J.H. BAXTER & CO.
Cleaner Air Oregon ProfileHexion, Inc.
Cleaner Air Oregon (CAO) is a health-based permitting program that regulates emissions of toxic air contaminants from facilities based on risk to nearby communities. CAO requires facilities to report toxic air contaminant emissions, assess potential health risks to people nearby and reduce toxic air contaminant risk if it exceeds legal limits.
As part of the Cleaner Air Oregon process, each facility has a dedicated web page to provide communities access to facility information and updates on where it is involved in the process.
- Each step of the CAO risk assessment process has a section that includes LRAPA’s communications and deliverables from the facility.
- A color-coded graphic shows where a facility is in the Cleaner Air Oregon Process.
- For additional information and history of the program, visit the DEQ Cleaner Air Oregon website.
| Document Type | Anticipated Submittal Date | Approval Date |
|---|---|---|
| Emissions Inventory | 12/02/2019 | 05/11/2022 |
| Modeling Protocol | N/A | N/A |
| Risk Assessment Report | 03/15/2022 | 03/25/2023 |
| Risk Reduction Plan | N/A | N/A |
| CAO Completed | 03/30/2023 | 03/30/2023 |
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
- LRAPA’s call in letter to J.H. Baxter & Co.
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.
- J.H. Baxter’s Liquid Sampling Plan to LRAPA submitted March 6, 2020.
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.
June – December 2022: J.H. Baxter & CO. applies for a Simple ACDP.
- On December 7, 2022 – Facility applied for a Simple ACDP in lieu of maintaining the Standard ACDP. Simple ACDPs are less costly, less complex, and require less time to permit and inspect than those required to obtain a Standard ACDP. Facilities on Simple ACDPs also are not allowed to maintain their Baseline Emission Rate and/or Netting Basis. A Simple ACDP issuance would remove the facility’s actual emissions from operations that occurred during the 1978 baseline year. The facility’s active Standard Air Contaminant Discharge Permit (ACDP) expires on June 7, 2023. By LRAPA’s rules, a facility with a Standard ACDP must submit a permit renewal application no later than 180 days before the permit expiration date.
January – February 2023: LRAPA issues letter detailing the significance of its legal requirements, compliance expectations, and environmental responsibilities.
- On February 21, 2023 – LRAPA provides a letter summarizing the compliance status of J.H. Baxter regarding air quality regulations since the facility ceased wood preserving activities effective January 31, 2022, as well as assure the facility fully understands the significance of its legal requirements, compliance expectations, and environmental responsibilities.
March 2023: LRAPA establishes CAO emissions inventory based on emissions from J.H. Baxter & Co.’s non-operational status.
- The facility now only operates an evaporator, which dries rainwater that falls into containment areas, as well as a natural gas-fired boiler that provides steam to the evaporator.
Modeling Protocol & Risk Assessment
Below are identified Receptor locations around J.H. Baxter & Co.’s facility.
March 2023: LRAPA conducted an agency-initiated assessment of potential health risks from facility emissions in their non-operational state. The only emissions created by the facility in this state is from the boiler and evaporator. LRAPA’s agency-initiated potential health risk assessment assure potential health risks from the boiler and evaporator are not above certain health risk levels.
Risk Assessment Report
March 2023: LRAPA conducted an Agency-initiated Level 1 Risk Assessment to determine cancer and noncancer risk levels from the Toxic Air Contaminants (TAC) emissions from operations at the facility.
Risk Reduction Plan
J.H. Baxter & Co. has successfully passed the Emissions Inventory step and the Risk Assessment portion of the CAO process. It has been determined that their potential health risk does not require the implementation of a Risk Reduction plan.
CAO Progress Completed
LRAPA conducted an Agency-initiated Level 1 Risk Assessment, and the permit which includes permit conditions based on the CAO health assessment, was issued on June 21, 2023.
FACILITY
The facility treats various wood products such as railroad ties, electrical service poles, and crossarms with water and oil-based chemicals. The facility has operated at the location since the early 1940s. An ArcGIS StoryMap was created as an interactive tool intended to tell the story of past, current, and future regulatory efforts regarding air, land, and water pollution from J.H. Baxter. View the StoryMap by clicking here. The Department of Environmental Quality (DEQ) also has a webpage specific to J.H. Baxter. View the page by clicking here. The Oregon Health Authority (OHA) also has a webpage specific to J.H. Baxter. View the page by clicking here. DEQ, OHA, and LRAPA have a joint Frequently Asked Question sheet about the facility. Read the FAQ by clicking here. At the request of west Eugene Residents, LRAPA requested the Oregon Health Authority (OHA) provide a public health interpretation of naphthalene concentrations measured at LRAPA’s air toxics monitoring site located at HWY 99 and Elmira Rd. OHA provided the letter to LRAPA in February of 2022 and can be read by clicking here. To watch a recording of LRAPA’s May 11, 2023 informational meeting and public hearing on J.H. Baxter’s Simple ACDP permit renewal, click here. To review the Public Hearing Summary and LRAPA’s responses to public comments, click here.
Site Address
3494 Roosevelt Blvd.
Eugene, OR 97402
Current Air Permit
Permit type: Standard ACPD
Source Number: 200502
LRAPA Contact
Max Hueftle
541-736-1056, ext. 231
Site Address
470 S. 2nd St.
Springfield, OR
Current Air Permit
Permit type: Standard ACDP
Source Number: 200510
LRAPA Contact
Jonathan Wright
541-736-1056, ext. 236
Legend
Facility
Hexion Inc. operates a resin manufacturing facility at 470 South Second Street in Springfield, Oregon. Formaldehyde is produced on-site and used primarily as a raw material for various types of resins. Wax emulsions are also produced at this facility. The facility uses boilers, scrubbers and baghouses to control emissions from various portions of the operation. Learn more about LRAPA’s regulation of Hexion by viewing their current air permit below.
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.January 4, 2021: LRAPA calls Hexion, Inc. into the program
- LRAPA’s call in letter to Hexion, Inc.
January 29, 2021: Hexion requested an extension on the submittal date for the Emission Inventory because they have a new owner audit agreement with US EPA related to their Toxic Release Inventory emissions. This audit may affect Hexion’s emission calculations of compounds regulated by Cleaner Air Oregon
- Hexion’s Emission Inventory extension request letter.
February 12, 2021: After confirming with US EPA that Hexion is participating in a new owner audit agreement, LRAPA granted an extension on the due date for the Emission Inventory.
- LRAPA’s extension request response letter.
June 18, 2021: Hexion requested a second extension to the submittal date for the Emission Inventory because US EPA extended the due date for completion of the TRI new owner audit report.
- Hexion’s second Emissions Inventory extension request letter.
June 29, 2021: After confirming that US EPA has extended the due date for the TRI new owner audit report, LRAPA granted a second extension of the submittal date of the Emission Inventory.
- LRAPA’s second extension request response letter.
October 25, 2021: LRAPA extends Hexion’s Emissions Inventory to aligned with a December 10, 2021, due date listed in Stipulation and Final Order (SFO) No. 21-3839 signed on September 3, 2021.
- LRAPA’s third extension request response letter.
December 10, 2021: Hexion submits their emissions inventory.
- Hexion’s Compiled CAO Inventory.
- Hexion’s AQ520 Form.
March 7, 2022 and March 11, 2022: LRAPA reviewed Hexion’s submitted emissions inventory and requested modifications and clarifications. LRAPA expects a response to these requests by June 1, 2022.
Modeling Protocol & Risk Assessment
Hexion, Inc. – was called in into the Cleaner Air Oregon Program in January of 2021 and entered the Emissions Inventory Step of the Cleaner Air Oregon process. This field will be updated once the facility reaches this portion of CAO.
Risk Assessment Report
Hexion, Inc. – was called in into the Cleaner Air Oregon Program in January of 2021 and entered the Emissions Inventory Step of the Cleaner Air Oregon process. This field will be updated once the facility reaches this portion of CAO.
Risk Reduction Plan
Hexion, Inc. – was called in into the Cleaner Air Oregon Program in January of 2021 and entered the Emissions Inventory Step of the Cleaner Air Oregon process. This field will be updated once the facility reaches this portion of CAO.
CAO Progress Completed
Hexion, Inc. – was called in into the Cleaner Air Oregon Program in January of 2021 and entered the Emissions Inventory Step of the Cleaner Air Oregon process. This field will be updated once the facility reaches this portion of CAO.