Field Office Compliance - Assistance

Assistance ID - 67486
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
2/27/2014 From: Miller, David [DNR] Sent: Thursday, February 27, 2014 2:36 PM To: [email protected] Cc: Vansteenburg, Jeff [DNR] Subject: Pressure washing of metals from Northwood fire Mr. Eastman - This email follows up on our discussion today regarding the efficacy of pressure-washing metals from the subject incident. I understood your position to be that it may be infeasible to pressure-wash the metal, and that you intend to do wipe testing of the burned equipment and building material in an attempt to demonstrate that the pressure-washing need not be done. The basis for DNR’s requirement that metals involved in hazardous materials incidents be pressure-washed, and the rinsate collected, is that it is important to ensure that surface contamination is properly removed before the metals are introduced back into the community. I am not aware that there is a standard test for combustion byproducts of agricultural chemicals, nor am I aware that there are generally accepted risk-based standards which can be used to evaluate the results of such testing. DNR does not have the toxicological expertise to evaluate whether any particular wipe test result poses a risk to the community. If you desire to make the case that the metal can be tested and those results used to demonstrate that it need not be cleaned, you should test for combustion byproducts of those compounds on your chemical inventory list. Be advised that DNR is not prepared to interpret the results of the wipe testing, and you should engage a qualified consultant to interpret the analytical results, and be on record with a credible opinion of whether the test results do or do not warrant cleaning of the metal. If it is infeasible to pressure-wash the metal, DNR would prefer an alternative method of cleaning be employed. However, we can rely upon risk analyses made by qualified professionals when the data is provided to us. DAVID MILLER Environmental Specialist Senior DAVID MILLER
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