Site updates
Operational
Period #31
- Completed retort 85 removal operations.
- Began removal of penta / creo liquids and sludges,
and deconstruction of appurtenances, surge tanks and piping connected to
Retorts 81-84 starting with R-81.
- Completed concrete demolition in Zone 1 and for the
ACQ (T-16, T-17, T-18) tanks.
- Test Pits: excavation of three test pits took place
during this operational period. Two test pits were dug in DU01, near the
former locations of T-15 and T-20. Additionally, a test pit was dug in the
ACQ area. No odor, staining, or water with sheen were observed in any test
pit.
- Secondary containment areas that have been removed
have been backfilled and graded to drain stormwater away from remaining
secondary containments to ensure proper water management.
- Continued evaluation, photography and documentation
of scrap metal roll-off pins prior to transportation off-site for
recycling.
- Continued to collect, manage, and evaporate process
water (see process metrics below).
Unmanned Aerial Systems (UAS) Activities:
USCG conducted one drone flight on Monday (3/24/2025)
Monitoring,
Sampling, and Analysis
- Air Monitoring: AM03, AM05, AM07, AM15
- No sampling activities took place during this
operational period
- XRF readings from underneath the secondary
containment, as it was removed from the ACQ containment area. No elevated
readings were identified.
- Wind storm occurred on 3/26/2025 causing dust plumes
to pick up across the area. A water truck was used in dry areas to
suppress dust. No PM exceedances were detected at air station AM03 (fence
line monitor) nor any other stations in work areas.
Tank and air monitoring status viewer

2.1.3 Progress Metrics
Tank Status Map:

Water Storage and Evaporation:
The Evaporation concentrate is collected and added to WS 5.0 for disposal

EPA continues to collect and manage more water then it can evaporate.
The main water collection location is the secondary containment throughout the
retort area.
Disposal / recycling:
- RCRA Debris Rolloff boxes: 20 boxes of concrete
- Non RCRA Rolloff boxes: 0
- Unprepared Scrap Steel: 2
- Stainless Steel: 0
- Creosote / Penta sludge: 0
Please visit the map section or click here to view the tank and air monitoring status
Please visit the document section of this website for prior operational period updates
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Incident Category
Time Critical Removal Action
Background
The JH Baxter Facility is wood treatment facility in Eugene, Oregon. The facility stopped operations "moth balling" the facility in 2022. Prior to closure, operations consisted of treating wood in any of five retorts using Creosote, Pentahlorophenol (PCP), Ammoniacal Copper Zinc Arsenate (ACZA). The main treatment area includes four retorts (Retorts 81, 82, 83, and 84), and multiple work, process, and storage tanks. Another area used for PCP treatment (Retort 85) includes one retort and several process and storage tanks. The ground surface beneath all retorts and tanks is currently concrete with secondary containment sidewalls averaging 2 feet in height. In 1992, in response to new regulations at 40 C.F.R. Part 264 Subpart W, all the retort areas had concrete drip pads with roofs installed. Approximately 80 percent of the remaining areas within the facility are unpaved.
The process and chemical storage area is broken into 2 primary tank farms, south and north, which are connected by underground piping. According to the facility Spill Prevention, Control, and Countermeasure Plan (SPCC), the total storage capacity exceeds 1 million gallons and contains materials such as PCP-based oil, creosote/bunker fuel oil, creosote, ACZA, 50/50 recovery, diesel, recovery water, PCP-a recovery, Arsenic Acid, and Aqua Ammonia.
The wood-treating facility portion of the Site is approximately 32 acres and has several areas of interest. The areas of interest have been divided into the following decision units (DU).
• The Main Treatment Area:
o North Retort and surrounding tanks – DU01
o North Tank Farm – DU02
o South Tank Farm – DU03
o Boiler room and surrounding area – DU04
o Hazardous Materials Shed and Drum Storage Area – DU05
• Drip pad sheds, storage, and drying areas – DU06
• Stormwater and Groundwater treatment systems – DU07
• Laboratory – DU08
The primary focus area of this TCRA will be DU01 thru DU05 (The Main Treatment Area) and DU08 (Laboratory). All these DUs contain large quantities of hazardous substances such as dioxins/furans, heavy metals, Volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs).
Description of Threat
During September 2023, EPA conducted a Removal Site Evaluation (RSE) to assess and sample all large containers, drums, totes, and tanks, within the south and north tank farms. EPA discovered greater than 500,000 gallons of hazardous substances in both liquid and solid phases. These hazardous substances have been evaluated to contain high levels of dioxins/furans, metals, VOCs, and SVOCs, and have been assigned potential Resource Conservation and Recovery Act (RCRA) hazardous waste codes including F032, FO33, F034, F035, D001, D002, D004, D018, and K001. Due to the aging infrastructure, the current mothballed status of the facility, the periodic vandalism and theft, and the lack of funding and plans by the owner to remove any of these wastes, there is a high threat of release from one or more of the tanks which would directly impact the neighboring residential community and the adjacent commercial area.
Removal Assessment Results
A combined total of over 750,000 gallons (or greater than 6,000,000 pounds) of various hazardous substance waste streams have been identified.