considerations). Two AOCs are documented, AOC A is a
portion of the former facility property and AOC B is in the adjacent residential neighborhood
immediately to the north, with approximately 109 residents within AOC B subject to Level I or
Level II concentrations (see Sections 5.1 and 5.1.1.3 of this HRS documentation record).

The J. H. Baxter facility is bordered to the north by Roosevelt Boulevard, Roosevelt Channel, and
a residential neighborhood (Figures 2 and 3B of this HRS documentation record; Ref. 5, p. 10).
Residential properties are located immediately to the north of Roosevelt Boulevard and Roosevelt
Channel (Ref. 12, p. 34). The neighborhood north of the facility was developed in the 1950s (Ref
12, p. 17). The southern border of the facility is formed by the Union Pacific Railroad right-of-
way (Ref. 4, p. 10). Industrial businesses surround the facility, with a metal recycling facility on
the eastern boundary and plating, aviation, and lumber mill facilities to the west (Ref. 4, p. 10;
Ref. 5, p. 10; Ref. 16, p. 7; Ref. 93, pp. 1-3). The J. H. Baxter facility has been as large as 42.45
acres (Ref. 5, p. 10; Ref. 12, p. 17), but was reduced to 31.5 acres by 2019 (Ref. 6, p. 9).

Facility History

Before construction of the J. H. Baxter facility in 1943, the property was undeveloped farmland
(Ref. 6, p. 10; Ref. 7, p. 18; Ref. 12, p. 17; Ref. 14, p. 11). Operations at the facility consisted of
wood treating in retorts using a variety of preservative chemicals, including creosotes, PCP, metal-
based solutions, and fire retardants (Ref. 5, pp. 13-18; Ref. 10, pp. 3-4; Ref. 14, p. 5; Ref. 15, p.
17; Ref. 15, p. 57; Ref. 16, p. 9). After raw wood products were treated in the retorts, they were
transported via tram to concrete drip pads where the treated wood was allowed to dry until no
further drippage occurred. Following drying on the drip pad, treated wood products were either
stored on one of several treated wood-storage areas on facility property, or transported elsewhere
by truck or rail (Ref. 7, p. 20; Ref. 15, p. 18). The facility began with one retort, ultimately
expanding to five before the facility was "mothballed" in early 2022, ceasing wood-treatment
operations and only performing essential maintenance and environmental compliance (Ref. 5, p.
13; Ref. 8, p. 1).

Historical records describe a burn pit, 40 square feet in area and 4 feet deep, in the southwest
portion of the facility that was used for the disposal of waste between 1945 and 1955. Oil sludge
was added to the pit via 55-gallon drums and a pipeline coming from the process area. The pit was
excavated and filled in 1955, and a still-standing dry shed was constructed on the excavation
footprint (Ref. 5, p. 19; Ref. 6, p. 11; Ref. 7, p. 18; Ref. 10, p. 4; Ref. 15, p. 16). There are no
known records documenting whether the excavated fill was removed from the property (Ref. 5, p.
19; Ref. 7, p. 18, Ref. 15, p. 16). Later records indicate that hazardous waste was stored at the
facility in the main treatment area. A designated hazardous waste storage shed was constructed in
that area in 1982 and still stands today (Ref. 5, p. 20; Ref. 12, p. 18; Ref. 16, p. 10).

20


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The retorts were situated on pavement and diked (Ref. 5, p. 13; Ref. 6, p. 11; Ref. 7, p. 19; Ref. 12,
p. 19). However, approximately 80% of the rest of the facility is unpaved (Ref. 6, p. 11; Ref. 7,
p. 19; Ref. 12, p. 19). Before 1976, most of the stormwater runoff from the facility went into the
ground, with some runoff going into drainage ditches to the north and south (Ref. 7, p. 20; Ref. 15,
p. 18). Subsequently, most of the surface runoff on the facility was routed to and stored in a
retention pond in the southwest corner of the property, which, after some aeration and skimming,
was transferred to a drainage ditch, ultimately connecting to the A-3 drainage channel in the
Amazon Creek watershed (Ref. 5, p. 22). A stormwater treatment system began operations in 1997
(Ref. 15, p. 30; Ref. 18, p. 12). The Oregon Department of Environmental Quality (ODEQ) and J.
H. Baxter entered into a consent order in 1989 after groundwater contamination from facility
operations was found (Ref. 10, p. 6). A groundwater treatment system was installed in 1993 to
extract and remove contaminants, preventing continuing migration of contaminated water off of
the facility (Ref. 15, p. 29).

Since 1981, the J. H. Baxter facility has been subject to numerous regulatory investigations and
actions during its operation and after its closure (Ref. 5, p. 26; Ref. 6, pp. 13-14; Ref. 7, pp. 27-28,
37-39; Ref. 15, op. 21, 24; Ref. 16, p. 12). In 2007, a 10-acre interim remedial action measure soil
cap was installed throughout the eastern third of the property, to mitigate airborne transport of
contaminated soil away from the facility (Ref. 6, p. 11; Ref. 7 pp. 19, 44; Ref. 15, p. 32; Ref. 18,
pp. 6, 11). Since 1977, when the first air quality complaint was recorded, residents of the
neighborhoods to the north and northeast of the facility reported numerous complaints to the Lane
Regional Air Protection Agency (LRAPA) concerning odor and symptoms of illness (Ref. 59, p.
14; Ref. 88, p. 5, 7, 10). The number of air quality complaints peaked in 2004, with 762 complaints
recorded (Ref. 88, p. 7).

A notice of violation (NOV) was issued to J. H. Baxter in 2017 by EPA, after an investigation
found Resource Conservation and Recovery Act (RCRA) violations at the facility (Ref. 13). These
violations included lack of curbs or berms surrounding the retorts; failure to minimize tracking of
product off of the drip pad; failure to hold wood on the drip pad until drippage is complete; failure
to conduct weekly inspections of the drip pad; failure to properly label containers; disposal of
hazardous waste without a permit; failure to comply with land disposal restriction treatment
standards; and treatment and storage of hazardous wastes without a permit (Ref. 13, pp. 1-5). The
2017 NOV indicates that J. H. Baxter is a significant non-complier (Ref. 13, p. 6). In 2020 and
2021, a consultant hired by J. H. Baxter collected soil samples near the facility and in residential
properties. Results identified elevated levels of dioxins above ODEQ residential soil risk-based
concentration (4.7 parts per trillion [ppt]) in six residential yards out of seven sampled, with three
yards exceeding 40 ppt of dioxins (Ref. 17, pp. 1-2).

In 2019, DEQ issued a Record of Decision (ROD) that required cleanup at the facility as well as
off-facility soil sampling. In January 2022, ODEQ issued the facility a scope of work including
the residential soil remedial elements prescribed by the 2019 ROD. A week later, the company
president indicated that the facility would not be able to complete the required actions due to
financial limitations. The state was notified by the company president of their decision to
'mothball' the facility, suspending all wood treatment operations, while maintaining a skeleton
crew to oversee the groundwater, stormwater, and process water treatment systems (Ref. 17, p. 2).
ODEQ issued a subsequent Orphan Site declaration for J. H. Baxter & Co., making the company
eligible for remediation funding through the state and federal government (Ref. 17, pp. 1-2).
ODEQ has completed soil removals at seven residential properties located to the north of the
facility. The properties with removals were not included in population counts or hazardous waste
quantity values for AOC B (Ref. 41, pp. 10, 30; section 5.1.0 AOC B of this HRS documentation
record).

21


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4.0 SURFACE WATER MIGRATION PATHWAY

The Surface Water Migration Pathway was not scored, as its inclusion does not affect the listing
decision. The Surface Water Migration Pathway is, however, a concern to EPA.

The J. H. Baxter facility is located within the Amazon Creek watershed. The Amazon Creek
watershed has been modified extensively over the years through a series of manmade ditches and
channels (Ref. 4, p. 62-63; Ref. 5, pp. 21-22). Stormwater treatment system and groundwater
treatment system outflow from the J. H. Baxter facility discharge to Roosevelt Channel and its
tributaries, located adj acent to the north of the facility (Ref. 4, pp. 60-61). Roosevelt Channel flows
to the A3 channel, approximately 1 mile downstream of the facility. The A3 channel flows 1.24
miles to Amazon Creek. From Amazon Creek, it is a further 12.32 miles to the confluence with
Clear Lake, and an additional 1.05 miles to the confluence with the Long Tom River. An additional
diversion channel exists on Amazon Creek, 330 feet south of the A3 channel confluence. During
a high water event, it is possible that surface water entering Amazon Creek from the A3 channel
may backflow into the diversion channel. The Amazon Creek diversion channel flows for 3.81
miles until it reaches the Fern Ridge Reservoir, which continues for 3.4 miles to the confluence
with the Long Tom River (Ref. 4, p. 62-63).

From 1955 to 1981, the annual mean flow rate for Amazon Creek ranged from 17.4 cubic feet per
second (cfs) to 54 cfs. More recent gaging data was not available (Ref. 81). USGS gaging data was
not available for Roosevelt Channel A3 Channel, and Amazon Creek Diversion Channel. From
2014 to 2024, annual mean flow rate to Long Tom River at the outfall from Fern Ridge Lake
ranged from 299.4 cfs to 751.9 cfs (Ref. 80).

2023 EPA IA Sampling

EPA tasked Weston, under START Contract No. 68HE0720D005 and TO 68HE0722F0059, to
conduct an IA at the J. H. Baxter site (Ref. 4, p. 9). Sampling was conducted under an
EPA-approved site-specific SAP (Ref. 4, p. 19; Ref. 9). As part of the IA, sediment samples were
collected in May 2023. Sediment samples were collected from Amazon Creek and its unnamed
tributaries, Roosevelt Channel, South Channel, and Amazon Creek Diversion Channel (Ref. 4, pp.
20, 44). Samples were submitted for off-site fixed laboratory analysis for TAL VOCs, TAL
SVOCs, TAL Pesticides, TAL Aroclors, and TAL Inorganics, using CLP SOW SFAM01.1
methodology for all analyses (Ref. 4, p. 19-20, 25). Some predetermined locations were also
analyzed for dioxins and furans using CLP SOW HRSM02.1, Total Organic Carbon using PSEP-
TOC-M, and grain size (Ref. 4, pp. 20, 25). Dioxin/furan congeners and metals were detected in
sediments collected from downstream of the J. H. Baxter facility (Ref. 4, pp. 82-84, 571-585).

Surface Water Targets

No drinking water intakes are located within 15 miles downstream of the J. H. Baxter facility (Ref.
4, p. 63). During the 2023 IA sampling event, a resident informed EPA that crawfish caught in
Amazon Creek had been fished and consumed "regularly" during the summer months (Ref. 4, p.
399). Online message boards also indicate that fishing occurs in Amazon Creek, Amazon Creek
Diversion Channel, Fern Ridge Reservoir, and Clear Lake. Rainbow trout (Oncorhynchus mykiss),
largemouth bass (Micropterus salmoides), bluegill (Lepomis macrochirus), crappie (Pomoxis sp.),
common carp (Cyprinus carpio) and yellow bullhead (Ameiurus natalis) are species reportedly

22

SWOF


-------
caught from these water bodies (Ref. 52, pp. 2-4; Ref. 53, pp. 1-2; Ref. 54, pp. 1-2, 8-16; Ref. 84,
pp. 1-2, 7-17).

Wetlands are located along Roosevelt Channel, A3 Channel, Amazon Creek, and Amazon Creek
Diversion Channel within 15 miles downstream of the J. H. Baxter facility (Ref. 4, p. 64; Ref. 56).
Long Tom River provides habitat known to be used by the Federal-listed threatened Upper
Willamette River Evolutionarily Significant Unit (ESU) Chinook salmon (Oncorhynchus
tshawytschd) (Ref. 4, p. 64).

23

SWOF


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5.0 SOIL EXPOSURE AND SUBSURFACE INTRUSION PATHWAY

5.1 SOIL EXPOSURE COMPONENT

Two areas of observed contamination (AOCs) attributable to the J. H. Baxter site were evaluated for
scoring. Descriptions of the individual areas, with reference citations, are provided in the sections below.

AOC A is the Facility Contaminated Soil, measuring approximately 714,744 square feet on the facility.
AOC B is the Residential Contaminated Soil, measuring approximately 454,604 square feet within the
neighborhood to the north of the facility. Hazardous substances associated with these AOCs include dioxin
and furan congeners, metals, pesticides, and SVOCs. Detailed information about hazardous substances
and hazardous waste quantities in each source, with reference citations, is available in Section 5.1.0 of
this HRS documentation record.

Approximately 109 residents occupy residential properties within AOC B (Tables 21 and 22 of this HRS
documentation record).

Table 1 J. H. Baxter Areas of Observed Contamination

AOC

AOC Name

AOC Type

A

Facility Contaminated Soil

Contaminated Soil

B

Residential Contaminated Soil

Contaminated Soil

24

SE-General


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5.1.0 GENERAL CONSIDERATIONS

Letter by which this AOC is to be identified: A
Name of AOC: Facility Contaminated Soil
AOC Type: Contaminated Soil

Location and description of area (see Figure 3 A of this HRS documentation record):

AOC A consists of contaminated soil within the J. H. Baxter facility property (Tables 2 through 4 and
Figure 3 A of this HRS documentation record). Soil contamination was a result of historical operations as
a wood-treatment facility. Operations at the facility included high-pressure wood treating in retorts using
a variety of preservative chemicals, including PCP, ACZA, 50/50 Heavy Oil Blends of Creosote and
Bunker C Oil (50/50), Creosote, and Alkaline Copper Quaternary-Type B (ACQ) (Ref. 5, pp. 13-18; Ref.
10, pp. 3-4; Ref. 14, p. 5; Ref. 15, pp. 17, 57; Ref. 16, p. 9; Ref. 87, pp. 9). After raw wood products were
treated in the retorts, they were transported via tram to concrete drip pads where the treated wood was
allowed to dry until no further drippage occurred. After drying on the drip pad, treated wood products
were either stored on one of several on-property treated wood-storage areas or transported off-property by
truck or rail (Ref. 7, pp. 20, 40; Ref. 15, p. 18; Ref. 87, p. 11).

In 2017, EPA issued J.H. Baxter & Co. a NOV detailing eight RCRA violations found during an inspection
in 2014. Several of the violations were related to hazardous materials interacting with soil due to
inadequate drip pad infrastructure and maintenance associated with the retorts, which are located within
AOC A. The EPA inspector observed several such instances, noting that "[i]n some areas, the oily
substance, waste wood preservative (EPA hazardous wastes numbers F032 and F034), had stained and
soaked into the soil, and in other areas the hazardous waste (waste wood preservative) was pooled on the
soil surface." In two other instances, the inspector noted PCP leakage from a pump hose and a pipe
connected to a PCP storage tank. The releases were deemed "disposals," and the facility was cited for
disposal of hazardous waste without a permit and for failure to comply with Land Disposal Restrictions
treatment standards. Based on the severity of these violations, the NOV classified the J. H. Baxter facility
as a "significant non-complier" (Figure 2 and Figure 3A of this HRS documentation record; Ref. 13, pp.
1-6).

Based on the soil sampling described below, AOC A was measured based on samples with concentrations
significantly above background. AOC A measures approximately 714,744 square feet (see Figure 3A of
this HRS documentation record).

AOC A is documented below based on the 2023 EPA IA soil sampling event. Contaminated samples are
compared to background samples collected during the same sampling event using the same field and
analytical methods (Table 2, Table 3, and Table 4 of this HRS documentation record; Ref. 4, pp. 17-18).
Background locations are shown on Figure 4 of this HRS documentation record. Contaminated samples
used to document AOC A are shown on Figure 3 A of his HRS documentation record. Grab surface soil
sampling for the IA was conducted by START on the J. H. Baxter facility and on residential properties in
2023 (Ref. 4, pp. 17, 19).

25

SE-Resident Population Threat


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EPA IA 2023 Site Assessment Surface Soil Samples

EPA tasked Weston Solutions, Inc. (Weston), under START Contract Number (No.) 68HE0720D005 and
Task Order (TO) 68HE0722F0059, to conduct an IA of the J. H. Baxter site (Ref. 4, p. 9). Sampling was
conducted under an EPA-approved site-specific Sampling and Analysis Plan (SAP) (Ref. 4, p. 19; Ref.
9). AOC A sampling was conducted in May 2023 (Ref. 4, pp. 17, 19).

Sample locations are presented on Figure 3A and Figure 4 of this HRS documentation record. In May
2023, twelve surface soil field samples were collected at the J. H. Baxter facility from 0 to 6 inches bgs.
Two background soil samples were collected for comparison to the contaminated soils (Ref. 4, p. 20).
Background locations included two public parks in Eugene, Oregon, located 3/4-mile northwest and 2 ]A-
miles south of the facility (Figure 4 of this HRS documentation record; Ref. 4, p. 19). Samples were
collected as grab samples from 0 to 6 inches bgs using a non-dedicated hand auger, which was
decontaminated after each use (Ref. 4, p. 17-18).

Samples were submitted for off-site fixed laboratory analysis for TAL VOCs (SFAM01.1), TAL SVOCs
(SFAM01.1), TAL Pesticides (SFAM01.1), TAL Aroclors (SFAM 01.1), TAL Inorganics (SFAM 01.1),
and dioxins/furans (HRSM02.1). All samples were analyzed under EPA CLP Statement of Work (SOW)
SFAM01.1, with the exceptions of dioxins and furans which were analyzed under CLP SOW HRSM02.1
(Ref. 4, pp. 19-21, 25-26). All sample analyses were validated following EPA's Stage 4 Data Validation
Electronic/Manual Process. A START chemist performed a Stage 1 verification of each CLP data package.
(Ref. 4, p. 26).

- Background Surface Soil

During the IA, background surface soils were collected from two locations not expected to be affected by
historical site operations. Sample JHB-S13 was collected from a public park 3/4-mile northwest believed
to be outside the influence of emissions sources at the J. H. Baxter facility. Sample JHB-S14 was collected
from a public park 2 H-miles south of the facility and believed to be outside the influence of migrant dust
emissions from the J. H. Baxter facility (Ref. 4, p. 43).

26

SE-Resident Population Threat


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Table 2

EPA IA Site Assessment Background Surface Soil Concentrations

Sample
ID

Sampling
Date

Units

Hazardous Substance

Result

Sample
Adjusted
CRQL*

Soil
Description

References

JHB-S13

5/2/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

95

5.0

Medium-dark

Ref. 4, pp. 43,





ng/kg

1,2,3,4,6,7,8-HpCDF

27

5.0

brown, mostly

80, 309, 397,





ng/kg

1,2,3,4,7,8,9-HpCDF

1.6 JO

5.0

silt with few

562, 1845-





ng/kg

1,2,3,4,7,8-HxCDD

1.3 JO

5.0

clay & gravel,

1847, 3211,





ng/kg

1,2,3,4,7,8-HxCDF

2.2 JO

5.0

moist, cohesive

3240, 3298,





ng/kg

1,2,3,6,7,8-HxCDD

3.9 JO

5.0



3314, 3316;





ng/kg

1,2,3,6,7,8-HxCDF

1.5 JO

5.0



Ref. 60, pp.
438, 619; Ref.
123, pp. 43,
181, 589





ng/kg

1,2,3,7,8,9-HxCDD

2.3 JQ

5.0







ng/kg

1,2,3,7,8,9-HxCDF

0.9 JQ

5.0







ng/kg

1,2,3,7,8-PeCDD

1 JQ

5.0







ng/kg

1,2,3,7,8-PeCDF

0.84 JQ

5.0









ng/kg

2,3,4,6,7,8-HxCDF

2 JQ

5.0









ng/kg

2,3,4,7,8-PeCDF

1.2 JQ

5.0









ng/kg

2,3,7,8-TCDD

0.35 JQ

1.0









ng/kg

OCDF

44

10









mg/kg

Antimony

7.6 U

7.6









mg/kg

Arsenic

5.7

1.3









mg/kg

Cadmium

0.63 U

0.63









mg/kg

Chromium

22

1.3









mg/kg

Copper

21

3.2









mg/kg

Lead

23

1.3









mg/kg

Selenium

4.4 U

4.4









mg/kg

Silver

1.3 U

1.3









mg/kg

Zinc

80

7.6









Ug/kg

Anthracene

190 U

190









Ug/kg

Benzo(a)anthracene

190 U

190









Ug/kg

Benzo(a)pyrene

190 U

190









Ug/kg

Benzo(g,h,i)perylene

190 U

190









Ug/kg

Benzo(k)fluoranthene

190 U

190









Ug/kg

Bis(2-

ethylhexyl)phthalate

190 U

190









Ug/kg

Chrysene

190 U

190









Ug/kg

Fluoranthene

190 U

190









Ug/kg

Indeno(l ,2,3 -cd)pyrene

190 U

190









Ug/kg

Pentachlorophenol

370 U

370









Ug/kg

Phenanthrene

190 U

190









Ug/kg

Pyrene

190 U

190





27

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Table 2

EPA IA Site Assessment Background Surface Soil Concentrations

Sample
ID

Sampling
Date

Units

Hazardous Substance

Result

Sample
Adjusted
CRQL*

Soil
Description

References

JHB-S14

5/2/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

15

5.0

medium-dark

Ref. 4, pp. 43,





ng/kg

1,2,3,4,6,7,8-HpCDF

1.6 JO

5.0

brown, mostly

80, 311-312,





ng/kg

1,2,3,4,7,8,9-HpCDF

0.43 UJ

5.0

silt to clay with

397, 562,





ng/kg

1,2,3,4,7,8-HxCDD

0.25 UJ

5.0

some large,

1851-1853,





ng/kg

1,2,3,4,7,8-HxCDF

0.36 UJ

5.0

angular gravel

2389, 3211,





ng/kg

1,2,3,6,7,8-HxCDD

0.69 J

5.0



3240, 3298,





ng/kg

1,2,3,6,7,8-HxCDF

0.31 UJ

5.0



3300-3301,
3303, 3314,
3316; Ref. 60,
p. 440; Ref.
121, p. 19;
Ref. 123, pp.
46-47, 182,
641





ng/kg

1,2,3,7,8,9-HxCDD

0.48 JQ

5.0







ng/kg

1,2,3,7,8,9-HxCDF

0.31 UJ

5.0







ng/kg

1,2,3,7,8-PeCDD

0.26 UJ

5.0







ng/kg

1,2,3,7,8-PeCDF

0.27 UJ

5.0







ng/kg

2,3,4,6,7,8-HxCDF

0.26 UJ

5.0







ng/kg

2,3,4,7,8-PeCDF

0.35 UJ

5.0







ng/kg

2,3,7,8-TCDD

0.15 UJ

1.0







ng/kg

OCDF

4.1 UJ

10









mg/kg

Antimony

6.8 U

6.8









mg/kg

Arsenic

42

1.1









mg/kg

Cadmium

0.32 JQ

0.56









mg/kg

Chromium

41

1.1









mg/kg

Copper

65

2.9









mg/kg

Lead

7.7

1.1









mg/kg

Selenium

4 U

4.0









mg/kg

Silver

1.1 U

1.1









mg/kg

Zinc

52

6.8









Ug/kg

Anthracene

240 U

240









Ug/kg

Benzo(a)anthracene

240 U

240









Ug/kg

Benzo(a)pyrene

240 U

240









Ug/kg

Benzo(g,h,i)perylene

240 U

240









Ug/kg

Benzo(k)fluoranthene

240 U

240









Ug/kg

Bis(2-

ethylhexyl)phthalate

240 U

240









Ug/kg

Chrysene

240 U

240









Ug/kg

Fluoranthene

240 U

240









US/kg

Indeno(l ,2,3 -cd)pyrene

240 U

240









US/kg

Pentachlorophenol

470 U

470









US/kg

Phenanthrene

240 U

240









US/kg

Pyrene

240 U

240





Notes:

CRQL: EPA Contract Laboratory Program Contract Required Quantitation Limit

EPA: United States Environmental Protection Agency

HpCDD Heptachlorodibenzo-p-dioxin

HpCDF Heptachlorodibenzofuran

HxCDD Hexachlorodibenzo-p-dioxin

HxCDF Hexachlorodibenzofuran

IA Integrated Assessment

mg/kg: milligrams per kilogram

ng/kg: nanograms per kilogram

Ug/kg: micrograms per kilogram

28

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OCDF Octachlorodibenzofuran
PeCDD Pentachlorodibenzo-p-dioxin
PeCDF Pentachlorodibenzofuran
TCDD Tetrachlorodibenzo-p-dioxin

U:	The material was analyzed for but was not detected above the level of the associated value. The associated value

is either the sample quantitation limit or the sample detection limit. (Ref. 60, p. 421)

J: The associated value is an estimated quantity (Ref. 60, p. 421)

Q: Concentration is below the CRQL but is above the method detection limit (Ref. 60, p. 421)

*: Since the samples were analyzed through the CLP, the CRQLs presented above are equivalent to the CRQL as defined
by the HRS (Ref. 1, Sections 1.1 and 2.3).

The minimum standard to establish observed contamination by chemical analysis is analytical evidence
of a hazardous substance significantly above the background level, and some portion of the significant
increase above the background level is attributable to the Site. In accordance with HRS Table 2-3, if the
background concentration is not detected, a significant increase is established when the sample
measurement equals or exceeds the SQL. If the SQL cannot be established, if the sample analysis was
performed under the EPA CLP, use the EPA CRQL in place of the SQL. If the sample analysis is not
performed under the EPA CLP, use the detection limit (DL) in place of the SQL. If the background
concentration equals or exceeds the detection limit, a significant increase is established when the sample
measurement is three times or more above the background concentration (Ref. 1, Section 2.3).

29

SE-Resident Population Threat


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Table 3

Background Levels to Establish Surface Soil AOC A

Sample
Type

Hazardous
Substance

Maximum Background
Concentration
2023 IA Sampling
Results

HRS Table 2-3
Minimum Concentration to Document
Observed Contamination by Chemical
Analysis



1,2,3,4,6,7,8-HpCDD

95

285



1,2,3,4,6,7,8-HpCDF

27

81



1,2,3,4,7,8,9-HpCDF

1.6 JO

4.8



1,2,3,4,7,8-HxCDD

1.3 JO

3.9



1,2,3,4,7,8-HxCDF

2.2 JO

6.6



1,2,3,6,7,8-HxCDD

3.9 JO

11.7



1,2,3,6,7,8-HxCDF

1.5 JO

4.5



1,2,3,7,8,9-HxCDD

2.3 JO

6.9



1,2,3,7,8,9-HxCDF

0.9 JO

2.7



1,2,3,7,8-PeCDD

1 JO

3



1,2,3,7,8-PeCDF

0.84 JO

2.52



2,3,4,6,7,8-HxCDF

2 JO

6



2,3,4,7,8-PeCDF

1.2 JO

3.6



2,3,7,8-TCDD

0.35 JO

1.05



OCDF

44

132



Antimony

7.6 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



Arsenic

42

126



Cadmium

0.32 JO

0.96



Chromium

41

123



Copper

65

195



Lead

23

69

Surface
Soil

Selenium

4.4 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL

Silver

1.3 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



Zinc

80

240



Anthracene

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



Benzo(a)anthracene

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



E3enzo(a)pyrene

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



Benzo(g,h,i)perylene

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



Benzo(k)fluoranthene

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



Bis(2-

ethylhexyl)phthalate

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



Chrysene

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



Fluoranthene

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



lndeno( 1,2,3 -cd)pyrene

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



Pentachlorophenol

470 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL

30

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Table 3

Background Levels to Establish Surface Soil AOC A

Sample
Type

Hazardous
Substance

Maximum Background
Concentration
2023 IA Sampling
Results

HRS Table 2-3
Minimum Concentration to Document
Observed Contamination by Chemical
Analysis



Phenanthrene

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL



Pyrene

240 U

The sample measurement equals or exceeds the sample
quantitation limit or CRQL

Notes:



CRQL:

EPA Contract Laboratory Program Contract Required Quantitation Limit

EPA:

United States Environmental Protection Agency

HpCDD

Heptachlorodibenzo-p-dioxin

HpCDF

Heptachlorodibenzofuran

HxCDD

Hexachlorodibenzo-p-dioxin

HxCDF

Hexachlorodibenzofuran

IA

Integrated Assessment

mg/kg:

milligrams per kilogram

ng/kg:

nanograms per kilogram

Hg/kg:

micrograms per kilogram

OCDF

Octachlorodibenzofuran

PeCDD

Pentachlorodibenzo -p-dioxin

PeCDF

Pentachlorodibenzofuran

TCDD

Tetrachlorodibenzo-p-dioxin

U:
J:

The material was analyzed for but was not detected above the level of the associated value. The associated value
is either the sample quantitation limit or the sample detection limit. (Ref. 60, p. 421)

The associated value is an estimated quantity (Ref. 60, p. 421)

Q:

Concentration is below the CRQL but is above the method detection limit (Ref. 60, p. 421). Results that are
qualified due to detection at or above the detection limit but below the quantitation limit are not considered biased.
The concentration is used without applying an adjustment factor (Ref. 50, pp. 6, 8).

- Contaminated Soil Samples

Table 4 EPA IA Site Assessment AOC A Contaminated Soil Concentrations

Sample
ID

Sample
Date

Units

Hazardous Substance

Concentration

Sample
Adjusted
CRQL*

Soil Description

References

JHB-
S01

5/4/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

16,000

100

Compacted layer of
gravel in first 2-3
inches of soil, with
clay that was very
cohesive on lower 3-4
inches. Larger pieces
of gravel removed &
clods crumbled before
homogenizing. Soil a
medium-dark brown
color.

Ref. 4, pp. 46,
79, 284-285,
296, 400, 559,
3197-3198,
3254, 3293,
3313,3315;
Ref. 60, p.
606; Ref. 123,
pp. 541

ng/kg

1,2,3,4,6,7,8-HpCDF

3,100

100

ng/kg

1,2,3,4,7,8,9-HpCDF

240

100

ng/kg

1,2,3,4,7,8-HxCDD

120

100

ng/kg

1,2,3,4,7,8-HxCDF

110

100

ng/kg

1,2,3,6,7,8-HxCDD

540

100

ng/kg

1,2,3,7,8,9-HxCDD

230

100

ng/kg

2,3,4,6,7,8-HxCDF

100

100

mg/kg

OCDF

14,000

200

31

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Table 4 EPA IA Site Assessment AOC A Contaminated Soil Concentrations

Sample
ID

Sample
Date

Units

Hazardous Substance

Concentration

Sample
Adjusted
CRQL*

Soil Description

References

JHB-

S02

5/4/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

37,000

100

Collected in path of
storm drain. Soil was
sandy with some silt,
somewhat compacted,
light-medium brown
with some gravel (20-
30% of sample), which
was removed prior to
homogenization.

Ref. 4, pp. 46,
55, 79, 286-
287, 400, 559,
3213,3252,
3293,3313,
3315; Ref. 60,
pp. 336, 607;
Ref. 123, pp.
215,545

ng/kg

1,2,3,4,6,7,8-HpCDF

5,800

100

ng/kg

1,2,3,4,7,8,9-HpCDF

440

100

ng/kg

1,2,3,4,7,8-HxCDD

560

100

ng/kg

1,2,3,4,7,8-HxCDF

290

100

ng/kg

1,2,3,6,7,8-HxCDD

2,000

100

ng/kg

1,2,3,6,7,8-HxCDF

280

100

ng/kg

1,2,3,7,8,9-HxCDD

1,000

100

ng/kg

1,2,3,7,8,9-HxCDF

120

100

ng/kg

1,2,3,7,8-PeCDD

340

100

ng/kg

2,3,4,6,7,8-HxCDF

370

100

ng/kg

2,3,7,8-TCDD

33

20

ng/kg

OCDF

14,000

200

mg/kg

Copper

230

2.4

mg/kg

Lead

70

0.96

JHB-

S03

5/5/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

60,000

250

Soil very compacted,
grey-brown in top 2
inches, medium dark
brown beneath. Mostly
gravel, sand, trace silt.

Ref. 4, pp. 46-
47, 57, 288-
289, 401, 559,
642-644,
3201, 3270,
3293,3317,
3319; Ref. 60,
p. 641; Ref.
123, pp. 99-
100, 458, 462

ng/kg

1,2,3,4,6,7,8-HpCDF

9,000

250

ng/kg

1,2,3,4,7,8,9-HpCDF

620

5.0

ng/kg

1,2,3,4,7,8-HxCDD

340

5.0

ng/kg

1,2,3,4,7,8-HxCDF

320

5.0

ng/kg

1,2,3,6,7,8-HxCDD

1,900

5.0

ng/kg

1,2,3,6,7,8-HxCDF

180

5.0

ng/kg

1,2,3,7,8,9-HxCDD

870

5.0

ng/kg

1,2,3,7,8,9-HxCDF

140

5.0

ng/kg

1,2,3,7,8-PeCDD

200

5.0

ng/kg

1,2,3,7,8-PeCDF

57

5.0

ng/kg

2,3,4,6,7,8-HxCDF

320

5.0

ng/kg

2,3,4,7,8-PeCDF

54

5.0

ng/kg

2,3,7,8-TCDD

13

1.0

ng/kg

OCDF

93,000

500

^g/kg

Benzo(a)pyrene

250

190

^g/kg

Bis(2-ethylhexyl)phthalate

7,100

970

^g/kg

Chrysene

320

190

^g/kg

Fluoranthene

330

190

^g/kg

PCP

610

380

^g/kg

Pyrene

320

190

32

SE-Resident Population Threat


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Table 4

EPA IA Site Assessment AOC A Contaminated Soil Concentrations



Sample
ID

Sample
Date

Units

Hazardous Substance

Concentration

Sample
Adjusted
CRQL*

Soil Description

References

JHB-

5/5/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

44,000

100

Moderately to very

Ref. 4, pp. 47,

S04



ng/kg

1,2,3,4,6,7,8-HpCDF

10,000

100

compact, grey in top 1

55-57, 79,





ng/kg

1,2,3,4,7,8,9-HpCDF

700

100

inch, then dark brown.

290-291, 401,





ng/kg

1,2,3,4,7,8-HxCDD

510

100

Soil was mostly gravel

559, 648-650,





ng/kg

1,2,3,4,7,8-HxCDF

440

100

and sand.

3201, 3270,





ng/kg

1,2,3,6,7,8-HxCDD

1,900

100



3293, 3313,
3315; Ref. 60,
pp. 342, 608;
Ref. 123, pp.
107,218, 549





ng/kg

1,2,3,6,7,8-HxCDF

270

100







ng/kg

1,2,3,7,8,9-HxCDD

940

100







ng/kg

1,2,3,7,8,9-HxCDF

160

100







ng/kg

1,2,3,7,8-PeCDD

280

100







ng/kg

1,2,3,7,8-PeCDF

100

100









ng/kg

2,3,4,6,7,8-HxCDF

460

100









ng/kg

2,3,7,8-TCDD

20

20









ng/kg

OCDF

41,000

200









mg/kg

Cadmium

1.3

0.37









mg/kg

Zinc

280

4.5









^g/kg

PCP

800

380





JHB-

5/5/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

860,000

3,400

On edge of asphalt

Ref. 4, p. 47,

S05



ng/kg

1,2,3,4,6,7,8-HpCDF

130,000

3,400

near northern edge of

55, 57, 79,





ng/kg

1,2,3,4,7,8,9-HpCDF

9,900

3,400

tank farm. Soil was

292, 401, 559,





ng/kg

1,2,3,4,7,8-HxCDD

3,900

3,400

moderately to very

679, 680,





ng/kg

1,2,3,4,7,8-HxCDF

9,700

3,400

compact mix of sand

3201, 3270,





ng/kg

1,2,3,6,7,8-HxCDD

29,000

3,400

and smaller gravel.

3307, 3325;





ng/kg

1,2,3,7,8,9-HxCDD

9,300

3,400

Soil had green
sheening (likely
copper). Located near
sample site is a pipe
labeled "ACZA
receiving line." Soil
otherwise a light to
medium brown.

Ref. 60, pp.
520, 680; Ref.
123, pp. 128,
131, 137, 338





ng/kg

2,3,4,6,7,8-HxCDF

5,300

3,400





mg/kg

Antimony

260

5.9





mg/kg

Arsenic

16,000

25





mg/kg

Cadmium

270

0.49







mg/kg

Chromium

3,500

25







mg/kg

Copper

32,000

62







mg/kg

Lead

490

0.99







mg/kg

Selenium

11

3.5









mg/kg

Silver

1.6

0.99









mg/kg

Zinc

9,400

150









^g/kg

Anthracene

490

240









^g/kg

Benzo(a)anthracene

390

240









^g/kg

Benzo(a)pyrene

350

240









^g/kg

Benzo(g,h,i)perylene

590

240









^g/kg

Benzo(k)fluoranthene

390

240









^g/kg

Bis(2-ethylhexyl)phthalate

1,900

240









Ug/kg

Chrysene

860

240









Ug/kg

Fluoranthene

1,000

240









Ug/kg

Indeno( 1,2,3 -cd)pyrene

520

240









Ug/kg

PCP

6,400

930









Ug/kg

Phenanthrene

550

240









Ug/kg

Pyrene

840

240





33

SE-Resident Population Threat


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Table 4 EPA IA Site Assessment AOC A Contaminated Soil Concentrations

Sample
ID

Sample
Date

Units

Hazardous Substance

Concentration

Sample
Adjusted
CRQL*

Soil Description

References

JHB-

S06

5/4/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

59,000

200

Located in area of
heavy staining with an
oily substance, which
had strong petroleum-
like odor. Up to 4
inches bgs was
collected due to
impenetrable layer of
cobbles beyond this.
Sample was sandy
with some gravel
mixed in.

Ref. 4, pp. 48,
55, 57, 79,
294-295, 400,
559, 1888,
3214,3243,
3294, 3305,
3325; Ref. 60,
p. 501, 677
Ref. 123, pp.
70, 169, 314,
318

ng/kg

1,2,3,4,6,7,8-HpCDF

5,600

50

ng/kg

1,2,3,4,7,8,9-HpCDF

390

50

ng/kg

1,2,3,4,7,8-HxCDD

210

50

ng/kg

1,2,3,4,7,8-HxCDF

400

50

ng/kg

1,2,3,6,7,8-HxCDD

3,000

50

ng/kg

1,2,3,6,7,8-HxCDF

210

50

ng/kg

1,2,3,7,8,9-HxCDD

460

50

ng/kg

1,2,3,7,8,9-HxCDF

230

50

ng/kg

1,2,3,7,8-PeCDD

110

50

ng/kg

1,2,3,7,8-PeCDF

110

50

ng/kg

2,3,4,6,7,8-HxCDF

430

50

ng/kg

2,3,4,7,8-PeCDF

110

50

ng/kg

OCDF

28,000

100

mg/kg

Cadmium

0.97

0.39

^g/kg

Pentachlorophenol

1,000

350

JHB-

S07

5/4/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

38,000

50

Collected near
historical burn pit.
Sample was heavy
gravel in first 3 inches,
becoming clay in
lower 3 inches. Very
compact and dry.
Upper layer was light
brown-gray, lower
layer dark brown.

Ref. 4, p. 48,
79, 400, 559,
3197,3254,
3293,3317,
3319; Ref. 60,
p. 642; Ref.
123, pp., 470,
474

ng/kg

1,2,3,4,6,7,8-HpCDF

4,700

50

ng/kg

1,2,3,4,7,8,9-HpCDF

280

5.0

ng/kg

1,2,3,4,7,8-HxCDD

190

5.0

ng/kg

1,2,3,4,7,8-HxCDF

130

5.0

ng/kg

1,2,3,6,7,8-HxCDD

620

5.0

ng/kg

1,2,3,6,7,8-HxCDF

54

5.0

ng/kg

1,2,3,7,8,9-HxCDD

280

5.0

ng/kg

1,2,3,7,8,9-HxCDF

19

5.0

ng/kg

1,2,3,7,8-PeCDD

130

5.0

ng/kg

1,2,3,7,8-PeCDF

16

5.0

ng/kg

2,3,4,6,7,8-HxCDF

77

5.0

ng/kg

2,3,7,8-TCDD

10

0.99

ng/kg

2,3,4,7,8-PeCDF

24

5.0

ng/kg

OCDF

32,000

99

JHB-

S08

5/4/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

21,000

100

Soil medium-dark
brown, mix of sand
and silt with about
10% small pebbles.

Ref. 4, pp. 49,
55, 79, 400,
559,3213,
3252, 3293,
3313,3315;
Ref. 60, pp.
346, 609; Ref.
123, pp. 220,
553

ng/kg

1,2,3,4,6,7,8-HpCDF

4,700

100

ng/kg

1,2,3,4,7,8,9-HpCDF

270

100

ng/kg

1,2,3,4,7,8-HxCDD

100

100

ng/kg

1,2,3,4,7,8-HxCDF

180

100

ng/kg

1,2,3,6,7,8-HxCDD

900

100

ng/kg

1,2,3,7,8,9-HxCDD

250

100

ng/kg

2,3,4,6,7,8-HxCDF

110

100

ng/kg

OCDF

24,000

200

mg/kg

Zinc

280

5.3

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Table 4 EPA IA Site Assessment AOC A Contaminated Soil Concentrations

Sample
ID

Sample
Date

Units

Hazardous Substance

Concentration

Sample
Adjusted
CRQL*

Soil Description

References

JHB-

S09

5/4/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

29,000

50

Soil heavily
compacted with 60%
gravel, removed prior
to homogenizing.
Non-gravel was sandy,
medium brown.

Ref. 4, pp. 49,
57, 79, 301-
302, 400, 559,
1636, 1637,
3213,3252,
3293,3317,
3319; Ref. 60,
p. 643; Ref.
123, pp. 11,
474, 478

ng/kg

1,2,3,4,6,7,8-HpCDF

5,300

50

ng/kg

1,2,3,4,7,8,9-HpCDF

310

5.0

ng/kg

1,2,3,4,7,8-HxCDD

270

5.0

ng/kg

1,2,3,4,7,8-HxCDF

220

5.0

ng/kg

1,2,3,6,7,8-HxCDD

1,000

5.0

ng/kg

1,2,3,6,7,8-HxCDF

180

5.0

ng/kg

1,2,3,7,8,9-HxCDD

500

5.0

ng/kg

1,2,3,7,8,9-HxCDF

89

5.0

ng/kg

1,2,3,7,8-PeCDD

170

5.0

ng/kg

1,2,3,7,8-PeCDF

56

5.0

ng/kg

2,3,4,6,7,8-HxCDF

250

5.0

ng/kg

2,3,4,7,8-PeCDF

47

5.0

ng/kg

2,3,7,8-TCDD

17

1.0

ng/kg

OCDF

21,000

100

^g/kg

Benzo(g,h,i)perylene

260

180

^g/kg

Fluoranthene

190

180

JHB-
S10

5/4/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

43,000

50

Located near stained
area, likely water
staining. Sample was
compacted with mix of
gravel and sand, going
from grey-light brown
at surface to medium
brown about 1 inch
below.

Ref. 4, pp. 50,
57, 79, 303-
304, 400, 559,
661,662,
2560,3197,
3254, 3295,
3306,3313,
3315; Ref. 60,
p. 611; Ref.
123, pp. 116,
561

ng/kg

1,2,3,4,6,7,8-HpCDF

11,000

50

ng/kg

1,2,3,4,7,8,9-HpCDF

710

50

ng/kg

1,2,3,4,7,8-HxCDD

420

50

ng/kg

1,2,3,4,7,8-HxCDF

440

50

ng/kg

1,2,3,6,7,8-HxCDD

1,800

50

ng/kg

1,2,3,6,7,8-HxCDF

300

50

ng/kg

1,2,3,7,8,9-HxCDD

840

50

ng/kg

1,2,3,7,8,9-HxCDF

160

50

ng/kg

1,2,3,7,8-PeCDD

250

50

ng/kg

1,2,3,7,8-PeCDF

97

50

ng/kg

2,3,4,6,7,8-HxCDF

500

50

ng/kg

2,3,4,7,8-PeCDF

83

50

ng/kg

2,3,7,8-TCDD

13

10

ng/kg

OCDF

36,000

100

^g/kg

Benzo(g,h,i)perylene

260

180

^g/kg

Fluoranthene

200

180

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Table 4 EPA IA Site Assessment AOC A Contaminated Soil Concentrations

Sample
ID

Sample
Date

Units

Hazardous Substance

Concentration

Sample
Adjusted
CRQL*

Soil Description

References

JHB-
Sll

5/4/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

63000

250

Soil was very
compact, mix of sand
and gravel. Grey-light
brown at surface,
medium brown about
1 inch below.

Ref. 4, pp. 50,
55, 58, 79,
305-306, 400,
559, 667, 668,
3197,3254,
3295, 3306,
3319; Ref. 60,
pp. 356, 645;
Ref. 123, pp.
119-120, 225,
490, 494

ng/kg

1,2,3,4,6,7,8-HpCDF

9400

250

ng/kg

1,2,3,4,7,8,9-HpCDF

690

5.0

ng/kg

1,2,3,4,7,8-HxCDD

420

5.0

ng/kg

1,2,3,4,7,8-HxCDF

420

5.0

ng/kg

1,2,3,6,7,8-HxCDD

2300

50

ng/kg

1,2,3,6,7,8-HxCDF

280

5.0

ng/kg

1,2,3,7,8,9-HxCDD

850

5.0

ng/kg

1,2,3,7,8,9-HxCDF

230

5.0

ng/kg

1,2,3,7,8-PeCDD

180

5.0

ng/kg

1,2,3,7,8-PeCDF

100

5.0

ng/kg

2,3,4,6,7,8-HxCDF

480

5.0

ng/kg

2,3,4,7,8-PeCDF

78

5.0

ng/kg

2,3,7,8-TCDD

11

1.0

ng/kg

OCDF

39,000

500

mg/kg

Arsenic

150

0.83

mg/kg

Cadmium

1.6

0.42

^g/kg

Benzo(a)pyrene

280

180

^g/kg

Benzo(g,h,i)perylene

420

180

^g/kg

Benzo(k)fluoranthene

250

180

^g/kg

Chrysene

400

180

^g/kg

Indeno( 1,2,3 -cd)pyrene

390

180

^g/kg

PCP

840

350

JHB-
S12

5/4/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

14,000

50

Near abandoned
stormwater
conveyance line. Mix
of gravel and sand,
grey-brown on surface
and medium brown
below.

Ref. 4, pp. 51,

79, 307-308,
559, 400,
3197,3214,
3243, 3254,
3294, 3295,
3305,3306,
3313,3315,
3325; Ref. 60,
p. 612; Ref.
123, p. 565

ng/kg

1,2,3,4,7,8-HxCDD

180

50

ng/kg

1,2,3,4,7,8-HxCDF

110

50

ng/kg

1,2,3,6,7,8-HxCDD

710

50

ng/kg

1,2,3,6,7,8-HxCDF

89

50

ng/kg

1,2,3,7,8,9-HxCDD

330

50

ng/kg

1,2,3,7,8-PeCDD

110

50

ng/kg

2,3,4,6,7,8-HxCDF

120

50

Notes:



CRQL:

EPA Contract Laboratory Program Contract Required Quantitation Limit

EPA:

United States Environmental Protection Agency

HpCDD

Heptachlorodibenzo-p-dioxin

HpCDF

Heptachlorodibenzofuran

HxCDD

Hexachlorodibenzo-p-dioxin

HxCDF

Hexachlorodibenzofuran

IA

Integrated Assessment

mg/kg:

milligrams per kilogram

ng/kg:

nanograms per kilogram

Hg/kg:

micrograms per kilogram

OCDF

Octachlorodibenzofuran

PeCDD

Pentachlorodibenzo -p-dioxin

PeCDF

Pentachlorodibenzofuran

TCDD

Tetrachlorodibenzo-p-dioxin

*•

Since the samples were analyzed through the CLP, the CRQLs presented above are equivalent to the CRQL as



defined by the HRS (Ref. 1, Sections 1.1 and 2.3).

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AOC A Hazardous Waste Quantity

Hazardous Constituent Quantity (Tier A)

The hazardous constituent quantity for AOC A could not be adequately determined according to the HRS
requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from
the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.1).
There are insufficient historical and current data (manifests, potentially responsible party [PRP] records,
state records, permits, waste concentration data, etc.) available to adequately calculate the total or partial
mass of all CERCLA hazardous substances in the source and the associated releases from the source.
Therefore, there is insufficient information to calculate the hazardous constituent quantity for AOC A with
reasonable confidence. Scoring proceeds to the evaluation of Tier B, hazardous wastestream quantity (Ref.
1, Section 2.4.2.1.1).

Hazardous Constituent Quantity Value: Not Scored (NS)
Hazardous Wastestream Quantity (Tier B)

The total Hazardous Wastestream Quantity for AOC A could not be adequately determined according to
the HRS requirements; that is, the total mass, or a partial estimate, of all hazardous wastestreams and
CERCLA pollutants and contaminants for the source and releases from the source is not known and cannot
be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.2). Insufficient historical and current data
(permits, waste concentration data, annual reports, etc.) are available to adequately calculate the total
mass, or a partial estimate, of all hazardous wastestreams and CERCLA pollutants and contaminants for
the source and the associated releases from the source. Therefore, there is insufficient information to
adequately calculate or extrapolate a total or partial Hazardous Wastestream Quantity for AOC A with
reasonable confidence. Scoring proceeds to the evaluation of Tier C, volume (Ref. 1, Section 2.4.2.1.3).

Hazardous Wastestream Quantity Value: NS

Volume (Tier C)

Tier C, volume is not applicable to source type contaminated soil for the soil exposure component (Ref.
1, Section 5.1.1.2.2).

Volume Assigned Value: 0

Area (Tier D)

The area of AOC A is estimated to be approximately 714,744 square feet, based on surface soil samples
collected by EPA in 2023 during the IA with concentrations of hazardous substances that were
significantly above background (see Figure 3 A and Tables 2 through 4 of this HRS documentation record).
However, the area of AOC A is not considered to be adequately determined as the sampling was limited
and not comprehensive across the full facility; due to the likely varying modes of deposition of hazardous
substances at the facility, soil contamination is not inferred throughout AOC A. In addition, an
undetermined portion of AOC A is beneath buildings, roads, or other impervious covers. Therefore, the
area of AOC A is greater than 0 but unknown.

Area Assigned Value: >0

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5.1.0 GENERAL CONSIDERATIONS

Letter by which this AOC is to be identified: B
Name of AOC: Residential Contaminated Soil
AOC Type: Contaminated Soil
Location and description of area:

AOC B consists of contaminated soil within the residential neighborhood north of the J. H. Baxter facility
(Figure 3B of this HRS documentation record). Soil contamination was a result of historical operations of
J. H. Baxter as a wood-treatment facility. Operations at the facility included high-pressure wood treating
in retorts using a variety of preservative chemicals, including PCP, ACZA, 50/50 Heavy Oil Blends of
Creosote and Bunker C Oil (50/50), Creosote, and ACQ (Ref. 5, pp. 13-18; Ref. 10, pp. 3-4; Ref. 14, p. 5;
Ref. 15, pp. 17, 57; Ref. 16, p. 9; Ref. 87, pp. 9). After raw wood products were treated in the retorts, they
were transported via tram to concrete drip pads where the treated wood was allowed to dry until no further
drippage occurred. After drying on the drip pad, treated wood products were either stored on one of several
on-property treated wood-storage areas or transported off-property by truck or rail (Ref. 7, pp. 20, 40; Ref.
15, p. 18; Ref. 87, p. 11).

Seasonal downwind direction from the facility is northward toward the residential neighborhood (Ref. 39,
p. 33; Ref. 59, pp. 3, 14, 16, 35; Ref. 92, p. 1). In 2007, LRAPA completed an air sampling study in
response to community concerns regarding emissions from J. H. Baxter. The study was designed to
measure maximum downwind exposures in the neighborhoods nearest to the J. H. Baxter facility adjacent
to the north, northeast and northwest. The process at the J. H. Baxter facility that generated the majority
of the off-property emissions used mixtures of creosote, oil and PCP to treat wood products for
preservation. The various stages of treatment operations were performed in drying kilns and large retorts
using pressure and vacuum. Emissions occurred from many points, including vacuum pumps, tank vents,
retort door openings, and treated product storage (Ref. 59, pp. 1, 3).

Detections of hazardous substances related to plant processes correlated well with downwind exposure.
None of the facility-related hazardous substances were ever detected in samples that had no downwind
exposure (Ref. 59, pp. 6, 9). LRAPA staff documented operations-related odors on the facility and in the
neighborhood to the north during many of the air sampling events as part of the 2005-2006 study. Resident
complaints were received during these times and confirmed by LRAPA staff (Ref. 59, pp. 25-27, 29-34).

Based on the soil sampling described below, AOC B was measured based on samples with concentrations
significantly above background. The area of contaminated soil measures approximately 454,604 square
feet (see Figure 3B of this HRS documentation record).

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AOC B is documented below based on four soil sampling events conducted by J. H. Baxter, ODEQ, and
EPA in 2021, 2022, and 2023. Contaminated samples are compared to background samples collected
during the same sampling events using the same field and analytical methods. Background locations are
shown on Figure 4 of this HRS documentation record. Contaminated samples used to document AOC B
are shown on Figure 3B of this HRS documentation record. ISM soil sampling was conducted at
residential properties by J. H. Baxter and ODEQ in 2021 and 2022 (Ref. 39, p. 7; Ref. 92, pp. 1-2; Ref.
118, pp. 9, 11-12, 14). As part of the EPA IA, ISM soil sampling was conducted by the EPA START on
residential properties in 2022 (Ref. 4, p. 17). ISM soil sampling was conducted by START at additional
residential properties in 2023 (Ref. 4, p. 17). Grab surface soil sampling for the IA was conducted by
START on the J. H. Baxter facility and on residential properties in 2023 (Ref. 4, pp. 9, 17, 19).

J. H. Baxter and ODEQ 2021-2022 ISM Surface Soil Sampling

In 2021, J. H. Baxter conducted characterization of dioxin and furan concentrations in surface soils at
eight properties suspected to be affected by air emissions deposition from the J. H. Baxter facility (Ref.
39, p. 7; Ref. 92, pp. 1-2; Ref. 118, pp. 9, 11-12, 14). Elevated dioxin and furan concentrations were
identified in soil samples collected from residential yards immediately north of the facility (Ref. 118, p.
12). Concentrations were highest in yards within areas where air deposition modeling completed by
LRAPA predicted predominant summer wind direction and deposition areas from the facility (Ref. 92, pp.
1-2; Ref. 118, p. 12).

In January 2022, J. H. Baxter notified ODEQ it would not be able to implement cleanup at the residential
yards in a timely manner, and suspended wood treatment activities at its facility. ODEQ subsequently
declared the facility an Orphan Site to enable utilization of the Industrial Orphan Site Account to complete
Removal Assessments at the residential yards (Ref. 118, pp. 9, 12). In June 2022, ODEQ implemented
investigation of five additional residential properties (Ref. 118, pp. 1, 9, 13).

Samples were collected in background and residential DUs using ISM (Ref. 4, pp. 79-81; Ref. 39, pp. 9-
10; Ref. 117; Ref. 118, pp. 11-13, 15-17, 22). ISM samples were analyzed for metals, PAHs/PCP, and/or
dioxins/furans (Ref. 39. pp. 10, 15-16, 33-34; Ref. 118, pp. 11-13, 22). Sampling locations are shown on
Figure 3B.

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- Background ISM Surface Soil

During the 2021 J. H. Baxter sampling event, background ISM samples were collected from undeveloped
areas of public parks located to the north and south of the J. H. Baxter facility (BKGD-04, BKGD-08, and
BKGD-09) (Ref. 39, pp. 11, 34; Ref. 118, p. 11; Figure 4 of this HRS documentation record).

Table 5 J. H. Baxter and ODEQ 2021-2022 ISM Surface Soil Background

Concentrations

Sample ID

Sampling
Date

Hazardous
Substance

Concentration

(ng/kg)

PQL*

(ng/kg)

References

ISM-
BKGD-04

9/21/2021

1,2,3,4,6,7,8-HpCDD

40.3

4.48

Ref. 40, p. 24; Ref. 45, p. 16;
Ref. 89, pp. 26, 30-31

1,2,3,4,6,7,8-HpCDF

8.62

4.48

1,2,3,4,7,8,9-HpCDF

0.509 JO

4.48

1,2,3,4,7,8-HxCDD

0.971 JO

4.48

1,2,3,4,7,8-HxCDF

4.48 U

4.48

1,2,3,6,7,8-HxCDD

1.81 JO

4.48

1,2,3,6,7,8-HxCDF

4.48 U

4.48

1,2,3,7,8,9-HxCDD

0.998 JO

4.48

1,2,3,7,8,9-HxCDF

0.333 JO

4.48

1,2,3,7,8-PeCDD

0.419 JO

4.48

1,2,3,7,8-PeCDF

4.48 U

4.48

2,3,4,6,7,8-HxCDF

4.48 U

4.48

2,3,4,7,8-PeCDF

4.48 U

4.48

2,3,7,8-TCDD

0.134 JQ

0.895

2,3,7,8-TCDF

0.179 JQ

0.895

OCDD

341

8.95

OCDF

17.8

8.95

ISM-
BKGD-08

9/21/2021

1,2,3,4,6,7,8-HpCDD

24.7

4.67

Ref. 40, p. 24; Ref. 45, p. 18;
Ref. 89, pp. 27, 30-31

1,2,3,4,6,7,8-HpCDF

5.46

4.67

1,2,3,4,7,8,9-HpCDF

4.67 U

4.67

1,2,3,4,7,8-HxCDD

0.411 JQ

4.67

1,2,3,4,7,8-HxCDF

4.67 U

4.67

1,2,3,6,7,8-HxCDD

0.967 JQ

4.67

1,2,3,6,7,8-HxCDF

4.67 U

4.67

1,2,3,7,8,9-HxCDD

0.712 JQ

4.67

1,2,3,7,8,9-HxCDF

4.67 U

4.67

1,2,3,7,8-PeCDD

0.368 JQ

4.67

1,2,3,7,8-PeCDF

4.67 U

4.67

2,3,4,6,7,8-HxCDF

4.67 U

4.67

2,3,4,7,8-PeCDF

4.67 U

4.67

2,3,7,8-TCDD

0.934 U

0.934

2,3,7,8-TCDF

0.934 U

0.934

OCDD

250

9.34

OCDF

13.9

9.34

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Table 5

J. H. Baxter and ODEQ 2021-2022 ISM Surface Soil Background
Concentrations

Sample ID

Sampling
Date

Hazardous
Substance

Concentration

(ng/kg)

PQL*

(ng/kg)

References





1,2,3,4,6,7,8-HpCDD

4.51 JQ

4.62







1,2,3,4,6,7,8-HpCDF

4.62 U

4.62







1,2,3,4,7,8,9-HpCDF

4.62 U

4.62







1,2,3,4,7,8-HxCDD

0.153 JQ

4.62







1,2,3,4,7,8-HxCDF

4.62 U

4.62







1,2,3,6,7,8-HxCDD

0.277 JQ

4.62







1,2,3,6,7,8-HxCDF

4.62 U

4.62



ISM-
BKGD-09



1,2,3,7,8,9-HxCDD

0.238 JQ

4.62

Ref. 40, p. 24; Ref. 45, p. 12;
Ref. 89, pp. 24, 30-31

9/20/2021

1,2,3,7,8,9-HxCDF

4.62 U

4.62



1,2,3,7,8-PeCDD

0.227 JQ

4.62





1,2,3,7,8-PeCDF

4.62 U

4.62







2,3,4,6,7,8-HxCDF

4.62 U

4.62







2,3,4,7,8-PeCDF

4.62 U

4.62







2,3,7,8-TCDD

0.923 U

0.923







2,3,7,8-TCDF

0.164 JQ

0.923







OCDD

31.5

9.23







OCDF

9.23 U

9.23



Notes:

BKGD:	background

CRQL:	Contract Required Quantitation Limit

HpCDD:	Heptachlorodibenzo-p-dioxin

HpCDF:	Heptachlorodibenzofuran

HxCDD:	Hexachlorodibenzo-p-dioxin

HxCDF:	Hexachlorodibenzofuran

ID:	Identification Number

ISM:	Incremental Sampling Methodology

JQ:	The analyte was positively identified, and the associated value is an estimated quantity. The result is estimated

because the concentration is below the sample quantitation limit (Ref. 89, p. 4).

ng/kg:	nanograms per kilogram

OCDD:	Octachlorodibenzodioxin

OCDF:	Octachlorodibenzofuran

ODEQ:	Oregon Department of Environmental Quality

PeCDD:	Pentachlorodibenzo-p-dioxin

PeCDF	Pentachlorodibenzofuran

PQL:	Practical Quantitation Limit

TCDD:	Tetrachlorodibenzo-p-dioxin

TCDF:	Tetrachlorodibenzofuran

U:	The material was analyzed for but was not detected above the level of the associated value. The associated value is

either the Sample Quantitation Limit or the Sample Detection Limit (Ref. 89, p. 4; Ref. 116, pp. 36-38).

*:	According to the laboratory, the PQLs presented above are most closely related to the SQL as defined by the HRS
(Ref. 1, Sections 1.1 and 2.3; Ref. 115)

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The minimum standard to establish observed contamination by chemical analysis is analytical evidence
of a hazardous substance significantly above the background level, and some portion of the significant
increase above the background level is attributable to the Site. In accordance with HRS Table 2-3, if the
background concentration is not detected, a significant increase is established when the sample
measurement equals or exceeds the Sample Quantitation Limit (SQL). If the SQL cannot be established,
if the sample analysis was performed under the EPA CLP, use the EPA CRQL in place of the SQL. If the
sample analysis is not performed under the EPA CLP, use the detection limit (DL) in place of the SQL if
the background concentration equals or exceeds the detection limit, a significant increase is established
when the sample measurement is three times or more above the background concentration (Ref. 1, Section
2.3).

Table 6

J. H. Baxter and ODEQ 2021-2022 ISM Background Levels to Establish the
Surface Soil Area of Observed Contamination







HRS Table 2-3

Sample Type

Hazardous Substance

Maximum Background
Concentration (ng/kg)

Minimum Concentration to Document
Observed Contamination by Chemical
Analysis (ng/kg)



1,2,3,4,6,7,8-HpCDD

40.3

120.9



1,2,3,4,6,7,8-HpCDF

8.62

25.86



1,2,3,4,7,8,9-HpCDF

0.509 JQ

1.527



1,2,3,4,7,8-HxCDD

0.971 JQ

2.913



1,2,3,4,7,8-HxCDF

4.67 U

The sample measurement equals or exceeds
the sample quantitation limit



1,2,3,6,7,8-HxCDD

1.81 JQ

5.43



1,2,3,6,7,8-HxCDF

4.67 U

The sample measurement equals or exceeds
the sample quantitation limit



1,2,3,7,8,9-HxCDD

0.998 JQ

2.994

ISM Surface Soil

1,2,3,7,8,9-HxCDF

0.333 JQ

0.999

1,2,3,7,8-PeCDD

0.419 JQ

1.257



1,2,3,7,8-PeCDF

4.67 U

The sample measurement equals or exceeds
the sample quantitation limit



2,3,4,6,7,8-HxCDF

4.67 U

The sample measurement equals or exceeds
the sample quantitation limit



2,3,4,7,8-PeCDF

4.67 U

The sample measurement equals or exceeds
the sample quantitation limit



2,3,7,8-TCDD

0.134 JQ

0.402



2,3,7,8-TCDF

0.179 JQ

0.537



OCDD

341

1,023



OCDF

17.8

53.4

Notes:



BKGD:

background

CRQL:

Contract Required Quantitation Limit

HpCDD:

Heptachlorodibenzo-p-dioxin

HpCDF:

Heptachlorodibenzofuran

HxCDD:

Hexachlorodibenzo-p-dioxin

HxCDF:

Hexachlorodibenzofuran

ID:

Identification Number

ISM:

Incremental Sampling Methodology

JQ:

The analyte was positively identified, and the associated value is an estimated quantity. The result is estimated



because the concentration is below the sample quantitation limit (Ref. 89, p. 4). Results that are qualified due to

42

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detection at or above the detection limit but below the quantitation limit are not considered biased. The



concentration is used without applying an adjustment factor (Ref. 50, pp. 6, 8).

ng/kg:

nanograms per kilogram

OCDD:

Octachlorodibenzodioxin

OCDF:

Octachlorodibenzofuran

ODEQ:

Oregon Department of Environmental Quality

PeCDD:

Pentachlorodibenzo-p-dioxin

PeCDF

Pentachlorodibenzofuran

TCDD:

Tetrachlorodibenzo-p-dioxin

TCDF:

Tetrachlorodibenzofuran

U:

The material was analyzed for but was not detected above the level of the associated value. The associated value



is either the Sample Quantitation Limit or the Sample Detection Limit (Ref. 89, p. 4; Ref. 116, pp. 36-38).

- Contaminated ISM Soil Samples

Table 7

J. H. Baxter and ODEQ 2021-2022 ISM AOC B Contaminated Soil Concentrations

Sample ID

Sample Date

Hazardous
Substance

Concentration

(ng/kg)

PQL*

(ng/kg)

References





1,2,3,4,6,7,8-HpCDD

644

0.0712**







1,2,3,4,6,7,8-HpCDF

222

0.0350**







1,2,3,4,7,8,9-HpCDF

10.8

0.0421**







1,2,3,4,7,8-HxCDD

8.97

0.0555**







1,2,3,4,7,8-HxCDF

11.2

0.0339**



ISM-DU-

009***



1,2,3,6,7,8-HxCDD

25.2

0.0558**

Ref. 61, p. 5; Ref. 89, pp. 21,
2901-2902; Ref. 117, p. 1; Ref.

6/20/2022

1,2,3,6,7,8-HxCDF

8.02

0.0340**



1,2,3,7,8,9-HxCDD

16.9

0.0528**

119, p. 8





1,2,3,7,8-PeCDD

5.21

0.0515**







2,3,4,6,7,8-HxCDF

9.00

0.0353**







2,3,7,8-TCDD

6.23

0.0286**







OCDD

4,930

0.195**







OCDF

907

0.0820**







1,2,3,4,6,7,8-HpCDD

1,110

4.58







1,2,3,4,6,7,8-HpCDF

313

4.58







1,2,3,4,7,8,9-HpCDF

20.1

4.58







1,2,3,4,7,8-HxCDD

14.0

4.58







1,2,3,4,7,8-HxCDF

25.3

4.58







1,2,3,6,7,8-HxCDD

41

4.58



ISM-DU-

10***



1,2,3,6,7,8-HxCDF

9.87

4.58

Ref. 40, p. 24; Ref. 45, p. 22; Ref.
89, pp. 6,30-31

9/22/2021

1,2,3,7,8,9-HxCDD

24

4.58



1,2,3,7,8,9-HxCDF

4.93

4.58





1,2,3,7,8-PeCDD

7.43

4.58







2,3,4,6,7,8-HxCDF

12.2

4.58







2,3,4,7,8-PeCDF

6.39

4.58







2,3,7,8-TCDD

22.0

0.916







2,3,7,8-TCDF

1.35

0.916







OCDF

1,100

9.16



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Table 7

J. H. Baxter and ODEQ 2021-2022 ISM AOC B Contaminated Soil Concentrations

Sample ID

Sample Date

Hazardous
Substance

Concentration

(ng/kg)

PQL*

(ng/kg)

References





1,2,3,4,6,7,8-HpCDD

947

4.98







1,2,3,4,6,7,8-HpCDF

132

4.98







1,2,3,4,7,8,9-HpCDF

8.11

4.98







1,2,3,4,7,8-HxCDD

10.3

4.98



ISM-DU-



1,2,3,4,7,8-HxCDF

8.1

4.98

Ref. 42, p. 38; Ref. 46, p. 15; Ref.
89, pp. 11, 700-701; Ref. 117, pp.

9/23/2021

1,2,3,6,7,8-HxCDD

29.6

4.98



1,2,3,7,8,9-HxCDD

16.2

4.98

3,4





2,3,4,6,7,8-HxCDF

5.8

4.98







2,3,7,8-TCDD

89.6

0.996







2,3,7,8-TCDF

1.94

0.996







OCDF

356

9.96







1,2,3,4,6,7,8-HpCDD

483

4.64







1,2,3,4,6,7,8-HpCDF

78

4.64







1,2,3,4,7,8,9-HpCDF

5.1

4.64







1,2,3,4,7,8-HxCDD

5.59

4.64







1,2,3,4,7,8-HxCDF

5.46

4.64

Ref. 40, p. 24; Ref. 45, p. 25; Ref.
89, pp. 7,30-31

ISM-DU-12

9/22/2021

1,2,3,6,7,8-HxCDD

16.9

4.64





1,2,3,7,8,9-HxCDD

10.2

4.64





2,3,4,6,7,8-HxCDF

5.69

4.64







2,3,7,8-TCDD

1.52

0.929







2,3,7,8-TCDF

1.29

0.929







OCDF

179

9.29







1,2,3,4,6,7,8-HpCDD

1,260

5.02







1,2,3,4,6,7,8-HpCDF

267

5.02







1,2,3,4,7,8,9-HpCDF

23.8

5.02







1,2,3,4,7,8-HxCDD

13

5.02







1,2,3,4,7,8-HxCDF

75.6

5.02







1,2,3,6,7,8-HxCDD

47.9

5.02







1,2,3,6,7,8-HxCDF

18.4

5.02



ISM-DU-

10/4/2021

1,2,3,7,8,9-HxCDD

21.8

5.02

Ref. 44, p. 25; Ref. 48, p. 11; Ref.

15***

1,2,3,7,8,9-HxCDF

14

5.02

89, pp. 17, 1674; Ref. 117, p. 3





1,2,3,7,8-PeCDD

6.82

5.02







1,2,3,7,8-PeCDF

5.28

5.02







2,3,4,6,7,8-HxCDF

23.7

5.02







2,3,4,7,8-PeCDF

18.1

5.02







2,3,7,8-TCDD

14.9

1.0







2,3,7,8-TCDF

2.38

1.0







OCDF

392

10



Notes:

CRQL: EPA Contract Laboratory Program Contract Required Quantitation Limit

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DU: Decision Unit

HpCDD: Heptachlorodibenzo-p-dioxin

HpCDF: Heptachlorodibenzofuran

HxCDD: Hexachlorodibenzo-p-dioxin

HxCDF: Hexachlorodibenzofuran

ID: Identification number

ISM: Incremental Sampling Methodology

ng/kg: nanograms per kilogram

OCDD: Octachlorodibenzodioxin

OCDF: Octachlorodibenzofuran

ODEQ: Oregon Department of Environmental Quality

PeCDD: Pentachlorodibenzo-p-dioxin

PeCDF: Pentachlorodibenzofuran

SQL: Sample Quantitation Limit

TCDD: Tetrachlorodibenzo-p-dioxin

TCDF: T etrachlorodibenzofuran

*:	According to the laboratory, the PQLs presented above are most closely related to the SQL as defined by the HRS

(Ref. 1, Sections 1.1 and 2.3; Ref. 115)

**: For sample ISM-DU-09, the laboratory provided Method Detection Limits, which are equivalent to Detection Limits

as defined by the HRS (Ref. 1, Sections 1.1 and2.3;Ref. 115)

***: This property has undergone soil removal/cleanup actions and as such is not considered in the HRS scoring of this site
(Hazardous Waste Quantity or Targets) based on currently available information.

2022 and 2023 EPA Integrated Assessment (IA) Sampling

EPA tasked Weston Solutions, Inc. (Weston), under START Contract Number (No.) 68HE0720D005 and
Task Order (TO) 68HE0722F0059, to conduct an IA at the J. H. Baxter site (Ref. 4, p. 9). Sampling was
conducted under an EPA-approved site-specific Sampling and Analysis Plan (SAP) (Ref. 4, p. 19; Ref.
9). AOC B sampling was conducted in May 2022, March 2023, and May 2023 (Ref. 4, pp. 17, 19).

EPA IA 2023 Site Assessment Surface Soil Samples

EPA tasked Weston Solutions, Inc. (Weston), under START Contract Number (No.) 68HE0720D005 and
Task Order (TO) 68HE0722F0059, to conduct an IA of the J. H. Baxter site (Ref. 4, p. 9). Sampling was
conducted under an EPA-approved site-specific Sampling and Analysis Plan (SAP) (Ref. 4, p. 19; Ref.
9). AOC A sampling was conducted in May 2023 (Ref. 4, pp. 17, 19).

Sample locations are presented on Figure 3B and Figure 4 of this HRS documentation record. In May
2023, 26 surface soil field samples were collected from 0 to 6 inches bgs at residential properties north of
the J. H. Baxter facility across Roosevelt Boulevard. Two background soil samples were collected for
comparison to the contaminated soils (Ref. 4, p. 20). Background locations included two public parks in
Eugene, Oregon, located 3/4-mile northwest and 2 '/t-miles south of the facility (Figure 4 of this HRS
documentation record; Ref. 4, p. 19). Samples were collected as grab samples from 0 to 6 inches bgs using
a non-dedicated hand auger, which was decontaminated after each use (Ref. 4, p. 17-18).

Samples were submitted for off-site fixed laboratory analysis for TAL VOCs (SFAM01.1), TAL SVOCs
(SFAM01.1), TAL Pesticides (SFAM01.1), TAL Aroclors (SFAM 01.1), TAL Inorganics (SFAM 01.1),
and dioxins/furans (HRSM02.1). All samples were analyzed under EPA CLP Statement of Work (SOW)
SFAM01.1, with the exceptions of dioxins and furans which were analyzed under CLP SOW HRSM02.1
(Ref. 4, pp. 19-21, 25-26). All sample analyses were validated following EPA's Stage 4 Data Validation

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Electronic/Manual Process. A START chemist performed a Stage 1 verification of each CLP data package.
(Ref. 4, p. 26).

- Background Surface Soil

During the IA, background surface soils were collected from two locations not expected to be affected by
historical site operations. Sample JHB-S13 was collected from a public park 3/4-mile northwest believed
to be outside the influence of emissions sources at the J. H. Baxter facility. Sample JHB-S14 was collected
from a public park 2 H-miles south of the facility and believed to be outside the influence of migrant dust
emissions from the J. H. Baxter facility (Ref. 4, p. 43). Background soils were medium-dark brown, mostly
silt and clay with some gravel (Ref. 4, p. 397).

Table 8

EPA IA Site Assessment Background Surface Soil Concentrations

Sample ID

Sampling
Date

Units

Hazardous Substance

Result

Sample
Adjusted
CRQL*

References

JHB-S 13

5/2/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

95

5.0

Ref. 4, pp. 43, 80, 309,





ng/kg

1,2,3,4,6,7,8-HpCDF

27

5.0

397, 562, 1845-1847,





ng/kg

1,2,3,4,7,8,9-HpCDF

1.6 JO

5.0

3211, 3240, 3298, 3314,





ng/kg

1,2,3,4,7,8-HxCDD

1.3 JO

5.0

3316; Ref. 60, pp. 438,





ng/kg

1,2,3,4,7,8-HxCDF

2.2 JO

5.0

619; Ref. 123, pp. 43,





ng/kg

1,2,3,6,7,8-HxCDD

3.9 JO

5.0

181, 589





ng/kg

1,2,3,6,7,8-HxCDF

1.5 JO

5.0







ng/kg

1,2,3,7,8,9-HxCDD

2.3 JO

5.0







ng/kg

1,2,3,7,8-PeCDD

1 JO

5.0







ng/kg

2,3,4,6,7,8-HxCDF

2 JO

5.0







ng/kg

2,3,7,8-TCDD

0.35 JO

1.0







ng/kg

OCDD

570

10







ng/kg

OCDF

44

10







mg/kg

Lead

23

1.3







W?/kg

Bis(2-ethylhexyl)phthalate

190 U

190



JHB-S 14

5/2/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

15

5.0

Ref. 4, pp. 43, 80, 311-





ng/kg

1,2,3,4,6,7,8-HpCDF

1.6 JQ

5.0

312,397, 562, 1851-





ng/kg

1,2,3,4,7,8,9-HpCDF

0.43 UJ

5.0

1853,2389, 3211,3240,





ng/kg

1,2,3,4,7,8-HxCDD

0.25 UJ

5.0

3298, 3300-3301, 3303,





ng/kg

1,2,3,4,7,8-HxCDF

0.36 UJ

5.0

3314, 3316; Ref. 60, p.





ng/kg

1,2,3,6,7,8-HxCDD

0.69 J

5.0

440; Ref. 121, pp. 19;





ng/kg

1,2,3,6,7,8-HxCDF

0.31 UJ

5.0

Ref. 123, pp. 46-47,
182, 641





ng/kg

1,2,3,7,8,9-HxCDD

0.48 JQ

5.0





ng/kg

1,2,3,7,8-PeCDD

0.26 UJ

5.0







ng/kg

2,3,4,6,7,8-HxCDF

0.26 UJ

5.0







ng/kg

2,3,7,8-TCDD

0.15 UJ

1.0







ng/kg

OCDD

65

10







ng/kg

OCDF

4.1 UJ

10







mg/kg

Lead

7.7

1.1







W?/kg

Bis(2-ethylhexyl)phthalate

240 U

240



Notes:

CRQL:	EPA Contract Laboratory Program Contract Required Quantitation Limit

EPA:	United States Environmental Protection Agency

HpCDD	Heptachlorodibenzo-p-dioxin

HpCDF	Heptachlorodibenzofuran

46

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HxCDD Hexachlorodibenzo-p-dioxin
HxCDF Hexachlorodibenzofuran
IA	Integrated Assessment

mg/kg: milligrams per kilogram
ng/kg: nanograms per kilogram
|ig/kg: micrograms per kilogram
OCDF Octachlorodibenzofuran
PeCDD Pentachlorodibenzo-p-dioxin
PeCDF Pentachlorodibenzofuran
TCDD Tetrachlorodibenzo-p-dioxin

U:	The material was analyzed for but was not detected above the level of the associated value. The associated value

is either the sample quantitation limit or the sample detection limit. (Ref. 60, p. 421)

J:	The associated value is an estimated quantity (Ref. 60, p. 421)

Q:	Concentration is below the CRQL but is above the method detection limit (Ref. 60, p. 421)

*: Since the samples were analyzed through the CLP, the CRQLs presented above are equivalent to the CRQL as defined
by the HRS (Ref. 1, Sections 1.1 and 2.3).

Table 9 Background Levels to Establish the Surface Soil Area of Observed Contamination

Sample Type

Hazardous Substance

Maximum Background
Concentration
2023 IA Sampling
Results

HRS Table 2-3
Minimum Concentration to
Document Observed Contamination
by Chemical Analysis

Surface Soil

1,2,3,4,6,7,8-HpCDD

95

285

1,2,3,4,6,7,8-HpCDF

27

81

1,2,3,4,7,8,9-HpCDF

1.6 JQ

4.8

1,2,3,4,7,8-HxCDD

1.3 JQ

3.9

1,2,3,4,7,8-HxCDF

2.2 JQ

6.6

1,2,3,6,7,8-HxCDD

3.9 JQ

11.7

1,2,3,6,7,8-HxCDF

1.5 JQ

4.5

1,2,3,7,8,9-HxCDD

2.3 JQ

6.9

1,2,3,7,8-PeCDD

1 JQ

3

2,3,4,6,7,8-HxCDF

2 JQ

6

2,3,7,8-TCDD

0.35 JQ

1.05

OCDD

570

1710

OCDF

44

132

Lead

23

69

Bis(2-ethylhexyl)phthalate

240 U

The sample measurement equals or exceeds
the sample quantitation limit or CRQL

Notes:



CRQL:

EPA Contract Laboratory Program Contract Required Quantitation Limit

EPA:

United States Environmental Protection Agency

HpCDD

Heptachlorodibenzo-p-dioxin

HpCDF

Heptachlorodibenzofuran

HxCDD

Hexachlorodibenzo-p-dioxin

HxCDF

Hexachlorodibenzofuran

IA

Integrated Assessment

mg/kg:

milligrams per kilogram

ng/kg:

nanograms per kilogram

Hg/kg:

micrograms per kilogram

OCDD

Octachlorodibenzodioxin

OCDF

Octachlorodibenzofuran

PeCDD

Pentachlorodibenzo-p-dioxin

47

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TCDD Tetrachlorodibenzo-p-dioxin

U:	The material was analyzed for but was not detected above the level of the associated value. The associated value

is either the sample quantitation limit or the sample detection limit. (Ref. 60, p. 421)

J:	The associated value is an estimated quantity (Ref. 60, p. 421)

Q:	Concentration is below the CRQL but is above the method detection limit (Ref. 60, p. 421). Results that are

qualified due to detection at or above the detection limit but below the quantitation limit are not considered biased.
The concentration is used without applying an adjustment factor (Ref. 50, pp. 6, 8).

- Contaminated Soil Samples

Where descriptions were provided, AOC B soil samples were described as medium brown, mostly silt,
with a trace of gravel (Ref. 4, p. 397).

Table 10 EPA IA Site Assessment AOC B Contaminated Soil Concentrations

Sample
ID

Sample
Date

Units

Hazardous Substance

Concentration

Sample
Adjusted
CRQL*

References

JHB-S16

5/2/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

340

5.0

Ref. 4, pp. 51, 56,58,
81, 315-316, 397, 562,
1660-1661, 1819-1821,
3207, 3210, 3239,
319; Ref. 60, p. 646;
Ref. 123, pp. 31,498

ng/kg

1,2,3,6,7,8-HxCDD

15

5.0

ng/kg

1,2,3,7,8,9-HxCDD

10

5.0

ng/kg

OCDD

2,900

10

ng/kg

OCDF

210

10

lig/kg

Bis(2-ethylhexyl)phthalate

54,000

220

JHB-S17

5/1/2023

ng/kg

2,3,7,8-TCDD

1.2

1.00

Ref. 4, pp. 51, 81,317-
318,397, 562, 2563,
3313, 3315; Ref. 60, p.
614; Ref. 123, pp. 573

JHB-S18

5/1/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

490

5.0

Ref. 4, pp. 51, 81,319-
320, 397, 562, 3300,
3302, 3328; Ref. 121,
p. 17; Ref. 123, pp. 633

ng/kg

1,2,3,6,7,8-HxCDD

16

5.0

ng/kg

1,2,3,7,8,9-HxCDD

8.9

5.0

ng/kg

OCDD

3,500

10

ng/kg

OCDF

190

10

JHB-S19

5/1/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

370

5.0

Ref. 4, pp. 52, 55,81,
321-322, 397, 562,
3295, 3331; Ref. 60,
pp. 379; Ref. 120, p.
23; Ref. 123, pp. 194,
302

ng/kg

1,2,3,4,7,8-HxCDD

6.1

5.0

ng/kg

1,2,3,6,7,8-HxCDD

18

5.0

ng/kg

1,2,3,7,8,9-HxCDD

12

5.0

ng/kg

1,2,3,7,8-PeCDD

6.6

5.0

ng/kg

2,3,7,8-TCDD

2.0

1.0

ng/kg

OCDD

2,600

10

mg/kg

Lead

90

0.95

JHB-S20

5/1/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

460

5.0

Ref. 4, pp. 52, 56, 86,
323-324, 397, 562,
2588, 3317, 3319; Ref.
60, p. 639 Ref. 123, pp.
446

ng/kg

1,2,3,4,6,7,8-HpCDF

120

5.0

ng/kg

1,2,3,6,7,8-HxCDD

17

5.0

ng/kg

1,2,3,7,8,9-HxCDD

10

5.0

ng/kg

2,3,4,6,7,8-HxCDF

7.5

5.0

ng/kg

OCDD

3,800

10

ng/kg

OCDF

270

10

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Table 10 EPA IA Site Assessment AOC B Contaminated Soil Concentrations

Sample
ID

Sample
Date

Units

Hazardous Substance

Concentration

Sample
Adjusted
CRQL*

References

JHB-S21

5/1/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

390

5.0

Ref. 4, pp. 52,81,325-
326, 397, 562, 2596,
3317, 3319; Ref. 60, p.
647; Ref. 123, pp. 502

ng/kg

1,2,3,6,7,8-HxCDD

14

5.0

ng/kg

1,2,3,7,8,9-HxCDD

8.7

5.0

ng/kg

OCDD

2,900

9.9

ng/kg

OCDF

140

9.9

JHB-S22

5/1/2023

ng/kg

2,3,7,8-TCDD

4.6

5.0

Ref. 4, pp. 52,81,327-
328, 397, 562, 2597,
3317, 3319; Ref. 60, p.
648; Ref. 123, pp. 506

JHB-S23

5/1/2023

ng/kg

2,3,7,8-TCDD

13

5.0

Ref. 4, pp. 52, 81, 329-
330, 397, 562, 2602,
3318, 3320; Ref. 60, p.
653; Ref. 123, pp. 526

ng/kg

OCDD

1,800

10

JHB-S26

5/1/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

1,500

5.0

Ref. 4, pp. 53, 81, 335-
336, 397, 565, 2604,
3318, 3320; Ref. 60, p.
655; Ref. 123, pp. 534

ng/kg

1,2,3,4,6,7,8-HpCDF

86

5.0

ng/kg

1,2,3,4,7,8-HxCDD

12

5.0

ng/kg

1,2,3,6,7,8-HxCDD

27

5.0

ng/kg

1,2,3,7,8,9-HxCDD

18

5.0

ng/kg

1,2,3,7,8-PeCDD

8.6

5.0

ng/kg

2,3,7,8-TCDD

1.6

1.0

ng/kg

OCDD

19,000

10

ng/kg

OCDF

360

10

JHB-S27

5/1/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

290

5.0

Ref. 4, pp. 53,81,337-
338, 397, 565, 2605,
3318, 3320; Ref. 60, p.
656; Ref. 123, pp. 538

ng/kg

1,2,3,7,8,9-HxCDD

7.3

5.0

ng/kg

2,3,7,8-TCDD

7.4

1.0

ng/kg

OCDD

2,100

10

JHB-S28

5/1/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

360

5.0

Ref. 4, pp. 53,81,339-
340, 397, 565, 2567,
3314, 3316; Ref. 60, p.
618; Ref. 123, pp. 585

ng/kg

1,2,3,6,7,8-HxCDD

12

5.0

ng/kg

1,2,3,7,8,9-HxCDD

7

5.0

ng/kg

2,3,7,8-TCDD

1.6

1.0

ng/kg

OCDD

2,400

10

ng/kg

OCDF

140

10

JHB-S32

5/1/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

460

5.0

Ref. 4, pp. 53,81,347-
348,397, 565,3318,
3320; Ref. 60, p. 651;
Ref. 123, pp. 518

ng/kg

1,2,3,4,7,8-HxCDD

6.3

5.0

ng/kg

1,2,3,6,7,8-HxCDD

18

5.0

ng/kg

1,2,3,7,8,9-HxCDD

12

5.0

ng/kg

2,3,7,8-TCDD

2.1

1.0

ng/kg

OCDD

3,300

10

JHB-S34

5/1/2023

ng/kg

2,3,7,8-TCDD

1.5

1.0

Ref. 4, pp. 53, 81, 351-
352, 397, 565, 3300,
3302, 3328; Ref. 121,
p. 16; Ref. 123, pp. 629

49

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Table 10 EPA IA Site Assessment AOC B Contaminated Soil Concentrations

Sample
ID

Sample
Date

Units

Hazardous Substance

Concentration

Sample
Adjusted
CRQL*

References

JHB-S36

5/2/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

540

5.0

Ref. 4, pp. 54, 56,81,
355-356, 397, 568,
3300, 3302, 3328; Ref.
121, p. 14; Ref. 123,
pp. 621

ng/kg

1,2,3,4,6,7,8-HpCDF

120

5.0

ng/kg

1,2,3,4,7,8,9-HpCDF

7.7

5.0

ng/kg

1,2,3,4,7,8-HxCDD

6.9

5.0

ng/kg

1,2,3,6,7,8-HxCDD

18

5.0

ng/kg

1,2,3,7,8,9-HxCDD

13

5.0

ng/kg

1,2,3,7,8-PeCDD

6.6

5.0

ng/kg

2,3,7,8-TCDD

62

1.0

ng/kg

OCDF

370

10

JHB-S37

5/2/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

1,300

5.0

Ref. 4, pp. 54, 56,81,
357-358, 397, 568,
3313, 3315; Ref. 60, p.
613; Ref. 123, pp. 569

ng/kg

1,2,3,4,6,7,8-HpCDF

260

5.0

ng/kg

1,2,3,4,7,8,9-HpCDF

14

5.0

ng/kg

1,2,3,4,7,8-HxCDD

22

5.0

ng/kg

1,2,3,4,7,8-HxCDF

12

5.0

ng/kg

1,2,3,6,7,8-HxCDD

49

5.0

ng/kg

1,2,3,6,7,8-HxCDF

10

5.0

ng/kg

1,2,3,7,8,9-HxCDD

35

5.0

ng/kg

1,2,3,7,8-PeCDD

17

5.0

ng/kg

2,3,4,6,7,8-HxCDF

14

5.0

ng/kg

2,3,7,8-TCDD

2.7

1.0

ng/kg

OCDF

710

10

JHB-S38

5/2/2023

ng/kg

2,3,7,8-TCDD

2.2

1.0

Ref. 4, pp. 54,81,359-
360, 397, 568, 3299,
3300, 3302, 3328; Ref.
121, p. 21; Ref. 123,
pp. 649

ng/kg

OCDD

1,800

10

JHB-S39

5/1/2023

ng/kg

1,2,3,4,6,7,8-HpCDD

330

5.0

Ref. 4, pp. 54,81,361-
362,397, 568,3318,
3320; Ref. 60, p. 649;
Ref. 123, pp. 510

ng/kg

1,2,3,6,7,8-HxCDD

12

5.0

ng/kg

1,2,3,7,8,9-HxCDD

7.8

5.0

ng/kg

OCDD

2,600

9.9

JHB-S40

5/4/2023

ng/kg

1,2,3,7,8,9-HxCDD

7.1

5.0

Ref. 4, pp. 54, 56,81,
363-364, 401, 568,
3321, 3324; Ref. 122,
p. 26; Ref. 123, pp. 430

ng/kg

OCDD

2,500

10

Notes:



CRQL:

EPA Contract Laboratory Program Contract Required Quantitation Limit

EPA:

United States Environmental Protection Agency

HpCDD

Heptachlorodibenzo-p-dioxin

HpCDF

Heptachlorodibenzofuran

HxCDD

Hexachlorodibenzo-p-dioxin

HxCDF

Hexachlorodibenzofuran

IA

Integrated Assessment

mg/kg:

milligrams per kilogram

ng/kg:

nanograms per kilogram

Hg/kg:

micrograms per kilogram

OCDF

Octachlorodibenzofuran

PeCDD

Pentachlorodibenzo -p-dioxin

50

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PeCDF Pentachlorodibenzofuran
TCDD Tetrachlorodibenzo-p-dioxin

*:	Since the samples were analyzed through the CLP, the CRQLs presented above are equivalent to the CRQL as

defined by the HRS (Ref. 1, Sections 1.1 and 2.3).

EPA IA 2022 Removal Site Evaluation (RSE) ISM Surface Soil Samples

In April 2022, EPA initially tasked START with evaluating 30 properties by collecting soil samples to be
analyzed for dioxins and furans, as part of a Removal Site Evaluation (RSE). The scope of the RSE
included collecting soil samples from residential properties in the neighborhood north of the facility,
analyzing those samples, then reporting the results to EPA and ODEQ. EPA worked with ODEQ to
identify the properties to evaluate. After agreeing on the initial 30 properties, EPA and START conducted
RSE field activities from May 23, 2022, through May 27, 2022 (Ref. 4, p. 17).

START collected samples following the ISM. START collected increments of soil to a depth of six inches
below ground surface (bgs) and from 30-75 increments within each Decision Unit (DU). The exact number
of increments was determined by the EPA on site. For the May 2022 sampling, each property was divided
into DUs based upon features of the property, and each sample was identified as either a Front Yard,
Backyard, Side Yard, or Garden Area. Soil samples were collected from each of these DUs and submitted
to the laboratory for analysis (Ref. 4, p. 17). During the May 2022 sampling effort, an ISM Whole Yard
sample was collected from 0-6 inches bgs. Additionally, one 5-point composite sample was collected from
each DU from 0-3 inches bgs (Ref. 4, p. 18).

At the end of the project, samples were shipped to an analytical laboratory for ISM processing and
chemical analysis (Ref. 4, p. 18). The subcontracted analytical laboratory dried, sieved, and processed
each sample according to ISM. After processing, the samples were analyzed for dioxins and furans using
EPA Method 1613B (Ref. 4, p. 18).

- 2022 Background Surface Soil

Background location JHB-33-WY was collected from Residence ID 52 (Ref. 51; Figure 4 of this HRS
documentation record). This location was selected to represent background concentrations for the 2022
ISM sampling as it was the residence located furthest to the east and was not directly north of the facility,
so was less likely to have received airborne contaminated soil or emissions from the J. H. Baxter facility
(Ref. 39, p. 33; Ref. 59, pp. 3, 16, 35; Ref. 92, p. 12).

Table 11 EPA IA 2022 ISM Background Surface Soil Concentrations

Sample ID

Sampling
Date

Hazardous
Substance

Concentration
(ng/kg)

MRL*
(ng/kg)

References

JHB-33-
WY-00-
06-01

5/26/2022

1,2,3,4,7,8-HxCDF

2.57 U

2.57

Ref. 4, p. 81,2933,2947, 3171;
Ref. 25, pp. 9, 59-63; Ref. 49,
p. 15; Ref. 82, p. 6

1,2,3,7,8,9-HxCDD

2.57 U

2.57

2,3,7,8-TCDD

0.513 U

0.513

Notes:



EPA:

United States Environmental Protection Agency

HxCDD

Hexachlorodibenzo-p-dioxin

HxCDF

Hexachlorodibenzofuran

IA

Integrated Assessment

MRL:

Method Reporting Limit

ng/kg:

nanograms per kilogram

51

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SQL: Sample Quantitation Limit
TCDD Tetrachlorodibenzo-p-dioxin

U:	The material was analyzed for but was not detected. The associated numerical value is the sample quantitation or

detection limit, which has been adjusted for sample weight/sample volume, extraction volume, percent solids,
sample dilution or other analysis specific parameters. (Ref. 49, p. 2; Ref. 116, pp. 36-38)

*:	According to the laboratory, the MRLs presented above are most closely related to the SQL as defined by the HRS

(Ref. 1, Sections 1.1 and 2.3; Ref. 113).

Table 12 EPA IA 2022 ISM Background Levels to Establish the Surface Soil Area of

Observed Contamination

Sample Type

Hazardous
Substance

Maximum Background
Concentration
EPA IA 2022 Results
(ng/kg)

HRS Table 2-3
Minimum Concentration to Document
Observed Contamination by Chemical
Analysis (ng/kg)

ISM soil
sample

1,2,3,4,7,8-HxCDF

2.57 U

The sample measurement equals or exceeds the
sample quantitation limit

1,2,3,7,8,9-HxCDD

2.57 U

The sample measurement equals or exceeds the
sample quantitation limit

2,3,7,8-TCDD

0.513 U

The sample measurement equals or exceeds the
sample quantitation limit

Notes:



CRQL:

EPA Contract Laboratory Program Contract Required Quantitation Limit

EPA:

United States Environmental Protection Agency

HxCDD

Hexachlorodibenzo-p-dioxin

HxCDF

Hexachlorodibenzofuran

IA

Integrated Assessment

ID

Identification number

ISM

Incremental Sampling Methodology

ng/kg:

nanograms per kilogram

TCDD

Tetrachlorodibenzo-p-dioxin

U:

The material was analyzed for but was not detected. The associated numerical value is the sample quantitation or



detection limit, which has been adjusted for sample weight/sample volume, extraction volume, percent solids,



sample dilution or other analysis specific parameters. (Ref. 49, p. 2; Ref. 116, pp. 36-38)

- Contaminated ISM Soil Samples

Table 13 EPA IA ISM AOC B Contaminated Soil Concentrations

Sample ID

Sample
Date

Hazardous
Substance

Concentration
(ng/kg)

MRL*
(ng/kg)

References

JHB-07-WY-00-06-01

5/25/2022

2,3,7,8-TCDD

5.17 JK (0.517)

0.513

Ref. 4, p. 86; Ref. 26, pp.
11, 37-40; Ref. 62, p. 7;
Ref. 82, pp. 5.

JHB-12-FY-00-03-

03***

5/24/2022

1,2,3,7,8,9-HxCDD

63 JK (6.3)

5 6**

Ref. 4, p. 86; Ref. 24, pp.
33-34, 2971; Ref. 69, pp.
26-27; Ref. 82, pp. 4.

JHB-15-WY-00-06-

01***

5/25/2022

1,2,3,4,7,8-HxCDF

63.8 JK (6.38)

5.15

Ref. 4, p., 86; Ref. 26, p.
11, 57-60; Ref. 62, p. 15;
Ref. 82, pp. 5.

1,2,3,7,8,9-HxCDD

58.3 JK (5.83)

2.59

JHB-24-BY-00-03-

01***

5/24/2022

2,3,7,8-TCDD

19 JK (1.9)

\ 4**

Ref. 4, p. 86; Ref. 22, pp.
21, 2132; Ref. 67, p. 16;
Ref. 82, pp. 4.

52

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Table 13 EPA IA ISM AOC B Contaminated Soil Concentrations

Sample ID

Sample
Date

Hazardous
Substance

Concentration
(ng/kg)

MRL*
(ng/kg)

References

JHB-24-FY-00-03-
02***

5/24/2022

2,3,7,8-TCDD

53 JK (5.3)

\ 4**

Ref. 4, p. 86; Ref. 22, pp.
18, 2132; Ref. 67, p. 13,
Ref. 82, pp. 4.

JHB-24-WY-00-06-

01 ***

5/24/2022

2,3,7,8-TCDD

20.7 JK (2.07)

0.515

Ref. 4, p. 86; Ref. 27, pp.
9, 54-57; Ref. 63, p. 13,
Ref. 82, pp. 4.

Notes:

CRQL EPA Contract Laboratory Program Contract Required Quantitation Limit

EPA: United States Environmental Protection Agency

HxCDD Hexachlorodibenzo-p-dioxin

HxCDF Hexachlorodibenzofuran

IA Integrated Assessment

ID Identification number

ISM Incremental Sampling Methodology

MRL: Method Reporting Limit

ng/kg: nanograms per kilogram

RL: Reporting Limit

SQL: Sample Quantitation Limit

TCDD Tetrachlorodibenzo-p-dioxin

J:	The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually

present in the environmental sample or may not be consistent with the sample detection or quantitation limit. The
value is an estimated quantity. The data should be seriously considered for decision-making and are usable for many
purposes (Ref. 62, p. 2; Ref. 63, p. 2; Ref. 67, p. 2; Ref. 69, p. 2).

K: J-qualified data has an unknown bias (Ref. 62, p. 2; Ref. 63, p. 2; Ref. 67, p. 2; Ref. 69, p. 2). The concentration is

divided by the adjustment factor of 10. The adjusted value is provided in parentheses (Ref. 50, pp. 8-9).
*: According to the laboratory, the MRLs presented above are most closely related to the SQL as defined by the HRS

(Ref. 1, Sections 1.1 and2.3;Ref. 113).

**: For samples JHB-12-FY-00-03-03, JHB-24-BY-00-03-01, and JHB-24-FY-00-03-02, the laboratory provided
Reporting Limits (RLs). According to the laboratory, the RLs presented above are most closely related to the Sample
Quantitation Limit (SQL) as defined by the HRS (Ref. 1, Sections 1.1 and 2.3; Ref. 114).

***: This property has undergone soil removal/cleanup actions and as such is not considered in the HRS scoring of this
site (Hazardous Waste Quantity or Targets) based on currently available information.

EPA IA 2023 RSE ISM Surface Soil Samples

After reviewing the results of the May 2022 field sampling event, EPA and ODEQ determined that
additional properties should be evaluated. EPA and START conducted another round of residential soil
sampling from March 6, 2023, through March 16, 2023, which included evaluation of an additional 22
properties (Ref. 4, p. 17).

START collected samples following the ISM. START collected increments of soil to a depth of six inches
bgs and from 30-75 increments within each DU. The exact number of increments was determined by the
EPA on site. During the 2023 sampling effort, each property was broken up into two DUs, called Front
Yard and Backyard, and a 0-6-inch bgs ISM sample was collected from each of those DUs. The difference
in approach for ISM samples was directed by EPA and ODEQ. Soil samples were collected from each of
these DUs and submitted to the laboratory for analysis (Ref. 4, p. 17). Additionally, one 5-point composite
sample was collected from each DU from 0-3 inches bgs (Ref. 4, p. 18). Sample locations are shown on
Figure 3B and Figure 4 of this HRS documentation record.

53

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Each increment within a DU was composited into a sample bag. Upon completion of the ISM sample, the
5-point composite sample was collected and placed into a separate bag. Once all samples were collected
from a property, the samples were returned to the command post for sample processing and placed in a
sample cooler. At the end of the project, samples were shipped to an off-site analytical laboratory for ISM
processing and chemical analysis (Ref. 4, p. 18). The subcontracted analytical laboratory dried, sieved,
and processed each sample according to ISM. After processing, the samples were analyzed for dioxins
and furans using EPA Method 1613B (Ref. 4, p. 18).

- 2023 Background Surface Soil

Background samples JHB-02-FY, JHB-57-FY, JHB-57-BY, JHB-59-BY, and JHB-59-FY were collected
from Residence IDs 53, 55, and 54, respectively (Ref. 4, pp. 30, 32; Ref. 51; Figure 4 of this HRS
documentation record). These locations were selected to represent background concentrations for the 2023
ISM sampling as they were located furthest to the east beyond properties with lower concentrations during
the 2022 sampling and not directly downwind of the retort area (Figure 2, Figure 3B, and Figure 4 of this
HRS documentation record; Ref. 4, pp. 74-75, 78, 86; Ref. 39, p. 33; Ref. 59, pp. 3, 16, 35).

Table 14 EPA IA 2023 ISM Background Surface Soil Concentrations

Sample ID

Sampling
Date

Hazardous
Substance

Concentration
(ng/kg)

PQL*
(ng/kg)

References

JHB-02-
FY-00-06-
01

3/14/2023

1,2,3,4,6,7,8-HpCDD

93.6

6.15

Ref. 4, p. 380; Ref. 34, pp. 9,26-
27; Ref. 77, p. 7

1,2,3,4,6,7,8-HpCDF

14.6

6.15

1,2,3,4,7,8,9-HpCDF

6.15 U

6.15

2,3,7,8-TCDD

1.23 U

1.23

OCDD

787

12.3

OCDF

47.0

12.3

JHB-57-
FY-00-06-
01

3/14/2023

1,2,3,4,6,7,8-HpCDD

91.8

6.74

Ref. 4, p. 380; Ref. 34, p. 9, 33;
Ref. 77, p. 14

1,2,3,4,6,7,8-HpCDF

15.0

6.74

1,2,3,4,7,8,9-HpCDF

6.74 U

6.74

2,3,7,8-TCDD

1.35 U

1.35

OCDD

871

13.5

OCDF

47.9

13.5

JHB-57-
BY-00-06-
01

3/14/2023

1,2,3,4,6,7,8-HpCDD

128

6.45

Ref. 4, p. 380; 35, pp. 9,32; Ref.
79, p. 15

1,2,3,4,6,7,8-HpCDF

30.2

6.45

1,2,3,4,7,8,9-HpCDF

6.45 U

6.45

2,3,7,8-TCDD

1.29 U

1.29

OCDD

951

12.9

OCDF

76.3

12.9

JHB-59-
BY-00-06-
01

3/14/2023

1,2,3,4,6,7,8-HpCDD

85.4

6.26

Ref. 4, p. 380; Ref. 35, pp. 9,34-
35; Ref. 79 p. 17

1,2,3,4,6,7,8-HpCDF

12.7

6.26

1,2,3,4,7,8,9-HpCDF

6.26 U

6.26

2,3,7,8-TCDD

1.25 U

1.25

OCDD

743

12.5

OCDF

47.2

12.5

JHB-59-
FY-00-06-
01

3/14/2023

1,2,3,4,6,7,8-HpCDD

139

5.90

Ref. 4, p. 380; 35, pp. 9,39; Ref.
79, p. 22

1,2,3,4,6,7,8-HpCDF

21.3

5.90

1,2,3,4,7,8,9-HpCDF

5.90 U

5.90

2,3,7,8-TCDD

1.18 U

1.18

OCDD

1,170

11.8

OCDF

59.3

11.8

54

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Notes:



EPA:

United States Environmental Protection Agency

HpCDD:

Heptachlorodibenzo-p-dioxin

HpCDF:

Heptachlorodibenzofuran

IA:

Integrated Assessment

ISM:

Incremental Sampling Methodology

ng/kg:

nanograms per kilogram

OCDD:

Octachlorodibenzodioxin

OCDF:

Octachlorodibenzofuran

PQL:

Practical Quantitation Limit

SQL:

Sample Quantitation Limit

TCDD:

Tetrachlorodibenzo-p-dioxin

U:

The material was analyzed for but was not detected. The associated numerical value is the sample quantitation or



detection limit, which has been adjusted for sample weight/sample volume, extraction volume, percent solids,



sample dilution or other analysis specific parameters. (Ref. 77, p. 2; Ref. 79, p. 2; Ref. 116, pp. 36-38)

According to the laboratory, the PQLs presented above are most closely related to the SQL as defined by the HRS
(Ref. 1, Sections 1.1 and 2.3; Ref. 115)

Table 15 EPA IA 2023 ISM Background Levels to Establish the Surface Soil Area of

Observed Contamination

Sample Type

Hazardous
Substance

Maximum
Background
Concentration
EPA IA 2023
ISM Sampling
Results (ng/kg)

HRS Table 2-3
Minimum Concentration to
Document Observed Contamination
by Chemical Analysis (ng/kg)

ISM Surface Soil

1,2,3,4,6,7,8-HpCDD

139

417

1,2,3,4,6,7,8-HpCDF

30.2

90.6

1,2,3,4,7,8,9-HpCDF

6.74 U

The sample measurement equals or exceeds
the sample quantitation limit

2,3,7,8-TCDD

1.35 U

The sample measurement equals or exceeds
the sample quantitation limit

OCDD

1,170

3,510

OCDF

76.3

228.9

Notes:



EPA:

United States Environmental Protection Agency

HpCDD:

Heptachlorodibenzo-p-dioxin

HpCDF:

Heptachlorodibenzofuran

IA:

Integrated Assessment

ISM:

Incremental Sampling Methodology

ng/kg:

nanograms per kilogram

OCDD:

Octachlorodibenzodioxin

OCDF:

Octachlorodibenzofuran

TCDD:

Tetrachlorodibenzo-p-dioxin

U:

The material was analyzed for but was not detected. The associated numerical value is the sample



quantitation or detection limit, which has been adjusted for sample weight/sample volume, extraction



volume, percent solids, sample dilution or other analysis specific parameters (Ref. 77, p. 2; Ref. 79, p.

55

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- Contaminated ISM Soil Samples

Table 16 EPA IA 2023 ISM AOC B Contaminated Soil Concentrations

Sample ID

Sample Date

Hazardous
Substance

Concentration

(ng/kg)

PQL*

(ng/kg)

References

JHB-09-FY-
00-06-01

3/8/2023

1,2,3,4,6,7,8-HpCDD

1,100

6.10

Ref. 4, p. 377; Ref. 32 pp. 10, 65;
Ref. 71, p. 28

1,2,3,4,6,7,8-HpCDF

125

6.10

1,2,3,4,7,8,9-HpCDF

8.07

6.10

2,3,7,8-TCDD

2.95

1.22

OCDF

294

12.2

JHB-09-BY-
00-06-01

3/8/2023

2,3,7,8-TCDD

2.34

1.31

Ref. 4, p. 377; Ref. 31, pp. 9, 49;
Ref. 72, p. 17

JHB-23-FY-
00-06-01

3/7/2023

2,3,7,8-TCDD

8.51

1.26

Ref. 4, p. 376; Ref. 30, pp. 9, 48;
Ref. 73, p. 13

JHB-25-FY-
00-06-01

3/7/2023

1,2,3,4,6,7,8-HpCDD

417

6.27

Ref. 4, p. 376; Ref. 30, pp. 9, 54;
Ref. 73, p. 19

JHB-25-BY-
00-06-01

3/7/2023

1,2,3,4,6,7,8-HpCDD

430

6.04

Ref. 4, p. 376; Ref. 30, pp. 9, 57;
Ref. 73, p. 22

OCDD

3,800

12.1

JHB-27-FY-
00-06-01

3/7/2023

1,2,3,4,6,7,8-HpCDD

576

5.72

Ref. 4, p. 376; Ref. 28, p. 9, 45;
Ref. 74, p. 13

1,2,3,4,7,8,9-HpCDF

7.85

5.72

OCDF

341

11.4

JHB-27-BY-
00-06-01

3/7/2023

1,2,3,4,6,7,8-HpCDD

958

6.12

Ref. 4, p. 376; Ref. 30, pp. 9, 43;
Ref. 73, p. 8

1,2,3,4,6,7,8-HpCDF

173

6.12

1,2,3,4,7,8,9-HpCDF

10.3

6.12

2,3,7,8-TCDD

3.95

1.22

OCDF

433

12.2

JHB-28-FY-
00-06-01

3/8/2023

1,2,3,4,6,7,8-HpCDD

1,030

6.14

Ref. 4, p. 377; Ref. 32, p. 10, 55-
56; Ref. 71, p. 18

1,2,3,4,6,7,8-HpCDF

230

6.14

1,2,3,4,7,8,9-HpCDF

18.4

6.14

OCDF

850

12.3

JHB-37-BY-
00-06-01

3/6/2023

2,3,7,8-TCDD

6.25

1.09

Ref. 4, p. 375; Ref. 28, pp. 9, 42-
44; Ref. 74, p. 11

JHB-37-FY-
00-06-01

3/6/2023

2,3,7,8-TCDD

8.71

1.11

Ref. 4, p. 375; Ref. 28, p. 9, 39-41;
Ref. 74, p. 8

JHB-38-FY-
00-06-01

3/8/2023

1,2,3,4,6,7,8-HpCDD

825

6.19

Ref. 4, p. 377; Ref. 31, pp. 9, 41-
42; Ref. 72, p. 9

1,2,3,4,6,7,8-HpCDF

134

6.19

1,2,3,4,7,8,9-HpCDF

6.50

6.19

JHB-39-FY-
00-06-01

3/8/2023

OCDF

254

11.2

Ref. 4, p. 377; Ref. 28, pp. 9, 58-
59; Ref. 74, p. 26

JHB-41-BY-
00-06-01

3/7/2023

1,2,3,4,6,7,8-HpCDD

476

5.95

Ref. 4, p. 376; Ref. 29, pp. 9, 57-
59; Ref. 75, p. 24

2,3,7,8-TCDD

3.48

1.19

OCDD

4,330

11.9

JHB-41-FY-
00-06-01

3/7/2023

1,2,3,4,6,7,8-HpCDD

991

6.16

Ref. 4, p. 376; Ref. 29, pp. 9, 60-
61; Ref. 75, p. 26

1,2,3,4,6,7,8-HpCDF

144

6.16

1,2,3,4,7,8,9-HpCDF

8.48

6.16

OCDF

393

12.3

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Table 16 EPA IA 2023 ISM AOC B Contaminated Soil Concentrations

Sample ID

Sample Date

Hazardous
Substance

Concentration

(ng/kg)

PQL*

(ng/kg)

References

JHB-42-FY-
00-06-01

3/8/2023

1,2,3,4,6,7,8-HpCDD

954

6.21

Ref. 4, p. 377; Ref. 32, pp. 10, 47;
Ref. 71, p. 10

1,2,3,4,6,7,8-HpCDF

145

6.21

1,2,3,4,7,8,9-HpCDF

8.24

6.21

2,3,7,8-TCDD

6.94

1.24

OCDF

320

12.4

JHB-42-BY-
00-06-01

3/8/2023

1,2,3,4,6,7,8-HpCDD

1,230

6.37

Ref. 4, p. 377; Ref. 31, pp. 9, 39;
Ref. 72, p. 7

1,2,3,4,6,7,8-HpCDF

266

6.37

1,2,3,4,7,8,9-HpCDF

19.8

6.37

2,3,7,8-TCDD

2.12

1.27

OCDF

827

12.7

JHB-43-BY-
00-06-01

3/7/2023

2,3,7,8-TCDD

5.81

1.10

Ref. 4, p. 376; Ref. 28, pp. 9, 48;
Ref. 74, p. 16

JHB-43-FY-
00-06-01

3/7/2023

1,2,3,4,6,7,8-HpCDD

1,340

6.13

Ref. 4, p. 376; Ref. 29, pp. 9, 41;
Ref. 75, p. 7

1,2,3,4,6,7,8-HpCDF

98.6

6.13

OCDF

234

12.3

JHB-44-FY-
00-06-01

3/8/2023

1,2,3,4,6,7,8-HpCDD

864

6.20

Ref. 4, p. 377; Ref. 32, p. 10, 51;
Ref. 71, p. 14

1,2,3,4,6,7,8-HpCDF

137

6.20

1,2,3,4,7,8,9-HpCDF

11.8

6.20

JHB-44-BY-
00-06-01

3/8/2023

1,2,3,4,6,7,8-HpCDD

638

5.94

Ref. 4, p. 377; Ref. 31, pp. 9, 46;
Ref. 72, p. 14

1,2,3,4,6,7,8-HpCDF

109

5.94

1,2,3,4,7,8,9-HpCDF

8.45

5.94

2,3,7,8-TCDD

1.60

1.19

JHB-52-BY-
00-06-01

3/9/2023

1,2,3,4,6,7,8-HpCDD

493

6.45

Ref. 4, p. 377; Ref. 31, pp. 9, 51;
Ref. 72, p. 19

1,2,3,4,6,7,8-HpCDF

101

6.45

2,3,7,8-TCDD

1.48

1.29

OCDF

327

12.9

JHB-55-FY-
00-06-01

3/7/2023

1,2,3,4,6,7,8-HpCDD

479

5.64

Ref. 4, p. 376; Ref. 28, pp. 9, 50;
Ref. 74, p. 18

2,3,7,8-TCDD

1.61

1.13

OCDF

246

11.3

JHB-55-BY-
00-06-01

3/7/2023

1,2,3,4,6,7,8-HpCDD

423

5.93

Ref. 4, p. 376; Ref. 30, pp. 9, 45;
Ref. 73, p. 10

1,2,3,4,6,7,8-HpCDF

107

5.93

2,3,7,8-TCDD

1.58

1.19

OCDF

283

11.9

JHB-65-BY-
00-06-01

3/15/2023

1,2,3,4,6,7,8-HpCDD

464

6.56

Ref. 4, p. 380; Ref. 33, pp. 10, 43;
Ref. 76, p. 24

OCDD

3,980

13.1

JHB-67-BY-
00-06-01

3/14/2023

1,2,3,4,6,7,8-HpCDD

929

6.64

Ref. 4, p. 380; Ref. 34, pp. 9, 37;
Ref. 77, p. 18

1,2,3,4,6,7,8-HpCDF

119

6.64

2,3,7,8-TCDD

11.5

1.33

JHB-67-FY-
00-06-01

3/14/2023

1,2,3,4,6,7,8-HpCDD

1,120

6.09

Ref. 4, p. 380; Ref. 34, pp. 9, 39;
Ref. 77, pp. 20

1,2,3,4,6,7,8-HpCDF

117

6.09

1,2,3,4,7,8,9-HpCDF

6.26

6.09

OCDF

297

12.2

Notes:

EPA: United States Environmental Protection Agency
HpCDD: Heptachlorodibenzo-p-dioxin

57

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HpCDF: Heptachlorodibenzofuran
IA:	Integrated Assessment

ID:	Identification number

ISM: Incremental Sampling Methodology
ng/kg: nanograms per kilogram
OCDD: Octachlorodibenzodioxin
OCDF: Octachlorodibenzofuran
SQL: Sample Quantitation Limit
TCDD: Tetrachlorodibenzo-p-dioxin

*: According to the laboratory, the PQLs presented above are most closely related to the SQL as defined by the HRS
(Ref. 1, Sections 1.1 and 2.3; Ref. 115).

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AOC B Hazardous Waste Quantity

Hazardous Constituent Quantity (Tier A)

The hazardous constituent quantity for AOC B could not be adequately determined according to the HRS
requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from
the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.1).
There are insufficient historical and current data (manifests, PRP records, State records, permits, waste
concentration data, etc.) available to adequately calculate the total or partial mass of all CERCLA
hazardous substances in the source and the associated releases from the source. Therefore, there is
insufficient information to calculate the hazardous constituent quantity for AOC B with reasonable
confidence. Scoring proceeds to the evaluation of Tier B, hazardous wastestream quantity (Ref. 1, Section
2.4.2.1.1).

Hazardous Constituent Quantity Value: NS

Hazardous Wastestream Quantity (Tier B)

The total Hazardous Wastestream Quantity for AOC B could not be adequately determined according to
the HRS requirements; that is, the total mass, or a partial estimate, of all hazardous wastestreams and
CERCLA pollutants and contaminants for the source and releases from the source is not known and cannot
be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.2). Insufficient historical and current data
(permits, waste concentration data, annual reports, etc.) are available to adequately calculate the total
mass, or a partial estimate, of all hazardous wastestreams and CERCLA pollutants and contaminants for
the source and the associated releases from the source. Therefore, there is insufficient information to
adequately calculate or extrapolate a total or partial Hazardous Wastestream Quantity for AOC B with
reasonable confidence. Scoring proceeds to the evaluation of Tier C, volume (Ref. 1, Section 2.4.2.1.3).

Hazardous Wastestream Quantity Value: NS

Volume (Tier C)

Tier C, volume is not applicable to source type contaminated soil for the soil exposure component (Ref.
1, Section 5.1.1.2.2).

Volume Assigned Value: 0

Area (Tier D)

The area of AOC B is estimated to be approximately 454,604 square feet, based on surface soil samples
collected by ODEQ in 2021 and by EPA in 2022 and 2023 during the IA with concentrations of hazardous
substances that were at concentrations significantly above background (see Figure 3B, Tables 5 through
16 of this HRS documentation record.) However, the area of AOC B is not considered to be adequately
determined as an undetermined portion of AOC B is beneath buildings, roads, or other impervious covers
and seven properties within the AOC boundaries have undergone removal actions (Figure 3B of this HRS
documentation record; Ref. 41, pp. 10, 30). Therefore, the area of AOC B is greater than 0 but unknown.

Area Assigned Value: >0

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Attribution of Observed Contamination in AOC A and AOC B to the J. H. Baxter Facility
Facility Operations and Emissions

J. H. Baxter operated as a wood-treatment facility from 1943 through 2022 (Ref. 6, p. 10; Ref. 7, p. 18;
Ref. 8, p. 1; Ref. 12, p. 17; Ref. 14, p. 11). Operations at the facility included high-pressure wood treating
in retorts using a variety of preservative chemicals, including PCP, ACZA, 50/50 Heavy Oil Blends of
Creosote and Bunker C Oil (50/50), Creosote, and ACQ (Ref. 5, pp. 13-18; Ref. 10, pp. 3-4; Ref. 14, p. 5;
Ref. 15, pp. 17, 57; Ref. 16, p. 9; Ref. 87, p. 9). After raw wood products were treated in retorts, they were
transported to concrete drip pads where the treated wood was allowed to dry until no further drippage
occurred. After drying on the drip pad, treated wood products were either stored on one of several on-site
treated wood-storage areas, or transported off-site by truck or rail (Ref. 7, pp. 20, 40; Ref. 15, p. 18; Ref.
87, p. 11).

Vapors generated during the wood-treating process were routed to a condenser to remove liquid from the
exhaust stream. Liquids removed by the condenser were routed to a hot well prior to flowing to a
downstream collection sump. Process liquids collected in the sump were delivered to a recovery tank prior
to entering the process water treatment system. The dried exhaust stream was routed to a knock-out drum
prior to exhausting to atmosphere through the PCP stack. The dried exhaust stream during heavy oil
charges were routed to a downstream air pollution control device for control of VOC emissions prior to
emitting to atmosphere (Ref. 87, p. 10).

Poor housekeeping, including pipe leakage, soil staining, pooling of hazardous waste on the soil surface,
and failure to abide by odor abatement requirements have been noted during facility operations (Ref. 13,
pp. 1-6; Ref. 90, pp. 4-5; Ref. 91, pp. 14-15, 19, 23-24, 26-27). In 2014, an inspection was conducted at
the J. H. Baxter facility using Forward Looking Infrared (FLIR) technology and a Photoionization
Detector (PID) to identify process gas releases. Gas releases were identified at multiple locations including
the oil-water separators, cooling tower basin, process water clarifier and vault, creosote and PCP sumps,
ACZA scrubber vent, condensate unit, retorts, and treated wood (Ref. 91, pp. 1-2, 3-5, 31-57).

In 2021, J. H. Baxter collected multiple raw material and process water samples from the facility for
analysis of dioxins and furans, PAHs, VOCs, ammonia, wood organics, and/or total metals (Ref. 85, p. 1;
Ref. 87, pp. 1-2, 13-15, 21, 24-25). As shown in Table 17 of this HRS documentation record below,
hazardous substances associated with AOC A and AOC B, including PCP, dioxins, furans, and PAHs,
were detected in raw material and process water samples from the facility (Ref. 85, pp. 4-7).

The hazardous substances found at observed contamination concentrations in AOCs A and B include
PAHs, PCP, dioxins, furans, and metals (see Tables 2 through 16 of this HRS documentation record).
There are three types of contaminants generally found at wood treater facilities, either alone or in
combination: creosote, PCP, and chromated copper arsenate (CCA). Creosote is an oily liquid made up of
approximately 85% PAHs (Ref. 11, p. 23; Ref. 19, p. 165). In the wood preserving industry, creosote
signifies a distillate of coal tar produced by the high temperature carbonization of bituminous coal. Coal
tar creosote refers to "the fractions or blends of fractions specifically used for timber preservation" (Ref.
19, p. 165). The PAHs commonly found at wood treater sites include anthracene, benzo(a)anthracene,
benzo(a)pyrene, benzo(k)fluoranthene, chrysene, fluoranthene, indeno(l,2,3-cd)pyrene, PCP,
phenanthrene, and pyrene (Ref. 11, p. 23; Ref. 19, pp. 166, 169-171, 184). PCP was first used in the U.S.
in 1936 as a wood preservative to prevent fungal decay and insect damage. PCP and by-products of its

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synthesis (hereinafter collectively referred to as PCP because those exposed to PCP are also exposed to
products formed during its synthesis) include higher-chlorinated dioxins and furans (Ref. 20, pp. 1, 3).
Common PCP synthesis by-products include polychlorinated phenols (tetra- and tri-); hexachlorobenzene
(HCB); hexa-, hepta-, and octachlorodibenzo-p-dioxins (HxCDD, HpCDD, and OCDD); and hexa-,
hepta-, and octachlorodibenzofurans. 2,3,7,8-TCDD is a by-product of 2,4,5-trichlorophenol; 2,3,7,8-
TCDD may also result from the alkaline hydrolysis of HCB to PCP although it is rarely detected in
commercial preparations (Ref. 20, pp. 1, 3). Metals, such as arsenic, cadmium, chromium, copper, and
lead, are associated with CCA or are otherwise commonly found at wood treater sites (Ref. 11, p. 23).
Pesticides may also be used in wood treatment to prevent rotting, insect damage, and mold (Ref. 23, p. 1).
The presence of the PAH benzo(g,h,i)perylene and the phthalate bis(2-ethylhexyl) phthalate (aka di(2-
ethylhexyl) phthalate) at the site may be associated with the use of pesticides during the wood treating
process (Ref. 43, p. 2; Ref. 47, p. 1).

J. H. Baxter Process and Wastestream Samples

Table 17 J. H. Baxter Raw Material and Process Water Sampling Results

Sample ID and
Description

Sampling
Date

Hazardous Substance

Concentration

PQL

References

PCPHW-01
PCP Hot Well
Influent

2/11/2021

1,2,3,4,6,7,8-HpCDD

22,500 J ng/kg

2,580 ng/kg

Ref. 85, pp. 4, 21-22;
Ref. 87, pp. 21, 25

1,2,3,4,6,7-HpCDF

18,400 J ng/kg

2,580 ng/kg

OCDD

96,700 J ng/kg

5,150 ng/kg

OCDF

206,000 J ng/kg

5,150 ng/kg

PCPHW-02
Penta Hot Well
Influent

6/3/2021

Pentachlorophenol

37,800 mg/kg

480 mg/kg

Ref. 85, pp. 6, 265-
266; Ref. 87, pp. 21,
25

Phenanthrene

118 mg/kg

96 mg/kg

BLND-01
50/50 Blend
Preservative
Solution

2/11/2021

1,2,3,4,6,7,8-HpCDD

728,000 J ng/kg

2,690 ng/kg

Ref. 85, pp. 4, 25-26;
Ref. 87, pp. 21, 25

1,2,3,4,6,7,8-HpCDF

125,000 J ng/kg

2,690 ng/kg

1,2,3,4,7,8,9-HpCDF

3,460 J ng/kg

2,690 ng/kg

1,2,3,4,7,8-HxCDD

4,880 J ng/kg

2,690 ng/kg

1,2,3,6,7,8-HxCDD

89,400 J ng/kg

2,690 ng/kg

1,2,3,7,8,9-HxCDD

20,600 J ng/kg

2,690 ng/kg

1,2,3,7,8-PeCDD

4,220 J ng/kg

2,690 ng/kg

OCDD

1,920,000 ng/kg

5,380 ng/kg

OCDF

225,000 J ng/kg

5,380 ng/kg

BLND-02
50/50 Blend
Preservative
Solution

6/3/2021

Anthracene

6,750 mg/kg

500 mg/kg

Ref. 85, pp. 6, 263-
264; Ref. 87, pp. 21,
25

Benzo(a)anthracene

6,430 mg/kg

100 mg/kg

Benzo(a)pyrene

1,820 mg/kg

100 mg/kg

Benzo(g.h.i)pcr\icne

564 mg/kg

100 mg/kg

Benzo(k)fluoranthene

1,980 mg/kg

100 mg/kg

Chrysene

5,900 mg/kg

100 mg/kg

Fluoranthene

40,100 mg/kg

500 mg/kg

Indeno(l ,2,3 -c,d)pyrene

576 mg/kg

100 mg/kg

Naphthalene

21,400 mg/kg

500 mg/kg

Pentachlorophenol

1,070 mg/kg

not provided

Phenanthrene

54,400 mg/kg

2,500 mg/kg

Pyrene

24,700 mg/kg

500 mg/kg

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Table 17 J. H. Baxter Raw Material and Process Water Sampling Results

Sample ID and
Description

Sampling
Date

Hazardous Substance

Concentration

PQL

References

PCP-01

PCP Preservative
Solution

2/11/2021

1,2,3,4,6,7,8-HpCDD

2,500,000 J ng/kg

12,300 ng/kg

Ref. 85, pp. 4, 27-28;
Ref. 87, pp. 21, 25

1,2,3,4,6,7,8-HpCDF

2,050,000 J ng/kg

12,300 ng/kg

1,2,3,4,7,8,9-HpCDF

147,000 J ng/kg

12,300 ng/kg

1,2,3,4,7,8-HxCDF

18,800 J ng/kg

12,300 ng/kg

1,2,3,6,7,8-HxCDD

137,000 J ng/kg

12,300 ng/kg

1,2,3,7,8,9-HxCDD

21,600 J ng/kg

12,300 ng/kg

OCDD

6,110,000 J ng/kg

24,500 ng/kg

OCDF

19,900,000 J ng/kg

24,500 ng/kg

PCP-01-DUP
PCP Preservative
Solution

2/11/2021

1,2,3,4,6,7,8-HpCDD

2,670,000 J ng/kg

13,300 ng/kg

Ref. 85, pp. 4, 29-30;
Ref. 87, pp. 21, 25

1,2,3,4,6,7,8-HpCDF

2,180,000 J ng/kg

13,300 ng/kg

1,2,3,4,7,8,9-HpCDF

150,000 J ng/kg

13,300 ng/kg

1,2,3,4,7,8-HxCDF

18,400 J ng/kg

13,300 ng/kg

1,2,3,6,7,8-HxCDD

132,000 J ng/kg

13,300 ng/kg

1,2,3,7,8,9-HxCDD

23,700 J ng/kg

13,300 ng/kg

OCDD

12,500,000 J ng/kg

26,600 ng/kg

OCDF

27,100,000 J ng/kg

26,600 ng/kg

PCP-02

PCP Preservative
Solution

6/3/2021

Pentachlorophenol

68,900 mg/kg

2,500 mg/kg

Ref. 85, pp. 6, 259-
260; Ref. 87, pp. 21,
25

PCPHO-Ol
PCP Chamber Oil
Water Separator
Influent

2/11/2021

1,2,3,4,6,7,8-HpCDD

2,070,000 J ng/kg

13,300 ng/kg

Ref. 85, pp. 4, 37-38;
Ref. 87, pp. 21, 25

1,2,3,4,6,7,8-HpCDF

1,740,000 J ng/kg

13,300 ng/kg

1,2,3,4,7,8,9-HpCDF

126,000 J ng/kg

13,300 ng/kg

1,2,3,4,7,8-HxCDF

14,400 J ng/kg

13,300 ng/kg

1,2,3,6,7,8-HxCDD

99,200 J ng/kg

13,300 ng/kg

1,2,3,7,8,9-HxCDD

17,500 J ng/kg

13,300 ng/kg

OCDD

9,910,000 J ng/kg

26,600 ng/kg

OCDF

21,500,000 J ng/kg

26,600 ng/kg

OWSPCP-02
PCP Chamber Oil
Water Separator
Influent

6/3/2021

Fluoranthene

119 mg/kg

98 mg/kg

Ref. 85, pp. 6, 267-
268; Ref. 87, pp. 21,
25

Pentachlorophenol

67,100 mg/kg

2,500 mg/kg

Phenanthrene

164 mg/kg

98 mg/kg

EVAP-01

Evaporator Influent
(Carbon Filter
Discharge)

2/11/2021

1,2,3,4,6,7,8-HpCDD

371,000 J pg/L

2,490 pg/L

Ref. 85, pp. 5, 7, 39-
40, 146; Ref. 87, pp.
21,25

1,2,3,4,6,7,8-HpCDF

203,000 J pg/L

2,490 pg/L

1,2,3,4,7,8,9-HpCDF

13,600 J pg/L

2,490 pg/L

1,2,3,4,7,8-HxCDD

3,370 J pg/L

2,490 pg/L

1,2,3,6,7,8-HxCDD

24,000 J pg/L

2,490 pg/L

1,2,3,7,8,9-HxCDD

12,000 J pg/L

2,490 pg/L

1,2,3,7,8-PeCDD

4,700 J pg/L

2,490 pg/L

OCDD

1,700,000 J pg/L

4,970 pg/L

OCDF

2,280,000 J pg/L

4,970 pg/L

Arsenic

5,645.79 J ug/L

1,000.000 ng/L

Copper

3,560.88 J ng/L

200.000 ng/L

Zinc

309.72 J (ig/L

200.000 ng/L

62

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Table 17 J. H. Baxter Raw Material and Process Water Sampling Results

Sample ID and
Description

Sampling
Date

Hazardous Substance

Concentration

PQL

References

EVAP-01-DUP
Evaporator Influent
(Carbon Filter
Discharge)

2/11/2021

1,2,3,4,6,7,8-HpCDD

454,000 J pg/L J

2,520 pg/L

Ref. 85, pp. 5,7,41-
42, 147; Ref. 87, pp.
21,25

1,2,3,4,6,7,8-HpCDF

253,000 J pg/L J

2,520 pg/L

1,2,3,4,7,8,9-HpCDF

18,200 J pg/L J

2,520 pg/L

1,2,3,4,7,8-HxCDD

4,540 J pg/L J

2,520 pg/L

1,2,3,6,7,8-HxCDD

30,300 J pg/L J

2,520 pg/L

1,2,3,7,8,9-HxCDD

15,700 J pg/L J

2,520 pg/L

1,2,3,7,8-PeCDD

5,940 J pg/L J

2,520 pg/L

2,3,7,8-TCDD

507 J pg/L J

504 pg/L

OCDD

2,100,000 J pg/L J

5,040 pg/L

OCDF

2,930,000 J pg/L J

5,040 pg/L

Arsenic

7,405.846 J ug/L

1,000.000 ug/L

Copper

3,436.34 J ug/L

200.000 ug/L

Zinc

274.84 J ug/L J

200.000 ug/L

EVAP-02

Evaporator Influent
(Carbon Filter
Discharge)

6/2/2021

1,2,3,4,6,7,8-HpCDD

55,300 J pg/L

274 pg/L

Ref. 85, pp. 4, 6, 7,
192-193, 237-238,
288; Ref. 87, pp. 21,
25

1,2,3,4,6,7,8-HpCDF

16,600 J pg/L

274 pg/L

1,2,3,4,7,8,9-HpCDF

1,030 J pg/L

274 pg/L

1,2,3,6,7,8-HxCDD

5,690 J pg/L

274 pg/L

1,2,3,7,8,9-HxCDD

2,310 J pg/L

274 pg/L

1,2,3,7,8-PeCDD

676 J pg/L

274 pg/L

OCDD

184,000 J pg/L

548 pg/L

OCDF

163,000 J pg/L

548 pg/L

Anthracene

21.9 J ug/L

1.9 ug/L

Benzo(a)anthracene

4.88 J ug/L

1.9 ug/L

Benzo(a)pyrene

2.13 J ug/L

1.9 ug/L

Benzo(k)fluoranthene

1.96 J ug/L

1.9 ug/L

Chrysene

3.42 J ug/L

1.9 ug/L

Fluoranthene

45 J ug/L

1.9 ug/L

Pentachlorophenol

258,000 J ug/L

2,900 ug/L

Phenanthrene

66.4 J ug/L

1.9 ug/L

Pyrene

16.3 J ug/L

1.9 ug/L

Arsenic

37,030.51 ug/L

1,000.000 ug/L

Copper

30,603 ug/L

1,000.000 ug/L

Zinc

2130.84 ug/L

100.000 ug/L

STRM-01
Storm Water
Treatment Influent

2/11/2021

1,2,3,4,6,7,8-HpCDD

96,100 J pg/L

508 pg/L

Ref. 85, pp. 4, 6, 43-
44, 97; Ref. 87, pp.
21,25

1,2,3,4,6,7,8-HpCDF

13,400 J pg/L

508 pg/L

1,2,3,4,7,8,9-HpCDF

631 J pg/L

508 pg/L

1,2,3,4,7,8-HxCDD

6,900 J pg/L

508 pg/L

1,2,3,4,7,8-HxCDF

597 J pg/L

508 pg/L

1,2,3,6,7,8-HxCDD

15,300 J pg/L

508 pg/L

1,2,3,6,7,8-HxCDF

688 J pg/L

508 pg/L

1,2,3,7,8,9-HxCDD

14,900 J pg/L

508 pg/L

1,2,3,7,8-PeCDD

11,000 J pg/L

508 pg/L

2,3,7,8-TCDD

834 J pg/L

102 pg/L

OCDD

210,000 J pg/L

1,020 pg/L

OCDF

31,400 J pg/L

1,020 pg/L

Pentachlorophenol

100 J ug/L

5.4 ug/L

63

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Table 17 J. H. Baxter Raw Material and Process Water Sampling Results

Sample ID and
Description

Sampling
Date

Hazardous Substance

Concentration

PQL

References

POND-01
Mill Pond

2/11/2021

1,2,3,4,6,7,8-HpCDD

13,900 J pg/L

508 pg/L

Ref. 85, pp. 4, 6, 7,
45-46, 99-100, 133;
Ref. 87, pp. 21, 25

1,2,3,4,6,7,8-HpCDF

2,790 J pg/L

508 pg/L

1,2,3,4,7,8-HxCDD

511 J pg/L

508 pg/L

1,2,3,6,7,8-HxCDD

1,390 J pg/L

508 pg/L

1,2,3,7,8,9-HxCDD

1,260 J pg/L

508 pg/L

1,2,3,7,8-PeCDD

554 J pg/L

508 pg/L

OCDD

47,300 J pg/L

1,020 pg/L

OCDF

7,770 J pg/L

1,020 pg/L

Pentachlorophenol

32 J ug/L

5.4 ug/L

CFI-01

Carbon Filter Inlet
(Pre-Treat)

6/2/2021

1,2,3,4,6,7,8-HpCDD

386,000 J pg/L

2,490 pg/L

Ref. 85, pp. 4, 6,
190-191,235-236;
Ref. 87, pp. 21, 25

1,2,3,4,6,7,8-HpCDF

188,000 J pg/L

2,490 pg/L

1,2,3,4,7,8,9-HpCDF

12,700 J pg/L

2,490 pg/L

1,2,3,4,7,8-HxCDD

3,480 J pg/L

2,490 pg/L

1,2,3,4,7,8-HxCDF

2,590 J pg/L

2,490 pg/L

1,2,3,6,7,8-HxCDD

26,300 J pg/L

2,490 pg/L

1,2,3,7,8,9-HxCDD

13,200 J pg/L

2,490 pg/L

OCDD

1,650,000 J pg/L

4,980 pg/L

OCDF

2,020,000 J pg/L

4,980 pg/L

Anthracene

1,250 J ug/L

20 ug/L

Benzo(a)anthracene

645 J ug/L

20 ug/L

Benzo(a)pyrene

166 J ug/L

20 ug/L

Bcnzo(g.hi)pcr\icne

46.6 J ug/L

20 ug/L

Benzo(k)fluoranthene

209 J ug/L

20 ug/L

Chrysene

605 J ug/L

20 ug/L

Fluoranthene

4,240 J ug/L

200 ug/L

Indeno(l ,2,3 -c,d)pyrene

55.2 J ug/L

20 ug/L

Pentachlorophenol

389,000 J ug/L

5,000 ug/L

Phenanthrene

6,530 J ug/L

200 ug/L

Pyrene

65.4 J ug/L

20 ug/L

EV-OUT-01
Evaporator
Blowdown
(Recycle)

6/2/2021

1,2,3,4,6,7,8-HpCDD

7,970,000 J pg/L

9,760 pg/L

Ref. 85, pp. 4, 6,194-
195, 239-240; Ref.
87, pp. 21,25

1,2,3,4,6,7,8-HpCDF

2,080,000 J pg/L

9,760 pg/L

1,2,3,4,7,8,9-HpCDF

144,000 J pg/L

9,760 pg/L

1,2,3,4,7,8-HxCDD

98,300 J pg/L

9,760 pg/L

1,2,3,4,7,8-HxCDF

30,200 J pg/L

9,760 pg/L

1,2,3,6,7,8-HxCDD

982,000 J pg/L

9,760 pg/L

1,2,3,6,7,8-HxCDF

15,200 J pg/L

9,760 pg/L

1,2,3,7,8,9-HxCDD

413,000 J pg/L

9,760 pg/L

1,2,3,7,8-PeCDD

106,000 J pg/L

9,760 pg/L

2,3,4,6,7,8-HxCDF

17,000 J pg/L

9,760 pg/L

2,3,7,8-TCDD

4,470 J pg/L

1,950 pg/L

OCDD

25,000,000 J pg/L

19,500 pg/L

OCDF

20,600,000 J pg/L

19,500 pg/L

Anthracene

245 J ug/L

20 ug/L

Benzo(a)anthracene

559 J ug/L

20 ug/L

Benzo(a)pyrene

41.6 J ug/L

20 ug/L

Benzo(b)fluoranthene

210 J ug/L

20 ug/L

Benzo(g,h,i)perylene

29.2 J ug/L

20 ug/L

Benzo(k)fluoranthene

216 ug/L

20 ug/L

Chrysene

567 J ug/L

20 ug/L

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Table 17 J. H. Baxter Raw Material and Process Water Sampling Results

Sample ID and
Description

Sampling
Date

Hazardous Substance

Concentration

PQL

References





Fluoranthene

2,460 J ng/L

200 ng/L



Indeno(l ,2,3 -c,d)pyrene

41 J ng/L

20 ng/L

Pentachlorophenol

2,820,000 J ng/L

30,000 ng/L

Phenanthrene

967 J ng/L

20 ng/L

Pyrene

1,490 J (ig/L

20 ng/L

Facility Emissions to the Residential Neighborhood North of the J. H. Baxter Property

Seasonal downwind direction from the facility is northward toward the residential neighborhood at AOC
B (Ref. 21; Ref. 39, p. 33; Ref. 59, pp. 3, 14, 16, 35; Ref. 64; Ref. 92, p. 1). Since 1977, when the first air
quality complaint was recorded, residents of the neighborhoods to the north and northeast of the facility
have reported numerous complaints to LRAPA concerning odor and symptoms of illness (Ref. 59, p. 14;
Ref. 88, pp. 5, 7, 8, 10; Ref. 90, pp. 11-12). The number of air quality complaints peaked in 2004, with
762 complaints recorded (Ref. 88, p. 7; Ref. 90, pp. 11-12). Soil deposition modeling was performed to
help determine which residential properties were likely to need removals of dioxin-contaminated soils just
north of the J. H. Baxter facility (Ref. 92, p. 5).

An Air Contaminant Discharge Permit renewal application submitted to LRAPA by Baxter in October
2003 indicated that most of Baxter's VOC emissions were from creosote. The permit application details
the weight fraction of polycyclic aromatic compounds in gaseous emissions from liquid creosote,
including naphthalene (44%), 2-methylnaphthalene (13%), dibenzofuran (5%), acenaphthene (5%), 1-
methylnaphthalene (4%), fluorene (2%), and phenanthrene (1%) (Ref. 59, p. 9).

In 2005-2006, LRAPA conducted an air sampling study in response to community concerns regarding
emissions from J. H. Baxter. The study was designed to measure maximum downwind exposures in the
neighborhoods nearest to the J. H. Baxter facility adjacent to the north, northeast and northwest. The
process at the J. H. Baxter facility that generated the majority of the emissions used mixtures of creosote,
oil and PCP to treat wood products for preservation. The various stages of treatment operations were
performed in drying kilns and large retorts using pressure and vacuum. Emissions occurred from many
points, including vacuum pumps, tank vents, retort door openings, and treated product storage (Ref. 59,
p. 3).

Detections of hazardous substances related to plant site processes correlated well with downwind
exposure. None of the facility-related hazardous substances were ever detected in samples that had no
downwind exposure (Ref. 59, pp. 6, 9). LRAPA staff documented operations-related odors on the facility
and in the neighborhood to the north during many of the air sampling events as part of the 2005-2006
study. Resident complaints were received during these times and confirmed by LRAPA staff (Ref. 59, pp.
25-27, 29-34).

Other Facilities

To assess attribution from the J. H. Baxter facility, multiple tools were used to examine other facilities
within the area. A search of available environmental records was conducted by Environmental Data
Resources, Inc. (EDR), including environmental databases, historical Sanborn maps, historical
topographic maps, historical aerial photographs, and historical city directories (Ref. 94, p. 1; Ref. 95, p.

65

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1; Ref. 96, p. 1; Ref. 97, p. 1; Ref. 98, p. 1; Ref. 99, p. 1). LRAPA provided information to EPA regarding
other potential contributors of emissions in the facility area (Ref. 100). Public records databases were
reviewed to identify other facilities within a mile radius of the J. H. Baxter facility that have CERCLA
hazardous substances associated with them (Ref. 98, p. 3; Ref. 100, p. 1).

The recycling facility, directly neighboring J. H. Baxter to the east, reports some dioxins and metals
attributed to their emissions. This facility is situated on land owned by J. H. Baxter until 2007 and has
been in business since 2015. (Ref. 100, p. 1). There are multiple other facilities within 1.5 miles of the J.
H. Baxter site (Ref. 93, pp. 1-7). These facilities include lumber and sawmills, plywood, truss, cabinet and
veneer manufactures, recycling facilities, a landfill, auto sales, tire re-treaders, gas stations and garages, a
laboratory, chemical products wholesaler, electroplating, surface coating, paint, resin, and glue
manufactures, a printing facility, and sheet metal manufacturing (Ref. 94; Ref. 95; Ref. 96; Ref. 97; Ref.
98; Ref. 99; Ref. 100; Ref. 101; Ref. 102; Ref. 103; Ref. 104; Ref. 105; Ref. 106; Ref. 107; Ref. 108; Ref.
109; Ref. 110; Ref. Ill; Ref. 112; see Ref. 93, pp. 1-7 for specific page numbers). Some of these facilities
are associated with some of the same hazardous substances as those attributable to J. H. Baxter emissions
and wastes and thus could be contributing to the soil contamination in the larger site area. Most of these
facilities, however, are located to the south of the J. H. Baxter site, beyond background soil sample
locations (Figure 4 of this HRS documentation record; Ref. 93, p. 1).

J. H. Baxter Attribution Summary

For over 50 years, J. H. Baxter operated a wood treatment facility at its Roosevelt Boulevard location,
formerly Baxter Street, in southwest Eugene, Lane County, Oregon (Figure 1 and Figure 2 of this HRS
documentation record; Ref. 4, p. 13; Ref. 7, p. 18; Ref. 18, p. 6). The hazardous substances found in AOC
A, located on the J. H. Baxter facility property, and/or AOC B, located immediately north and downwind
of the J. H. Baxter facility and its emissions sources, are commonly associated with wood-treating
operations and include PAHs, PCP, dioxins, furans, metals, and pesticides (see Tables 2 through 16 of this
HRS documentation record; Ref. 11, p. 23; Ref. 19, pp. 165, 166, 169-171, 184; Ref. 20, pp. 1, 3; Ref. 23,
p. 1; Ref. 36, p. 1; Ref. 37, p. 2; Ref. 38, p. 1; Ref. 43, p. 2; Ref. 47, p. 1; Ref. 92, pp. 1, 5, 12-35).

For decades, residents living in the neighborhoods to the north and northeast of the J. H. Baxter facility
have reported complaints to LRAPA concerning odor and symptoms of illness (Ref. 59, p. 14; Ref. 88,
pp. 5, 7, 8, 10; Ref. 90, pp. 11-12). An Air Contaminant Discharge Permit renewal application submitted
by J. H. Baxter in October 2003 indicated that most of J. H. Baxter's VOC emissions were from creosote
(Ref. 59, p. 9). In 2005-2006, an air sampling study was conducted in response to community concerns
regarding emissions from J. H. Baxter. Detections of hazardous substances related to plant site processes
correlated well with downwind exposure (Ref. 59, pp. 3, 6, 9).

The J. H. Baxter site is located in an industrialized area. Other facilities have been identified in the site
vicinity that may also be associated with some of the hazardous substances found in J. H. Baxter process
and waste samples and that are present at observed contamination levels in AOCs A and B (Ref. 93, p. 1-
7); some of these other facilities may have contributed to the soil contamination in the area. However, soil
deposition modeling indicates dioxins and metals were likely to be deposited in the neighborhood north
of the J. H. Baxter facility from J. H. Baxter's emissions sources (Ref. 92, pp. 1, 5, 12-35). Based on
available evidence, including the soil deposition modeling, air emission data, the significantly lower
contaminant levels found at background soil sample locations between the J. H. Baxter site and other
facilities south of the site, downwind odor complaints directly tied to J. H. Baxter operations, samples of

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J. H. Baxter process products with high concentrations of generally the same hazardous substances as
those found in the observed contamination, and predominant wind directions that are seasonally to the
north, the hazardous substances found at levels significantly above background in AOC A and AOC B are
clearly attributable, at least in part, to J. H. Baxter facility operations (Ref. 21; Ref. 39, pp. 33, 56, 59;
Ref. 59, pp. 3, 14, 16, 35; Ref. 64; Ref. 92, p. 1; Table 17 of this HRS documentation record).

67

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5.1.1

RESIDENT POPULATION THREAT

5.1.1.1	LIKELIHOOD OF EXPOSURE

Samples documenting observed contamination to residential properties north of the J. H. Baxter facility
were collected during the 2021 ODEQ sampling event and the 2022 and 2023 EPA IA sampling events
(Ref 4, pp. 15, 17-20). Residential samples were collected within property boundaries and within 200 feet
of the residential structures within AOC B (Figure 3B of this HRS documentation record). In addition,
although operations ceased at the J. H. Baxter facility in 2022, two full-time workers continue to report to
the facility to maintain the stormwater and groundwater treatment systems in the vicinity of AOC A and
a single retort (Figure 2 and Figure 3 A of this HRS documentation record; Ref. 4, p. 66).

Resident Population Threat Likelihood of Exposure Factor Category Value: 550

5.1.1.2	WASTE CHARACTERISTICS

5.1.1.2.1 Toxicity

Table 18 Toxicity

Hazardous Substance

Toxicity Factor Value

References

1,2,3,4,6,7,8-HpCDD

10,000

Ref. 2, p. 20

1,2,3,4,6,7,8-HpCDF

10,000

Ref. 2, p. 22

1,2,3,4,7,8,9-HpCDF

10,000

Ref. 2, p. 24

1,2,3,4,7,8-HxCDD

10,000

Ref. 2, p. 26

1,2,3,4,7,8-HxCDF

10,000

Ref. 2, p. 32

1,2,3,6,7,8-HxCDD

10,000

Ref. 2, p. 28

1,2,3,6,7,8-HxCDF

10,000

Ref. 2, p. 34

1,2,3,7,8,9-HxCDD

10,000

Ref. 2, p. 30

1,2,3,7,8,9-HxCDF

10,000

Ref. 2, p. 36

1,2,3,7,8-PeCDD

10,000

Ref. 2, p. 46

1,2,3,7,8-PeCDF

10,000

Ref. 2, p. 48

2,3,4,6,7,8-HxCDF

10,000

Ref. 2, p. 38

2,3,4,7,8-PeCDF

10,000

Ref. 2, p. 50

2,3,7,8-TCDD

10,000

Ref. 2, p. 56

2,3,7,8-TCDF

10,000

Ref. 2, p. 58

OCDD

10,000

Ref. 2, p. 42

OCDF

10,000

Ref. 2, p. 44

Antimony

10,000

Ref. 2, p. 61

Arsenic

10,000

Ref. 2, p. 2

Cadmium

10,000

Ref. 2, p. 8

Chromium

10,000

Ref. 2, p. 63

Copper

100

Ref. 2, p. 65

Lead

10,000

Ref. 2, p. 40

Selenium

100

Ref. 2, p. 67

Silver

100

Ref. 2, p. 90

Zinc

10

Ref. 2, p. 69

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Table 18 Toxicity

Hazardous Substance

Toxicity Factor Value

References

Anthracene

10

Ref. 2, p. 72

Benzo(a)anthracene

100

Ref. 2, p. 4

Benzo(a)pyrene

10,000

Ref. 2, p. 6

Benzo(g,h,i)perylene

0

Ref. 2, p. 74

Benzo(k)fluoranthene

10

Ref. 2, p. 78

Bis(2-ethylhexyl)phthalate

100

Ref. 2, p. 80

Chrysene

10

Ref. 2, p. 82

Fluoranthene

100

Ref. 2, p. 76

Indeno( 1,2,3 -cd)pyrene

100

Ref. 2, p. 84

Pentachlorophenol

100

Ref. 2, p. 86

Phenanthrene

1

Ref. 2, p. 88

Pyrene

100

Ref. 2, p. 54

Notes:

HpCDD:	Heptachlorodibenzo-p-dioxin

HpCDD:	Heptachlorodibenzo-p-dioxin

HpCDF:	Heptachlorodibenzofuran

HxCDD:	Hexachlorodibenzo-p-dioxin

HxCDF:	Hexachlorodibenzofuran

OCDD:	Octachlorodibenzodioxin

OCDF:	Octachlorodibenzofuran

PeCDD	Pentachlorodibenzo-p-dioxin

PeCDF	Pentachlorodibenzofuran

TCDD:	Tetrachlorodibenzo-p-dioxin

TCDF:	Tetrachlorodibenzofuran

Toxicity Factor Value: 10,000

5.1.1.2.2

Hazardous Waste Quantity

Table 19 Hazardous Waste Quantity

AOC Letter

Source Type

Area Hazardous Waste Quantity

A

Contaminated Soil

>0

B

Contaminated Soil

>0

Sum of Values:

>0

Hazardous Waste Quantity Factor Value (Ref. 1, Table 2-6): 10

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5.1.1.2.3 Calculation of Waste Characteristics Factor Category Value

Toxicity Factor Value: 10,000
Hazardous Waste Quantity Factor Value: 10

Toxicity Factor Value x Hazardous Waste Quantity Factor Value: 100,000

Waste Characteristics Factor Category Value (Ref. 1, Table 2-7): 18

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5.1.1.3 TARGETS

Residential properties are identified by Residence IDs rather than addresses, to protect the privacy of
individual residents. The cross-reference between Residence IDs and street addresses is provided in
confidential reference 51. Sample concentrations are provided in Tables 7, 10, 13, and 16 of this HRS
documentation record. Only those properties where removals have not occurred are listed below and used
in scoring (Ref. 41, pp. 10, 30).

Table 20 Level I Concentrations

Residence

ID
(Ref. 51)

Sample ID

Hazardous
Substance

Hazardous
Substance
Cone,
(ng/kg)

Benchmark
Cone.

(ng/kg)

Benchmark

Reference

3

JHB-S36

1,2,3,4,6,7,8-HpCDD

540

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

1,2,3,7,8-PeCDD

6.6

5.35

Cancer Risk Screen Cone.

Ref. 2, p. 47

2,3,7,8-TCDD

62

5.35

Cancer Risk Screen Cone.

Ref. 2, p. 57

7

JHB-S37

1,2,3,4,6,7,8-HpCDD

1,300

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

1,2,3,7,8-PeCDD

17

5.35

Cancer Risk Screen Cone.

Ref. 2, p. 47

13

JHB-28-FY-00-
06-01

1,2,3,4,6,7,8-HpCDD

1,030

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

14

JHB-44-FY-00-
06-01

1,2,3,4,6,7,8-HpCDD

864

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

JHB-44-BY-00-
06-01

1,2,3,4,6,7,8-HpCDD

638

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

23

JHB-S19

1,2,3,7,8-PeCDD

6.6

5.35

Cancer Risk Screen Cone.

Ref. 2, p. 47

24

JHB-23-FY-00-
06-01

2,3,7,8-TCDD

8.51

5.35

Cancer Risk Screen Cone.

Ref. 2, p. 57

26

JHB-27-FY-00-
06-01

1,2,3,4,6,7,8-HpCDD

576

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

JHB-27-BY-00-
06-01

1,2,3,4,6,7,8-HpCDD

958

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

30

JHB-09-FY-00-
06-01

1,2,3,4,6,7,8-HpCDD

1,100

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

36

JHB-S26

1,2,3,4,6,7,8-HpCDD

1,500

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

OCDD

19,000

17800

Cancer Risk Screen Cone.

Ref. 2, p. 43

40

JHB-38-FY-00-
06-01

1,2,3,4,6,7,8-HpCDD

825

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

41

JHB-67-BY-00-
06-01

1,2,3,4,6,7,8-HpCDD

929

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

2,3,7,8-TCDD

11.5

5.35

Cancer Risk Screen Cone.

Ref. 2, p. 57

JHB-67-FY-00-
06-01

1,2,3,4,6,7,8-HpCDD

1,120

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

43

JHB-42-FY-00-
06-01

1,2,3,4,6,7,8-HpCDD

954

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

2,3,7,8-TCDD

6.94

5.35

Cancer Risk Screen Cone.

Ref. 2, p. 57

JHB-42-BY-00-
06-01

1,2,3,4,6,7,8-HpCDD

1,230

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

44

JHB-41-FY-00-
06-01

1,2,3,4,6,7,8-HpCDD

991

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

45

JHB-37-BY-00-
06-01

2,3,7,8-TCDD

6.25

5.35

Cancer Risk Screen Cone.

Ref. 2, p. 57

JHB-37-FY-00-
06-01

2,3,7,8-TCDD

8.71

5.35

Cancer Risk Screen Cone.

Ref. 2, p. 57

71

SE-Resident Population Threat


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Table 20

Level I Concentrations





Residence

ID
(Ref. 51)

Sample ID

Hazardous
Substance

Hazardous
Substance
Cone,
(ng/kg)

Benchmark
Cone.

(ng/kg)

Benchmark

Reference

46

JHB-43-BY-00-
06-01

2,3,7,8-TCDD

5.81

5.35

Cancer Risk Screen Cone.

Ref. 2, p. 57

JHB-43-FY-00-
06-01

1,2,3,4,6,7,8-HpCDD

1,340

535

Cancer Risk Screen Cone.

Ref. 2, p. 21

Notes:



HpCDD:

Heptachlorodibenzo-p-dioxin

HxCDF:

Hexachlorodibenzofuran

ID:

Identification Number

ng/kg:

nanograms per kilogram

OCDD:

Octachlorodibenzodioxin

PeCDD

Pentachlorodibenzo-p-dioxin

PeCDF

Pentachlorodibenzofuran

TCDD:

Tetrachlorodibenzo-p-dioxin

72

SE-Resident Population Threat


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5.1.1.3.1 Resident Individual

AOC Letter: B

Level of Contamination: Level I

According to the HRS, hazardous constituents that meet the criteria for an observed release (or observed
contamination) and meet or exceed media-specific benchmark values meet the criteria for Level I
contamination (Ref. 1, Sect. 2.5). Based on results from the 2021 ODEQ Soil Sampling Investigation and
the 2023 Weston IA, Level I concentrations shown in Table 20 of this HRS documentation record have
been established on residential properties (refer to HRS documentation record Section 5.1.0, Summary of
Site Contamination). A value of 50 is assigned to resident individual because there is at least one resident
individual subject to Level I concentrations (Ref. 1, Sect. 5.1.1.3.1).

Resident Individual Factor Value: 50

5.1.1.3.2 Resident Population
5.1.1.3.2.1 Level I Concentrations
Level I Resident Population Targets

Observed contamination has been documented at residences in AOC B (see Section 5.1.0). Interviews
were conducted at most residences to determine the number of occupants in each household (Ref. 55). For
residences where interviews were not conducted, each residence is multiplied by the U.S. Census persons
per household for Lane County, Washington, to determine the resident population (Ref. 83).

Table 21 Level I Resident Population Targets

AOC
Letter

Residence with

Observed
Contamination

Total No.
of Residents

References

B

3

2

Ref. 51; Ref. 55

B

7

2.35*

Ref. 51; Ref. 55

B

13

5

Ref. 51; Ref. 55

B

14

2.35*

Ref. 51; Ref. 55

B

23

4

Ref. 51; Ref. 55

B

24

2.35*

Ref. 51; Ref. 55

B

26

2.35*

Ref. 51; Ref. 55

B

30

2.35*

Ref. 51; Ref. 55

B

36

2

Ref. 51; Ref. 55

B

40

2.35*

Ref. 51; Ref. 55

B

41

2.35*

Ref. 51; Ref. 55

B

43

2.35*

Ref. 51; Ref. 55

B

44

2.35*

Ref. 51; Ref. 55

B

45

4

Ref. 51; Ref. 55

B

46

2.35*

Ref. 51; Ref. 55

* Interview of occupants was not conducted. Lane County multiplier is applied.

73

SE-Resident Population Threat


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Sum of individuals subject to Level I concentrations: 40.5
Sum of individuals subject to Level I concentrations x 10: 405

Level I Concentrations Factor Value: 405

5.1.1.3.2.2 Level II Concentrations

The Area B AOC was documented based on sampling conducted during the 2023 IA. In accordance with
Ref. 1, Section 5.0.1, observed contamination is inferred for residences where samples were not collected,
but that are located within the AOC (see Figure 3B of this HRS documentation record). For residences
where interviews were not conducted, each residence is multiplied by the U.S. Census persons per
household for the County of Lane County, Washington, to determine the resident population (Ref. 83).

Table 22 Level II Resident Population r

"argets

AOC Letter

Residence with

Observed
Contamination

Total No.
of Residents

References

B

4

2.35*

Ref. 51; Ref. 55

B

5

2.35*

Ref. 51; Ref. 55

B

6

2.35*

Ref. 51; Ref. 55

B

9

2.35*

Ref. 51; Ref. 55

B

10

2.35*

Ref. 51; Ref. 55

B

11

2.35*

Ref. 51; Ref. 55

B

12

2.35*

Ref. 51; Ref. 55

B

15

2.35*

Ref. 51; Ref. 55

B

16

2.35*

Ref. 51; Ref. 55

B

17

2.35*

Ref. 51; Ref. 55

B

21

2.35*

Ref. 51; Ref. 55

B

22

3

Ref. 51; Ref. 55

B

28

1

Ref. 51; Ref. 55

B

29

2.35*

Ref. 51; Ref. 55

B

31

4

Ref. 51; Ref. 55

B

32

1

Ref. 51; Ref. 55

B

33

2.35*

Ref. 51; Ref. 55

B

34

4

Ref. 51; Ref. 55

B

35

3

Ref. 51; Ref. 55

B

37

2.35*

Ref. 51; Ref. 55

B

38

2.35*

Ref. 51; Ref. 55

B

39

2.35*

Ref. 51; Ref. 55

B

42

2.35*

Ref. 51; Ref. 55

B

47

2.35*

Ref. 51; Ref. 55

B

48

2.35*

Ref. 51; Ref. 55

74

SE-Resident Population Threat


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Table 22 Level II Resident Population r

"argets

AOC Letter

Residence with

Observed
Contamination

Total No.
of Residents

References

B

49

3

Ref. 51; Ref. 55

B

50

2.35*

Ref. 51; Ref. 55

B

51

2.35*

Ref. 51; Ref. 55

* Interview of occupants was not conducted. Lane County multiplier is applied.

Sum of individuals subject to Level II concentrations: 68.35

Level II Concentrations Factor Value: 68.35

5.1.1.3.3 Workers

Operations ceased at the J. H. Baxter facility in 2022; however, two full-time workers continue to report
to the facility to maintain the stormwater and ground water treatment systems and a single retort. A portion
of the stormwater treatment system and the retorts are located within AOC A (Ref. 4, p. 66, Figures 2 and
3 A of this HRS documentation record).

AOC Letter

Number of Workers

References

A

2

Ref. 4, p. 66

Total workers: 2

Workers Factor Value (Ref. 1, Table 5-4): 5

5.1.1.3.4	Resources

No known commercial agriculture, silviculture, livestock production, or grazing are known to be
conducted within AOC A or B.

5.1.1.3.5	Terrestrial Sensitive Environments

There are no known terrestrial-sensitive environments within AOC A or B.

75

SE-Resident Population Threat


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5.1.2 NEARBY POPULATION THREAT

The Nearby Population Threat was not scored, as it does not significantly affect the listing decision.

76

SE-Resident Population Threat


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