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Poles, Incorporated (Poles, Inc.) is an active pole peeling and storage treatment facility. It wasformerly a pole treating facility utilizing pentachlorophenol as a wood preservative. Poles, located in Oldtown, Bonner County, Idaho. The Pend Oreille River borders the northern edgeof the site and the Idaho Hill Elementary School (school) borders the southern edge of the site. The Bureau of Environmental Health and Safety, Division of Health, Idaho Department ofHealth and Welfare reviewed available environmental, toxicological, and epidemiologicalinformation and prepared this public health assessment under a cooperative agreement with thefederal Agency for Toxic Substances and Disease Registry.

What kind of chemical contamination was found?

Pentachlorophenol, dioxin, furan, and polycyclic aromatic hydrocarbons contamination wasfound in surface and subsurface soil onsite. This contamination appears to have migrated intogroundwater. Pentachlorophenol and polycyclic aromatic hydrocarbons were also detected atlow levels in air, sediment in the Pend Oreille River, and offsite surface soils. Dioxins andfurans were found in on and offsite surface soils. Pentachlorophenol was not found in schoolindoor air, and no contaminants were found in school dust wipe samples. Arsenic and other inorganic metals were also detected in soils, sediment, and groundwater both on and off site. Arsenic and other inorganic metals are not known to be site-related contaminants.

What are pentachlorophenol, dioxins, furans, and polycyclic aromatic hydrocarbons?

Pentachlorophenol is a manufactured chemical not naturally found in the environment and is aregistered biocide (or pesticide). Pentachlorophenol is used in industry as a wood preservativefor power line poles, railroad ties, cross arms, and fence posts. It is no longer allowed for publicuse at home or for gardening. People are generally exposed to the technical-grade ofpentachlorophenol versus the pure form of pentachlorophenol. The technical-gradepentachlorophenol contains impurities such as polychlorinated dibenzo-p-dioxins anddibenzofurans. Polychlorinated dibenzo-p-dioxins are a family of 75 different compounds.These compounds have varying harmful effects. They are produced naturally as well as byhuman activities such as industrial, municipal and domestic incineration and combustionprocesses and the manufacture of chlorinated phenols and other chlorinated chemicals likepentachlorophenol. Polychlorinated dibenzofurans are a family of 135 individual compoundswith varying harmful health and environmental effects. With very few exceptions, thesechemicals are not deliberately produced by industry. The processes that emit the unwanteddibenzofurans are much the same as those that emit dibenzo-p-dioxins. These two chemicalfamilies are often found in association with one another and cause similar toxic effects. Theindividual compounds that comprise the families are called congeners. During the woodtreatment process, technical-grade pentachlorophenol is mixed with wood treatment oil thatcontains polycyclic aromatic hydrocarbons. There are more than 100 different polycyclicaromatic hydrocarbons, which generally occur as complex mixtures. While some polycyclicaromatic hydrocarbons can be formed naturally in the environment, human activities such asburning coal, car exhaust, and tobacco smoke are the major sources of polycyclic aromatichydrocarbons in the air. Polycyclic aromatic hydrocarbons, as well as pentachlorophenol, can bereleased during the process of heating the pentachlorophenol and treating oil solution mixtures.

How might I be exposed to chemical contamination from the site?

The Bureau of Environmental Health and Safety evaluated current environmental sampling datafrom on and off-site. Currently, only onsite surface soils contain elevated levels ofpentachlorophenol, polychlorinated dibenzo-p-dioxins, polychlorinated dibenzofurans, andseveral polycyclic aromatic hydrocarbons (contaminants of concern). Workers, trespassers, andchildren playing at the pole yard may be exposed to chemical contamination from the site. TheBureau of Environmental Health and Safety advises community members to avoid exposure tothe contaminated soil by refraining from trespassing on the site. Workers should be careful tolimit exposure to onsite soil and to leave work clothes and shoes at work. The Bureau ofEnvironmental Health and Safety did not find site-related chemical concentrations off-site atlevels that could be a health risk.

What are the public health implications of exposures to site-related contaminants?

After reviewing available environmental data, current exposure to contaminants in the onsitesurface soil at Poles Inc. is categorized by the Bureau of Environmental Health and Safety as a"no apparent public health hazard" as defined by the Agency for Toxic Substances and DiseaseRegistry. Trespassers may be exposed to the contaminated surface soil; however, levels ofcontaminants to which they are exposed are not expected to cause adverse health effects. Current exposures to all other environmental media (e.g., air, sediment, offsite surface soil,onsite subsurface soil, and indoor dust) do not pose a health hazard. This assessment does notaddress past exposures to site-related contaminants. The Bureau of Environmental Health andSafety makes recommendations to minimize or eliminate exposures and for continued activity atthe site and in the community. Further explanation of the findings can be found in the fullreport.

Could exposures to chemical contamination at the site cause an increased rate of cancer inthe community?

The overall cancer incidence in the combined area of Oldtown and Priest River, Idaho andNewport, Washington between 1992 and 1999 was within the expected range when compared tothe remainder of the State of Idaho. However, the Cancer Data Registry of Idaho found anincreased rate of sarcoma cancer in the same three ZIP Code area. Sarcoma is a rare type ofcancer. There are known medical, environmental, and genetic factors associated with it. Literature suggests that the technical-grade pentachlorophenol that includes impurities maycause one form of sarcoma, called soft tissue sarcoma. Currently, the Bureau of EnvironmentalHealth and Safety does not know whether the identified sarcoma cases are related to the pastexposures to the Oldtown site but is further investigating the cases in collaboration with theCancer Data Registry of Idaho.

What are the major recommendations of the public health assessment?

The Bureau of Environmental Health and Safety has made several recommendations for actionsto minimize or eliminate possible exposures of the community from site contamination and sitephysical hazards and to address concerns heard from community members. The key elementsare: 1) as a precaution, restrict site access; 2) conduct a well survey for nearby private wells andgroundwater monitoring at the site; 3) further investigate the elevated sarcoma cancer rate; and4) conduct a cancer incidence evaluation for Idaho Hill Elementary School employees.

What are the follow up public health actions that will be taken?

The Environmental Protection Agency (EPA) is in the process of determining the HazardRanking Score for Poles, Inc.--this is part of the EPA's Superfund process. The EPA and theIdaho Department of Environmental Quality will be working with the site owner to controlcontamination. The Cancer Analysis Working Group of Idaho will further investigate thebiologically plausible cancer cases possibly linked to site-related exposures for the surroundingcommunities and the Idaho Hill Elementary school employees. The Bureau of EnvironmentalHealth and Safety will provide health education to assist residents in mitigating exposure.

Where can I get more information?

If you have more questions about this public health assessment or want to obtain extra copies ofthis document, please contact the Bureau of Environmental Health and Safety at 208-334-0606,toll-free 1-866-240-3553, or If you would like more information onadditional site activities, please contact the Idaho Department of Environmental Quality at 208-769-1422 or and/or the Environmental Protection Agency at 206-553-1388 or


In fall 2000, the United States Environmental Protection Agency (EPA) was petitioned by aconcerned citizen and was requested by the Idaho Department of Environmental Quality (IDEQ)to conduct an integrated site assessment for Poles, Incorporated (Poles, Inc.) in Oldtown, Idaho. Poles, Inc. is an active pole peeling facility and formerly treated wood poles withpentachlorophenol (penta), a wood preservative. The Bureau of Environmental Health andSafety (BEHS), Division of Health, Idaho Department of Health and Welfare has a cooperativeagreement with the Agency for Toxic Substances and Disease Registry (ATSDR) to conductpublic health assessments and consultations for hazardous waste sites in Idaho. BEHScompleted this public health assessment under this cooperative agreement.

A public health assessment is a tool used to determine if and what kind of activities are needed toprotect the health of a community residing/working near a hazardous waste site, and todetermine the need for follow-up health activities (e.g., health study). To achieve this goal, thisassessment contains three types of evaluations: (1) the identification of pathways of exposure tosite contaminants and an evaluation of their public health implications; (2) a summary ofrelevant and available health outcome data (e.g., cancer registry data); and (3) evaluations ofspecific community health concerns about the site. The first type of evaluation addresses thecontaminants that are present at site above comparison values, the determination of exposurepathways and the potential for those chemicals to enter people's bodies. These evaluations canbe found in Sections 4.1 - 4.3 and Sections 5.1, respectively. The evaluation of relevant andavailable health outcome data can be found in Section 5.2, and the evaluation of community health concerns about the site can be found in Section 5.3.


2.1 Site Description

Poles, Inc. a current pole peeling and storage facility was an active, open-vat, thermal woodtreatment facility using penta as a wood preservative. The facility is located within the city limitof Oldtown, just 400 feet south of the Pend Oreille River in the Panhandle of Northern Idaho,Bonner County (Appendix A, Figure A-1).

The site, although in the process of dismantling and decommissioning processes structures,included a treatment shed, thermal dip tank, office building, garage, boiler building, wood wastedisposal area, peeler, and pole storage yard (Appendix A, Figure A-2). The partially belowground thermal dip tank was next to the treatment shed which is a fenced, roofed structure withopen sides. The dip tank had covers that prevented precipitation from entering the tank. Thetank covers helped to reduce the production of sludge . The tank did not have any secondarycontainment. In the treatment shed, there were one 10,000-gallon and three 20,000-gallon aboveground storage tanks used for storing wood-treating oil. There was also an area where blocks ofsolid penta were stored on a concrete pad. Additionally, there were above ground diesel tanksand a gasoline fuel tank located either within concrete vaults or inside the boiler building. Aneast and west running railroad track is located south of the property border. The railroad track isused for shipping logs to and from the site. The Poles, Inc. property is approximately 15 acres. Most of the property is not paved.

The pole dipping tank at Poles, Inc. was 95 feet long by 8 feet wide by 12 feet deep with acapacity of approximately 68,000 gallons of penta preservative solution. The wood preservativesolution contained approximately 5% penta mixed with Imperial Pole Treating Oil. In a typicaltreating cycle, 150 pre-processed (peeled and cleaned) raw logs were placed in the tank. Pentaoil solution was pumped into the tank at 60 degrees Fahrenheit (F). The penta oil solutioncirculated through a steam heat exchanger that utilized an oil-fired boiler as the heat source. Infall 1999, the current oil-fire boiler replaced an old wood-fired boiler that significantly reducedthe heating cycle from approximately 17 hours to 8 hours. Most recently, it took roughly 3.5hours to heat the oil mixture to 225F for the wood treating process. The heated oil was thenheld in the tank for an additional 3.5 hours before it was drained back into the above groundstorage tank. Cool oil was pumped into the tank for another hour to cool the poles. Once thepoles were cool, they remained in the tank on steel rails 6 inches above the tank bottom whileexcess oil dripped off and the poles dried. Once dry, the poles were moved from the dip tank tothe storage area until shipment. The whole process including the time for the poles to dry tookapproximately three days. Poles, Inc. could treat a maximum of 2 - 2.5 batches of poles perweek. However, a typical production was one batch of poles per week (IDEQ 2000). Poles weretreated in two ways: whole poles were submerged in the penta oil solution, or just one end of thepoles were dipped in the penta, called butt dipping. Poles, Inc. modified its wood treatmentpractices over the years. Poles, Inc. prior to discontinuation installed new tighter sealed coverson the dip tank and the covers were closed when the tank was not in operation and when treatingwhole poles. During the butt-dipping process, a wrap was placed around the poles to reducevolatilization of the treating oil. In 2001, Poles, Inc. installed an ambient air vapor condensingsystem that collected and condensed penta vapor emission and recycled it back into the dip tank(EPA 1993, 2002).

The facility operates nine months of the year and is closed during December, January, andFebruary. The nearest residence is approximately 400 feet west of the facility. Idaho HillElementary School is located approximately 500 feet south of the facility and situated on a hillapproximately 30 feet higher in elevation than the site. A railroad track is situated at the base ofthe hill running along the southern border of the site. The Oldtown Log Yard, an active logprocessing business not owned by Poles, Inc. is situated in the narrow strip of property betweenthe railroad tracks and the base of the hill below the school. The log yard does not handle, store,or ship treated poles from the site. The Pend Oreille River, approximately 400 feet north of the facility dip tank, flows in a general north-northwest direction (Appendix A, Figure A-2).

2.2 Site History

Poles, Inc. has been owned and operated by the Tinling family at its current location since 1945. Prior to 1945, the Great Northern Railroad owned the land. Operations prior to 1945 areunknown. EPA and IDEQ (formally Division of Environment with Idaho Department of Healthand Welfare) investigated Poles, Inc. multiple times in the 1980s and early 1990s. Theinvestigations were either routine investigations or a result of odor complaints. No site-specificenvironmental samples were collected during those investigations. In fall 2000, the HealthyBuilding Committee, formed by Idaho Hill Elementary School staff members, requested thatIDEQ, BEHS and the Cancer Data Registry of Idaho (CDRI) evaluate the site. Concurrentlywith a citizen's petition, IDEQ requested EPA's involvement for a thorough site investigation. Jointly, EPA and IDEQ conducted a comprehensive site investigation in fall 2001. BEHS isevaluating the potential health risks from the exposures associated with the site activities.

In fall 2000, several teachers and school administrative staff from the nearby Idaho HillElementary School raised concerns about a strong chemical smell coming from the facilityduring pole treatment. Teachers and students experienced eye and throat irritation, headaches,and nausea during the treating process. Additionally, citizens in the border communityexperienced the same symptoms. School staff members and a concerned citizen contacted theIDEQ, BEHS, and CDRI to investigate the potential exposures and health effects of penta andpenta-associated impurities. The community members were also concerned with what wasperceived as an elevated cancer rate among current and former schoolteachers at Idaho HillElementary.

In response to community requests, IDEQ visited Poles, Inc. on October 19, 2000. During thissite visit, IDEQ noted that no objectionable odors were detected and fugitive dust emissionswere well controlled. However, the plant was not actively treating poles during the visit (IDEQ2000). Soon after the visit, to accommodate community concerns, Poles, Inc. changed theirpole-dipping schedule so the treatment process occurred when Idaho Hill Elementary was not insession. This schedule continued when the facility restarted operations in the Spring of 2001. InApril 2001, IDEQ performed an initial evaluation of potential inhalation exposure to pentautilizing two air dispersion models (IDEQ 2001). BEHS reviewed IDEQ's April 2001 airmodeling report and prepared a health consultation to address public health issues (BEHS 2001a,Appendix B). The consultation concluded that there might be a potential inhalation exposure topenta based on the modeling results. BEHS recommended a thorough site exposureinvestigation for the facility in order to adequately address public health concerns. BEHSconvened a conference call to address the community comments and questions regarding theconsultation in August 2001. Some of the comments and questions were later summarized inanother health consultation to document the issues raised by community members (BEHS 2002,Appendix C).

Besides IDEQ and BEHS activities, CDRI performed a cancer incidence evaluation for the ZIPCode of Oldtown (83822) between 1991 and 1999. For the ZIP Code compared to the reminderof the State of Idaho, the rates of the reported 24 cancer types were all within or lower than theirexpected ranges (Attachment D, Table D-1). Since Oldtown is a relatively small area, peoplecommute to Oldtown for work or school from different areas or ZIP Codes. CDRI could not ruleout the possibility of underestimating the risk (Johnson 2001). Additionally, the initial 24 typesof cancer evaluated by CDRI did not include two specific types of cancers for which penta issuspected of being associated.

In May 2001, BEHS and IDEQ convened a public meeting. During this meeting, IDEQpresented the results of the April 2001 air dispersion modeling and proposed the possibility ofsurface soil sampling at the Poles, Inc. property. At the request of BEHS, the OldtownCommunity Advisory Group (CAG) was formed. The CAG is composed of volunteers fromOldtown and nearby communities as well as agency representatives from BEHS, IDEQ, IdahoState Department of Agriculture, EPA, and ATSDR. Members of the CAG suggested that BEHSconduct an epidemiological study and/or biological testing of Oldtown residents and teachers. BEHS and ATSDR stated that the need for additional health studies would be determined afterenvironmental data was available and evaluated. In the mean time, BEHS reviewed the Oldtownsituation with the Idaho Cancer Analysis Working Group (CAWG). CAWG members includethe Idaho State Epidemiologist and representatives from CDRI, the Bureau of Vital Records andHealth Statistics, and BEHS. CAWG requested that CDRI perform another cancer incidenceevaluation to better define potentially impacted populations around Poles, Inc. The studyincluded additional target cancer sites that are biologically plausible as a result of the site-specific exposures. The results of this cancer incidence evaluation are discussed in section 5.2.3of this public health assessment.

In June 2001, IDEQ sampled surface soil between the Poles, Inc. treatment dip tank and theschool fence line (Appendix E). Penta concentrations in the samples decreased as distance to thedip tank increased. Penta was not detected in soil taken from outside the pole yard border. However, high levels of penta were detected in the soil near the dip tank (IDEQ 2001). Theseresults further supported the need for EPA's involvement.

EPA convened a meeting with the CAG in June 2001 to discuss the multiple, ongoing activitiesthat were proposed by EPA and IDEQ. Given the community interests in petitioning EPA'saction, BEHS'S recommendation, and IDEQ's requests, the EPA's Superfund TechnicalAssessment and Response Team (START) contractor, Ecology and Environment, Inc. (E&E)performed an Integrated Assessment (IA) at the Poles, Inc. Oldtown site. At this meeting, EPAdiscussed the IA and the public health goals for the IA. Those goals were: (1) to identify andconduct a removal assessment of potentially contaminated environmental media at the site; (2) tocharacterize the potential sources of contamination; (3) to acquire adequate information todetermine whether the site is eligible for placement on the National Priorities List; (4) todocument threats or potential threats to public health posed by the site; and (5) to determinewhether removal actions are warranted. BEHS reviewed the START IA sampling plan andcommented on it in the form of a health consultation (BEHS 2001b, Appendix F). EPAincorporated BEHS and IDEQ's comments before finalizing the IA plan and conductingenvironmental sampling.

START collected samples for air, surface soil, subsurface soil, sediments of the Pend OreilleRiver, groundwater, and indoor dust samples. Samples particularly focusing on Idaho HillElementary included indoor air samples, wipe samples in Classroom 1, which is the closest to thefacility, and surface soil samples from the school playground. Dip tank products includingsludge and oil were tested. Because the penta treatment oil is a complex mixture of manychemicals, START analyzed the collected samples for heavy metals, semivolatile organiccompounds (SVOCs) which included penta, and volatile organic compounds (VOCs). STARTcompleted the final Poles, Inc. IA Report in January 2002 (EPA 2002a).

After EPA's investigation, EPA requested Poles, Inc. hire a contractor to perform a dip tankintegrity study. Poles, Inc. hired Mountain Construction Services in September 2001. Crackswere found in the floor's center, the southwest corner welds, and on the west wall of the tank. The cracks ranged from 0.06 to 1.5 inches. All cracks were repaired by the contractor after theinspection (EPA 2002a).

On June, 18, 2002, EPA START conducted limited dioxin and furan sampling at the Poles, Inc.facility. They collected one groundwater, one product, and five surface soil samples to test forpolychlorinated dibenzo-p-dioxin (PCDD) and polychlorinated dibenzofuran (PCDF). Thesampling was to complete data gaps from the 2001 IA (EPA 2002b). Surface soil samples werecollected at the top of a trail along the north bluff of Idaho Hill Elementary school, from theplayground at the school, from a residence on the edge of the site, from the treated butt-dip polestorage area and a background surface soil was collected near the intersection of East 7th Southand Meadowdale Streets (the same background location was used during the IA). A groundwatersample was collected from the monitoring well east of the dip tank and a product sample wascollected from the dip tank itself. START completed their report in August 2002 (EPA 2002b).

BEHS is preparing this public health assessment relying on the data and information providedfrom the START IA (EPA 2002a), the START dioxin/furan sampling (EPA 2002b), and theIDEQ soil sampling report (IDEQ 2001b). Data demonstrated to have QualityAssurance/Quality Control (QA/QC) problems were not used in this public health assessment. IDEQ's April 2001 air modeling results were not used due to high uncertainties of the modeling outcome.

2.3 Demographics

According to the 2000 US Census, the population of Oldtown is approximately 190. SinceOldtown is a relatively small town and it immediately borders Newport, Washington, theestimated population that may potentially be impacted by the facility needs to include residentsof Newport. E&E estimated the population within a 1-mile radius of the site to be 2586 and3722 within a 4-mile radius of the site. Those estimates are based on the sum of (1) census datafor Newport and Oldtown; and (2) multiplying the house count for people outside city limits bythe average number of persons per household (2.5) for Bonner and Pend Oreille Counties (EPA2002a). Citizens in Priest River, a town six miles west of Oldtown, have expressed concernsabout the site because many people in Priest River drive to the Oldtown/Newport area for workor school. The population of Priest River in 2000 was 1754 (Census 2000). Approximately 10people work at the Poles, Inc. facility. It is currently not known from where those employees commute to work.


An essential part of every public health assessment is to review environmental contaminants onthe site. In this section, BEHS has listed the contaminants of concern. BEHS evaluates thesecontaminants in the subsequent sections of the public health assessment to determine whetherexposure to them has any public health significance. The results from environmental testing atthe Oldtown site are summarized for each different environmental media (e.g., air, groundwater,surface soil, subsurface soil, etc.).

Concentrations of chemicals in each of the media have been compared to media-specific health-based comparison values developed by ATSDR to decide whether any of the chemicals needfurther evaluation. Health-based comparison values are derived using chemical toxicityinformation and assuming frequent human exposure to contaminants (e.g., a residential settingrather than industrial setting). For non-cancer toxicity, BEHS typically uses EnvironmentalMedia Evaluation Guides (EMEGs) derived from ATSDR's Minimal Risk Levels (MRLs) or theReference Dose Media Evaluation Guides (RMEG) derived from EPA's References Doses(RfDs). MRLs and RfDs are estimates of daily human exposure to a contaminant that is unlikelyto cause adverse non-cancer health effects over a lifetime. Cancer Risk Evaluation Guides(CREGs) are risk comparison values based on EPA's chemical-specific cancer slope factors andan estimated excess lifetime cancer risk of one in one million. Therefore, if the concentration ofa chemical is less than its comparison value, it is unlikely that exposure would result in adversehealth effects. Further evaluation of exposures to that chemical is not warranted. If theconcentration of a chemical exceeds a comparison value, adverse health effects from exposureare not necessarily expected, but potential exposures to that chemical at the site should beevaluated.

In addition to the health-based comparison values, BEHS also references other standards andregulations when health-based comparison values are not available or when other standards arelower than the health-based comparison values. EPA's Maximum Contaminant Level (MCL) isthe highest level of a contaminant that is allowed in drinking water. MCLs are enforceablestandards and they are set as close to Maximum Contaminant Level Goal (MCLG) as feasible. MCLG is the level of a contaminant in drinking water below which there is no known orexpected risk to health. MCLGs are non-enforceable public health goals. The Lifetime HealthAdvisories for Drinking Water (LTHAs) are lifetime exposure levels for drinking water at whichadverse, noncarcinogenic health effects would not be expected to occur. EPA also recommendssecondary standards that are non-enforceable guidelines regulating contaminants that may causecosmetic or aesthetic effects (e.g., smell, taste, and color) in drinking water. The secondarystandards are not health-based. Sometimes secondary standards are 10 to 100 times lower thanlevels that would induce health effects. Ambient and indoor air measurements have beencompared to Idaho Ambient Air Criteria (IAAC) and EPA Region IX's Preliminary RemediationGoals (PRGs) for air. Surface soil and sediment concentration have been compared to EPARegion IX's PRG for residential soil. The lowest of all comparison values was used to identifycompounds for further evaluation. The abbreviation of above described guidelines, standards, and criteria are summarized in the following Table.

Table 1.

Summary of Comparison Values and other Environmental Standards
Guides,Regulations,Standards Unit Unit Example Target Media Regulatory (Y/N) Health Based (Y/N)
CREG concentration g/M3, g/kg, g/L air, soil, water N Y
EMEG concentration g/M3, g/kg, g/L air, soil, water N Y
IAACa concentration g/M3 air Y Y
LTHA concentration g/L water N Y
MCL concentration g/L water Y Nb
MCLG concentration g/L water N Y
MRL dose mg/kg/day -- N Y
PRG concentration g/M3, g/kg, g/L air, soil, water N Y
RfD dose mg/kg/day -- N Y
RMEG concentration g/M3, g/kg, g/L air, soil, water N Y
Secondary concentration g/L water N N

a: an criterion for incremental air release; applicable to new facility or change of operation for existing facility
b: MCL was set as close to the health based MCLG as feasible using the best available treatment technology and taking cost into consideration.

The public health implications of exposures to selected contaminants are evaluated in detail inthe discussion section of this document. With this in mind, the following summary ofenvironmental data highlights the target chemicals that have been found on the site at levelsabove the comparison values. The sampling location identification numbers referenced in thispublic health assessment are the same as the START IA report (EPA 2002a) and the STARTdioxin/furan sampling (EPA 2002b). The details about the selection of contaminants of concerns are summarized in Appendix G.

3.1 Air

The following sections present air sampling results from the START IA report. Air sampleswere taken while Poles, Inc. was butt-dipping the poles. It is generally believed that the butt-dipping process generates the worst case air emission scenario. Air samples represent the airconcentrations at that particular sampling time period. The results do not represent the pastexposures before the change of operation.

3.1.1 Ambient (Outdoor) Air

Twenty-one outdoor air samples (including background) were collected from August 23rdthrough 25th, 2001. Samples were collected from seven locations over three consecutive 24-hoursampling periods and were analyzed for SVOCs. The temperatures during the sampling periodranged from 40 to 90 F. The most common wind direction was west southwesterly followingthe Pend Oreille River Valley. A meteorological station 1000 feet east of the treatment shedrecorded the weather information. The downtown/residential areas of Oldtown/Newport arelocated within half a mile west-northwest of the site. Penta is the only compound that wasdetected in the outdoor air at concentrations above the comparison value. In general, the highestpenta concentrations were found next to the wood treatment area (0.01 to 0.63 microgram pentaper cubic meter air, g/M3) with an exception of the first day where the highest concentrationwas detected at a nearby residence (1.48 g/M3) downwind from the facility at the time ofsampling. The penta air sampling analytical data are summarized in Table 2. As a reminder,comparison values for air are theoretical calculations assuming daily exposure over 30 years. Since the exposure to this level of contamination would only occur during the pole treatmentprocess (once a week), the use of these comparison values is a conservative (protective) tool forscreening purposes.

Table 2.

Pentachlorophenol August 2001 Air Sample Analytical Results, Poles, Inc.
LocationID Location Description Aug. 22-23 Aug. 23-24 Aug. 24-25
PY04AM400 feet south of the site at the school


PY01AM1000 feet east of the site


PY02AM120 feet north of the site near PendOreille River bluff


0.03a 0.06a
PY03AM800 feet west of the site at adjacentresidence


PY05AM50 feet east of the dip tank


0.63b 0.49b
PY07AM2000 feet northeast of the site at thenorth side of the river


PY08AM2520 feet east of the site


PY06AMIndoor air samples (school hallway)



a: Penta was positively identified. The number is an unknown bias estimate.
b: Penta was positively identified. The number is a low bias estimate.
BDL: Below detection limit. The detection limit is between 0.16 - 0.18 g/M3.
R: Rejected.

3.1.2 Indoor Air

Three indoor air samples were collected from August 23rd through 25th, 2001. The samples werecollected from inside of the School over three consecutive 24-hour sampling periods and wereanalyzed for SVOCs. The sampling station was near Classroom 1 in the school hallway directlybeneath the air vent. The outdoor air intake for this air vent is the closest to the facility. All thedetected indoor air contaminants were at concentrations below their comparison values. Pentawas not found in indoor air. The most prevalent wind direction during the sampling period waswest-southwest direction following the Pend Oreille River Valley. The school was notdownwind during the sampling period.

3.1.3 Odor

During the air sampling event, light to moderate odor was noted by the START investigatorswhile in the school. According to school staff, the odor issue for the school improved oncePoles, Inc. began treating poles at night. In addition, the odor has been less noticeable sincePoles, Inc. installed a vapor condensing system, according to respondents of the OldtownCommunity Health Concerns Survey (Appendix M). The facility is no longer treating poles,therefore eliminating the odor issue.

3.2 Soil

The following sections present soil sampling results from the IDEQ soil sampling study and theSTART IA and START dioxin/furan sampling. In this public health assessment, BEHSidentified samples within Poles, Inc. property as "onsite" and included the log-storage area,penta sack disposal area, wood waste disposal area and part of the Pend Oreille river bank.

3.2.1 Onsite Surface and Subsurface Soil

In June 2001, IDEQ collected 10 surface soil samples (including background) between Poles,Inc. dip tank and the school fence line. Surface soil grab or composite samples were taken from120, 170, 220, 270, 320, and 370 feet away from the dip tank toward the school (Appendix E,Figure E-1). A composite sample is a combination of five grab samples representing the samedistances away from the dip tank. Soils were analyzed for SVOCs. In the onsite surface soil, themaximum concentration of six contaminants were higher than the health-based comparisonvalues (benzo(a)anthrancene, benzo(b)fluoranthene, benzo(a)pyrene, dibenzo(a,h)anthracene,Ideno(1,2,3-cd)pyrene, and penta) (Appendix G, Table G-1). Except for penta, the compositesample collected around the railroad track (270 feet) and the haul road (320 feet) generally hadthe highest concentrations for all other detected contaminants. The highest concentrations were0.77 milligram per kilogram (mg/kg) for benzo(a)anthrancene, 1.64 mg/kg forbenzo(b)fluoranthene, 0.615 mg/kg for benzo(a)pyrene, 0.125 mg/kg fordibenzo(a,h)anthrancene, and 1.28 mg/kg for ideno(1,2,3-cd)pyrene. The highest concentrationfor penta was 234 mg/kg in soil collected 170 feet away from the dip tank. Generally, the furtheraway from the dip tank, the lower the penta soil concentrations. Penta was not detected in anysample locations beyond the railroad track toward the school.

In August 2001, START took onsite soil samples from the ground surface to about 80 feet belowground (above groundwater level). Subsurface soil was collected in order to characterize thepotential impact to groundwater. The surface soil sampling locations included four samplesaround the treatment shed, six samples around the log storage area, and one sample at the pentastorage sack area. Fourteen subsurface soil samples were collected from seven locations aroundthe treatment shed (Appendix A, Figure A-2). The top 6 inches of soil was defined as surfacesoil. The upper part of subsurface soil ranged from 10 to 40 feet below ground surface (bgs) andthe lower part of subsurface soil ranged from 75-80 feet bgs. Wood-treating oil stains and/orpetroleum odors were observed in one surface soil sample and five subsurface soil samplescollected from three locations around the treatment shed. According to E&E's estimation, thetotal volume of penta and oil impacted subsurface soil is approximately 3700 cubic meters (4978cubic yards) (EPA 2002a).

START soil samples were analyzed for metals, chlorinated pesticides, SVOCs, and VOCs. Theamount of contamination was generally greater in the lower portions of the subsurface soil. Themaximum concentrations of five contaminants in subsurface soil were higher than the health-based comparison values (arsenic, benzo(a)anthrancene , benzo(b)fluoranthene,dibenzo(a,h)anthracene, and penta). Arsenic levels ranged from 6.9 to 16.9 mg/kg. Subsurfacesoil background arsenic concentrations ranged from 7.8 - 9.1 mg/kg. The maximumconcentrations for benzo(a)anthrancene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, andpenta were 3, 2.6, 0.07, 0.14, and 1700 mg/kg, respectively (EPA 2002a). However, exposuresto onsite subsurface soil 10-80 feet bgs is highly unlikely for the public.

BEHS identified two contaminants, arsenic and penta, in the onsite surface soil that have higherconcentrations than the health-based comparison value. Arsenic in surface soil ranged from 6.2to 15 mg/kg, higher than the CREG of 0.5 mg/kg, but similar to site and regional backgroundlevels. Arsenic concentrations are not a site-related issue since Poles, Inc. has never used arsenicin its wood-treating process. From a public health perspective, BEHS evaluates the results ofarsenic in each environmental media separately from the site-related issue. Details can be foundin Section 3.7.2.

Penta was detected in eight out of 10 onsite surface soil samples. The highest pentaconcentration, 600 mg/kg, was found at the east log-storage area (PY03SS). The west side ofthis log-storage area is regularly used by locals as a shortcut between the school/residential areaand downtown Oldtown/Newport. Other SVOCs detected by START were below comparisonvalues.

Wood-treating compounds have migrated to surface and subsurface soils from past and recentsite activities. Contaminated surface soil around the log storage area may be due to airdeposition or from treated poles dripping onto the ground. Contaminated subsurface soil aroundthe treatment shed may be due to accidental spills and the cracks found at the bottom of the diptank.

In June 2002, START collected one surface soil sample (PY03SS02) on site from the butt-dippole storage area. While PCDDs and PCDFs were detected, the Toxicity Equivalent Quotient(TEQ) was below ATSDR's health-based comparison value. The TEQ represents the toxicity-related value that combines the toxicities for all dioxin-like PCDDs/PCDFs and expresses themas a sample concentration term for only one congener, 2,3,7,8-tetrachlorodibenzo-p-dioxin. Theconcentration of all of the congeners is expressed as a single value (EPA 2002b).

3.2.2 Offsite Surface Soil

The surface soil sampling study conducted by IDEQ in June 2001 included one grab and onecomposite sample at the Idaho Hill Elementary school fence line. The composite sample is acombination of five grab samples representing the school fence line. Samples were analyzed forSVOCs. SVOCs were not detected in the IDEQ offsite surface soil samples (Appendix G, Table G-1).

Seven offsite surface soil samples were collected by START in August 2001. The offsitesamples included a background sample, a sample taken from the closest residence (right by thewood waste disposal area), three samples around the school, and two samples from the schoolplayground. Samples were analyzed for metals, chlorinated pesticides, SVOCs, and VOCs. Arsenic concentrations ranged from 5.8 to 8.8 mg/kg similar to the background ranges. It isimportant to reiterate, arsenic is not known to be associated with the site activities (EPA 2002a). None of the detected pesticides, SVOCs, and VOCs had concentrations higher than thecomparison values. Penta was detected east of the school playground area near trees (SC05SS)and a nearby residence at levels 0.096 and 0.059 mg/kg, respectively, far below the soil CREGfor penta (4 mg/kg).

Wood-treating compounds from past and recent site activities were not found at levels abovecomparison values in the offsite surface soil. Contaminated surface soil onsite and future airemissions, erosion, and deposition may result in future off-site surface soil contamination. However, it is not possible to determine the probability or the levels of future contaminationbased on the available information.

Four offsite surface soil samples were collected by START in June 2002. The offsite samplesincluded a background sample, a sample taken from the closest residence (right by the woodwaste disposal area), one sample on the bluff near the school, and one sample from the schoolplayground. Samples were analyzed for PCDDs and PCDFs. The calculated TEQ was belowATSDR's health-based comparison values.

3.3 Sediment

Three sediment samples were collected by START from the Pend Oreille River to determinewhether contaminants are migrating from potential sources at the site toward the river. Abackground sample was collected from the northeast of the site, approximately 350 feet upstreamfrom the probable point of entry (PPE). One sample was collected at the PPE and the other wascollected downstream from the PPE. PPE is the most direct route of surface water drainage fromthe site into the river. Poles, Inc. does not have a surface water collection system and the site isrelatively flat. Water at the site would either drain into the soil or follow the path of a little useddirt road, determined by EPA to be the PPE (Appendix A, Figure A-2) (EPA 2002a). None ofthe detected pesticides, SVOCs, or VOCs were at levels of health concern. Arsenic sedimentbackground was 5.3 mg/kg. Arsenic levels at the PPE and downstream of the site were 5.2 and5.7 mg/kg, respectively. The onsite surface soil contamination currently does not appear toreach the river.

3.4 Groundwater

During the IA, START collected eight groundwater samples from five monitoring wells aroundthe treatment shed during two sampling events. The monitoring wells were installed in August2001. Five samples were taken at the time prior to well development. Those samples are notused in this public health assessment because they may be biased due to possibly high dissolvedsolids from unsettled, disturbed well water. START re-sampled three wells (TP04, TP06, andTP05) after well development in January 2002. These wells were 88.5 feet bgs and thegroundwater samples were taken at approximately 77.5 feet bgs. The groundwater samples wereanalyzed for metals, chlorinated pesticides, SVOCs and VOCs. Penta along with 12 metalsshowed elevated concentrations compared to health comparison values. Penta was detected inone of the wells at 46 micrograms per liter (g/L). The maximum concentrations for metalswere 115000 g/L for aluminum, 14 g/L for antimony, 344 g/L for arsenic, 1970 g/L forbarium, 9 g/L for beryllium, 214 g/L for chromium, 199 g/L for cobalt, 298000 g/L foriron, 327 g/L for lead, 174 g/L for nickel, 17 g/L for thallium, and 297 g/L for vanadium. Most reported metal concentrations were similar among three monitoring wells. Metals were notknown to be used in Poles, Inc. wood-treating process (EPA 2002a).

START collected one groundwater sample from existing monitoring well #3 in June 2002 to test for PCDDs and PCDFs. 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) and 2,3,7,8-tetrachlorodibenzofuran (TCDF) were not detected in the groundwater sample, but other congeners of the contaminants were detected at a combined TEQ level above the ATSDR health-based comparison value. However, the groundwater pathway is not a completed exposure pathway (for more information on the groundwater pathway see Section 4.2.1). BEHS did not evaluate PCDD and PCDF concentrations further. It is not expected that private wells are located down gradient of the Oldtown site (EPA 2002a); therefore, the wells are not likely to be impacted by contamination. However, domestic wells were not sampled during the START IA and the exposures cannot be determined until further monitoring is completed and a beneficial well use survey is completed.

There are 46 domestic wells and 13 public wells located within a 1-mile radius of the siteaccording to the well logs maintained by Idaho and Washington. The nearest well is locatedapproximately 2500 feet southeast (up gradient) of the site. The Oldtown/Newport public watersupply system primarily uses surface water taken upstream of the facility. Eight public wells areoccasionally used for the Oldtown/Newport public water supply system when water demands arehigh. Those wells are up gradient of the site and SVOCs were routinely tested for in the wells. SVOCs were not detected in 1993, 1994, 1996, and 1998 sampling (Taylor 2002). In August2001, IDEQ sampled the West Bonner Well (one of the public wells) and analyzed water forpolynuclear aromatic hydrocarbons (PAHs), penta, and VOCs. The only detected chemical wastrichloroethylene at 2.7 g/L, which was higher than the EPA Region IX tap water PRG (1.6g/L) but lower than the MCL (5 g/L). This contamination may be attributable to a nearbyformer dry cleaner but does not appear to relate to Poles, Inc. The Oldtown/Newport publicwater system stopped using this well after IDEQ's finding (EPA 2002a).

It is not known whether the monitoring wells are in the same aquifer as any of the nearbydrinking water (private or public) wells. Groundwater in the vicinity of the site flows to the eastto northeast towards the Pend Oreille River and may ultimately enter the River. Surface waterwas not sampled in the START IA (EPA 2002a) or in the START dioxin/furan sampling (EPA2002b).

3.5 Wipe Samples

Wipe samples were taken by START during the IA to determine whether contaminants havemigrated from the potential sources at the site and deposited onto the school property. ThreeSVOC wipe samples were collected from Classroom 1 at the school. Two samples werecollected from potentially high-contact areas in each of the classroom walls (composite of fourwipes). The third sample was collected from the top of each fluorescent light fixture in an areanot regularly cleaned (composite of six wipes). This classroom was intentionally not painted orcleaned after the end of the last school year to ensure that wipe samples represented theconditions during the year. The dust sample on top of the fluorescent light fixtures accumulatedover the year. SVOCs were not detected in any of the wipe samples. The low levels of the woodtreating contaminants do not appear to have deposited and accumulated in Classroom 1 throughthe air migration pathway (EPA 2002a).

3.6 Physical Hazards

The treatment shed area of Poles, Inc. has a locked gate but the remainder of the property is notfenced. The public regularly access through the pole yard and the log processing yard as ashortcut between the school/residences and the downtown area of Oldtown/Newport. During themultiple site visits conducted by BEHS, IDEQ and EPA, the investigators observed frequenttrespassers including children disregarding multiple "no trespassing" signs (Appendix H). According to the Idaho Hill Elementary school staff; however, the signs were relatively newadditions to the site (installed prior to EPA sampling event in August 2001). The frequentlytrespassed area is full of piled logs, debris, and heavy equipment. A nearby resident told theBEHS investigator that it is common to see elementary school children playing at the area afterschool. BEHS could not exclude the possibility of physical hazards.

3.7 Other Concerns

3.7.1 Data Gaps

Poles, Inc. is located adjacent to the Pend Oreille River which is used for recreational boatingand fishing. START did not find wood-treatment chemicals in sediments collected from theriver. However, the contaminated groundwater from the site is expected to flow toward and toultimately enter the Pend Oreille River. During the IA, START personnel did not observefishing activities near the site, but did observe boats with fishing gear both upstream anddownstream of the facility. The amount of fish caught from the river that were consumed byanglers is unknown (EPA 2002a). Recreational sportsmen and children may come in contactwith surface water. Surface water, fish, or other biota was not sampled in the IA.

3.7.2 Background Arsenic

As described throughout sections 3.2 to 3.5, the elevated arsenic levels were found in surface soil(5.7 - 15 mg/kg), subsurface soil (6.9 - 16.9 mg/kg), and sediments (5.2 - 5.7 mg/kg). The soilarsenic results are similar to the area background level. The site-specific background arseniclevels were 9.7 mg/kg in surface soil and 9.1 mg/kg in the upper and 7.8 mg/kg in the lowerportions of the subsurface soil, and 5.3 mg/kg in the river sediment. These background levelsare similar to the Spokane Basin area average (9 mg/kg). The Spokane Basin, 40 miles south ofOldtown is the nearest geographic region for which natural arsenic soil backgroundconcentrations were reported. Elevated heavy metals including arsenic (0.15 - 0.34 mg/L) werefound in groundwater samples (EPA 2002a). However, arsenic does not appear to be a concernfor the public drinking water system. Prior to the chlorination process, arsenic detected in theNewport public water system was 0.01 mg/L (Woodke 2002). The health implications of beingexposed to arsenic are part of the discussion in this public health assessment. Arsenic is not related to the site activities.


BEHS evaluates the environmental and human components that lead to exposure. Humancontact with environmental contamination is only possible when a completed exposure pathwayexists. A completed exposure pathway exists when all of the following five elements arepresent: (1) a source of contamination; (2) transport through an environmental medium; (3) apoint of exposure; (4) a route of human exposure; and (5) an exposed population.

ATSDR categorizes an exposure pathway as a completed or potential exposure pathway if theexposure pathway cannot be eliminated. Completed pathways require that all five elements existand indicate that exposure to a contaminant has occurred in the past, is currently occurring, orwill occur in the future. Potential pathways, however, require that at least one of the fiveelements is missing, but could exist. Potential pathways indicate that exposure to a contaminantcould have occurred in the past, could be occurring now, or could occur in the future. Anexposure pathway can be eliminated if at least one of the five elements is missing and will neverbe present. Table 3, Table 4, and Table 5 summarize the pathways for the Oldtown site. Thediscussion following these three tables concentrates on the pathways that are of public healthsignificance and relevant to the site. Eliminated pathways are briefly described. As anadditional note, even though an exposure pathway might be complete or potential, it does notnecessarily mean there is a public health risk from the exposure pathway contamination. For apublic health risk to occur, contamination in a completed or potential exposure pathway must bepresent in a substantial enough dose. Further explanation of this can be found in Section 5.1.

4.1 Completed Exposure Pathways

A completed exposure pathway requires all of the five elements to be present: (1) a source ofcontamination; (2) transport through an environmental medium; (3) a point of exposure; (4) aroute of human exposure; and (5) an exposed population. Table 3 lists the completed exposurepathways for the Oldtown site.

Table 3.

Completed Exposure Pathways
Source Media Point of Exposure Route of Exposure Exposed Population Time Status
Poles, Inc. onsite surface soil Poles property eating
skin contact
workers, trespassers, children playing in log storage area Past completed
Present completed
Future potential
Poles, Inc. offsite surface soil Nearby homes and school eating
skin contact
nearby residents, gardeners, children playing in school playground, school teachers and staff Past potential
Present completed
Future potential
Poles, Inc. sediment Pend Oreille River bank eating
skin contact
sport fishermen, children playing along the river Past potential
Present completed
Future potential
Poles, Inc. air, fumes and dust Poles, Inc. property, nearby area breathing workers, residents nearby, school children, teachers and staff Past completed
Present completed
Future potential

4.1.1 Air Pathway

A completed air exposure pathway exists for past exposures. Higher contaminant concentrations in the past versus the most recent past could have been possible because Poles, Inc. recently installed, prior to their removal, new covers on the dip tank that had a tighter seal and a vapor condensing system. Poles, Inc. also shortened the wood treatment process with a more efficient boiler. The new covers and the vapor condensing system minimized and controlled part of the air emissions. A shorter heating process reduced the time for air emissions to occur. The odor was better controlled and the air emissions improved over time. However, it is not possible to estimate air quality for both indoor and outdoor air prior to the recent air sampling during the IA. Presently, the facility is no longer treating poles and had decommissioned and dismantled the treatment tank at the site. Future exposures to site-related contaminants through the air pathway are possible.

Nearby residents, workers, and trespassers could be have been exposed to certain SVOCs during the wood treatment process. Higher SVOC concentrations were detected outdoors close to the treatment area. Penta was detected in nine out of 24 air samples taken between August 23rd and 25th, 2001.

4.1.2 Surface Soil Pathway Onsite Surface Soil

A completed onsite soil exposure pathway exists currently, as well as in the past. Residents, including children, trespass on the site. Contaminants have migrated from the surface soil into the subsurface soil to 80 feet bgs. Contaminants found in the onsite surface soil include multiple metals, SVOCs, and VOCs. Residents, children, school staff, and site workers are currently being exposed and could have been exposed in the past. Penta and arsenic were found at levels higher than the health-based comparison values; therefore, the public health implications of these exposures will be further evaluated.

Trespassers on the site could come in contact with contaminated soils and be exposed to chemicals. Since children have been reported to play around the log storage area, it is likely that they are exposed to contaminants by accidentally eating contaminated soils or touching the treated logs, if any continue to remain on site. Young children and infants could be exposed to dirt that was carried home with workers and trespassers. Exposure can occur through ingestion, skin contact, or both. Offsite Surface Soil

A completed exposure pathway currently exists. Nearby residents, particularly gardeners, children playing in school playground, school teachers and staff could be exposed to soils that contain metals, chlorinated pesticides, SVOCs, and VOCs. Young children frequently put foreign objects in their mouth and some children may eat dirt. These children may be exposed to more contamination due to increased ingestion of soil. However, detected contaminants related to the wood treatment process were all lower than health-based comparison values. Future exposure to site related chemicals through offsite soil is possible but unlikely, especially considering that the facility is no longer treating poles. Without major changes in operation, such as beginning the treatment of poles again using penta, elevated future exposure to offsite surface soil is unlikely because the contaminants did not transfer offsite significantly during the past decades. Arsenic levels in nearby household and the school play area ranged from 5.7 to 8.8 mg/kg, lower than the reported background level of 9.7 mg/kg.

4.1.3 Sediment Pathway

A completed sediment exposure pathway currently exists. Sport anglers, nearby residents, and children playing along the river could be exposed to sediment containing metals, SVOCs, and VOCs. Contaminants related to site activities include two SVOCs and one VOC. The levels were a thousand to a hundred thousand times lower than the comparison values. Arsenic in sediment ranged from 5.2 to 5.7 mg/kg, similar to the sediment background of 5.3 mg/kg. Contaminated groundwater onsite in general flows towards and eventually enters the Pend Oreille River. This may influence future sediment contamination. Future exposure to contaminated sediment is possible but unlikely because the site contaminants did not migrate significantly over the years.

4.2 Potential Exposure Pathways

A potential exposure pathway is defined as one where exposure could be possible except that one or more of the five elements is missing. In some cases, this means that the exposure is not possible now but may be possible in the future. In other cases, an exposure may be possible but cannot be confirmed because data are not available. The potential pathways for the Oldtown site are summarized in Table 4.

Table 4.

Potential Exposure Pathways
Source Media Point of Exposure Route of Exposure Exposed Population Time Status
Poles, Inc.groundwaterresidentialwells eating
skin contact
people who usewells as drinkingwaterPastpotential
Poles, Inc.surface waterPend OreilleRiverskin contactrecreationalsportsmen, childrenplaying along theriverPastpotential
Poles, Inc.biotafisheatingconsumers of fishor other water biotaPastpotential

4.2.1 Groundwater

A potential groundwater exposure pathway exists for individuals who use private wells as their drinking water source. However, most people obtain drinking water from the Oldtown/Newport combined public water supply system. The municipal water supply system serves about 2250 people in the Oldtown and Newport area. It uses surface water from a spring approximately 1.5 miles south (up stream) of the site as the primary water source. When additional capacity is required, eight municipal wells located approximately 0.75 miles southwest (up gradient) of the site may be blended with the surface water. EPA estimated about 30% of the public drinking water is coming from groundwater (EPA 2002a). The public water system discontinued using water from the West Bonner Public Well after IDEQ's July and September 1994 sampling results indicated the presence of trichloroethylene in well water (Lyon 2002). However, trichloroethylene is not likely to be an Oldtown site-related contaminant.

Well logs maintained by Idaho and Washington indicate that there are 46 domestic wells within a 1-mile radius and 530 domestic wells within a 4-mile radius of the site. It is not known if those domestic wells are drawing groundwater from the same aquifer as EPA's monitoring wells or if those private wells are impacted by the groundwater contamination onsite. Since none of the private wells are located down gradient of the Oldtown site (EPA 2002a), the wells are not likely to be impacted. However, domestic wells were not sampled during the START IA and the exposures cannot be determined. BEHS recommends that further groundwater monitoring be conducted at the site and that a beneficial well use survey be conducted to determine if site contamination is migrating off site and if there are any private drinking water wells located down gradient of the site.

4.2.2 Surface water

A potential surface water exposure pathway exists for individuals who come in contact with the river. Those individuals include recreational sportsmen and children playing in the Pend Oreille river. The River is used as a source of drinking water and recreational boating and fishing. There are three water intakes within 15 miles upstream of the facility. No surface water is taken as a drinking water source within 15 miles downstream of the site. Site-related contaminants were found in groundwater that flows toward and may be entering the river. If penta migrates into surface water, it will undergo biotransformation and photolysis (breaking down by sunlight). Penta is more likely to be absorbed into the sediment than to stay in water or volatilize into air. The river sediment showed low levels of site-related contaminants. Exposure to penta through contacting surface water is unlikely.

4.2.3 Biota - fish and other water organisms

A potential exposure pathway exists for individuals who consume biota such as fish and other water organisms from the Pend Oreille River. Those individuals could include sports fishermen and their families and friends who share the catch. EPA does not know how much fish is caught near the site for human consumption from the river. In this case, it is unlikely that significant amount of penta would accumulate in fish caught from the Pend Oreille River. Penta is less likely to stay in river water than in sediment, and the river sediment showed low levels of site-related contaminants.

4.3 Eliminated Pathways

Eliminated exposure pathways are defined when exposure is unlikely and that one or more of the five elements ((1) a source of contamination; (2) transport through an environmental medium; (3) a point of exposure; (4) a route of human exposure; and (5) an exposed population.) is missing. This means that the exposure is not possible now and it is not likely to be possible in the future. The eliminated pathways for the Oldtown site are summarized in Table 5.

Table 5.

Eliminated Exposure Pathways
Source Media Point of Exposure Route of Exposure Exposed Population Time Status
Poles, Inc.onsitesubsurfacesoilPolesproperty skin contact
workers during siteconstruction (ifany)Pastpotential
Poles, Inc.dust wipesamplesschool;possiblynearbyresidence eating
skin contact
residents, schoolchildren, teachersand staffPasteliminated

4.3.1 Subsurface Soil

Exposure to onsite subsurface soil is highly unlikely for the general population. It was only possible for workers during past construction activities. It is not know if this activity existed. The current and future exposure pathways to subsurface soil for the public are eliminated.

4.3.2 Indoor Dust

Three wipe samples were collected in Classroom 1 of Idaho Hill Elementary by START during the IA. START did not find any detectable contaminants in the dust wipe samples. The exposure pathways through indoor dust are eliminated.

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