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 - December, 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.
- December 10, 2021 - Facility completes source testing of the carbon adsorption unit, penta stack, and PTE verification (see November 5, 2021 bulleted item above). The test report is due 60 days after testing completion, resulting in a due date of February 8, 2022.
January – May 2022: J.H. Baxter & Co. stops treating wood and requests an extension of the source test report due date for the testing completed on December 10, 2021.
- January 28, 2022 - Facility submits a letter to LRAPA and other regulatory agencies indicating that they intend to stop treating wood by January 31, 2022
- February 8, 2022 - Facility submits a letter to LRAPA requesting a 3-month extension of the source test report due date so that the facility can secure additional funds to complete the lab testing and development of the report.
- February 9, 2022 - LRAPA conditionally approves the extension and sets a due date of May 9, 2022.
- February 17, 2022 - LRAPA, DEQ, and OHA participate in an Active Bethel Community neighborhood association meeting to discuss soil sampling results of dioxins in residential properties near the facility.
- March 1, 2022 – The Oregon Health Authority hosts a public meeting to communicate conclusions about health risks related to the soil samples DEQ collected in 2021.
- March 28, 2022 – Facility submits a letter to LRAPA requesting to discontinue PID (photoionization detector) monitoring of the carbon adsorption unit (CAU) and turn off the CAU fan.
- April 20, 2022 – Facility submits a second 3-month extension request of the source test report due date so that the facility can secure additional funds to complete the lab testing and development of the report.
- April 29, 2022 – LRAPA approves the facility’s request to cease PID readings and operation of the CAO blower fan.
- May 11, 2022 – LRAPA conditionally approves the facility’s request and sets a new due date of August 9, 2022.
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