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PUBLIC HEALTH ASSESSMENT

REILLY TAR & CHEMICAL CORPORATION SITE
ST. LOUIS PARK, HENNEPIN COUNTY, MINNESOTA

APPENDICES

APPENDIX 1


EMEG1

Table A.

Soil Ingestion EMEGs and CREGs (mg/kg; ppm) used for Selecting Reilly Tar & Chemical Corporation Site Contaminants for Further Evaluation

Chemical Pica Child1 Child
EMEG
Adult
EMEG
Adult
CREG

Acenaphthene* 120 3000 42000 NE
Anthracene* 600 15000 210000 NE
Benzene NE NE NE 24
B[a]A2 NE NE NE NE
B[b]F NE NE NE NE
B[k]F NE NE NE NE
B[a]P NE NE NE NE
B[g,h,i]P NE NE NE NE
1,1-Biphenyl* 100 2500 35000 NE
Chrysene NE NE NE NE
Cresols (o,m,p) NE NE NE NE
D[a,h]A NE NE NE NE
Ethylbenzene* 200 5000 70000 NE
Fluoranthene* 80 2000 28000 NE
Fluorene* 80 2000 28000 NE
I[1,2,3-c,d]P NE NE NE NE
2-Methylnaphthalene NE NE NE NE
Naphthalene NE NE NE NE
Phenol* 1200 30000 420000 NE
Pyrene* 60 1500 21000 NE
Toluene* 400 10000 140000 NE
Xylenes* 4000 100000 1400000 NE

* EMEG derived using EPA oral RfD
1 NE - No EMEG or CREG has been established
2 PAH Abbreviations - B[a]A, Benzo[a]anthracene; B[b]F, Benzo[b]fluoranthene; B[k]f,Benzo[k]fluoranthene; B[a]P, Benzo[a]pyrene; B[g,h,i]P, Benzo[g,h,i]perylene; D[a,h]A, Dibenzo[a,h]anthracene; I[1,2,3-c,d]P, Indeno[1,2,3-c,d]Pyrene

Table B.

Drinking Water EMEGs and CREGs (ug/L; ppb) used for Selecting Reilly Tar & Chemical Corporation Site Contaminants for Further Evaluation

Chemical Child
EMEG
Adult
EMEG
Adult
CREG

Acenaphthene* 600 1200 NE
Acenaphthylene NE NE NE
Anthracene* 3000 11000 NE
B[a]A2 NE NE NE
B[b]F NE NE NE
B[k]F NE NE NE
B[a]P NE NE NE
B[g,h,i]P NE NE NE
Chrysene NE NE NE
Cresols (o,m,p) NE NE NE
D[a,h]A NE NE NE
Fluoranthene* 400 1400 NE
Fluorene* 400 1400 NE
I[1,2,3-c,d]P NE NE NE
2-Methylnaphthalene NE NE NE
Naphthalene NE NE NE
Phenanthrene NE NE NE
Phenol* 6000 21000 NE
Pyrene* 300 1100 NE

* EMEG derived using EPA oral RfD
1 NE - No EMEG or CREG has been established
2 PAH Abbreviations - B[a]A, Benzo[a]anthracene; B[b]F, Benzo[b]fluoranthene; B[k]f,Benzo[k]fluoranthene; B[a]P, Benzo[a]pyrene; B[g,h,i]P, Benzo[g,h,i]perylene; D[a,h]A, Dibenzo[a,h]anthracene; I[1,2,3-c,d]P, Indeno[1,2,3-c,d]Pyrene

APPENDIX 2.

Minnesota Recommended Allowable Limits (RALs) for Reilly Tar & Chemical Corporation Site Contaminants in Groundwater

Chemical RAL (ug/L) Basis for RAL1

1. PAHs

Acenaphthene 4000.0 NC
Anthracene 2000.0 NC
Fluoranthene 300 NC
Fluorene 300 NC
Naphthalene 30 NC
Total other noncarcinogenic2 0.3 NC
Total carcinogenic2 0.03 C

2. Other Chemicals

Cresols (o,m,p) 30 S
Phenol 4000 S

1 NC - Noncarcinogenic effects; C - Carcinogenic effects

2 For the other noncarcinogenic PAHs, RALs are set to be protective against unknown healtheffects (there is little of no toxicological data on them). For the noncarcinogenic PAHs otherthan the five listed above, the RAL is 0.3 ug/L. This RAL is compared to their totalconcentration in the drinking water sample. For all carcinogenic PAHs (see the table in theToxicological Evaluation subsection), the RAL is 0.03 ug/L. Again, this RAL is compared to thetotal concentration of carcinogenic PAHs in the drinking water sample. For example, if each ofthe fifteen carcinogenic PAHs were found in a private drinking water well at 1.0 ug/L, the RALwould be exceeded (15 ug/L vs. the RAL of 0.3 ug/L) and appropriate actions would be taken byMDH.

APPENDIX 3.

Carcinogenic and Other PAHs As Defined In the 1986 CD-RAP

1. Carcinogenic PAH:
Benz[a]anthracene Benzo[b]fluoranthene
Benzo[j]fluoranthene Benzo[ghi]perylene
Benzo[a]pyrene Chrysene
Dibenz[ah]anthracene Indeno[1,2,3-cd]pyrene
Quinoline

2. Other PAH:
Acenaphthene Acenaphthylene
Acridine Anthracene
Benzo[k]fluoranthene 2,3-Benzofuran
Benzo[e]pyrene Benzo[b]thiophene
Biphenyl Carbazole
Dibenzofuran Dibenzothiophene
2,3-Dihydroindene Fluoranthene
Fluorene Indene
Indole 1-Methylnaphthalene
2-Methylnaphthalene Naphthalene
Perylene Phenanthrene
Pyrene

APPENDIX 4

This appendix was not available in electronic format for conversion to HTML at the time of preparation of this document. For a hard copy, please contact:

    The Agency for Toxic Substances and Disease Registry
    Division of Health Assessment and Consultation
    Attn: Chief, Program Evaluation, Records and Information Services Branch
    1600 Clifton Road N.E. MS E-56
    Atlanta, GA 30333.

APPENDIX 5

Summary of the Public Comments Received by the Minnesota Department of Health Regarding the Reilly Tar & Chemical Corporation Site

The Minnesota Department of Health (MDH) obtained mailing lists of concerned citizens andstate and local government officials from the Minnesota Pollution Control Agency Office ofPublic Information and the city of St. Louis Park. A copy of the draft Public Health Assessmentfor the Reilly Tar & Chemical Corporation site was mailed to each of these interested partiesalong with a request for written comments on any aspect of the document. The MDH also issueda press release to local newspapers that summarized the major findings of the draft assessmentand gave information on how to obtain a copy of the draft assessment from MDH.

Written comments on the draft Public Health Assessment were received from two parties duringthe 30-day public comment period. MDH appreciates their time and efforts in making thesecomments.

One letter with five comments came from the City of St. Louis Park. Two comments suggested changes in grammar; the other three (with MDH responses) are summarized below:
1. Comment - Change: "Reilly completed a Remedial Investigation (RI) for the area directlyeast of the Site (referred to as the Northern Area)...." to: "The City of St. Louis Park completed afinal Remedial Investigation [for the Northern Area] on Reilly's behalf."

MDH Response - The change was made in the draft Public Health Assessment

2. Comment - Change: "Reilly submitted a final RI report for the St. Peter aquifer...." to: "TheCity of St. Louis Park submitted a final RI report [for the St. Peter aquifer] on Reilly's behalf."

MDH Response - The change was made in the draft Public Health Assessment

3. Comment - Change the following sentence: "The groundwater discharge from W23 is routedto the GAC treatment facility prior to discharge." to read: "The groundwater discharge fromW23 is routed to the GAC treatment facility currently treating the discharge from Drift-Platteville source control wells W420 and W421. The treated water is discharged to MinnehahaCreek."

MDH Response - The change was made in the draft Public Health Assessment

The other letter with written comments came from a citizen of St. Louis Park. The comments (ora concise version) and MDH responses are as follows:

1. Comment - The Summary subsection of the draft Public Health Assessment "should include astatement that indicates that although due warnings [regarding contamination] were provided byresidents, no action was taken by local government for forty years".

MDH Response - The Summary subsection of the Public Health Assessment is intended only toprovide the reader with a very brief overview of the document. An expanded history of thecontamination at and around the Reilly Tar & Chemical Corporation site, and response actions bylocal and state government are given in the Background subsection of the Public HealthAssessment. MDH feels that this discussion gives citizens sufficient background to understandthe contamination problems at the Site. However, for a more detailed account of these issues,interested readers are referred to the documents listed in last two paragraphs of the Backgroundsubsection of the Public Health Assessment.

2. Comment - With respect to the MDH's conclusion in the Summary that "the Reilly Tar &Chemical Corporation site does not pose an apparent public health hazard", five facts that do not"bear out such a foregone and (unintentional) politically expedient conclusion" were made: Fact1. There is a tremendous quantity of hazardous materials remaining on site; Fact 2. Public fundswill be necessary for many years to maintain the status quo (for example, carbon filtration); Fact3. It is unclear how highway construction in the vicinity of the site will affect soil stability andcontaminant migration; Fact 4. Multi-aquifer wells may have an adverse impact upon futurewater quality; Fact 5. Statistically significant increases in breast cancer may not yet beattributable to the contamination, but neither are they unattributable.

MDH Response - Fact 1: Estimates of the volume of contaminated soil materials range as highas one million cubic yards, both on- and off-Site. The MDH has recommended that on-Sitesurface and subsurface soils be sampled for the presence and amount of contamination (seeRecommendation subsection).

Fact 2: The City of St. Louis Park realized/realizes that under the provisions of the CD-RAP itwould incur some long-term expenses. These planned expenses were incorporated, and will beincorporated into the City's future budgets (personal communication with the City of St. LouisPark). Fact 3: The excavated soils from this construction are currently kept in the area of theinterchange construction; however, they were placed on a liner, covered, and a fence put aroundthem to minimize contact with them. Fact 4: In 1978-1979, the MDH contracted for the closureof 29 multi-aquifer wells. The RAP contains provisions for investigating abandoning leakingmulti-aquifer wells open to the Mt. Simon-Hinckley, Ironton-Galesville, and Prairie du Chienaquifers. Fact 5: The issue of an increase the breast cancer rate in St. Louis Park is discussed inCommunity Health Concerns Evaluation subsection of the Public Health Implications section ofthe document.

The Public Health Assessment for the Reilly Tar & Chemical Corporation site gatheredinformation about hazardous substances known to be present at the site and evaluated whetherexposure to these substances might cause any harm to people. MDH made the conclusion that"the Reilly Tar & Chemical Corporation site does not pose an apparent public health hazard"based on the review of available environmental sampling data, local health data, and communityconcerns about the Reilly site. While MDH obtained this information from a number of sourcesincluding the Minnesota Pollution Control Agency, the City of St. Louis Park, the MinnesotaDepartment of Health, and the U.S. Environmental Protection Agency, this conclusion was basedonly on MDH's review and interpretation of this information.

3. Comment - [As stated in the Background subsection of the document] What public health orother action was taken as a result of well contamination documented during the 1930's through1950's.

MDH Response - The Background section of the document is intended to give readers a generalintroduction to the Site's history and thus, gives only a very brief description of these issues. More detailed information on actions taken during those years can be found in references cited atthe end of the Background section.

4. Comment - [With regard to contamination detected at the Site during the 1930' through the1950's] Why is leaving the contamination in the soil acceptable, when it is highly likely that yoursuccessor(s) will not feel that this was an acceptable decision?

MDH Response - Speculation on decisions to be made by MDH at any time in the future is notpossible. The MDH will make their decisions regarding public health issues based on manyconsiderations including the facts of the particular situation, consultations with other state and/orlocal governmental agencies and professional judgment.

5. Comment - Site visits by MDH and MPCA staff were made during the months of March andApril. At those times they may not have been aware of the all the activities that the park is usedfor nor see the migratory waterfowl that gather at the park.

MDH Response - Based on this comment, MDH staff made an additional visit to the Site inearly May, 1992. Observations made at this time are now noted in the Site Visit subsection. MDH noted the presence of geese in the on-Site pond in the draft document.

6. Comment - Residents of the on-Site rental units have not been made aware of the potentialdangers of growing food items or handling soil in their yards.

MDH Response - Although there is very little data on actual levels of contamination in the on-Site soils, MDH has assumed that subsurface soils in areas of the Site are contaminated (see discussion of the OPERABLE UNIT: NEAR-SURFACE CONTAMINATION). MDH hasadded the recommendation for a thorough investigation of all on-Site soils. The City of St. LouisPark has stated that property managers responsible for the housing units on the Site are aware ofsubsurface contamination and that they are to notify residents. For example, excavation, even forinstalling posts, can't be undertaken without the knowledge of the city. Even though thesecontrols are in place, MDH has included contact with contaminated soils as a potential route ofhuman exposure to Site-related contaminants because of the present uncertainty as to the actuallevels of soil contamination (see Potential Exposure Pathways subsection of the PathwaysAnalyses section). This information would also be invaluable for proceeding with in-place soilremediation (see Comment 15, below).

7. Comment - Why was nothing done at the time [regarding the complaints about odors and thepresence of contaminants in private wells, soil, and surface water prior to the 1970's], whenaction might have ameliorated or eliminated the present problem?

MDH Comment - During that period, the MDH was not adequately staffed (or funded) toinvestigate the potential impact that exposure to contaminants from dumps/waste sites wouldhave on human health. However, in 1987, the MDH began to receive funding from the federalAgency for Toxic Substances and Disease Registry (ATSDR) to assess any current or futureimpact on the public's health posed by the release of hazardous substances into the environmentfrom Superfund sites. This assessment is carried-out after MDH evaluates all of the availableenvironmental data, health data, and community health concerns for the site. The conclusions ofthis assessment are released to all interested parties in the form of the Public Health Assessmentdocument. Again, more detailed information on actions taken during those times can be found inreferences cited at the end of the Background section.

8. Comment - Toxic Chemical Release Inventory (TRI) data from 1989 and 1990 is availableand should be included in the document.

MDH Response - TRI data for 1989 and 1990 has been added to the document.

9. Comment - Microbiological degradative processes [in soil] aren't going to do much good forregions of high contamination saturation.

MDH Response - The MDH agrees that very high contaminant levels in soils may be inhibitoryto microbial degradation. The document has been amended to reflect this view.

10. Comment - What about migratory waterfowl accumulating site-related chemicals in theirbodies from surface water and sediment of the on-site pond?

MDH Response - MDH agrees that migratory waterfowl may be exposed to site-relatedchemicals such as PAHs during ingestion of sediment and water from the pond. However, thefollowing three points should be considered in relation to this comment: 1) PAHs are susceptibleto numerous degradative processes in both surface waters and sediment, 2) metabolism of PAHsin tissues of humans and animals renders them more water-soluble and thus more excretable, 3)the on-site surface water/sediment are only accessible to waterfowl during certain parts of theyear, thus limiting potential exposure and 4) while waterfowl are not humans, PAHs have notbeen detected in surveys of human fat tissue and other biological media presumably becausethese chemicals are fairly rapidly metabolized [and subsequently excreted]. Thus, while limitedexposure to PAHs may occur, their long-term accumulation in the tissues of waterfowl and otheranimals is considered to be minimal.

11. Comment - No ambient air data have been collected on or near the site, even though the airis an obvious transmission medium during construction of the highway project which lies on andabuts the site.

MDH Response - Conversations with the City of St. Louis Park regarding this commentrevealed that the City carried out an air monitoring program during phases of the LouisianaAvenue/Highway 7 construction project. Air monitoring for organic vapors (using an HNumeter) took place from June through October, 1991 at the perimeter of the construction zone. There were no reported organic vapor measurements above background at any sampling pointduring that sampling period. On July 2, 1991, one upwind and two downwind 10-hour airsamples were collected using personal air samplers during construction activities in an area southof Walker St. and north of Highway 7. The samples were analyzed for semivolatile organiccompounds listed on the U.S. EPA Target Compound List; chemicals on this list includephenolics, carcinogenic PAHs, and noncarcinogenic PAHs. None of these chemicals was foundabove the reportable detection limit.

This information has been added to the Environmental Contamination and Other Hazardssubsection.

12. Comment - Restricting access to certain portions of the park is a temporary fix, not a long-term viable solution.

MDH Response - MDH completely agrees. The Recommendations subsection of the documenthas been changed to reflect this position.

13. Comment - There was an observed excess of breast cancer in St. Louis Park during 1969-1971. MDH should initiate a follow-up epidemiological study in the area targeting carcinogenicand teratogenic phenomena relating to the PAH substances found there.

MDH Response - An observed excess of breast cancer during that period was noted by MDH. MDH addressed the feasibility of conducting an epidemiological study of the relationshipbetween drinking water and health (breast cancer included) in 1985. Portions of this feasibilitystudy were discussed in the Community Health Concerns Evaluation subsection of the PublicHealth Assessment. Interested readers can obtain a copy of the complete report from the MDHSection of Chronic Disease Epidemiology.

14. Comment - The sediment of Oak Pond (the on-site pond) should be tested immediately andat annual intervals for suspect substances.

MDH Response - Neither contact with surface water/sediment of Oak Pond nor ingestion ofwaterfowl that use the pond is considered to be a route of exposure to Site-related contaminants. However, because of the lack of data regarding potential contamination of the pons surface waterand sediment, MDH has added a recommendation for the testing both media.

15. Comment - The potential of using various remedial technologies (including newtechnologies) for soil and groundwater contamination should be investigated.

MDH Response - Testing and/or planning of remedial technologies to clean-up soils is currentlyin progress: 1) The University of Minnesota is currently in the first year of a two-year study todetermine the treatability of the contaminated soils, 2) The U.S. EPA SITE (SuperfundInnovative Technologies Evaluation) Program is looking at soil treatability technologies, and 3)The City of St. Louis Park is beginning to look at technologies for treating the soils excavatedduring highway construction.


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