Given the Onpost land use controls, visitor access restrictions, Interim Response Actions
(IRAs), groundwater intercept and treatment systems (BCSs), and the selected final
remedy documented in the Onpost ROD, the RMA Onpost area is for the present and
future considered to be a No Apparent Public Health Hazard. The detailed mosaic of
mitigation provided by the land use and visitors restrictions, IRAs, and BCSs has
eliminated many possible Onpost and Offpost pathways of human exposure to RMA
contaminants. The provisions of the Onpost ROD coupled with the existing institutional
controls and regulations will ensure that the final site remediation activities will be
carried out in such a fashion as to minimize or eliminate exposures of public health
concern.
ATSDR has reviewed the USFWS Health and Safety Plan for Wildlife Area visitors,
workers, and remediation personnel and concluded that provisions of that plan are
protective of public health. Surface soil data reviewed to date show that no harm will
come to those visitors who, prior to the completion of the final site cleanup measures, go
on the guided tours or who do not stray off designated tour routes or out of the areas
deemed safe for RMA visitors (referred to as "the white areas"). Appendix A has an
explanation of ATSDR's Public Health Hazard Conclusion Categories.
Because people residing in the Offpost Study Area to the north and northwest
experienced past exposures to RMA contaminants via groundwater and air, the area may
be considered a Public Health Hazard in the past. However, the frequency, magnitude,
and duration of those past exposures is unknown. Many public health concerns have
been expressed about the possible effects of RMA remediation and about specific health
conditions and diseases, including cancer. Past exposure to the groundwater
contaminants in off-post private wells has not been directly associated with the types of
cancers or health conditions in question. Many health studies and investigations have
been conducted because of community health concerns and past exposures from RMA.
To date, those studies and investigations have been inconclusive.
Off-post private wells to the west of RMA in the EPA Study Area (OU 2), including
wells used by businesses, are considered to be an Indeterminate Public Health Hazard.
A past and present pathway of human exposure to four different solvents exists for
individuals who work or reside in the EPA Study Area of Commerce City and have
continued to use their private Alluvial Aquifer wells (see Table 7) rather than be
connected to the South Adams County Water and Sanitation Department (SACWSD)
municipal water offered to them. The contaminants are emanating from several sources
in addition to RMA. The data on the wells were collected between 1987 and 1989; the
current concentrations in the wells are not known. If those wells are still in use they are
of concern even though the well owners have refused to discontinue their use.
Data gathered on the foodchain pathway associated with the use of the Offpost irrigation
wells indicates that consumption of garden vegetables grown in the Offpost Study Area is
No Apparent Public Health Hazard.
Based upon the data reviewed for this assessment, there are 9 Offpost Study Area private
wells that contain levels of lead that are of public health concern, and they are considered
to be a Public Health Hazard. The lead in the water may be from several sources, such
as naturally occurring lead in groundwater or lead contamination in plumbing.
Lead was detected at a range of 65.2 ppb to 119 ppb in the water of private wells
numbered 372A, 540A, 550A, 551A, 578A, 602A, and 603A (see Table 13). Bottled
water is provided, at present, to the residents using these wells, so it is presumed that
those wells are not used as a drinking water supply. According to TCHD, water from the
wells is used mainly for activities such as bathing, showering, and cooking. Non-cancerous health effects are not expected to result from the use of water from those wells
for showering, bathing, mopping, or other such household uses. However, cooking with
and/or drinking water from the wells (including infant formula made with water from the
wells) might cause non-cancerous health effects in adults, children, and the fetuses of
pregnant women, especially given the lead levels, the known health effects that might
result from exposure to those levels, and the possibility for additional lead exposure that
might occur from the workplace and the environment. According to the data given in
Table 13, the numbers of people who use these wells are the following: 1 person (372A),
72 people (540A), 16 people (550A), 5 people (551A), 5 people (578A), 1 person
(602A), and 4 people (603A).
Based upon the provisions documented in the Offpost ROD, of those wells discussed
here, only well 550A may not qualify for connection to a municipal water supply system
or an alternative water source. Human consumption of water containing about 65.5 ppb
lead may be resumed if the use of this well is continued. Non-cancerous health effects
may occur in adults, children, infants, and the fetuses of pregnant women who use this
well as a drinking water supply (including infant formula made with water from the well)
and/or for cooking, as described above.
Lead was detected at a concentration of 98.8 ppb in the water of the private well
numbered 579A (see Table 13). Lead was detected at a concentration of 18.6 ppb in the
water of the private well numbered 931A (see Table 14). Bottled water was not provided
to the residents using these wells at the time this assessment was compiled, so it is
presumed that these wells are used as a drinking water supply and for activities such as
showering, bathing, and cooking. Both of these wells qualify for connection to a
municipal or alternative water source and, thus, use of these wells for drinking and
domestic water supply is not expected to continue.
Before replacement, non-cancerous health effects are not expected from the use of the
well water from these wells for showering, bathing, mopping, or other such household
uses. However, non-cancerous health effects may result in children, infants, and the
fetuses of pregnant women who use these wells as a drinking water supply (including
infant formula made with water from the wells) and/or for cooking, especially given the
lead level, the known health effects that might result from exposure to those levels, and
the possibility for additional lead exposure that might occur from the environment. Non-cancerous health effects are not expected in adults who use the well numbered 931A;
however, non-cancerous health effects may occur in adults who use water from the well
numbered 579A as a drinking supply or for cooking. According to the data given in
Table 13, three people use the well numbered 579A, and according to the data given in
Table 14, three people use 931A.
In samples collected in the 1991-1994 interval, nitrate was detected at a concentration of
10,000 ppb to 24,000 ppb in the well water from the wells numbered 456A, 579A, 739A,
973A, and 1276A (see Table 13). Bottled water was not provided to the residents using
these wells at the time this assessment was compiled, so it is presumed that the wells are
used for drinking water and for activities such as bathing, showering, and cooking.
However, based upon the decision documented in the Offpost ROD, all these wells
qualify for connection to a municipal water supply or an alternative water source and,
thus, the use of these wells for drinking and domestic water supply is not expected to
continue.
Prior to replacement with an alternative water supply, the non-cancerous health effects
that may result from using these wells for showering, bathing, mopping, or other such
household uses are unknown, because very little information exists to assess dermal
exposures; inhalation is expected to be negligible. Adults and children drinking water
from these wells and cooking with it are not expected to develop non-cancerous health
effects. However, non-cancerous health effects may result in infants, the fetuses of
pregnant women, and pregnant women from using the water from these wells for
drinking (including infant formula made with this water) and/or for cooking. Nitrate is
known to be taken into vegetables (see the Toxicological Evaluation section and
Appendix B for more information). According to the data given in Table 13, three
people each use most of these wells. Two people use the well numbered 456A, and six
use 1276A.
Nitrate was detected at a concentration of 11,000 ppb to 26,000 ppb in the well water
from the wells numbered 331A, 332B, 332D, 540A, 541A, 547A, 551A, 578A, 613A,
616A, 969A, 981A, and 1305A (see Table 13). Bottled water is provided to the residents
using the water from these wells, so it is presumed that water from the wells is used
mainly for activities such as bathing, showering, and cooking.
Of the wells listed in this category, only well 547A may not qualify for connection to a
municipal water system or an alternative water supply. However, the level of nitrate
contamination is this well has declined from its high level of 12, 700 ppb and the January
and July, 1995 samples collected from this well found 7,300 ppb and 6,600 ppb nitrate;
below the 10,000 ppb MCL level of health concern.
Prior to replacement with an alternative water supply, the non-cancerous health effects
that may result from using these wells for showering, bathing, mopping, or other such
household uses are unknown, because very little information exists to assess dermal
exposures; inhalation is expected to be negligible. Non-cancerous health effects are not
expected to result in adults or children who drink water from the well or eat food cooked
with the water. Nitrate is known to be taken into vegetables (see the Toxicological
Evaluation section and Appendix B for more information). However, non-cancerous
health effects may result in infants, the fetuses of pregnant women, and pregnant women
from using the water from these wells for drinking (including infant formula made with
this water) and/or for cooking. According to the data given in Table 13, the following
numbers of people use each of these wells: 331A (3 people), 332B (2 people), 332D (2
people), 540A (72 people), 541A (3 people), 547A (3 people), 551A (5 people), 578A (5
people), 613A (2 people), 616A (6 people), 969A (3 people), 981A (4 people), and
1305A (2 people).
It should be noted that wells contaminated with nitrate are also frequently affected by
elevated levels of coliform bacteria. Water treatment technologies used to eliminate or
significantly diminish nitrate levels, such as ion exchange resins and reverse osmosis, are
not adequate to remove coliform bacteria.
Several chemicals were detected in groundwater, surface water, soil, and/or air for which
regulatory or other appropriate comparison values and health guidelines do not exist or
are rather limited in their focus. A list of these chemicals and information concerning the
need for comparison values and health guidelines for use in evaluating potential public
health issues was submitted to the ATSDR Division of Toxicology. Those chemicals are
bicycloheptadiene, dicyclopentadiene, ethylbenzene, methylphosphonate, parathion,
supona, vapona, isodrin, dimethyldisulfide, CPMS/CPMSO/CPMSO2, and DIMP.
Dieldrin has been detected above the FDA Action Level of 0.3 ppm in waterfowl,
pheasants, and mourning doves inhabiting RMA. The birds are a potential pathway of
off-site human exposure. Pheasants are less of a concern, given their estimated home
ranges and the low concentrations of dieldrin detected thus far in the livers of off-site
birds. Biomonitoring conducted by the USFWS in 1994 found that edible-tissue body
burdens of waterfowl and mourning doves was below FDA Action Levels for dieldrin
and other contaminants. Those data suggest that no adverse health effects would result
from human consumption of those species.
For the purposes of this public health assessment, ATSDR reviewed the existing studies
of the toxicological effects of Diisopropyl methylphosphonate (DIMP) and has
concluded that the EPA LTHA of 600 ppb and RfD of 0.08 mg/kg/day are protective of
public health. ATSDR is preparing a Toxicological Profile for DIMP that will further
evaluate the issue of potential human health risks that may be associated with exposure to
DIMP. A public comment draft of that report is scheduled for release in the late Summer
or Fall of 1996.
Because some drinking water well owners in the Commerce City (OU 2) area have
refused connection to municipal water and monitoring of those wells may be difficult,
periodic review of available data describing the water quality of the Alluvial Aquifer in
the Commerce City (OU 2) Area should be conducted. As long as it can be reasonably
inferred that contamination of those wells remains above health-based levels, the well
owners should periodically be provided with information, similar to the notification they
previously received, describing the risks associated with the continued use of that well
water.
Lead, a non-RMA contaminant, has been detected in the water from wells numbered
372A, 540A, 550A, 551A, 578A, 602A, and 603A. Bottled water is supplied to the users
of these wells. It is recommended that, until these residences have been connected to a
municipal water supply system or an alternate source of water, the practice of notifying
the users of these wells of the well testing results be continued and that the notification
encourage the users of these wells not to use the water from these wells for drinking,
cooking, or the preparation of infant formula. Of the wells listed, apparently only well
550A does not qualify for connection to a replacement water supply.
Lead has also been detected in the water from wells numbered 579A and 931A. Bottled
water was not provided to the users of these wells at the time the data was compiled for
this assessment. It is recommended wells 550A, 579A, and 931A be resampled to
determine the current level of lead contamination locally present in the aquifer. If the
lead levels remain elevated in these wells, the residents should be encouraged to connect
to a municipal water supply system or to develop an alternate source of water. The
practice of notifying the users of these wells of the well testing results should be
continued and the notification should encourage that children, infants, and pregnant
women not drink the water (including infant formula made with this water) or eat food
cooked with it. In addition to children and infants, all adults should be discouraged from
drinking the well water or eating food cooked with water from well 579A.
Proper use of filters on taps served by the wells will also significantly diminish the
exposure to lead. The Toxicological Evaluation section and Appendix B contains
additional information on reducing exposure to lead.
Nitrate, a non-RMA contaminant, was detected, in the water of numerous wells listed in
Tables 13 and 14 of this assessment. Nitrate levels in those wells was above the MCL of
10,000 ppb in April 1994, but since then nitrate levels in those wells has continued to
decline and, as of August 1996, none of those wells contain nitrate levels greater than the
10,000 MCL value for nitrate.
Because all of those wells, except well 547A, qualify for connection to a municipal water
supply system or an alternative water supply continued use of those wells for drinking
and domestic water supply is not expected to continue. The use of well 547A may
continue, but, at present, the level of nitrate contamination is below the MCL and level of
health concern. It is recommended that periodic testing of the nitrate level in well 547A
be performed and that the practice of notifying the users of this well of the testing results
be continued. The well user should be encouraged to test their well for the presence of
coliform bacteria.
ATSDR's Division of Toxicology should consider developing media-specific
comparison values, health guidelines, or substance-specific applied research for
the chemicals identified in Conclusion 8.
We recommend that current-access and allowable-use restrictions set forth in the RMA
policy memorandum of July 17, 1991, be maintained until superseded by a comparable
remediation-action-specific system of access and use restrictions imposed to ensure the
safety and well being of RMA workers and visitors. We also recommend that guests at
the RMA National Wildlife Area receive health education via videos, short discussions,
updated health and safety fact sheets, and pamphlets before their visits. USFWS should
retain the lead in enforcing compliance with safety guidelines and educating visitors on
the dangers of wandering onto restricted areas. If, prior to completion of the final site
cleanup, unsupervised public access is permitted in some areas, maps provided to visitors
and signs or markers in the areas managed as a wildlife refuge should clearly delineate
areas where access is prohibited. We further recommend periodic updates of the access
restriction map. We recommend that those access restriction map updates be developed
in anticipation of the potential effects of planned or ongoing site cleanup measures to
further ensure that no unanticipated conflicts arise with RMA National Wildlife Area
users.
We recommend continued enforcement of statutory and institutional controls that
prohibit taking and consuming biota at RMA, particularly the catch and release program
aimed at preventing consumption of fish in RMA lakes and the prohibition of taking deer
for consumption.
ATSDR should review key elements of the design of final site cleanup measures,
including provisions for environmental monitoring, to ensure that appropriate steps have
been taken to protect public health during the final remendiation process.
ATSDR should review and coordinate with all members of the RMA Federal Facility
Agreement any changes to the health and safety plan that has been established to ensure
that the various agencies involved in remediation at RMA adhere to current industrial
hygiene standards to prevent harm to remedial and maintenance workers.
The Comprehensive Environmental Response Compensation, and Liability Act
(CERCLA; also known as Superfund) as amended, requires ATSDR to conduct needed
follow-up health actions in communities living near hazardous waste sites. To identify
appropriate actions, ATSDR created the Health Activities Recommendation Panel
(HARP). HARP has evaluated the data and information contained in the Rocky
Mountain Arsenal Public Health Assessment for appropriate public health actions.
HARP determined that both Community Health Education and Health Professions
Education are warranted because, as discussed above, exposure is now occurring to
several chemicals in specific drinking water wells above health-based guidelines. In
addition, health studies are underway. When those studies are completed, ATSDR will
evaluate them for the need for further follow-up public health actions. Media-specific
health guidelines are not available for some of the substances detected. Those substances
will be referred to ATSDR's Division of Toxicology for consideration of comparison
values, health-based guidelines, or substance-specific applied research.
The public health action plan (PHAP) for the Rocky Mountain Arsenal (RMA) contains a
description of actions to be taken by ATSDR and/or other governmental agencies at and in the
vicinity of the sites subsequent to the completion of this public health Assessment. The purpose
of the PHAP is to ensure that this Assessment not only identifies public health hazards but also
provides a plan of action designed to mitigate and prevent adverse human health effects resulting
from exposure to hazardous substances in the environment. The PHAP includes a commitment
on the part of ATSDR to follow up on this plan to ensure that it is implemented. The following
public health actions have been undertaken or are planned:
A. Actions Undertaken
Before the beginning of this Assessment, RMA, USFWS, EPA, TCHD, and CDPHE took
numerous actions that contribute to or are protective of public health. The text of this
Assessment summarizes most of those actions. The Agreement for a Conceptual Remedy for the
Cleanup of the Rocky Mountain Arsenal (Colorado, 1995) and the subsequent finalization of
both the Offpost ROD (HLA, 1995 and the Onpost ROD (Foster Wheeler, 1996) have specified
the scope and nature of the final cleanup of RMA and numerous actions designed to be
protective of the public health during and after the cleanup. All parties to the Conceptual
Agreement have actively participated in the furthering of the goals of Component 18 (Medical
Monitoring) of that agreement. Specific mention is not made below of all such Component 18
actions taken by all parties, but the cooperation of all parties is recognized and appreciated.
Many of those actions have already been initiate and will be noted in this section, along with
other actions taken since the preparation of this Assessment began in January 1993.
ATSDR has:
Reviewed the USFWS Addendum to Amendment 5 of the 1994 Fish and Wildlife
Management Plan - Biomonitoring Program. One of the main objectives of the plan is to
characterize the potential for contaminant uptake into the fish and wildlife of RMA.
Reviewed the USFWS Health and Safety Plan, which is the basis for the plan of action
for USFWS volunteers, employees, and public use of the National Wildlife Area. The
objective of the Health and Safety Plan is to prevent or minimize exposure of workers
and the public to hazardous chemicals remaining onsite.
Assisted the USFWS in the development of a fact sheet on public health considerations
relating to public use of the refuge. The fact sheet presents information that can be used
to prevent or minimize public exposure to hazardous chemicals present onsite.
Assisted and will continue to assist CDPHE and CSU in completing health studies
relating to possible past exposures of people to RMA contaminants.
Compiled a Toxicological Profile on DIMP that is scheduled for release as a public
comment draft in late Summer or Fall of 1996 by ATSDR's Division of Toxicology.
Participated in the establishment and monthly meetings of the Medical Monitoring
Advisory Group (MMAG, see CDPHE entry below) and actively worked to develop a
technical framework for and an increased level of community information and
involvement in the development of the followup public health actions that may be
appropriate during the final cleanup of the Arsenal.
The CDPHE has:
Consistent with the provisions of the Conceptual Agreement (Colorado, 1995) and both
RODs (HLA, 1995; Foster Wheeler, 1996) organized the Medical Monitoring Advisory
Group (MMAG) to assist CDPHE ad ATSDR in the design of a medical monitoring
program: a public health action plan to help ensure the protection of individual and
community health during the final cleanup of RMA. The first MMAG meeting was held
in December 1996 and the monthly meeting will occur until the group's objectives are
achieved. In addition to the CDPHE and ATSDR representatives, the MMAG is
comprised of representatives of the neighborhoods near RMA, the Army, Shell Oil
Company, EPA, TCHD, and area health care providers.
The USFWS has:
Implemented, managed, and updated, in conjunction with the Army, the Activities
Coordination program that coordinates all remediation, scientific research, and public use
activities on RMA. This on-going program includes production of a weekly map and a
schedule that designates locations of all activities, with a special designation for tasks
that represent a significant hazard to other field activities. The schedules include type,
location, duration of activity, level of Personal Protective Equipment required, and a
specified point of contact. To prepare for weekly meetings, the USFWS collects the
information one week in advance for consolidation and dissemination by facsimile
transmission. All revisions are kept at the Activities Coordination Office of the USFWS
(USFWS, 1993b).
Created and maintained a health and safety plan to ensure a safe working environment
for arsenal employees, contractors, research assistants, and volunteers conducting a wide
variety of scientific and public use tasks. Health and safety training covers all USFWS
employees on all- terrain vehicle use, aircraft safety, equipment operation, OSHA
hazardous waste protection procedures, cardiopulmonary resuscitation (CPR), and first
aid. USFWS has also established monthly health and safety orientations, and the agency
maintains a two-way radio communication system for reporting emergency situations
(USFWS, 1993b).
Ensured that agency employees receive physical examinations and medical monitoring as
prescribed in the Medical Monitoring Policy outlined in the USFWS memo dated
February 23, 1993. The results of those examinations are used to assess and monitor the
health of their employees (USFWS, 1993b).
Provided an ongoing National Wildlife Area visitor safety program. The program
includes daily reviews of bus tour routes basis to ensure the routes' compatibility with
other arsenal field activities. It also addresses health and safety concerns regarding
anglers and fishing programs for children and the handicapped. (USFWS, 1993b).
Designed a wildlife study and sampling plans that resulted in thorough evaluations of
contaminant levels in the fish and wildlife species that inhabit or frequent RMA. In
addition to monitoring the relative health of those fish and wildlife populations, the data
derived permitted further evaluation of a potential foodchain pathway.
Participated actively in the meetings and work of the MMAG
The U. S. Army has:
Completed, under the direction of the U. S. Army Environmental Hygiene Agency, the
development of a methodology for the analysis of DIMP in produce. The Arsenal, with
the assistance of TCHD, collected and analyzed vegetable produce collected in the
Offpost Study Area to permit a more thorough evaluation of a potential foodchain
pathway.
Participated actively in the meetings and work of the MMAG. Along with personnel of
Shell Oil Company, RMA has worked actively to assure that adequate funding is
available to enable the work of the MMAG.
B. Actions Planned
ATSDR will:
Actively cooperate and assist, as necessary, the CDPHE in the planning and
implementation of an integrated mosaic of public health actions responsive to the goals
of Component 18 of the Conceptual Agreement and the requirements of the Offpost and
Onpost RODs.
As needed, plan and produce community involvement and information activities
including informational meetings, handouts, and press releases, consistent with the PHA
process, after the release of this public health assessment.
Consider development of media-specific comparison values, health guidelines, or
substance-specific applied research for the following compounds: bicycloheptadiene,
dicyclopentadiene, ethylbenzene, methylphosphonate, parathion, supona, vapona, isodrin,
dimethyldisulfide, and CPMS/CPMSO/CPMSO2.
As needed, assist the CDPHE and the USFWS in the development of public health
education materials for distribution to residents of nearby neighborhoods and to visitors
to the RMA National Wildlife Area.
As needed, provide or assist in securing health professionals education to ensure proper
recognition and treatment of the possible health effects of environmental exposure to
contaminants detected in water from Offpost Study Area private wells or to contaminants
that might be accidentally released during finally site cleanup.
As needed, assist CDPHE or others to provide community health education activities to
provide area residents with information about the levels at which health effects are
possible from exposure to lead and nitrate detected in well water from Offpost Study
Area private wells (see Tables 13 and 14) and how to reduce or stop their exposure to
lead and nitrate.
Review the findings of future RMA-focused health studies for public health significance
and future follow-up public health actions when the studies are completed. ATSDR will,
as appropriate, submit the findings of these studies to other members of the Federal
Facility Agreement (FFA) and the public for review and comment.
CDPHE will:
Develop an integrated and comprehensive public health action plan (Component 18
Medical Monitoring Plan) to ensure protection of the public health of the nearby
neighborhoods during the extended final cleanup of the Rocky Mountain Arsenal.
Inform and involve the communities near RMA, the members of the MMAG, the Parties,
health care professionals, and other interested parties during the development of the
Medical Monitoring Plan.
Tri-County Health Department will:
As appropriate, continue to monitor the quality of drinking water wells that remain in use in use in the Offpost Study Area and to send written notification to owners and users of
contaminated drinking water wells, or to the owners/users of drinking water wells that
may be contaminated in the future, of the health threat(s) that may be associated with the
use of their well water.
Ensure that drinking water wells identified in this assessment that do not qualify for a
replacement water source and that may represent a potential health threat from human
exposure to elevated levels of lead or other contaminants are retested periodically and
their owners sent written notification of the health threat(s) that may be associated with
the use of their well water.
EPA will:
To the extent there is data or a reasonable basis to infer the continued contamination of the Alluvial Aquifer in the vicinity of those private drinking water wells in the OU 2 area
of Commerce City that remain in use, in cooperation with local heath officials, provide
notification to the well owners of the health risks that may be associated with the
continued use of those wells.
The U. S. Army will:
Coordinate with USFWS representatives throughout the final remediation process to
review data relevant to contamination sources and remediation activities and, as
necessary, to update or revise the RMA access map and/or activity and wildlife refuge
use coordination requirements.
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