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. ------- 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 ------- 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 ------- 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 ------- REFERENCES Reference Number Description of the Reference 1 U.S. Environmental Protection Agency (EPA). Hazard Ranking System (HRS), Title 40 of the Code of Federal Regulations (CFR) Part 300, Appendix A (55 Federal Register [FR] 51583, December 14, 1990, as amended at 82 FR 2779, Jan. 9, 2017; 83 FR 38037, Aug. 3, 2018), as published in the CFR on July 1, 2019, with two attachments. Attachment A: FR Vol. 55, No. 241. December 14, 1990. HRS Preamble. AttachmentB: FR Vol. 82, No. 5, January 9, 2017. Addition of a Subsurface Intrusion Component to the HRS Preamble. 197 Pages. Available online at: httDs://semsDub.eDa.gov/work/HO/100002489.Ddf 2 EPA. Superfund Chemical Data Matrix (SCDM). Accessed March 10, 2024, 93 oases. Available online at: httD://www. eDa.gov/suDerfund/suDerfund- chemical-data-matrix-scdm. 3 U.S. Department of the Interior, U.S. Geological Survey (USGS), 7.5 Minute Series Topographic Map Eugene West Quadrangle, Oregon - Lane County. 2020 1 Map. 4 Weston Solutions, Inc. Integrated Assessment Report, J. H. Baxter Site. April 2024. 3,342 pages. 5 Keystone Environmental Resources Ltd., (Keystone) August 1991. Remedial Investigation Report (Phase I) of J.H. Baxter & Company Eugene, Oregon Site. 263 pages. 6 Oregon Department of Environmental Quality (ODEQ) Western Region Office, October 2019. Record of Decision for J.H. Baxter & Co. Facility, Eugene, Oregon. 44 pages. 7 GSI Water Solutions, Inc. April 28, 2016. Final Feasibility Study Report, J.H. Baxter & Co., Eugene, Oregon. 138 pages. 8 J.H. Baxter & Co. January 28, 2022. Correspondence from Georgia Baxter to Michael Kucinski (ODEQ Clean Up and Emergency Response Manager) regarding J.H. Baxter & Co. Intentions. 1 page. 9 Weston Solutions, Inc. April 2023. J.H. Baxter Integrated Assessment Sampling and Analysis Plan. 205 pages. 10 ODEQ. August 1989. J.H. Baxter & Co. Order of Consent. 22 pages. 11 EPA. December 1995. Presumptive Remedies for Soils, Sediments and Sludges at Wood Treater Sites. 123 pages. 12 J. H. Baxter & Co. Project Team. July 28, 2006. Revised Baseline Human Health Risk Assessment. 214 pages. 13 EPA. July 20, 2017. Notice of Violation, JH Baxter & Company. 10 pages. 14 J. H. Baxter & Co. June 28, 2002. Beneficial Water Use Determination JH Baxter & Co. Eugene, Oregon Facility. 34 pages. 15 J. H. Baxter & Co. March 10, 2010. Remedial Investigation Summary Report Revision 1 J.H. Baxter & Co. Eugene, Oregon Facility. 587 pages. 16 Oregon Department of Environmental Quality (ODEQ) May 2019. Staff Report Recommended Remedial Action for J.H. Baxter & Co. Facility, Eugene, Oregon. 75 pages. 4 ------- 17 ~L8 ~L9 20 21 22 23 24 25 26 27 28 29 30 IT 32 33 34 35 36 Description of the Reference ODEQ. February 10, 2022. Memorandum with Attachments. Subject: Request for Orphan Site Designation - J H Baxter & Co. - Eugene EC SI #0055. Attachments: Accounting & Financial Addendum and DEQ Time Reporting System Accounting Schedule. 4 pages. Premier Environmental Services, Inc. April 2009. Site Management Plan J.H. Baxter & Co. Eugene, Oregon Facility. 23 pages. U.S. Department of Health and Human Services Agency for Toxic Substances and Disease Registry (ASTDR). July 2024. Toxicological Profile for Creosote. 290 pages. National Toxicology Program, Department of Health and Human Services. 2021. Report on Carcinogens, Fifteenth Edition: Pentachlorophenol and By- products of Its Synthesis. 7 pages. Lane Regional Air Protection Agency (LRAPA). Wind Rose Plot: Eugene Airport with Wilkes monitor wind - Wind Rose. 1 page. Eurofins, September 27, 2022. Analytical Report, Job Number: 320-91617-1, Job Description: JHB. 2,134 pages. Strid, A.; Hanson, W.; Cross, A.; Jenkins, J. 2019. Treated Wood Fact Sheet; National Pesticide Information Center, Oregon State University Extension Services, http://npic.orst.edu/factsheets/treatedwood.html. 7 pages. Eurofins, September 23, 2022. Analytical Report, Job Number: 320-91614-1, Job Description: JHB. 2,972 pages. ALS Environmental, August 5, 2022. Analytical Report for Service Request No. K2206134. 980 pages. ALS Environmental, August 5, 2022. Analytical Report for Service Request No. K2206133. 613 pages. ALS Environmental, August 25, 2022. Analytical Report for Service Request No. K2206131. 744 pages. GEL Laboratories, LLC, June 15, 2023. ISM Prep to Subcontract, SDG: 614003. 622 pages. GEL Laboratories, LLC, March 22, 2023. ISM Prep to Subcontract, SDG: 614006. 734 pages. GEL Laboratories, LLC, June 30, 2023, 2023. ISM Prep to Subcontract, SDG: 614007. 760 pages. GEL Laboratories, LLC, June 30, 2023. ISM Prep to Subcontract, SDG: 614009. 660 pages. GEL Laboratories, LLC, June 30, 2023. ISM Prep to Subcontract, SDG: 614011. 685 pages. GEL Laboratories, LLC, July 6, 2023. ISM Prep to Subcontract, SDG: 614933. 637 pages. GEL Laboratories, LLC, July 10, 2023. ISM Prep to Subcontract, SDG: 614941. 555 pages. GEL Laboratories, LLC, June 19, 2023. ISM Prep to Subcontract, SDG: 614944. 542 pages. EPA Region 5 Records Center. Undated. Toxic Substances Fact Sheet; Common Names: DDT, DDE, DDD. CAS Numbers: 50-29-3; 72-55-9; 72-54- 8. 3 pages. 5 ------- Reference Number Description of the Reference 37 American Chemical Society. June 20, 2016. Molecule of the Week Archive: Dieldrin. Accessed on July 15, 2024. Available online at: httDs://www.acs.org/molecule-of-the-week/archive/d/dieldrin.html. 3 pages. 38 ASTDR. August 2015. Public Health Statement Endosulfan. 8 pages. 39 GSI Water Solutions, Inc., August 2021. Sampling and Analysis Plan, J.H. Baxter & Co. Wood Treating Facility. 135 pages. 40 Apex Laboratories, LLC, October 25, 2021. Analytical Report A1I0832, JH Baxter-Eugene ISM - 0302. 25 pages. 41 GSI Water Solutions, Inc., October 10, 2023. Offsite Removal Action Work Plan, Former JH Baxter & Co. Facility, 30 pages. 42 Apex Laboratories, LLC, October 25, 2021. Analytical Report A1I0925, JH Baxter-Eugene ISM - 0302. 39 pages. 43 USEPA Archive Document: ASTDR. Undated. Benzo(g,h,i)perylene, CAS Number: 191-24-2. 3 pages. 44 Apex Laboratories, LLC, November 2, 2021. Analytical Report A1J0098, JH Baxter-Eugene ISM - 0302. 26 pages. 45 Cape Fear Analytical, LLC, November 10, 2021. DXN & PCB Subcontract, Work Order: 18822, SDG: A1I0832. 43 pages. 46 Cape Fear Analytical, LLC, November 2, 2021. DXN & PCB Subcontract, Work Order: 18844, SDG: A1I0925. 48 pages. 47 National Toxicology Program, Department of Health and Human Services. 2021. Report on Carcinogens, Fifteenth Edition: Di(2-ethylhexyl) Phthalate. 3 pages. 48 Cape Fear Analytical, LLC, November 10, 2021. DXN & PCB Subcontract, Work Order: 18908, SDG: A1J0098. 32 pages. 49 Weston Solutions, Inc. August 12, 2022. Data Quality Assurance Review, J.H. Baxter Removal Site Evaluation, SDG Number K2206134. 40 pages. 50 EPA. Office of Superfund Remediation and Technology Innovation. November 2022. Using Qualified Data to Document an Observed Release and Observed Contamination. Directive 9285.7-89FS. 20 pages. 51 Weston Solutions, Inc. April 1, 2024. Residence IDs Cross-Referenced to Confidential Residential Addresses, 1 page. 52 Apalategui, Eric. Fishing at Fern Ridge Reservoir. Accessed on March 19, 2024. Available online at: https://www.bestfishinginamerica.com/or-fern- ridge-reservoir-fishing-eugene-oregon.html. 5 pages. 53 Fishbrain. Fishing spots, fishing reports and regulations in Amazon Creek, Oregon, United States. Accessed on March 19, 2024. Available online at: https://fishbrain.com/fishing-waters/IJ3eHuOZ/amazon-creek. 6 pages. 54 Fishbrain. Fishing spots, fishing reports and regulations in Clear Lake, Oregon, United States. Accessed on April 3, 2024. Available online at: https://fishbrain.com/fishing-waters/HCFKu007/clear-lake. 16 pages. 55 EPA. September 22-23, 2023. J. H. Baxter IA Resident Census. 4 pages. 56 United States Fish and Wildlife Service (USFWS), 2023. National Wetlands Inventory (NWI). Available online at: https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/ on August 9, 2024. 2 pages. 6 ------- Reference Number Description of the Reference 57 Reference No. Reserved 58 Reference No. Reserved 59 LRAPA. February 2007. Initial Assessment of Hazardous Emission Impacts from the J.H. Baxter Wood Treatment Facility in Eugene, Oregon. 37 pages. 60 Weston Solutions, Inc. September 8, 2023. Memorandum regarding CLP Organic Data Summary Check, SDG JRED2. 782 pages. 61 Frontier Analytical Laboratory, July 15, 2022, Test Report project 14487. 13 pages. 62 Weston Solutions, Inc. August 10, 2022. Data Quality Assurance Review, SDG Number K2206133, 18 pages. 63 Weston Solutions, Inc. August 26, 2022. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number K2206131, 22 pages. 64 LRAPA. Wind Rose Plot: Eugene Airport - Wind Rose. 1 page. 65 Reference No. Reserved 66 Reference No. Reserved 67 Weston Solutions, Inc. October 14, 2022. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number 320-91617-1, 28 pages. 68 Reference No. Reserved 69 Weston Solutions, Inc. October 14, 2022. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number 320-91614-1, 39 pages. 70 Reference No. Reserved 71 Weston Solutions, Inc. July 10, 2023. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number 614011, 29 pages. 72 Weston Solutions, Inc. July 10, 2023. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number 614009, 24 pages. 73 Weston Solutions, Inc. July 7, 2023. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number 614007, 30 pages. 74 Weston Solutions, Inc. June 19, 2023. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number 614003, 27 pages. 75 Weston Solutions, Inc. June 23, 2023. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number 614006, 27 pages. 76 Weston Solutions, Inc. July 10, 2023. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number 614933, 26 pages. 77 Weston Solutions, Inc. July 10, 2023. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number 614941, 24 pages. 78 Reference No. Reserved 79 Weston Solutions, Inc. July 10, 2023. Data Quality Assurance Review, JH Baxter Removal Site Evaluation, SDG Number 614944, 23 pages. 80 USGS Surface Water data for USA: USGS Surface-Water Annual Statistics. National Water information System. Accessed on April 2, 2024. Available online at: httDs://waterdata.usgs.gov/nwis/annual/?referred module=sw. USGS 14169000 Long Tom River Near Alvadore, OR. 1 page. 7 ------- Reference Number Description of the Reference 81 USGS Surface Water data for USA: USGS Surface-Water Annual Statistics. National Water information System. Accessed online on April 2, 2024. Available online at: https://waterdata.usgs.gov/nwis/annual/7referred module=sw. USGS 14169500 Amazon Creek near Eugene, OR. 1 page. 82 Weston Solutions, Inc. May 2022. J. H. Baxter RSE Field Logbook. 7 pages. 83 United States Census Bureau. Undated. QuickFacts. Lane County, Oregon Population Estimates, July 1, 2023 (v2023) Families & Living Arrangements 2018-2022. Available online at: httDs://www.census.gov/auickfacts/fact/table/lanecountvoregon/HSD310222 #HSD310222. 3 pages. 84 Fishbrain. Fishing spots, fishing reports and regulations in Amazon Creek Diversion Channel, Oregon, United States. Accessed on April 3, 2024. Available online at: https://fishbrain.com/fishing-waters/ckSVR 7r/amazon- creek-diversion-channel. 17 pages. 85 Maul Foster Alongi (MFA). October 21, 2021. Final Liquid-Oil Sampling Results and Lab Reports with Attachments. Attachments: Attachment A—Updated Liquid-Oil Sampling Summary Tables, and Attachment B—Final Laboratory Reports. 293 pages. 86 Reference No. Reserved 87 J. H. Baxter & Co. January 22, 2021. Response to LRAPA Cleaner Air Oregon Testing and Sample Letter with Attachments. Attachments: Attachment A: Revised Liquid Sampling Plan. 29 pages. 88 Pacific Northwest Center for Translational Environmental Health Sciences Research at the Oregon State University (OSU). February 2, 2022. The J. H. Baxter & Co. Wood Treatment Facility in West Eugene. Available online at: httDs://storvmaDS.arcgis.com/stories/61elle3a99a54ff784a68ffacaccffcc/Drin t. 55 pages. 89 EPA. May 23, 2024. Memorandum with Attachments. Subject: Data Validation Report for Dioxin/Furan Analysis of Samples Collected for the J.H. Baxter Integrated Assessment. Attachments: Data Validation Summary Dioxin/Furans by Method 1613. 3,258 pages. 90 LRAPA. June 14, 2023. Simple Air Contaminant Discharge Permit, Review Permit No. 200502, J.H. Baxter & Co. - Eugene Plant. 22 pages. 91 ERG. December 22, 2014. Memorandum with Attachments. Subject: Field Analysis Results and Photographs - JH Baxter and Company. Attachments: Attachment A: Photograph Log, Attachment B: FLIR Images, Attachment C: QC Information for Field Analyses. 60 pages. 92 LRAPA. May 21, 2024. Summary of Preliminary J.H. Baxter Soil Deposition Modeling by LRAPA. Subject: LRAPA 2021 Modeling of JH Baxter Emissions forDEQ Soil Sampling. 35 pages. 93 Weston Solutions, Inc. July 2024. Local Industry Search. 7 pages. 94 Environmental Data Resources Inc. (EDR). November 17, 2023. Certified Sanborn Map Report, JH Baxter, 85 Baxter Street, Eugene, OR 97402. 4 pages. 95 EDR. November 17, 2023. Certified Sanborn Map Report, JH Baxter, 85 Baxter Street, Eugene, OR 97402. 4 pages. 8 ------- Reference Number Description of the Reference 96 EDR. November 15, 2023. Historical Topo Map Report, JH Baxter, 85 Baxter Street, Eugene, OR 97402. 16 pages. 97 EDR. November 15,2023. The EDR Aerial Photo Decade Package, JH Baxter, 85 Baxter Street, Eugene, OR 97402. 16 pages. 98 EDR. November 15, 2023. The EDR Radius Map Report with GeoCheck, JH Baxter, 85 Baxter Street, Eugene, OR 97402. 1,491 pages. 99 EDR. November 20, 2023. The EDR-City Directory Image Report, JH Baxter, 85 Baxter Street, Eugene, OR 97402. November 20, 2023. 89 pages. 100 Weston Solutions, Inc. July 10, 2024. Contact Report between Max Hueftle (Operations Manager, LRAPA) and Brandon Perkins (EPA) with Attachments. Subject: Facilities / Sites in the Vicinity of J. H. Baxter. Attachments: 2020 Air Toxics Emissions Inventory (ATEI) findings, 2016 LRAPA CAO emissions, and site source numbers. 522 pages. 101 LRAPA. October 8, 2018. Assignment to General Air Contaminant Discharge Permit. Permittee: Zip O Log Mills, Inc. 57 pages. 102 LRAPA. October 5, 2018. Assignment to General Air Contaminant Discharge Permit. Issued to: Cascade Plating and Machine. 59 pages. 103 LRAPA. July 29, 2019. Simple Air Contaminant Discharge Permit (Simple ACDP). Issued to: Whittier Wood Products Company. 11 pages. 104 LRAPA. June 5, 2023. Simple Air Contaminant Discharge Permit (Simple ACDP). Issued to: King Retail Solutions, Inc. 12 pages. 105 LRAPA. February 15, 2019. Simple Air Contaminant Discharge Permit: Oregon Rubber Company, DBA Oregon Tread Rubber Co. & Wyatt's Tire Company. 12 pages. 106 LRAPA. April 10, 2020. Basic Air Contaminant Discharge Permit: Caffe Pacori. 11 pages. 107 LRAPA. August 10, 2022. Standard Air Contaminant Discharge Permit (Standard ACDP). Issued to: Western Pneumatics LLC. 14 pages. 108 LRAPA. July 11, 2019. Standard Air Contaminant Discharge Permit. Issued to: Emeral Forest Products, Inc. - Plant #1. 17 pages. 109 LRAPA. May 24, 2024. Standard Air Contaminant Discharge Permit (ACDP). Issued to: Lanz Cabinet Shop, Inc. 20 pages. 110 LRAPA. September 26, 2023. Title V Operating Permit. Issued to: Weyerhaeuser NR Company - Eugene EWP. 36 pages. 111 LRAPA. August 9, 2023. Standard Air Contaminant Discharge Permit. Issued to: Forrest Paint Company. 26 pages. 112 LRAPA. October 5, 2018. Assignment to General Air Contaminant Discharge Permit. Permittee: Valley Milling and Lumber LLC. 57 pages. 113 Electronic mail correspondence between Mark Harris (Project Manager, ALS Global) and Mark Woodke (Senior Project Scientist, Weston). July 18, 2024. Regarding: Dioxin MRL Question. 2 pages. 114 Electronic mail correspondence between Karen Dahl (Eurofinsus) and Mark Woodke (Senior Project Scientist, Weston). July 18, 2024. Regarding: Definition of RL - One More Question. 4 pages. 9 ------- Reference Number Description of the Reference 115 Electronic mail correspondence between Chris Cornwell (Laboratory Director, Cape Fear Analytical) and Mark Woodke (Senior Project Scientist, Weston). July 18, 2024. Regarding: CFA Definition of PQL - One More Question. 4 pages. 116 EPA. Office of Superfund Remediation and Technology Innovation. November 2020. National Functional Guidelines for High Resolution Superfund Methods Data Review. Directive 9240.1-65. 86 pages. 117 ODEQ. June 20, 2022. Field Log Book, J.H. Baxter. 6 pages. 118 GSI Water Solutions, Inc. June 6, 2022. Offsite Investigation Work Plan Former JH Baxter & Co. Facility, Eugene, Oregon, ECSI No. 55. Prepared for: ODEQ. 172 pages. 119 Apex Laboratories, LLC. July 11, 2024. Analytical Report for A2F0755 - JH Baxter-Eugene ISM - 0202323-005-004. 9 pages. 120 Weston Solutions, Inc. July 6, 2023. Memorandum. Subject: CLP Organic Data Summary Check, SDGPJREH7. 24 pages. 121 Weston Solutions, Inc. July 7, 2023. Memorandum. Subject: CLP Organic Data Summary Check, SDGMJREE0. 33 pages. 122 Weston Solutions, Inc. July 14, 2023. Memorandum. Subject: CLP Organic Data Summary Check, SDGPJREE1. 29 pages. 123 EPA. May through July 2023. EPA Contract Laboratory Program (CLP) Form Is. 700 pages. 10 ------- 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 ------- )hn Elmira Verieta -P. o- Cheshire -3: <5 <£> -P Fern Ridge Lake * or Meadowview Rd Alvadore \ X % Randy Pape Be/. -tfc 1l'hA Ve o zr 0) 3 (i f ' Washington State Highway ^ Main St 1 ^ 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 ; ,||| ^ 1 IH iM B iB^B' & - J I « — © ¦ - ~'1 * _ E, upsm c ii " ¦¦ " ,^*Lrv. B » *J IrvlngtonDr W 11th Av* anrte l_.. 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 ------- 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 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 ------- 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 ------- 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 34 SE-Resident Population Threat ------- 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 35 SE-Resident Population Threat ------- 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). 36 SE-Resident Population Threat ------- 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 37 SE-Resident Population Threat ------- 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). 38 SE-Resident Population Threat ------- 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. 39 SE-Resident Population Threat ------- - 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 40 SE-Resident Population Threat ------- 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) 41 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 43 SE-Resident Population Threat ------- 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 44 SE-Resident Population Threat ------- 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 45 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 48 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- - 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 56 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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). 58 SE-Resident Population Threat ------- 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 59 SE-Resident Population Threat ------- 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 60 SE-Resident Population Threat ------- 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 61 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 64 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 66 SE-Resident Population Threat ------- 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 SE-Resident Population Threat ------- 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 68 SE-Resident Population Threat ------- 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 69 SE-Resident Population Threat ------- 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 70 SE-Resident Population Threat ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- |