HomeMy WebLinkAbout6.p. Minnesota Department of Health’s Public Health Assessment of the Former Gopher Ordinance Works � ROSEMO[..I1�1T EXECUTIVE SUMMARY
tITY COUNCIL
City Council Regular Meeting: November 18, 2014
AGENDA ITEM: Minnesota Department of Health's Public AGENDA SECTION:
Health Assessment of the Former Consent
Gopher Ordnance Works
PREPARED BY: Eric Zweber, Senior Planner AGENDA NO. �
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ATTACHMENTS: Public Health Assessment Comments;
Public Health Assessment APPROVED BY:
Recommendations
RECOMMENDED ACTION: Motion to Authorize staff to Submit Public Health Assessment
Comments to the Minnesota Department of Health
SUMMARY
The Minnesota of Department of Health (MDH) has received funding from the US Department of Health
and Human Services to perform a Public Health rlssessment (I'HA) of the former Gopher Ordnance
Works. MDH staff has stated that there was no new investigation as part of the PHA. Further, staff notes
that the PHA evaluates previous environmental investigations,predominately Barr Engineering's UMore
East Remedial Investigation Report, UMore Mining r,rea Environmental Impact Statement, and
Vermillion Highlands Propexty Environmental Site Assessment;United States Army Corps of Engineers'
Former Gopher Ordnance Works Final Focused Site Inspection Report; and the United States
Environmental Protection Agency's Rosemount Research Center Superfund Record of Decision.
r,ttached to this Executive Summary is the draft City comment letter. The first four bullets have been
prepared by City staff and the final three bullets have been suggested by Councilmember Demuth. Staff's
comments are requesting clarification of the recommendations and their titnirig;while Councilmember
Demuth's comments are to clearly state that the City has land use authority and a several more technical
comments.
City staff has requested Dakota County's comments regarding the PHA. At this time, Dakota Count�r staff
has not completed their comments and they have stated that it is unlikely that they would be completed by
the November 18 City Council meeting. The comment period ends November 24, 2014, and therefoxe
Rosemount cannot wait until the County comments are available to take action. Dakota County staff
verbally indicated that they are generally supportive of the PHA and that since the PHA reviews previous
environmental analysis,it is likely that Dakota County's comments will be similar to comments previously
pYOVided by Dakota County.
RECOMMENDATION
Staff recommends that the City Council authorize staff to submit comments regarding the Minnesota
Department of Health's Public Health Assessment.
November 18, 2014
Community Relations Coordinator
Site Assessment and Consultation Unit
Minnesota Department of Health
625 North Robert Street
PO Box 64975
St. Paul, MN 55164-0975
RE: Former Gopher Ordnance Works Public Health Assessment
Dear Department of Health:
The purpose of this letter is to submit comments and questions to the Department of Health from
the Ciry of Rosemount on the public comment release revision of the Former Gopher Ordnance
Works Public Health Assessment. We have reviewed the Public Health Assessment and appreciate
the opportunity to provide feedback. The City of Rosemount's comments are as follows:
• There appears to be no independent or additional investigation conducted within this Public
Health Assessment (PHA). The PHA appears to review the investigations of past
environmental revie�vs, predominately Barr Engineering's UMore East Remedial
Invesrigarion Report, UMore I�Zining Area Environmental Impact Statement, and Verinillion
Highlands Property Environmental Site Assessment; United States Army Corps of
Engineers' Former Gopher Ordnance Works Final Focused Site Inspection Report; and the
United States Environmental Protection r�gency's Rosemount Research Center Superfund
Record of Decision. If there are any new investigations conducted or new data provided as
a part of this PHA, please clearly indicate that�vithin the PHr1.
• The PHr� identifies many contaminants, provides some suggestions on common sources of
these contaminants,but the PHA does not determine the party that is responsible for the
contamination. The City requests that the Minnesota Pollution Control Agency and/or the
United States Environmental Protection Agency determine the appropriate Responsible
Party(ies) accountable for the contamination and ensure that the Responsible Party(ies)
conduct and/or pay for the appropriate environmental remediation.
• The PHr,provides 23 recommendations and a four (4) point Public Health Action Plan, but
does not prioritize the recommendations or action points. Please provide guidance on the
implementation of these recommendations including priorit��, ranking, order of
implementation, tiining or trigger that would require the implementation of the
recommendation(s).
• The third point of the Public Health r�ction Plan states the "MDH�vill communicate with
the communit��". In addirion to communication, the Cit��requests that the I�iinnesota
Department of Health, the University of 1�linnesota and all other agencies�vith jurisdiction
over the former Gopher Ordnance Works consult with and notify the City of any new
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detection of contamination or any planned environmental remediation. Please identify the
process by which the Minnesota Department of Health and the Minnesota Pollution Control
Agency will engage the City in future activities.
• As stated in the report, extensive redevelopment is planned for much of the site. The City
of Rosemount has land use authority and must make land use decisions consistent with the
level of contamination. Until a full investigation of the site,which may be conducted in
phases,is complete the site the must be maintained to provide foY the health, safety and
well-being of Rosemount citizens as well as our police and fire personal. CERCLA and
MERI.r� must be followed, in order for developers to have confidence in the process that
will be taken for the investigation and cleanup of the property.
• The city may site a municipal water supply well at UMore in order to meet water demands
when development occuxs (Alternative UYban Areawide Review UMore Study Area August
21, 2013 page 61 Scenario 1 Alternative 2). Due to data gaps in the ground�vater
information it is uncertain if the water quality will meet drinking water guidelines. The PHA
should recommend the construction of monitoring wells to determine the water quality in
the Prairie du Chien and Jordan Aquifers in the vicinity of the potential site of the well, to be
located West of Akron Avenue, southwest of Minnesota Unique Well Number 767876 on
Figure 21.
• The USEPr� (2012) states "The sand and gravel aquifer is underlain by fractured dolomite
(in some areas separated from the sand/gravel by clay�s). The dolomite is hydraulically
connected to the underlying Jordan Sandstone, a�vater-bearing unit or aquifer." The PHA
should recommend that a thorough hydrogeologic assessment be conducted in order for the
city to understand the vulnerability of the Jordan Aquifer to contamination.
We thank you for the opportuniry to comment on the Public Health Assessment. We look forward
to�vorking�vith the Minnesota Depaxtment of Health and all other agencies�vith jurisdiction over
the former Gopher Ordnance Works on redeveloping the site into a miYed use development within
Rosemount that is healthv for our residents and businesses.
Sincerely,
William H. Droste
Mayor
cc: Gary Krueger, Minnesota Pollution Control Agency Superfund Project Manager
Georg FischeY, Dakota County Environmental Resources Director
Dale Glowa, UMore Development LLC President
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u ic ea t
ssessment
. . .
Former Gopher Ordnance Works
ROSEMOUNT, DAKOTA COUNTY, MINNESOTA
EPA FACILITY ID: MND980613780
Prepared by
Minnesota Department of Health
SEPTEMBER 24, 2014
COMMENT PERIOD ENDS: NOVEMBER 24, 2014
Prepared under a Cooperative Agreement with the
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Agency for Toxic Substances and Disease Registry
Division of Community Health Investigations
Atlanta, Georgia 30333
I. Summary
INTRODUCTION The Minnesota Department of Health's(MDH) mission is to protect, maintain,
and improve the health of all Minnesotans. For communities living near state
or federal Superfund sites, MDH's goal is to provide health information the
community needs to take actions to protect their health. MDH also evaluates
environmental data, and advises state and local governments on actions that
can be taken to protect public health.
The Minnesota Pollution Control Agency(MPCA) asked the Minnesota
Department of Health (MDH)to review environmental data for the former
Gopher Ordnance Works (GOW)site and evaluate potential public health
concerns.
The former GOW site, located in the City of Rosemount in Dakota County,
Minnesota was constructed and operated by the federal government during
World War II for the production of smokeless gunpowder and nitric and
sulfuric acids. Following decontamination and demolition activities by the
federal government, portions of the site were purchased by the University of
Minnesota in 1947-1948. Since that time,the property has been used for a
variety of purposes by the University and their tenants. As a result of the
historic uses of the property, physical and chemical hazards are present at the
site,which have been evaluated in a series of site investigations starting in the
1980s.
Extensive redevelopment is planned for much of the site;as development
proceeds,additional environmental data will need to be collected to ensure
the safety of the property for future use. Many data gaps currently exist,due
in part to the large acreage of the site.
This document summarizes and catalogs information about the residual soil
and groundwater contamination in Rosemount, Minnesota, at the former
GOW site. It is written for multiple stakeholders who may be concerned about
current exposures and/or future development of the property. The residents
of Rosemount and nearby areas,the City of Rosemount, Dakota County,the
Minnesota Pollution Control Agency,the University of Minnesota,and future
residents and occupants of the site have varying interests in the site
information.
This report reviews the environmental data and relevant site history from a
large number of documents to provide recommendations and assist with
future response action and development decisions.
OVERVIEW MDH reached five major conclusions in this Public Health Assessment of the
former Gopher Ordnance Works site.
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CONCLUSION 1 MDH concluded that physical hazards are the most important public health
hazard on the site.
Basis for conclusion Crumbling building foundations and other ruins from the former GOW facilities
and debris from dump sites pose physical hazards for workers and others on
the site. The site is not fenced and evidence of trespassing was observed.
Recommendation Remove physical hazards or fence areas where they are present to prevent
injury.
CONCLUSION 2 MDH concluded that contaminated surface soil in some areas of the site pose a
public health hazard.
Basis for conclusion In limited areas of the site,concentrations of site-related contaminants in
surface soil are significantly above their respective Soil Reference Values
(SRVs)for industrial land use in these areas. Contaminants include lead,
carcinogenic polycyclic aromatic hydrocarbons (cPAHs),and polychlorinated
biphenyls (PCBs). Exposure to the contaminants may be occurring. Exposure
to these soils is expected to be limited mainly to onsite workers.
Recommendations 1. Remove and properly dispose of soils in selected areas that exceed the
industrial SRVs.
2. Notify tenants in affected areas of the contamination in the vicinity of their
rented properties.
CONCLUSION 3 MDH concluded that contaminated soils in some areas of the site pose an
indeterminate public health hazard.
Basis for conclusion Concentrations of site-related contaminants in soils exceed industrial and/or
residential SRVs. Contaminants include lead, mercury, arsenic,cPAHs, and
PCBs. Asbestos-containing building material debris was found in some areas of
the site.
Current exposure is expected to be limited in frequency and duration, but
future land uses may result in greater exposures.
Recommendations Asbestos containing building materials should be removed from the site. Soils
with contaminants exceeding the industrial and/or residential SRVs may need
to be removed and properly disposed of if future land use changes. Additional
investigation may be needed in order to determine what actions are required.
CONCLUSION 4 MDH concluded that some areas of the site have not had adequate
investigation to evaluate whether a public health hazard exists.
Basis for conclusion Several areas of the site have had very limited or no sampling.The magnitude
and extent of contamination, if present, is unknown.
Recommendation More data may be needed prior to development of these areas including
public recreational areas in the Vermillion Highland portion of the site.The
data will provide more confidence in the suitability of the site for public use.
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CONCLUSION 5 MDH concluded that groundwater poses an indeterminate public health
hazard.
Basis for conclusion There are no known exposures to site-related contaminants through drinking
water at this time, but there are some areas that warrant additional evaluation
to ensure groundwater contamination is not present.
Site-related contaminants have been detected in the groundwater beneath
some portions of the site and in off-site monitoring and private wells.
Sampling of site monitoring wells in 2011 and 2012 indicates that contaminant
concentrations have been decreasing over time and,with the exception of
trichloroethylene (TCE)and nitrate+nitrite,do not exceed levels of health
concern. Groundwater samples collected from soil borings in 2007 also
detected PAHs, bis(2-ethylhexyl) phthalate, 2,4,6-trichlorophenol, and diesel
range organics at concentrations above levels of health concern.
Recommendations 1. Install one additional monitoring well and complete a thorough private well
survey to more fully understand the extent and magnitude of the
contamination and the potential for exposure to groundwater contaminants.
2. Conduct vertical soil sampling in area AOC6 to determine if PAHs leached to
groundwater in that area.
3.Conduct sampling of all private wells on properties within 1,000 feet down-
gradient of the UMore East property. Test for VOCs (including 1,4-dioxane)
and metals (including antimony, cadmium, chromium,copper, lead,thallium,
and zinc).
4.Complete a thorough evaluation of all wells on the UM property and
properly seal any wells not in use.
5. MDH should continue to sample wells near the Coates Dump and test for
antimony,thallium, and VOCs, including 1,4-dioxane.
DATA LIMITATIONS Many data gaps exist at the site in part due to the large size of the
property. Portions of the site have not had adequate soil investigation to
evaluate whether a public health hazard exists. More information is needed to
better understand current land uses and potential exposures. There are a
number of wells on and near the site for which little is known regarding their
current use and water quality. Additional groundwater evaluation is
warranted.
II. Introduction
The Minnesota Pollution Contro)Agency(MPCA) asked the Minnesota Department of Health (MDH)to
review environmental data for the former Gopher Ordnance Works (GOW)site and evaluate potential
public health concerns. Soil contamination,groundwater contamination, and data gaps are discussed as
well as the potential for exposures to contaminants and impacts on drinking water resources due to
planned future development.
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• the lack of investigation of asbestos, nickel, zinc, copper,aluminum,tin, perchlorate, nitrates,
and herbicides that Barr stated were associated with GOW during an earlier critique of the
USACE's work
• the safety of the land that was recently donated to the City of Rosemount for ball fields
• the asbestos in the soil
• the failure to investigate thoroughly, and
• the site not getting cleaned up
Local news sources also reported on community discontent at the meeting(Rosemount Town Pages,
2012;Apple Valley-Rosemount Patch, 2012). The University responded to several concerns raised at the
meeting in a follow-up letter that was posted on the UMore Park Online Information Repository(UMN,
2012b).
VII. Conclusions and Recommendations
The investigations on this site have generally been targeted towards the areas where contamination is
suspected based on historical land use. All soil samples have been discrete samples, and there is
generally very little data given the large acreage of the site. For future investigations, composite or
multi-incremental sampling would allow for coverage of more land area, and more confidence that
contaminants have not been missed. The University has identified data gaps where the contamination
has not been delineated and some areas that have not been investigated. The University has stated that
additional investigation will be needed as development occurs to make sure that the land is health
protective for the desired use in the future. Although the new discovery of significant contamination is
not expected,there are many potential sub-sites that are not listed in Appendix A that may ultimately
be shown to need future remediation.
Health Hazard Conclusions:
Selected areas of the site present a public health hazard or an indeterminate public health hazard for
possible exposures to contaminated soils and physical safety hazards. Contaminated groundwater poses
an indeterminate public health hazard.An evaluation of health hazards by sub-sites can be found in
Appendix A.
Soil Conclusions and Recommendations:
• In limited areas, PCBs, lead, and cPAHs are present in surface soils above levels of concern for
industrial land use.
1) Recommendation: Remove PCBs, lead, and cPAHs that are present in surface soils
significantly above levels of concern for industrial land use to prevent exposure (see
Table 7).
• Soil near building 707FFF (currently leased as a machine shop) contains cPAHs above the
industrial SRVs (5.5, 5.7 ppm).
2) Recommendation: Remediate soil near building 707FFF to protect the tenants on the
site.
• There are no soil samples in the two residential areas on the site that are leased.
3) Recommendation: Sample the residential yards to ensure the soil surrounding the
homes is safe.
• Asbestos containing building materials are present at the site.
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4) Recommendation: Remove asbestos containing building materials present at the site.
Future development plans will need to take the potential for asbestos in soils in
consideration, especially for residential or other land uses where future soil
disturbances are likely.
• Because only seven cPAHs have been measured at the site, cPAH risk is likely underestimated.
5) Recommendation:As portions of the site are slated for redevelopment and
remediation,further investigate cPAHs with additional analytes measured or use a
mixtures approach (see discussion in section IV. C.).
• Potential still exists for the discovery of nitrocellulose grains that could be explosive.
6) Recommendation: Continue to take safety measures in areas where nitrocellulose grains
may exist.
• PCBs likely remain up to 10 ppm below the 10 inch covered areas in the former NPL areas.
7) Recommendation: PCBs in the former NPL areas will need to be addressed during
redevelopment.
• Consider dioxin/furans as a potential contaminant of concern, especially near the PCB
incineration area of the former NPL site.
8) Recommendation: Measure dioxins/furans in the soil in the PCB incineration area.
Additional Soil Recommendations:
9) Recommendation: Notify tenants near the former NPL site of the contamination in the
vicinity of their rented property.
10) Recommendation: Further soil investigation is recommended in select areas of the
Vermillion Highlands where the data are limited (see Appendix A)to provide more
confidence in the safety of the area for public use.
11) Recommendation: If the UMore site is developed into residential yards and playgrounds
for children, care should be taken to remediate soils with lead to levels lower than 300
ppm. EPA/MPCA may update their guidance on acceptable lead levels in residential
soils in the next several years.
12) Recommendation: Incorporate composite or incremental sampling in future soil
sampling to gain more confidence that contamination is not missed over large land
areas.
Groundwater Conclusions and Recommendations:
• There is no indication that site-related groundwater contaminants (chloroform,TCE, carbon
tetrachloride, PCE, 2,4-DNT) are currently adversely affecting the drinking water of nearby
residents.
• City records indicate that at least a dozen properties located down-gradient of the site are not
connected to city water.
13) Recommendation:Complete a thorough private well survey Sample any private wells
on properties within 1,000 feet of the north boundary of UMore Park for VOCs
(including 1,4-dioxane) and metals (including antimony, cadmium, chromium, copper,
lead,thallium, and zinc).
• High levels of benzo[a]pyrene (up to 490 ppm)and other PAHs exceeding the SLVs were
detected in the deepest soil samples collected by the USACE in the GOW West area/ 154`h St.
Dump (AOC-6-S-TPS and surrounding area). There are no groundwater data from this area or
directly downgradient of it. While the potential is low for PAHs to migrate as deep as the water
table,without additional information it cannot be ruled out.
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14) Recommendation: Complete vertical soil sampiing in this area to define the magnitude
and extent of soil contamination horizontally and vertically. If contaminants have
migrated downward to any significant extent install a monitoring well immediately
down-gradient of this area.
• Liquids with a "mothball" odor(likely naphthalene or a related PAH)were reported in soils
between 25-45 feet below grade in the area of former Building 237G in the ABC Line area.
There are no groundwater data from this area or directly downgradient of it. While subsequent
sampling in this area did not detect PAHs, only one deep soil boring was advanced.
15) Recommendation: Given the reported depth of the contamination observed in the initial
soil boring,the absence of any water quality data for this area, and the presence of
many residential drinking water wells less than one mile down-gradient, install a
monitoring well immediately down-gradient of the former Building 237G area to
evaluate the water quality.
• Earlier sampling events (TCT, 1985)detected trichloroethane (TCA) in on-site monitoring wells
and off-site private wells. 1,4-dioxane was commonly used as stabilizer in TCA.
16) Recommendation: Because 1,4-dioxane is more mobile and persistent than TCA, include
1,4-dioxane as an analyte in any future groundwater sampling event.
• Elevated metal levels were detected in the groundwater at the GOW Garage/GUE sub-site,
several above MDH drinking water criteria.
17) Recommendation: include antimony, cadmium, chromium, copper, lead,thallium, and
zinc as analytes in future groundwater samples collected from monitoring and private
wells located down-gradient of this area.
• Nitrates are above risk-based values in groundwater, but appear to be the result of agricultural,
rather than site-related activities.
• A number of wells reportedly are, or were, present at the site for which no current information
is available regarding their use or status. Unused, unsealed wells represent potential conduits
for contaminants to reach the groundwater.
18) Recommendation: locate wells at abandoned farmsteads and insure that all wells not in
use be properly sealed. Use tools including geophysical surveys,to locate wells.
Additional Groundwater Recommendations:
19) Recommendation: MDH should analyze for 1,4-dioxane, antimony,thallium, and zinc in
future MDH sampling of residential wells downgradient ofthe Coates Dump and GOW
Drainage Ditch Sites.
20) Recommendation:Test water in all livestock barns and the MPR radio transmitter
building for bacteria, nitrate, and site-related contaminants relevant to the area where
they are located OR all taps in the barns should be posted to warn workers that they are
not tested and may not be potable.
21) Recommendation:Clarify the status of the wells (UNs 207605, 207607, 207617, 208402)
in the UMore Mining Area. If the wells are still in use, re-sample the wells for metals,
including antimony,thallium and lead,to confirm concentrations and ensure exposures
above levels of health concern are not occurring.
General Conclusions and Recommendations:
• Physical hazards may be the most important health threat. Because exposure to soils in UMORE
East is thought to be limited, no one is likely to be exposed to contaminants at sufficient doses
to cause adverse health effects.
22) Recommendation: Remove physical hazards and/or restrict access.
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• For recreational users in the Vermillion Highlands area, no adverse health effects are expected
from exposure to contaminants in the soil, sediment, or surface water.
• More information is needed to better understand current land uses and potential exposures.
• Many data gaps exist and no conclusions can be drawn about public health hazards in many
areas of the site.
23) Recommendation: More investigation will be needed before developing the property for
unrestricted land uses.
VIII. Public Health Action Plan
• MDH will continue to review environmental data and land use plans for this site as they are
available.
• MDH will work with the MPCA to support the implementation of recommendations in this
report.
• MDH will communicate with the community regarding health risk as needed.
• Future MDH sampling near the site will include the recommended additional analytes.
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