Field Office Compliance - Assistance

Assistance ID - 67430
Northwood Ag. Products, Northwood - 311907005
2106 Central Avenue East Northwood, IA 50459
Worth County

FO 2

Report
File Name File Type File Date Note
Comments
2/26/2014 I attended a meeting at Northwood Ag products on 25FEB14 to discuss the cleanup of the agricultural chemical warehouse that burned on 20FEB14. Attending were Steve and Deanna Eastman (owners of Farmers Feed and Grain and subsidiary Northwood Ag Products), Dean Eastman (employee of Farmers Feed and Grain), Tim Berge (Manager of Northwood Ag Products) and Zach Tesar (representing Austin Mutual Insurance Company). I explained the geology of the area (sand with a shallow ground-water table) and noted that there were nearby shallow wells in use. I indicated that DNR was quite concerned about ground-water contamination from the remnants of the burned building and residual chemicals in the frozen firefighting water. I stated that remedial measures must be urgently implemented to prevent any runoff or infiltration of contamination. Mr. Tesar indicated that Austin Mutual Insurance does not choose contractors or manage projects of this sort, so Mr. Eastman would be responsible for choosing a remediation contractor and running the project. Mr. Tesar also asked that DNR provide a written request to proceed with the cleanup, as that would trigger the insurance coverage. I stated I would do so. I was asked to recommend a remediation contractor and I declined, stating that DNR could not endorse any particular firm. I did, however, indicate that the chosen firm must have properly trained employees to comply with OSHA 1910.120 HAZWOPER requirements. I was asked what, specifically, the remedy should be. I stated that DNR would rely upon the experience of the remediation contractor to determine how precisely to go about the work, but DNR would establish performance standards for the remedy. I indicated that the most urgent project performance standard would be to ensure that the frozen firefighting water and associated chemicals did not thaw and seep into the ground, and this might be approached by removing the ice or building some type off runoff containment around the building. Several ideas were discussed, but I was clear that Mr. Eastman should finalize the specific approach with his chosen remediation contractor and that DNR’s role would be to ensure the approach met the project performance standards. (continued below) DAVID MILLER
2/26/2014 (25FEB14 meeting notes continued from above) I stated that it was urgent that the clean up process begin immediately because some mitigating measures should be in place before the next thaw, when contaminants would start to mobilize. Mr. Tesar noted that proceeding with haste could incur additional cost, with which I agreed. I then pointed out that, if contaminants were allowed to infiltrate into the soil, there would be additional soil testing and remediation required, and possibly a ground-water investigation and remediation, the costs for which would far outweigh any rapid mobilization costs to get some mitigating measures in place. I also stated that DNR would require some sort of sampling regimen to ensure the remedy had been effective, and that it could consist of soil sampling, ground-water sampling or both. Mr. Eastman indicated that he understood the urgency of the project and would proceed immediately to select a remediation contractor. I indicated that I was available to consult during the project planning and would attend any project meetings upon request. I asked for, and received, an inventory of chemical that had been in the burned building (attached). I asked to see the Spill Prevention, Control and Countermeasure (SPCC) Plan for the facility and was shown some written spill response procedures. I noted that these did not meet the SPCC requirements under 40 CFR 112.3, noting that there was no secondary containment specifications in the policies and it was not certified by a Professional Engineer or self certified as required in the Rule. DAVID MILLER
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