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Idaho Pole Co.
|Site Type: Final NPL
Street Address: Cedar St.
ZIP Code: 59715
EPA ID: MTD006232276
Site Aliases: Idaho Pole Company
Congressional District: At Large
Updated August 2014
Pursuant to an EPA-approved In-situ Enhanced Biodegredation Pilot Study Work Plan, field work was performed on May 28–29, 2014. This involved drilling three injection wells upgradient of the Bark Filled Extraction Gallery, located just south of Interstate 90. This area has continually had the highest levels of pentachlorophenol (PCP) in the groundwater at the Idaho Pole Co. site. The work plan details proposed methods to be used for evaluating the effectiveness of two remedial technologies for enhancing aerobic degradation for treatment of PCP in groundwater.
Additional soil borings were also installed between the bark fill extraction and injection galleries to determine if any contamination remains. Residual contamination was encountered at the groundwater interface in a couple of these borings. Based on observations made during this field work, the Idaho Pole Co. submitted an amended In-situ Enhanced Biodegredation Pilot Study Work Plan, which is posted in Site Documents. An additional investigation were completed on August 13 and 14, 2014. The objective of the additional investigation is to further evaluate the extent of subsurface impacts and source material that may still exist in the area.
The Idaho Pole Co. (IPC) wood treating facility began operation in 1945 using creosote to preserve wood. In 1952 the company switched to pentachlorophenol in carrier oil (similar to fuel oil) for the wood treating solution. Site processes included pole treatment in butt vats with later addition of pressurized heated retort equipment in the area south of Cedar St. Treated poles were stacked for drying and shipment in the area. Burlington Northern operated a railroad roundhouse where wood treating chemicals and timber were shipped in and treated poles were shipped out of the site. Pole treatment processes included pole peeling with a bark-fill area for wood waste north of Cedar St. The current I-90, including surface water culverts, was constructed some time after wood-treating activities commenced at the site. In 1975 a pressurized heated retort was added for treating full length poles. The pole-length vats were removed in the early 1980s. There was also a drying area where treated poles were stored prior to shipment. IPC continued wood treating with a pressurized heated retort and butt-dipping vat until September 1997 when the company ceased wood-treating operations.
In 1978, the Montana Department of Fish, Wildlife and Parks notified the Montana Department of Health & Environmental Services (MDHES) of a suspected release of oily wood treating fluid from the plant. MDHES found evidence of a release in ditches near the facility and near Rocky Creek. Consequently, MDHES issued a compliance order on September 29, 1978, notifying IPC of statutory violations and directing the company to stop uncontrolled releases and to clean up spilled treating fluid. The company built an interceptor trench along a portion of the property line to halt some of the pentachlorophenol (PCP) from entering the groundwater. In 1983, EPA and the state sampled the trench and found that PCP was moving away from the plant. EPA proposed the facility for the National Priorities List (NPL) in 49 FR 40320 of October 15, 1984. The listing was final on June 10, 1986 in 51 FR 21054.
The Idaho Pole Co. Superfund Site is located near the northern limits of Bozeman, Montana, in the east half of Section 6 and the west half of Section 5, Township 2S, Range 6E of Gallatin County. The site includes about 75 acres, of which approximately 65 acres are owned by Idaho Pole Co. A small section of I-90 (transects the property. The area to the south of I-90 consists of 41.4 acres and is currently zoned M-2 (heavy industrial). This southern portion of the property is bound by Montana Rail Link (MRL) tracks to the south, an old MRL rail spur and the Montana Ready Mix and Crane Service Company to the east, I-90 to the north, and residential property, "L" Street and commercial property (Empire Building Materials) to the west. The property is bisected by Cedar Street, which runs east-west across the property. According to the City of Bozeman, the planned future land use for that portion of the property is industrial. Significant remaining features of the property include offices, groundwater extraction and injection galleries, monitoring wells, a water treatment building and areas where treated soils have been left in place.
The property to the north of I-90 comprises 32.8 acres. This area contains property owned by Idaho Pole Co. and Northwestern Energy. It is bound by Bohart Lane and I-90 to the south, Rocky Creek to the east, and residential property to the north and west. "L" Street runs along the western edge of the property, bisecting the northwestern comer of the property. The existing zoning for the area north of I-90 is a mixture of manufacturing and residential. According to the city of Bozeman, the planned future land use is industrial and residential.
The Idaho Pole Company was founded in 1946 and is privately owned by McFarland Cascade Holdings, Inc. (MCHI). On November 30, 2012, MCHI was bought by Montreal-based Stella Jones, Inc. However, the McFarland family has retained the Idaho Pole properties located in Bozeman and assigned a new project manager to the site; see Site Contacts below.
Map of Superfund site boundary, February 26, 2007
The main reason for putting this site on the NPL was that groundwater beneath the site had become contaminated with oily wood-treating fluid that had spilled, dripped or discharged onto the ground surface. The oily wood-treating fluid migrated downward, contaminating the soil that it passed through, and entered the groundwater. Some of this fluid made its way to the surface of groundwater, and some of the fluid attached to soil particles above and below the water table. And a portion of this fluid dissolved in groundwater, where it migrated down-gradient toward potential human and ecological receptors, preventing the groundwater from being used for its designated classifications, beneficial uses and specific standards. The current site risks include someone using the contaminated water for potable use and trespassers encountering active components of the groundwater remedy. However, institutional controls are in place to prohibit groundwater use and fences have been placed around the active groundwater remedy components to restrict access.
|Media Affected||Contaminants||Source of Contamination|
|groundwater, soils||pentachlorophenol (PCP), polycyclic aromatic hydrocarbons (PAHs) and dioxins/furans||wood-product treatment|
A Record of Decision (ROD) selecting the site remedy was issued in September 1992 and subsequent Explanations of Significant Differences (ESDs) issued in 1996 and 1998. The ROD identified PCP, PAHs, polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (dioxins/furans) as contaminants of concern and identified soil and groundwater contamination as a single operable unit. The ROD established performance standards for those contaminants of concern at the site for both soil and groundwater that was predicated on the fact that long-term groundwater protection could only be achieved if the soil, acting as a source of contamination, no longer contributed contaminants to the groundwater and also that the existing groundwater be treated until performance standards are met.
The objective of the response actions implemented in the 1992 ROD as well as subsequent ESDs was to alleviate the primary threats to human health and the environment posed by contaminant sources and contaminant migration. Specifically, the response actions proposed for the site by EPA and the Montana Department of Environmental Quality (DEQ) were designed to prevent human exposure to contaminated soils by treating contaminated soils in a lined land treatment unit (LTU). The protection of the environment was to be accomplished through contaminant source removal and treatment as well as the cleanup of contaminated groundwater through an enhanced in-situ biodegradation process.
The Idaho Pole Co. began the soil excavation portion of the cleanup in 1995. The company dug up soils and constructed a land treatment unit. Contaminated soils were excavated from six areas at the site: the Pressure Plant Area, beneath Cedar Street, the Barkfill Area, the Roundhouse Area, the Cedar Street Ditch and the Pasture Area. In the summer of 1999, the company demolished and disposed of structures, and excavated additional contaminated soil from underneath the demolished structures. Approximately 24,000 cubic yards of contaminated soil were excavated and placed in the LTU for treatment. Normal LTU operations continued through October 2000 and then ceased, when the ROD performance standards for PCP and PAHs were determined to have been met. Two pits were then excavated on-site and the treated soil, along with the filter sand from the LTU, was placed in each of the pits and covered with 12 inches of clean fill to prevent direct contact. All the construction requirements for treatment of the soils at this site have been met as described in the Preliminary Site Close Out Report dated March 21, 1998 and the Remedial Action Completion Report dated December 23, 2002.
The groundwater remediation consists of an extraction/injection system with carbon treatment and an in-situ bioremediation component. The system began operation in February 1997 and approximately 510 million gallons have been processed by the groundwater recovery system through December 2013. A down-gradient product recovery trench is used to recover oily residue at the surface of the groundwater. Both systems are operating as designed and continue to remove contaminants from the groundwater. A series of wells are monitored semi-annually. Eight residential wells down gradient are tested for PCP annually. Test results from the residential well monitoring program indicate that contaminants have not been detected in residential wells at reported detection limits since sampling began in the 1990s. One residential well is sampled semi-annually because PCP concentrations are detected. However, this property is owned by IPC and the water is not used. Overall, approximately 56 pounds of PAHs and 284 pounds of PCP have been removed from the groundwater since start up in 1997. Groundwater data collected since 1997 and modeling done in 2007 demonstrate that the overall mass of the groundwater plume has decreased significantly since implementation of the remedy. The groundwater component of the remedy at the Idaho Pole Co. site is protective of human health and the environment.
The 2013 Groundwater Assessment Report has been reviewed and approved by EPA and the Montana Department of Environmental Quality (DEQ). The report is available in Site Documents below.
Community involvement plays an important role in the Superfund process. EPA uses a number of different tools and resources to promote effective, on-going, meaningful community involvement. The goals of the Superfund community involvement program are to:
- Keep communities affected by sites informed throughout the cleanup process.
- Provide opportunities for communities to comment and offer their input about site cleanup plans.
- Facilitate the resolution of community issues tied to a site.
EPA and DEQ updated the Gallatin Local Water Quality District Board during its monthly meeting on June 5, 2014. A copy of the presentation is posted in Site Documents.
EPA places a high priority on land reuse as part of its Superfund response program mission. The agency tries to select cleanup options that encourage and support future use of a site. EPA uses two fundamental methods to facilitate reuse of Superfund sites:
- Exploring future uses before the cleanup remedy is implemented, an approach that gives the Agency the best chance of designing cleanup remedies to support the likely future use of a site.
- Working with landowners and communities to remove barriers not considered necessary for the protection of human health or the environment at those sites where remedies are already in place.
One option for reuse is the siting of clean and renewable energy projects on contaminated (or formerly contaminated) lands. As part of this effort, EPA is evaluating the potential for energy projects on these properties and working with landowners and communities to identify ways to remove barriers to such projects.
Approximately 41 acres of vacant property located south of I-90 has been cleaned up and institutional controls have been placed on this property. EPA supports reuse of the Idaho Pole Co. site and is working cooperatively with all stakeholders to ensure that this property is put back to productive use. Superfund redevelopment helps communities return some of the nation's worst hazardous waste sites to safe and productive uses. In addition to cleaning up these Superfund sites and making them protective of human health and the environment, EPA is working with communities and other partners in considering future use opportunities and integrating appropriate reuse options into the cleanup process. EPA is also working with communities at sites that have already been cleaned up to ensure long-term stewardship of site remedies and to promote reuse.
Additional information about reuse and redevelopment of Superfund sites can be found at www.epa.gov/superfund/programs/recycle/.
After implementation of the institutional controls described below, EPA was able to make a Sitewide Ready for Anticipated Use determination for the site.
Idaho Pole Co.: Reuse Fact Sheet, September 2013
Land use controls are the most common type of institutional control (IC). ICs are administrative or legal controls that help reduce the likelihood for human exposure to contamination. ICs can also help protect the integrity of the remedy. Examples of ICs are:
- Zoning ordinances.
- Environmental covenants.
- Deed notices.
- Well-drilling restrictions.
- Building permits.
- Informational advisories.
A Controlled Groundwater Use Area (CGA) was issued by the Montana Division of Natural Resources (Decision 41H-114172) in 2001 pursuant to Section 85-2-506 and 508, Montana Code Annotated. This CGA restricts use of groundwater beneath the site for any purpose, except as provided in the remedial action or as otherwise authorized by EPA and DEQ. The CGA process allows for a description of the restrictions, and the restriction provided reads as follows: "No new wells within CGA except for remedial action activities. Complete restriction of groundwater use within the area except for remedial activities." The CGA does not distinguish between shallow and deeper groundwater, or groundwater in deeper aquifers.
As part of the CGA, a buffer zone was determined by conducting a capture zone analysis using site-specific aquifer parameters and the groundwater flow model, MODFLOW. The capture zone analysis included a hypothetical well with varying pumping rates and permeabilities representative of site conditions. The maximum capture zone included in the CGA was based on a 500-gallon-per-minute well and high permeability conditions. The resulting buffer zone included a distance of 170 feet upgradient and 320 feet cross-gradient from the source of PCP that exceeded the cleanup levels established in the ROD. While only a portion of the property south of I-90 is within the calculated capture and buffer zone, the original CGA includes all of the IPC property, including areas upgradient of the historic impacts and the buffer zone. This upgradient portion was included due to waste management practices on the property such as an active LTU at the time the CGA was established. These activities have since been completed and sampling results indicate the soil and groundwater upgradient of historic impacts are below cleanup levels established in the ROD. EPA and DEQ are currently working with the stakeholders to reduce the size of the CGA in the portion of the property south of I-90 to facilitate redevelopment.
Contaminated soil excavated from the site was successfully treated and then used as backfill in several areas on IPC property. Treated soil was placed above historic high groundwater levels and covered with a minimum of 12 inches of fill material to prevent direct contact risk. Areas where the treated soil was placed are restricted use areas and a survey has been completed to identify these areas. On September 13, 2010, the Idaho Pole Co. filed a Notice of Institutional Control (deed notice) with the Gallatin County Clerk and Recorder. The following covenants, conditions and restrictions were placed on the property south of I-90 and are binding on the owner, its successors and assigns:
- Restriction on New Construction. No new Construction, other than surface paving, landscaping curbs, light standards, traffic signs and greenways, shall take place on the Treated Soil Areas (TSA), except as provided in the Remedial Action or as otherwise authorized by EPA and DEQ.
- Restriction on Excavation within the TSAs. No excavation deeper than 12 inches shall take place on the TSAs, except as provided in the Remedial Action and described in the December 23, 2002 "Remedial Action Completion Report Idaho Pole Company Superfund Site Soil Remediation Phase" or as otherwise authorized by EPA and DEQ. Owner, its successors and assigns, shall maintain a protective cover of at least 12 inches of clean soil over the TSAs. A 12 inch gravel layer, gravel and asphalt overlay, or other cover that prevents erosion and which maintains the integrity of the remedy can be substituted for clean soil. In the event that soils within the TSA must be disturbed at or below 12 inches and approval has been granted by EPA and DEQ, Owner must comply with a soils and groundwater management plan that is approved by EPA and DEQ. Soils and groundwater management plans should provide guidance on health and safety precautions required to protect human health and the environment.
- Restriction on Excavation within Controlled Ground Water Area. In addition to the restriction on excavation within the TSAs, above, no excavation shall be allowed on the Property within CGA where that excavation reaches saturated soil or groundwater, except where the Owner meets the requirements of CERCLA, as amended, 42 U.S.C. § 9601, et seq.; CECRA, as amended, Title 75, Chapter 10, Part 7 MCA, including Section 75-10-727 MCA, and Title 85, Chapter 2, Part 5 MCA, including Sections 85-2-506 and 508, MCA (pertaining to Controlled Ground Water Areas) and the Occupational Safety and Health Administration, including 29 C.F.R. 1910.120 et seq.; and where the excavation is accomplished in compliance with the site soils and groundwater management plan or except as otherwise authorized by EPA and DEQ.
- Restriction on Use of Ground Water. Ground water within the boundaries described by the CGA shall not be used or developed for any purpose, except as provided in the Remedial Action or as otherwise authorized by EPA and DEQ.
- Protection of the Integrity of Remedial Action. Use of the Property shall not in any way materially interfere with the operation and/or maintenance of the Remedial Action, including, but not limited to, access to and the operation and maintenance of ground water monitoring wells, injection and extraction wells, any equipment or infrastructure constructed or used for the Remedial Action, or any cap or other covering to prevent contact with residual contamination, except as otherwise authorized by EPA and DEQ.
A Soil Management Plan has also been developed and approved by EPA and DEQ in March 2011. The plan identifies general precautions and procedures to protect human health and the environment from hazardous substances at the site. A more detailed soils and/or groundwater management plan must be submitted to and approved by EPA and DEQ prior to beginning any activities at the site that would disturb materials deeper than 12 inches within the treated soils area or that would involve saturated soil or groundwater within the controlled groundwater use area.
EPA and DEQ have determined that, with implementation of this Notice of Institutional Controls on the property, all appropriate Remedial Actions under CERCLA, other than five-year reviews and operation and maintenance, have been completed for the surface and unsaturated subsurface soils on all the property. EPA and DEQ have also determined that contaminated soil excavated from the property has been successfully treated, and the treated soil has been placed as backfill in several areas comprising 4.1 acres on the property south of I-90. This deed notice contains the covenants, conditions and restrictions that apply to the use of the property, run with the land and are binding on the owner, its successors and assignors.
The Gallatin City-County Health Department has raised concerns about the site and asked that their concerns be addressed before any proposed changes to the CGA will be supported. These concerns are summarized in a letter posted in the Institutional Controls area of the Site Documents section below.
EPA or the lead agency conducts five-year reviews following the start of a Superfund cleanup when contamination is left on the site. These reviews are repeated every five years. We use these reviews to determine:
- How the remedy is working.
- If the remedy remains protective of human health and the environment.
The third five-year review of the remedial actions at the Idaho Pole Co. site was completed in September 2010. It resulted in the determination that the remedial actions are protective of human health and the environment in the short term. Several issues are identified where some follow-up action is needed before the site is determined to be protective of human health and the environment in the long term. These remaining issues that still require action include:
- Evaluate the potential for reducing the extent of some portions of the Controlled Groundwater Use Area.
- Update the Sampling and Analysis Plan to lay out an appropriate statistical test for when a portion of the site is determined to be clean.
- Evaluate whether changes to the soil remedy are appropriate once Interim Preliminary Risk Goals in soil for dioxin are finalized.
The third five-year review report was released in September 2010. The next five-year review will be completed by 2015.
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Proposed In-situ Enhanced Aerobic Degradation Pilot Study Work Plan, amended July 2014
Explanation of Significant Differences (PDF), November 27, 1998(8 pp, 42K)
Explanation of Significant Differences, May 21, 1996
Record of Decision, September 28, 1992
Update to the Five-Year Review, January 2011
Third Five-Year Review Report, September 2010
Idaho Pole Fact Sheet, December 2009
Concerns about the Controlled Groundwater Area, July 3, 2012
Soil Management Plan, March 2011
Notice of Institutional Controls, September 9, 2010
Designation of a Controlled Groundwater Area, November 30, 2001
2013 Groundwater Assessment Report, March 2014
Remedial System Evaluation: Final Report, February 11, 2010
Remedial Action Completion Report, December 23, 2002
Preliminary Site Close Out Report, March 21, 1998
Remedial Investigation Report, March 1992
Remedial Project Manager
U.S. Environmental Protection Agency,
Region 8, Montana Office
10 West 15th Street, Suite 3200
Helena, MT 59626
866-457-2690 (toll free)
Idaho Pole Co.
5501 Pacific Highway E., Suite 2
Fife, WA 98424
253-922-4902, ext. 351
Montana Department of Environmental Quality
1100 North Last Chance Gulch
P.O. Box 200901
Helena, MT 59620-0901
800-246-8198 (toll free in-state only)
City of Bozeman
Director of Economic Development and Community Relations
City of Bozeman
Site Information Repositories:
Bozeman Public Library
626 East Main
Bozeman, MT 59715
EPA Superfund Records Center
10 West 15th Street, Suite 3200
Helena, MT 59626
866-457-2690 (toll free)
Hours: M-F, 8:00 a.m.-4:30 p.m.
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