Emissions Inventory
For an introduction to emissions inventories and why they matter, please see EPA’s Fact Sheet. A facility-specific emissions inventory timeline and associated documents are linked below.
December 2, 2019: LRAPA calls J.H. Baxter & Co. into the program
February 13, 2020: J.H. Baxter & Co. requests an extension to allow additional time to prepare the emission inventory and proposes to submit a Liquid Sampling Plan.
May - October, 2020: LRAPA and the facility entered discussions to clarify the emission inventory approach
- J.H. Baxter’s technical memo submitted May 5, 2020 regarding the scientific approach used as a basis for the liquid sampling plan.
- J.H. Baxter’s technical memo submitted August 5, 2020 describing the calculation approach to estimate air toxics along with example treated storage and retort door opening emission calculations
- LRAPA’s comments and requests for additional information sent to J.H. Baxter & Co. on September 23, 2020
- J.H. Baxter’s response to LRAPA’s request for information submitted October 23, 2020.
December, 2020: LRAPA joins DEQ Cleanup and other regulatory agencies in discussions after elevated levels of dioxins were found in offsite soil samples. A joint-agency website on cleanup efforts and community engagement methods is created.
January - May, 2021: LRAPA and J.H. Baxter & Co. come to an agreement on key points for the emission inventory approach. J.H. Baxter & Co. conducts liquid sampling and schedules third-party source testing.
- LRAPA’s January 7th letter requiring stack testing of the carbon adsorption unit and pentachlorphenol stacks, and agreement on the liquid sampling approach to supplement stack testing measurements of air concentrations.
- J.H. Baxter’s January 22nd response to the LRAPA stack testing letter along with a revised Liquid Sampling Plan to include dioxin analysis. LRAPA’s letter approving the revised Liquid Sampling Plan.
- Liquid sampling conducted February 11th. Preliminary lab results presented to LRAPA on April 16th indicating quality assurance issues. Resampling and new analysis conducted on June 2 and 3, 2021.
- May 2021: J.H. Baxter schedules third-party stack testing to potentially occur as early as August 2021.
June - November, 2021: J.H. Baxter & Co. make progress on finalizing liquid sampling data, as well as preparing for and conducting source-testing.
- August 5, 2021 - Facility submits a letter explaining the delays in the liquid sampling results.
- August 6, 2021 - Facility submits a source-testing protocol for the carbon adsorption unit, penta stack, and ammonia scrubber.
- September 8, 2021 - Facility submits a revised source-testing protocol for ammonia scrubber testing to be conducted the week of September 20, 2021.
- September 10, 2021 - LRAPA approves the source-testing protocol for the ammonia scrubber and permanent total enclosure (PTE) verification.
- September 10, 2021 - Facility submits a summary table of all validated liquid sampling data. Lab report to be submitted later.
- September 22 and 23, 2021 - Ammonia scrubber source testing conducted.
- October 1, 2021 – LRAPA responds to a set of seven questions from Beyond Toxics about the emission inventory approach.
- October 21, 2021 – Facility submits the full lab report for all the liquid sample data (see September 10, 2021 above).
- October 22, 2021 – Facility submits a revised source-testing protocol for the carbon adsorption unit, penta stack, and conduct additional permanent total enclosure (PTE) verification to be conducted by the week of December 16, 2021.
- November 5, 2021 – LRAPA approves the source-testing protocol for the carbon adsorption unit, penta stack, and conduct additional permanent total enclosure (PTE) verification to be conducted by the week of December 13, 2021.
- November 15, 2021 – Facility submits a cover letter for the Ammoniacal Copper Zinc Arsenate (ACZA) scrubber exhaust stack source testing, as well as the full emissions test report for the ACZA source testing.
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