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HEALTH CONSULTATION NO. 2

Evaluation of Environmental Protection Agency's Integrated Assessment Sampling and Quality Assurance Plan.

POLES, INCORPORATED WOOD TRAINING FACILITY
OLDTOWN, BONNER COUNTY, IDAHO


STATEMENT OF ISSUES

The U.S. Environmental Protection Agency (EPA) Superfund Technical Assessment and Response Team (START) recently completed a draft Integrated Assessment (IA) Sampling and Quality Assurance Plan (SQAP) for Poles Inc., a wood treating facility located in Oldtown Idaho (E&E 2001). EPA has asked both the Bureau of Environmental Health and Safety (BEHS), Division of Health, Idaho Department of Health of Welfare and the Idaho Department of Environmental Quality (IDEQ) to review the SQAP and determine if it can provide sufficient information for evaluating the potential public health impact for the nearby community. After reviewing the SQAP, BEHS prepared this Health consultation under its cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR) to summarize the Bureau's comments on the draft document. The purpose of this Health consultation is to document the BEHS review of the draft IA SQAP and incorporation of BEHS recommendations into the sampling plan.


SITE DESCRIPTION AND BACKGROUND

Poles Inc. is located in Oldtown just west of Priest River in the Panhandle of Northern Idaho (see Figure 1, Appendix A). The facility has produced pentachlorophenol (PCP)-treated utility poles since 1945. The facility currently operates nine months out of the year. An elementary school (Idaho Hill Elementary) and multiple residences are within proximity of the site.

In fall 2000, teachers from Idaho Hill Elementary and community members formed the Healthy Building Committee. The committee requested IDEQ to investigate an irritating chemical smell coming from the facility during its pole treating process. Following the request, IDEQ performed an evaluation of potential inhalation exposure to PCP using two air dispersion models called the Back Model and the SCREEN3 Model (IDEQ 2001). BEHS reviewed IDEQ's report and determined that modeled PCP concentrations may pose a public health concern if they are representative of actual exposure levels. Therefore, because of multiple uncertainties regarding the use of computer models, BEHS recommended that a thorough environmental investigation be conducted at the Oldtown site. Details are summarized in the previous Health consultation titled "Evaluation of Potential Pentachlorophenol Air Contamination Based on the Idaho Department of Environmental Quality April 2001 Air Modeling Results (BEHS 2001). BEHS formed the Community Advisory Group (CAG) during the process of drafting the previous Health consultation to ensure community involvement. In summary, BEHS suggested that the environmental investigation should include multiple environmental media and that it should be expanded to focus on potential contaminants other than PCP.

Given the community interests in petitioning EPA's action, BEHS's recommendation, and CAG's requests, the Superfund Technical Assessment and Response Team (START) plans to perform an IA at the Poles, Inc. Oldtown site. START's contractor, Ecology and Environment, Inc., completed the draft IA SQAP that proposed the technical and analytical approaches for field sampling activities. The proposed activities are summarized in the following section.


SUMMARY OF START PROPOSED SAMPLING ACTIVITIES

During the IA, samples will be collected from locations or features considered to be potentially contaminated. When applicable, site-specific conditions (i.e., topography or visual evidence of contamination) will be evaluated and incorporated into the placement of sampling locations. The following table lists the media to be sampled, the number of samples proposed, the, chemicals to be tested, and the proposed sampling schedule. The proposed sampling locations are presented in Appendix A, Figure 2. The locations are subject to change based on field information.

Table 1.

START Proposed Sampling Plan
Media # of samples/ locationsa Chemicals to be tested Proposed Timeframe Sample Description
Surface soil 9 locations, 1 location at nearby house, 3 locations at elementary school VOC, SVOC, Pesticides/PCBs, and TAL metals 8/25-8/30 2001 0-6 inches below ground surface
Subsurface soil 9 locations with 3 depths per location Appropriate depths
Sediment Up to 5 locations 0-6 inches below surface water/sediment interface
Groundwater 5 locations Appropriate depths
Air 14 samples in three days SVOC 8/22-8/24 2001 Downwind/Upwind locations while facility is operating.

a: The number of samples presented is an estimate; the actual number of samples to be collected will be determined in the field. Appropriate background samples will be collected.
VOC: Volatile organic compounds
SVOC: Semivolatile organic compounds (PCP is included in this list)
PCBs: Polychlorinated biphenyls
TAL: Target analyte list

Soil Samples
Surface soil and subsurface soil on-site/near site are proposed to be collected from the same locations (9 locations). Three additional surface soil samples are proposed to be taken from Idaho Hill Elementary and one from a selected nearby resident. Surface soil will be collected from 0-6 inches below ground surface and subsurface soil samples will be collected at the appropriate depths.

Sediment Samples
Sediment samples will be collected from 0-6 inches below the surface water/sediment interface. Three samples, right by and around the entry point of the drainage into the Pend Oreille River, are proposed. Two additional locations will be determined on site (i.e., visible contaminated spots).

Groundwater Samples
Five locations are proposed for groundwater samples. Four sampling locations are planned to be adjacent to the Poles Inc. wood treating dip tank and PCP storage tanks. The final sampling is planned to be located by the bank of the Pend Oreille River (site to be determined).

Air Samples
Air samples are proposed to be collected over three consecutive days from August 22 through August 24, 2001 (depending on weather condition). During the time of sampling, Poles Inc. will conduct both the whole pole and butt-dipping wood treatment process to simulate the worst case scenario. Representatives from IDEQ and EPA will be present to insure Poles Inc. is operating its regular heating cycle. The air samplers will be placed at locations designed to measure upwind and downwind concentrations of PCP and other SVOCs. The downwind locations will be approximately the same distance from the site as is the neighboring Idaho Hill Elementary. A meteorological station will be operated prior to and during the entire sampling event. It provides continuous wind speed, wind direction, temperature, barometric pressure, humidity, and 24-hour rainfall information.


DISCUSSION

After multiple discussions between EPA and IDEQ, BEHS has the following recommendations:

  • One additional indoor air-sampling station should be placed in Idaho Hill Elementary. As suggested by one of the CAG members, one of the stations will be placed in the classroom closest to the facility.
  • Three wipe samples for dust should be collected from the same classroom where indoor air samples are taken.
  • Two additional surface soil samples should be taken from the school play area.
  • A total of seven outdoor air sampling locations should be established: one upwind, one downwind, one or two by the dip tank, one across the river, one by the school, and the rest will be right outside of the property boundary (locations to be determined while on site).
  • Three additional surface soil samples should be taken from the treated pole staging area.
  • Two trained odor investigation personnel from IDEQ should be present while Poles Inc. is operating to assess the odor intensity for compliance with IDEQ's odor policy.
  • IDEQ, in cooperation with START, should design and provide an odor-reporting tracking sheet for the nearby residences to log their odor complaints.
  • START should provide a detailed list of analytes for TAL, VOCs, and SVOCs in the final SAQP document.

Prior to the start up of the sampling activities, START reviewed the suggestions and agreed to incorporate them in its IA SQAP. At the time of the publication of this Health consultation, the sampling activities have already begun and the BEHS recommendations incorporated into START's SQAP.


CONCLUSION AND RECOMMENDATION

START began the preparation for the actual sampling activities on August 20, 2001. At the publication of this Health consultation, START has published the final IA SQAP and it is anticipated that they will have completed their sampling activities. BEHS and ATSDR have reviewed the draft sampling plan for the Pole, Inc. site and offered several suggestions that would assist in providing a better understanding of the potential exposures at the site. BEHS and ATSDR will evaluate the results of the sampling event in relation to exposure pathways and the public health implication of any exposures identified. With the inclusion of these additional suggestions, the BEHS and ATSDR concur with the sampling plan.


REFERENCES

BEHS 2001. Evaluation of Potential Pentachlorophenol Air Contamination Based on the Idaho Department of Environmental Quality April 2001 Air Modeling Results. Poles Inc. Wood Treating Facility Oldtown, Bonner County, Idaho. Bureau of Environmental Health and Safety, Division of Health, Idaho Department of Health and Welfare, Boise, ID and Agency for Toxic Substances and Disease Registry, Atlanta, GA. August.

E&E 2001. Poles, Inc. Integrated Assessment Sampling and Quality Assurance Plan. Oldtown, Idaho. TDD: 01-07-007. Environmental Protection Agency Region 10 Superfund Technical Assessment and Response Team Two, Contract: 68-S0-01-01. Ecology and Environment, Inc., Seattle, WA. July Draft.

IDEQ 2001. Summary of Analysis: Ambient Air Impact of Pentachlorophenol from Poles, Inc. Idaho Department of Environmental Quality. Boise, ID.


PREPARERS OF REPORT AND CERTIFICATION

Preparers of Report

Mingyi Wen, Sc.D.
Health Assessor/Toxicologist
Elke Shaw-Tulloch
Manager
Environmental Health Education and Assessment Program
Bureau of Environmental Health and Safety
Division of Health
Idaho Department of Health and Welfare

ATSDR Technical Project Officer

Gregory V. Ulirsch
Environmental Health Engineer
Superfund Site Assessment Branch
Division of Health Assessment and Consultation

Any questions concerning this document should be directed to:

Mingyi Wen, Sc.D.
450 W. State St., 4th floor
P.O. Box 83720
Boise, ID 83720-0036
208-334-6584
wenm@idhw.state.id.us

Certification:

The Idaho Bureau of Environmental Health and Safety prepared this Health consultation under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the health consultation was initiated.

Gregory V. Ulirsch
Technical Project Officer, SPS, SSAB, DHAC


The Superfund Site Assessment Branch (SSAB), Division of Health Assessment and Consultation (DHAC), ATSDR has reviewed this health consultation and concurs with its findings.

Gregory V. Ulirsch
for Richard Gillig
Chief, SSAB, DHAC, ATSDR


APPENDIX A: POLES INC. LOCATION MAP

Poles Inc. Location Map


APPENDIX B: OLD POLES INC. OLDTOWN PROPOSED SAMPLING MAP

Old Poles Inc. Proposed Sampling Map



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