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Off-Site Sources of Contaminants

Off-site sources of contaminants are included here in recognition of their relative importanceincontributing to Onpost contamination of surface water and groundwater. Surface water andgroundwater contamination that enters RMA along the southern boundary is notable. Routes ofsurface water transport from offpost sources to the south include the Peoria and HavanaInterceptors. Contaminants in surface water entering RMA from the south include volatileorganic compounds, organophosphorus and organosulfur compounds, semivolatile halogenatedorganics, pesticides, arsenic, and zinc. Concentrations arewithin the range of surface watercontamination observed elsewhere at RMA. The occurrence of many of these compounds isconsistent with manufacturing and industrial activity south of RMA (EBASCO, 1992, p. 2-22).

Groundwater entering RMA from the south and southeast contains detectable nitrate, VOCs,andVOC-associated breakdown products. Numerous sites contribute to the groundwatercontamination of the area such as the Chemical Sales Company site, a major source oftrichloroethane (TRCLE or TCE) contamination (discussed below) or a site at 49th and Havana,less than one and one-half miles upgradient of the Western Study Area, a documented source oftetrachloroethene (TCLEE or PCE) and TCE contamination to groundwater (EBASCO, 1992,2-22; CDM, 1993, p 5-24).

Plumes originatingoff-post merge with RMA plumes as they follow alluvial paleochannels thatflow under the Western Study Area. The VOC and nitrate plume that flows below the WesternStudy Area and eventually flows off-post at the western boundary appears to consist largely ofcontamination originating off-post (EBASCO, 1992, p. 2-22; CDM, 1993, p. 6-1 - 6-15).

EPA Studies andthe EPA Study Area (Chemical Sales Company)

In 1981, a random national survey of drinking water systems was conducted by EPA. Thesampling and analyses completed during this survey detected several organic chemicals in theSouth Adams County Water and Sanitation District (SACWSD) wells. Additional sampling in1982 and 1985 confirmed these results. As a result of these findings, EPA began an RI/FS of anarea located west of RMA and south of the RMA Offpost Study Area and OU (HLA, 1992b, p.I-9).

RMA was suspected as one of the potential sources of contaminants in the EPA Study Areabecause of the history of waste disposal practices on that site. In response, the Army constructedthe Klein Water Treatment Plant for SACWSD. Further investigation by EPA's FieldInvestigation Team indicated that source areas other than RMA were contributing to much of thegroundwater contamination detected within the study area. Groundwater monitoring wellsinstalled on the Chemical Sales Company site, an NPL site (CERCLIS No. COD0077431620)and a major source of contamination, and elsewhere in and adjacent to the northern portion ofthe former Stapleton International Airport have since confirmed that there are several sources of groundwater contamination west and south of RMA (HLA, 1992b, p. I-9; CDM, 1993).

Several sources of trichloroethene have been documented south of Offpost Study Area in ornearCommerce City. Also, investigations by EPA and the Army along the western sections of RMAhave detected the presence of a trichloroethene plume entering Township 3 South, Range 67West (T3S, R67W), Section 9 along the southern boundary of RMA. Although trichloroethenehas been detected in selected dewatering wells and the influent sump of the Irondale system, notrichloroethene has been detected in the effluent sump of the system. Because of the potentialfor multiple trichloroethene sources upgradient of the Offpost Study Area, trichloroethenedetected in the area between 80th and 88th Avenues remains under the jurisdiction of EPA, apartfrom the remediationprocess underway at RMA (HLA, 1992b, p. I-10; Shell, 1995).

RMAOffpost Study Area and Operable Unit

A RMA Offpost Study Area was initially established to assess potential effects ofRMA-relatedcontamination beyond the RMA boundary. On the basis of north and northwesterly flowdirections of groundwater and surface water, the boundary of the Offpost Study Area wasdefined to include the area bound by 80th Avenue, the South Platte River, Second Creek, and thenorth and northwest boundaries of RMA. The Offpost Study Area also includes the surfacewaters of Barr Lake, the O'Brian Canal, and Burlington Ditch from 80th Avenue to Barr Lake(see Figure 2).

The Offpost Operable Unit is defined by the RMA Federal Facility Agreement (USEPA,1989,p.15) as that portion of the Offpost Study Area where hazardous substances,pollutants, orcontaminants from RMA that require remediation (HLA, 1992b, p. I-1). The Offpost OUoriginally encompassed the entire Offpost Study Area north of RMA, but as data has beengathered and the extent of contamination defined, the Offpost OU has been reduced in size andis now defined as a portion of the Offpost Study Area north of RMA and is designated as thecontaminated groundwater within the unconfined flow system (alluvial aquifer; see Fig. 5) thatrequire remediation (HLA, 1995).

As a result of the detection of chemicals in the Offpost Study Area, the Army initiated aregionalsampling of hydrogeologic surveillance program requiring the quarterly collection and analysisof samples from more than 100 onpost and offpost wells and surface-water stations. Thisprogram was carried out under the direction of the RMA Contamination Control Program,established in 1974 to ensure compliance with federal and state environmental laws. Theobjectives of this program were to evaluate the nature and extent of contamination and todevelop response actions to control chemical migration. Potential and actual chemical sourceswere assessed, and chemical migration pathways were evaluated. As a result of this evaluationthe three previously discussed groundwater intercept and treatment systems (ICS, NWBCS, andNBCS) were constructed to minimize offpost discharge of RMA chemicals via groundwater. Allthree systems are currently in operation to intercept and treat contaminated groundwater and torecharge treated water (HLA, 1992b, p. I-8).

From 1975 to the present, numerous groundwater monitoring programs have been conductedatRMA. The Army designed and implemented the 360 Degree Monitoring Program to monitorregional groundwater and surface water. The Army designed and implemented the boundarysystem monitoring program to support the operation of the boundary control systems (HLA,1992b, p. I-8).

The RMA Offpost Contamination Assessment Report (CAR) (ESE, 1987a) incorporated datafrom several studies to depict the distribution and concentrations of offpost contamination northand northwest of RMA. The scope of this investigation was intended to address critical datagaps required to evaluate a comprehensive set of multimedia exposure pathways. In themid-1980s, the potential for contamination of private wells was investigated. These were referredtoas Consumptive Use (CU) Studies, Phases I, II, and III. The CU Phase I and Il studies (ESE,1985; ESE, 1986) addressed the RMA offpost area bounded to the south by East 80th Avenue, tothe northwest by the South Platte River, and to the east by Second Creek (HLA, 1992b, p. I-8,I-9).

In the CU Phase III study (ESE, 1987b), the Army conducted an inventory of privatelyowneddrinking water wells in an area bound by East 80th Avenue on the south, East 96th Avenue onthe north, the South Platte River on the west, and RMA on the east. The objectives of the studywere as follows: locate all shallow domestic wells (less than 100 feet) in the study area, samplea representative number of the located wells, and assess the groundwater quality of the shallowalluvial aquifer (HLA, 1992b, p. I-9).

Data collection consisted of compiling new hydrogeologic and chemical data relevant to theOffpost Study Area. Data were obtained by drilling new wells and borings, collectinggroundwater and surface water samples for analysis, measuring groundwater levels and surfacewater flows, conducting aquifer tests, and obtaining sediment samples for analysis (HLA, 1992b,p. I-11).

The Offpost Operable Unit RI (ESE, 1988) assessed the possible off-site effects ofRMA-relatedcontamination throughout a 27 sq mi area. The highest levels of the groundwater contaminationwere found to lie in the area between the north boundary of RMA and the Burlington Ditch. Here, two major groundwater plume groups have been delineated as shown in Figure 5. Thoseplume groups are termed the North Plume Group (north and northwest of the RMA northboundary) and the Northwest Plume Group (west and north of the RMA northwest boundary).Those plumes of contaminated groundwater will be discussed in greater detail in subsequentsections of this Assessment.

Surface water and sediment samples were collected in the Offpost Study Area to definechemicals in the media. Samples were collected from streams, creeks, impoundments, and lakesthat were suspected pathways for migration of onpost contamination to the Offpost Study Area. The data were used to evaluate contamination in surface water and sediment as well as toevaluate surface water and groundwater interaction (HLA, 1992b, p. I-11).

Biota and air-quality condition were evaluated using onpost and offpost information collectedduring past and current studies. Input from the Offpost CAR was used to assess transport ofchemicals and impacts on biota in the Offpost Study Area from onpost conditions. Data fromthe Onpost Air RI Report (ESE, 1988) were used to assess the potential for migration of airbornechemicals to the Offpost Study Area (HLA, 1992b, p. I-11).

The Offpost Operable Unit RI Addendum (HLA, 1992a) was prepared to document furtherAssessment of the extent of contamination in various media (groundwater, soil, surface water,sediment, and biota) within specific geographic areas.

The Offpost remedial investigations (ESE, 1988; HLA, 1992a) conducted at RMA foundcontaminants present in groundwater, surface water, soil, and sediment in the Offpost StudyArea north and northwest of RMA. Additionally, the data presented in the Offpost RIandAddendum indicate that the areas south and east of RMA, including the Montbellocommunity area, have not been contaminated by RMA-related chemicals. The Offpost risk assessment (HLA, 1992b) concluded that, consistent with EPA definitions, the levels ofcontamination in surface water, soil, and sediment do not pose an unacceptable threat to humanhealth or to the environment. Therefore, groundwater contamination is the focus of the OffpostOU (USEPA, 1993; HLA, 1995).

The Agreement for a Conceptual Remedy for theCleanup of RMA and the Onpost andOffpost Records of Decision (RODs)

On June 13, 1995, after public comments had been received on this public health assessment, theU.S. Army, Shell Oil Company, the state of Colorado, the U.S. Environmental ProtectionAgency, and the U.S. Fish and Wildlife Service signed an "Agreement for a Conceptual Remedyfor the Cleanup of the Rocky Mountain Arsenal" ("the Conceptual Agreement"; Colorado,1995). The Conceptual Agreement incorporates 28 specific components of the conceptualremedy that were incorporated in the sitewide alternatives for water, structures, and soil aspresented in the final Detailed Analysis of Alternatives report and carried forward as integralcomponents in the Proposed Plan released in October 1995 (RMA, 1995). Some of theconceptual remedy components are integral components of both the on-post and off-postremedial programs that were considered in the selection of the preferred alternatives.

The ROD for the Offpost Operable Unit incorporates the Offpost components of theAgreement(Colorado, 1995) and was signed December 19, 1995 (HLA, 1995). Similarly, the Onpost ROD,signed June 11, 1996, also incorporates the relevant components of the Conceptual Agreement(Foster Wheeler, 1996). The selected remedy recorded in those RODs is extensive andthorough. Soil cleanup activities may take as long as 18 years to complete, but othercomponents of the final cleanup, such as actions undertaken as IRAs or ongoing BCSs, arein-place and operative now.

The 28 specific components outlined in the Conceptual Agreement which form the conceptualbasis for the final cleanup decisions incorporated in the RODs include provisions for Onpostcleanup of surface and subsurface soils in specific locations, for UXO clearance, and fordemolition and disposal of all contaminated structures. The decisions recorded in the RODsprovide for the ongoing operation of all existing groundwater pump and treatment systemsincluding the Irondale, Northwest Boundary, and North Boundary containment systems as wellas the system installed north of the RMA boundary in the Offpost area. Further, the RODsprovide that the U.S. Army and Shell Oil Company will, working with the South Adams CountyWater and Sanitation District (SACWSD), provide 4,000 acre feet of water, a system of waterdistribution lines, and individual residence hook-ups for all existing well owners within theOffpost area delineated by the plume of DIMP-contaminated groundwater. The extent of thatplume, the DIMP "Footprint Area", will be determined as that area where the last quarterlygroundwater monitoring results detects DIMP at levels greater than 0.392 ppb (the currentdetection limit for DIMP). The RODs also specify that, if DIMP is subsequently detected atlevels greater than 8 ppb in additional existing or newly drilled wells, the Army and Shell willpay for hook-up to the water distribution system or provide a deep well or other permanentsolution.

The combined effect of the numerous components of the final remedial actions to beundertakenin the Onpost and Offpost areas will be to eliminate or greatly minimize potential humanexposure to RMA contaminants and thereby result in a final cleanup that is protective of humanhealth. In this context, this public health assessment is descriptive of the potential humanhealth hazards associated with the Onpost and Offpost areas of RMA prior to thecompletion of the final remediation tasks.

Site Visit

ATSDR staff, Dr. W. Mark Weber, Ms. Linda West, and Dr. Glenn Tucker, the regionalrepresentative, made a site visit to RMA March 22-26, 1993. Other agencies also in attendancewere the U.S. Environmental Protection Agency, Colorado Department of Public Health &Environment, Rocky Mountain Arsenal personnel and contractors, and the U.S. Fish andWildlife Service. Representatives from Shell were also present. On the first day, on-post andoff-post areas of RMA were surveyed and the following observations were noted:

  • The perimeter of RMA is fenced and posted; access is controlled via guarded gates.
  • During the site visit there was no evidence of persons other than remedial workers and related contract personnel and U.S. Fish and Wildlife Service (USFWS) personnel affiliated with the Rocky Mountain Arsenal National Wildlife Area frequenting the site. Anglers and the general public do use the Arsenal area, however. Those ongoing public use programs are carefully regulated by the USFWS.
  • The site is now inactive and consists largely of empty buildings and open grounds sparsely vegetated with grasses, shrubs, brush, and few trees.
  • Remediation of RMA is ongoing; Basins A and F were observed. The tour also viewed the three boundary containment systems for groundwater and visited groundwater treatment and a wastewater treatment facilities.
  • The Submerged Quench Incinerator (SQI) was in its initial stage of operation; a test burn of a salt brine solution was occurring.
  • Wildlife is abundant at RMA; deer, rabbits, prairie dogs, and various birds were noted, but no hunting is allowed. Management efforts are directed at restricting access of wildlife to the areas of RMA with minimal contamination.
  • There are several lakes on the installation, but only catch and release fishingis permitted due to contamination.

Offsite, a windshield survey was conducted to view the off-site neighborhoods and ruralareas. The western and southern offpost areas are more densely populated than the remaining segmentsof the perimeter. Residential and commercial development occurs on the western boundary ofRMA in the Commerce City and Montbello areas. Some small home gardens were observed inthis area. In the northwestern and northern offpost areas development is less dense and morelands are devoted to agricultural uses or left vacant. Remedial investigations have termed thisnorthwest and north area the Offpost Study Area. Many of the lands being used for agriculturalpurposes in the Offpost Area utilize either sprinkler or ditch irrigation systems. Truck-farmingproducts from those lands include sweet corn, cucumbers, tomatoes, beans (Connally Mears,EPA, 03/23/93, personal communication, site visit) and cabbage (Jeff Edson, CDPHE, 03/24/93,personal communication, site visit). Private wells are used for both irrigation and for domesticpurposes. In those areas where DIMP has been detected at any level in domestic wells, CDPHEhas supplied bottled water. A large turf farm and a small auto salvage business were alsoobserved in this area.

East of RMA there are a few scattered houses and mobile homes and fields devoted todry-landagriculture and grazing livestock. The new Denver International Airport was being constructedon those lands at a distance of 3-9 mi east of the RMA boundary. Airport and access roadconstruction was occurring during the time of the site visit.

The Montbello neighborhood is located adjacent to the southeastern RMA boundary and islargely a residential neighborhood with numerous homes, some small gardens, schools, day carefacilities, businesses, restaurants, and other related commercial facilities. The southwesternboundary area contains primarily light and heavy industry. The northernmost runway extensionof Denver's now closed Stapleton International Airport lies in this area and the main terminalfacilities are 3-4 mi south of the RMA boundary.

Several local agencies provided information about RMA. Those agencies include: ColoradoDepartment of Public Health & Environment, Colorado State University, Tri-County HealthDepartment, South Adams County Water and Sanitation District, and Adams County Planningand Development. Citizens and elected officials also provided information. Pertinentinformation has been incorporated from those representatives into appropriate sections of thispublic health assessment.

Demographics, Land Use, and Natural Resource Use


RMA is located in Adams County, Colorado, approximately 9 miles northeast of downtownDenver. Some areas to the south and west of the site are densely populated neighborhoods,while the areas to the north and east are much more sparsely populated. Stapleton Airport (nowclosed) is immediately to the south of RMA; a prison which had over 1,200 inmates in 1990 isnorth of Stapleton and south of interstate highway I-70. Population and housing data from the1990 Census for the Montbello community south of the site and for other areas of potentialconcern west and north of the site are included in Table 3.

Montbello is a densely populated (5,082 persons per square mile), middle-class community inDenver County located south of the site and east of the former Stapleton International Airport. Montbello had a 1990 population of 17,582. Nearly 60 percent of the population were black,which was almost five times higher than the county percentage. Only 12.6 percent were ofHispanic origin, which was about half the county average. There was a slightly higherpercentage of children under age 10 and a substantially lower percent of persons age 65 andolder, along with a high average number of persons per household; these trends suggest thepresence of a large number of younger families in their childbearing years. Over 70 percent ofall households were owner occupied in 1990, indicating a non-transient population (i.e., renterstend to move much more frequently than homeowners).

The area west of RMA, Commerce City, in Adams County is not as densely populated asMontbello but still had over 1,700 persons per square mile. In contrast to Montbello, over 85percent of the 1990 population of that area were white and over one-third of the populationclaimed Hispanic origin. The percentages under age 10 and age 65 and over were similar to theAdams County averages. Over 60 percent of households were owner occupied, which suggests arelatively non-transient population.

In contrast, the Offpost Study Area just north of RMA is more rural in character and is moresparsely populated (see Table 3). Only 1,405 persons lived in that 27 square mile area in 1990. Other aspects of the demographic character of the area are similar to the character of AdamsCounty of which it is a part. Over 70 percent of all households were owner occupied in 1990.

To the east of RMA, the newly opened Denver International Airport represents a majorchangein landuse. Those previously open grasslands are undergoing many landuse changes as will thefuture demographic character of that area.

Table 3.

Rocky Mountain Arsenal Population and Housing Data Table (5)
area (6)
(SE of RMA)
City area (7)
(W of RMA)
Study Area (8)
(N of RMA)
Total persons17,58220,5361,405265,038467,610
Total area (sq. mi.)3.4612.0423.031,192153
Persons per sq.mi.5,0821,706612223,051
Percent Male49.250.052.849.648.7
Percent Female50.850.048.250.451.3
Percent White29.585.490.286.772.1
Percent Black59.
Percent American Indian, Eskimo, or Aleut0.
Percent Asian or Pacific Islander3.
Percent Other races6.
Percent Hispanic origin12.634.010.818.623.0
Percent Under Age 1016.717.915.817.313.8
Percent Age 65 and older2.

Table 3 (continued).

Rocky Mountain Arsenal Population and Housing Data Table (9)
City area
Study Area
Households (10)5,5797,18448596,353210,952
Persons perhousehold3.152.832.92.722.17
% Householdsowner-occupied70.862.073.865.549.2
% Householdsrenter-occupied29.
% Householdsmobile homes0.510.913.410.90.3
% Persons ingroup quarters0.
Median value,owner-occupiedhouseholds ($)~65,000~55,000~106,50071,50079,000
Median rentpaid, renter-occupiedhouseholds ($)~400~350~325373339

Land Use and Land Use Controls

Present Land Uses - Onpost

With respect to its former high level of activity, the RMA property can be viewed as a closedindustrial site. RMA employed as many as 3,000 people when it was a fully operationalproduction facility for chemicals, explosives, agricultural chemicals, and pesticides. Currentlythere is relatively little activity on the base. The primary activities that do occur involveadministration, remediation, and maintenance of the facility.

The current land uses at the RMA site has been classified as industrial-commercial, andrecreational. The industrial classification was related to the commercial nature of the existingbuildings: an army administration building, fire department, groundwater treatment facilities,rail classification yard, and a post office (EBASCO, 1990).

The recreational land-use classification of RMA has been related to USFWS uses of RMAincluding guided tours and the regulated "catch and release" fishing from several RMA lakes(EBASCO, 1990). The recreational classification includes individuals classified asbiological/maintenance workers, regulated/casual visitors, and recreational visitors (EBASCO,1994, p. 3-5).

The greatest proportion of acreage at the site is presently classified as a natural habitat forwildlife, which includes a bald eagle management area on the southeastern section (EBASCO,1990).

Restrictions Limiting Onpost Land Use

As a result of the Superfund Amendments and ReauthorizationAct (SARA) of 1986 and otherfactors, an agreement was made among the EPA, U.S. Army, U.S. Department of the Interior,ATSDR, and Shell Oil Company. This agreement, called the Federal Facility Agreement (FFA; EPA, 1989, p. 97-101), set forth the following restrictions on RMA:

  • "The United States shall retain title to the Arsenal...".
  • ..."The United States intends that significant portions of the Arsenal shalleventually be available for beneficial public uses that are consistent with thefollowing restrictions, which shall be maintained and enforced for all the propertywithin the boundary of the Arsenal..." (unless the need for the restriction has beeneliminated as a result of a Response Actions [IRA] or amendment of thisagreement).
  • "Residential development on the Arsenal shall be prohibited."
  • "The use of groundwater located under, or surface water located on, the Arsenalas a source of potable groundwater shall be prohibited."
  • "Consumption of all fish and game taken on the Arsenal shall be prohibited,although hunting and fishing on the Arsenal for non-consumptive use may occurif subject to appropriate restrictions."
  • "Agriculture, including all farming activities such as the raising of livestock,crops, or vegetables, shall be prohibited. Agricultural practices used in ResponseAction of used for erosion control, however, shall be permitted."
  • "Wildlife habitat(s) shall be preserved and managed as necessary to protectendangered species of wildlife to the extent required by the Endangered SpeciesAct (16 U.S.C. 1531 et seq.), migratory birds to the extent required by theMigratory Bird Treaty Act (16 USC 703 et seq.), and bald eagles to the extentrequired by the Bald Eagle Protection Act (16 USC 668 et seq.)."
  • "Other than as may be necessary in connection with a Response Action or as shallbe necessary to construct or a Response Action Structure, no major alterationshall be permitted in the geophysical characteristics of the Arsenal is suchalteration may have likely have an adverse effect on the natural drainage of theArsenal for Response Action Structures, or protection of wildlife habitat."

Additional discussion on restrictions limiting both present and projected future on-site landusesis given in the following discussion of Projected Future Land Uses - Onpost.

Projected Future Land Uses - Onpost

Future, site-specific, land-use at RMA decisions have largely been made. Beginning with theFFA (EPA, 1989) it was agreed and required that significant portions of RMA will be availablefor public benefit including, but not limited to, wildlife habitats and parks. The FFA alsoprovided that limited areas of RMA may also be used for commercial and industrial uses.

The passage of the Rocky Mountain Arsenal Wildlife Refuge Act of 1992 (106 STAT 1961;"RMA Refuge Act") codified and further restricted and defined many of the projected usesdelineated in the FFA. Foremost, the statute sets aside the majority of the acreage of RMA formanagement as a unit of the National Wildlife Refuge System (cf 16 U.S.C. 668dd et seq.) bythe U.S. Fish and Wildlife Service (USFWS). As set forth in Section 4 of the Act (106 STAT.1964-65), the refuge is established for the following purposes:

    1) "To conserve and enhance populations of fish, wildlife, and plants within the refuge,including populations of water-fowl, raptors, passerines, and marsh and water birds.
    2) To conserve species listed as threatened or endangered under the Endangered SpeciesAct as amended (16 U.S.C. 1531 et seq.) and species that are candidates for such listing.
    3) To provide maximum fish and wildlife oriented public use levels compatible withthe conservation and enhancement of wildlife and wildlife habitat (emphasisadded).
    4) To provide opportunities for compatible scientific research.
    5) To provide opportunities for compatible environmental and land use education.
    6) To conserve and enhance the land and water of the refuge in a manner that willconserve and enhance the natural diversity of fish, wildlife, plants, and their habitat.
    7) To protect and enhance the quality of the aquatic habitat within the refuge.
    8) To fulfill international treaty obligations of the United States with respect to fish andwildlife and their habitats."

The refuge act also includes prohibitions against future annexation by local governmententitiesand against the construction of public roads through the refuge. Specific provisions are made fordisposal of Arsenal lands for commercial, highway, and other public use purposes. Lands to bedisposed are:

    1) An area of real property consisting of approximately 815 ac located at the Arsenal, theapproximate legal description of which is section 9, T3S, R67W; W4E2W2 and theW2W2 section 4, T3S, R67W; the W2NW4, W4E2W2, and the SW4SW4 section 33,T2S, R67W; except that area designated shall not include the approximate 63.04 ac containing a U. S. Postal Service facility (Dept. of Army lease No. DACA 45-4-71-6185)and the water wells located in buildings 385, 386, and 387 at the Arsenal and associatedfacilities and easements necessary to operate and maintain the water wells.
    2) To permit the widening of existing roads, an area of real property of not more than100 ft inside the boundary of the Arsenal on
      A) the northwest side of the Arsenal adjacent to Colorado Highway #2;
      B) the northern side of the Arsenal adjacent to 96th Avenue; and
      C) the southern side of the Arsenal adjacent to 56th Avenue.

The disposal of real property described in the act is subject to the perpetual restrictions thatareattached to any deed to such property and that prohibit:

    1) the use of the property for residential or industrial purposes;
    2) the use of the groundwater located under, or surface water located on, the property asa source of potable water;
    3) hunting and fishing on the property, excluding hunting and fishing for non-consumptive usesubject to appropriate restriction; and
    4) agricultural use of the property, including activities such as the raising of livestock,crops, or vegetables, but excluding agricultural practices used in response actions or usedfor erosion control.

The transfer of real property from the Secretary of Army to the Secretary of Interior(USFWS)may only occur after the Administrator of the EPA certifies that environmental cleanup responseactions required at the Arsenal have been completed, except operation and maintenanceassociated with those actions. It is further specified that the Secretary of Army shall retainjurisdiction, authority, and control over the following real property at the Arsenal:

    1) Approximately 12.08 ac containing the South Adams County Water Treatment Plant(Dept. of Army lease No. DACA 45-1-87-6121) and
    2) Approximately 63.04 ac containing a U.S. Postal Service Facility (Dept. of Armylease No. DACA 45-4-71-6185).

Onpost Land Use Prohibitions, IRAs, and BCSs - The Additive Effect

As described, land use restrictions and/or limitations on the uses of environmental media werespecified in the FFA (USEPA, 1989) and made statutory requirements in the RMA Refuge Actof 1992 (106 STAT 1961). Those restrictions include prohibiting groundwater consumption,minimizing exposures to surface water and sediments, hunting and fishing for consumptivepurposes, and other consumptive pathways such as ingestion of vegetable,meat and dairyproducts (EBASCO, 1994, p. 3-1 - 3-7). Those Onpost land use controls result in elimination orfurther reduction of completed or potential pathways of exposure of humans to RMAcontaminants.

The land use controls are, in effect, added levels of mitigation or environmental protectionwhich are added to the effects resulting from the active and ongoing Interim Response Actions(IRAs) and the boundary groundwater containment systems (BCSs). As summarized in Table 4,the net result of this detailed mosaic of mitigation is the a significant reduction or elimination ofnumber of possible pathways of human exposure to RMA contaminants.

The remaining potential pathways of Onpost human exposure to those contaminants includeexposure to contaminated surface soils/sediments and potentially contaminated air. Thosepresent and future Onpost pathways are the focus of subsequent sections of this Assessment.

Present Land Uses - Offpost

Land usage around RMA is characterized by a varied pattern of heavy and light industrial,residential, and agricultural designations (ESE, 1988; HLA, 1992a). Agriculture predominatesto the north and east, residential use to the west and south, and commercial uses primarily to thewest. Heavily industrialized areas are intermixed with residential zones to the west and south. Commerce City, to the west, is associated with heavy industry such as petroleum refineries andconstruction equipment yards. Gravel and sewage treatment facilities to the northwest arelocated near the South Platte River.

The industry which occupied the most acreage adjacent to RMA is the, now closed, StapletonInternational Airport. This airport was, in 1990, the fifth largest in the United States andexperienced rapid growth in recent years. The new Denver International Airport (DIA) on landsto the east of RMA opened in 1995. Originally, DIA was proposed to expand onto RMA land. Those plans were rejected because of both the loud airport noise affecting nearby residentialareas and because of the time required to clean up RMA (EBASCO, 1990).

Several residential areas border the RMA property, primarily to the northwest, west, andsouth(e.g., Commerce City, Irondale, Montbello). Adult and childhood activities associated withresidences (e.g., outdoor play, school activities, home gardening) have been documentedpreviously (Woodward-Clyde, 1990; HLA, 1992b).

Since 1950, off-site agricultural land has been used primarily for grain crops, as temporarilyidlefields, and, to a lesser extent, pasture lands. This area includes approximately 2,500 to 2,700acres of irrigated farm land. Water for most of this land is supplied primarily by a combinationof several irrigation ditches traversing the Offpost Study Area just a short distance northwest ofthe RMA boundary (ESE, 1989a).

The primary field crops for this area are winter wheat, hay, barley, corn for grain and silage,sugar beets, and oats. Other crops grown include sorghum, dry beans, and spring wheat. Of thefield crops listed, winter and spring wheat, barley, sugar beets, and dry beans are all producedfor human consumption (ESE, 1989a).

Pastureland and livestock are not as important to local agricultural as are the grain fields.Pastureland is confined to limited areas, most of which is contiguous to the O'Brian Canal andthe Fulton Ditch (ESE, 1989a).

Information obtained from the Adams County Agricultural Extension Service indicates severalfeedlots and beef/dairy cattle operations have operated within about 20 miles of RMA, to thenorthwest, north, and east (Weston, 1994, p. 3-7).

The current land use within the RMA Offpost Study Area is predominantly agricultural andruralresidential with localized commercial/industrial land uses and open spaces. Areas within theOffpost Study Area are largely used for rangeland and dryland farming, with some ruralresidential areas and scattered areas of intensive agricultural use. Certain areas within theOffpost Study Area are currently zoned and developed for commercial/industrial activities.Commerce City, which is located west of RMA has recently annexed lands within the OffpostStudy Area. Another geographic feature in the Offpost Study Area is Barr Lake State Park(HLA, 1992b, p. I-7).

Farming in the Offpost Study Area ranges from large grain operations covering square milesto small subsistence farms to vegetable gardens. A number of these farms also maintain livestock. Subsistence and hobby farmers often consume a portion of their diet from locally produced vegetables and livestock produced in the Offpost Study Area.

Intentional application of pesticides for pest control purposes likely accounts for the presenceofsome concentrations of pesticides in Offpost Study Area soil. Many of the pesticides detected inOffpost Study Area soil are or have been commercially available and may have been applied foragricultural or residential uses. Those pesticides include organochlorine pesticides (OCPs) andchlorinated hydrocarbon insecticides. The OCPs aldrin, endrin, dieldrin, and isodrin detected inOffpost Study Area soil have been used as insecticides in areas similar to the Offpost Study Areafrom the l940s to the mid-1970s. Aldrin was used in the early l950s to protect cotton againstboll weevils and in the l970s for soil application in grain crops and termite control. In Colorado,dieldrin was used to control insects in field vegetable, grain, and fruit crops (Mullins, 1971) andagainst termites and locusts. Endrin was also used to control a wide range of pests. Theseinsecticides were banned for general uses in 1975 by the EPA. Aldrin and dieldrin may still beused for certain restricted uses such as subsurface insertion for termite control and dipping of non-food roots.

Projected Future Land Use - Offpost

Evaluation of projected future land use at the Offpost Study Area indicates that areas ofcommercial/industrial and recreational land use will increase (Adams County PlanningCommission, 1987). Rural residential (including agricultural) land use is expected to decrease inthe Offpost Study Area (HLA, 1992b).

As an outgrowth of the Offpost remedial investigations, the Offpost Study Area wassubdividedinto zones that differed in the degree or character of contamination. Six zones, differingprimarily on the pattern of groundwater contamination were delineated. Because existing landuse, population density, and water use varies throughout the Offpost Study Area, the existingand projected future land use was then determined for each of the six groundwater contaminationzones (HLA, 1993, p. 25-26, Fig. 6.1). Rural residential land use in Zones 1, 2, and 6 on theOffpost Study Area are expected to remain in rural residential use with use of availablegroundwater for domestic and irrigation uses. Zones 3 and 4, largely purchased and vacated byShell Oil Company are expected to remain unoccupied until after remediation of these Offpostlands is complete. Then those zones will likely become residential or commercial/industrial. It is further forecast that the commercial/industrial land uses of Zone 5 will continue with the resulting limited potential for human exposure to the area groundwater.

Summary: The Cumulative Effect of Land Use Controls, IRAs, and BCSs

The cumulative effect of the IRAs and BCSs implemented from 1979-present and the Onpostland and resource use restrictions adopted or imposed is a substantial reductions or theelimination of many potential pathways of human exposure to contaminants. Other measureshave been taken that temporarily or permanently greatly minimized the potential for humanexposure to contaminants and reduced the number of possible pathways for exposure. Thesemeasures include: the state of Colorado providing bottled water, on an interim basis, to manyprivate well users in the Offpost Study Area and the Shell Oil Company purchase of real estatelocated in the areas of greatest groundwater contamination, thereby eliminating well water use(and potential foodchain contamination) in those areas. Taken together those remediation andmitigation measures have served to greatly reduce the number of potential pathways of humanexposure and the concentration of contaminants in those pathways.

Even though only a small percentage of the contamination emanating from RMA sourcesaffected the Commerce City area west of RMA, the effect of the RMA remediation program hasalso substantially reduced or eliminated pathways of human exposure to non-RMA contaminantsin the Commerce City EPA Study Area as well.

The cumulative effects of completed and ongoing remediation and mitigation measures aresummarized in Table 4. The remaining potential Onpost pathway of exposure to contaminatedsurface soil and air-borne contaminants and the potential Offpost pathways of human exposureto contaminated groundwater, contaminated air, and foodchain components (wild game animals)are indicated in this table. Those pathways will be further evaluated in the following sections ofthis Assessment.

Table 4.

Summary of Remaining Pathways - Environmental Media and Mitigative Measures


Offpost - Exposure to contaminants eliminatedor reduced by BCSs, IRAs, and land use controls. Inorganic and organic chemical contaminants occur beyond BCSs. Some Offpost wells containcontaminants at levels above regulatory or health based values.

Onpost - Use of groundwater prohibited; nopathway remaining.

Surface Water


Offpost - Onpost IRAs minimize Offposteffects. No present pathway of exposure identified.

Onpost - Incidental exposure to lake water whilefishing is possible, but it is not expected to resultin adverse health effects.



Offpost - Low levels of contamination occurlocally, but no pathway of exposure has beenidentified. Shell Oil Co. land purchases and revegetation provisions (Component 22: Colorado,1995) minimize potential for human exposure to contaminants.

Onpost - Land use and access controls eliminateor reduce exposure to high levels of contaminants.Incidental exposure of public & workers to low levels of contaminants may occur.



Offpost - Low levels of contamination occurlocally. No pathway of exposure has been identified.

Onpost - Incidental exposure is possible, but notexpected to result in adverse health effects.



Offpost - Potential exposure limited by OnpostIRAs and land use controls, and ecologic factors.

Onpost - Catch and release fishing regulationseffectively preclude ingestion of contaminants.



Offpost - IRAs have eliminated past pathways ofexposure and minimize potential exposures. Observed low levels of contamination are not site-specific to RMA.

Onpost - IRAs and land use controls eliminateor minimize exposure.

Onpost - IRAs and regulatory controlseliminate or minimize pathways of exposure tocontaminants.

Natural Resource Use

On-Site Water Use

There are several lakes located on the southern sections of the arsenal: Upper Derby, LowerDerby, Mary, and Ladora Lakes. Ladora Lake is the only natural lake. The other lakes werecreated using water from the Highline Lateral. The Highline Lateral is an aqueduct that isconnected to the main Highline Canal, which brings water from the Rocky Mountains into theDenver area.

Surface water drainage at RMA has been complicated by the industrial land uses andassociateddrainage diversions. However, Onpost water is primarily drained by the First Creek and SandCreek Lateral. Water from the First Creek and Sand Creek Lateral is then intercepted by theO'Brian Canal and the Burlington Ditch. Both the O'Brian Canal and the Burlington Ditch areirrigation ditches, which transport water for off-site agricultural purposes. Both the O'BrianCanal and the Burlington Ditch flow to Barr Lake but only the Burlington Ditch continuesnortheastward across the agricultural lands flanking the South Platte River (ESE, 1988).

Drinking water uses of Onpost groundwater and surface water are prohibited by the FederalFacility Agreement (EPA, 1989). Regulated, nonconsumptive, "catch and release" fishing ispermitted in some Onpost RMA lakes (EPA, 1989; 106 STAT. 1966).

Off-site Water Use

Off-site water use (i.e., potable water sources, recreational fisheries) was identified within a12.5mile radius of RMA (cf. ESE, 1988). The Colorado Department of Natural Resources (DNR)Water Conservation Board, the DNR's State Engineering Board (Water Quality), water treatmentplants in Adams County and Denver County, and the Denver Department of Health (WaterQuality) were contacted to identify potable surface water sources (Weston, 1994, p. 3-8). Thosewater bodies designated as potable water supplies were Standley Lake and Marston LakeReservoir. Standley Lake is located about 10 miles west of RMA and Marston Lake Reservoir islocated approximately 1.25 miles southwest of the site.

The surface drainage in the upland area surrounding RMA is generally toward the northwest;drainage from RMA flows to the South Platte River, which flows in a north-northeasterlydirection (ESE, 1988). Therefore, it is unlikely that surface water drainage from RMA wouldhave any effect on potential drinking water sources such as Marston Lake Reservoir or StandleyLake.

Potential fishing areas within the 6-mile radius of RMA were identified during the preparationofthe Onpost and Offpost Study Area human health exposure assessments (EBASCO, 1990; ESE,1989). In addition, the DNR Fish and Game Department (Division of Wildlife) and local parkswere contacted for fishing information (Weston, 1994, p. 3-8).

Except for the limited "catch and release" fishing on-site at RMA, no lakes, ponds, orreservoirswere identified as designated fishing areas within a 3-mile radius of the RMA. However, lyingin the area between a 3- to 6-mile radius of RMA are several lakes and ponds designated asrecreational fishing areas.

The only lake located northeast of the Arsenal is Barr Lake, a nonpotable water body, whichislocated approximately 3.7 miles from the boundaries of RMA. Barr Lake is classified as awildlife refuge on its southern portion, and its northern half is used for recreational purposes,such as sport fishing. The surface waters of Barr Lake are included in the RMA Offpost StudyArea.

Four smaller water bodies located in Adams County, all approximately 5 miles west of RMA,were identified as designated recreational fishing areas: Clear Creek Pond, Engineers Lake,Rotella Park Pond, Grandview Ponds 1 to 4, and three Adams County Fairgrounds ponds.

Numerous gravel pit have been developed along the valley of the Platte River. Those pitsresultin large pond that now support fish populations. TCHD (1994) reports that residents areconsuming fish caught form these ponds that may have not been previously inventoried aspotential fishing areas.

Biological Habitat

RMA lies within the High Plains District of the North Temperate Grassland biome (EBASCO,1992, p. A1-14). The region is dominated by a mosaic of grassland communities with a diversecomponent of wildflowers. Tall grass species are common in moist sites and short grassesprevail in dry areas. Historical patterns of land use have altered the original patterns ofvegetation. Much of the off-post area north and east is used either as cropland or pasture. Mostof the areas to the south, west, and northwest are heavily urbanized. Onpost and off-post humanactivity has disturbed soils and vegetation over large areas resulting in vegetation dominatedeither by a variety of crops, grasses, or weed species and early successional species typical for theregion.

Regional wildlife is dominated by species of prairie, steppe, and savannah communities. Thewildlife inhabiting RMA are those found in similar habitats off post. RMA supports largepopulations of some species such as prairie dog, deer, hawks, and eagles. In contrast tosurrounding areas where those species are hunted or disturbed by human activities, the fencedenclosure of RMA provides a sanctuary for wildlife. Its large acreages of diverse, open habitatsinterspersed with lakes, small intermittent streams, small wooded areas, and tall grass/weedcover-areas, along with an absence of hunting pressure and low levels of human disturbance,have contributed to an abundance of many wildlife species in numbers greater than occur offpost.


Vegetation at RMA is dominated by five broad community types: weedy forbs,cheatgrass/weedy forbs, cheatgrass/perennial grassland, native perennial grassland, and crestedwheatgrass. Trees, shrubs, and minor communities of sagebrush, rubber rabbitbrush, yuccagrassland, cottonwood/willow stands, bottomland meadows, cattail marshes, and ornamentaltrees and shrubs are interspersed within the five broad community types. Further information is given in the Biota RI Report (see EBASCO, 1992, p. A1-15).

Wildlife and Wildlife Resource Management

The wildlife resources of the RMA area are diverse. The character and management of thesewildlife resources influences possible human consumptive uses. The following paragraphs givea brief overview there resources and uses.

The fish species of RMA are those species most common to the region. First Creek supportsplains killifish, fathead minnows, and some green sunfish. North Bog supports carp and fatheadminnows. Largemouth bass, bluegill, bullhead, channel catfish, and northern pike are found inLower Derby Lake, Lake Mary, and Lake Ladora. Sport fishing in those lakes is restricted tocatch and release.

Sport fishing is permitted in nearby off-post waters such as the South Platte River and BarrLake to the northeast of RMA.

Waterfowl are numerous at RMA and the lake and wetland areas of Barr Lake. Canadageese,and ducks are known nesters in those areas. Wading birds observed at RMA are the great blueheron and the black-crowned night heron. Pelicans have also been observed at RMA. Huntingof waterfowl is not permitted on RMA.

Upland bird species of RMA include ring-necked pheasant and mourning doves. While thesebirds cannot be hunted on post, they may be taken on the adjacent off-post lands.

in addition to significant raptor use of RMA during the summer, a large population of raptorsuse RMA during the winter. This high density is attributable to the abundance of prey andperching habitat, coupled with the lack of human disturbance. Long-eared and short-eared owlsare fairly common at RMA and are year-long residents. Great horned owls and barn owls arealso common year-long residents here. The number of barn owls on RMA is difficult todetermine though, because they typically inhabit buildings such as the South Plants which makescounting their number difficult. Rough-legged hawks, ferruginous hawks, red-tailed hawks,golden eagles, and bald eagles are common winter residents. Of those species, the bald eagle islisted as of July 4, 1994 as threatened under the provision of the Endangered Species Act of1973 (16 USC 1531-1536, 1538-1540) and the ferruginous hawk is candidate for listing.

The Bald Eagle Management Area, a 6,700-acre area in the eastern and southern portions ofRMA, is managed and maintained by the U.S. Fish and Wildlife Service. Locally, the baldeagle's diet consists primarily of prairie dogs and rabbits. During the winters of 1987 and 1988,eagles were rarely observed fishing on RMA lakes (EBASCO, 1992, p. A1-18).

Of the mammal populations at RMA, the most conspicuous and extensive population is thatofblack-tailed prairie dogs. Also common are both mule deer and white-tailed deer. Surveysconducted at RMA in 1986-1987 found about 350 mule deer and 125 white-tailed deer or a totalof about 18 deer/sq mi (EBASCO, 1992, p. A1-18). The USFWS estimated that in 1993 thedeer population had increased to about 500 mule deer and 150 white-tailed deer, or more than 24deer/sq mi (USFWS, 1993b, p. 12). Such population densities are high for the region, and bothspecies are more abundant at RMA than off post (EBASCO, 1992, p. A1-18).

Conservation and management of RMA wildlife resources is accomplished through acooperative agreement between the U.S. Fish and Wildlife Service (USFWS) and the Army. The USFWS has three areas of responsibility under this agreement: contaminants, conservationand mitigation, and public relations. Under the first responsibility, the USFWSreviewscontaminant-related documents pertaining to RMA and identifies ways to minimize fish andwildlife exposure to contaminants and makes recommendations to the Army on ways toimplement those protective measures. The Service conducts extensive investigations todetermine the effects of contaminants on wildlife health at the Rocky Mountain Arsenal nationalWildlife Area. The Service also has initiated a long-term biomonitoring program in 1993specifically to address the affect of contaminants on fish and wildlife and to monitor andevaluate the effects of remediation on pathways of wildlife exposure to those contaminants. Currently, USFWS and several universities are studying at least 20 species of fish and wildlife. Second, the USFWS utilizes its technical skills to conserve and protect wildlife and tomitigatehabitat loss during site cleanup. Third, the USFWS helps to publicize the wildliferesources ofRMA and undertakes programs that enable local community members to learn more about theresources to be found at RMA (EBASCO, 1992, p. A1-19). In the five year period endingNovember 1994 over 153,000 people have been involved in the Onpost activities and tours andover 177,000 people have participated in outreach activities such as presentations and specialprograms (RMA, 1991, p. 32; Long, 1994, Personal Communication).

Health Outcome Data

The availability of health information sources or "health outcome data" was investigated toassess community health concerns and possible health conditions related to chemicals associatedwith RMA. Health outcome data are records of birth, death, and illness (e.g., investigations ofrates of disease in a community, health studies by universities or other researchers, new cases ofcancer, deaths from cancer, and medical discharge records).

County level data, such as cancer registries, can be used to determine the general health of anarea's population. By reviewing such data, increases in specific diseases within the county canbe identified. Knowledge of diseases that are prevalent in an area is important because somemay be caused by exposure to environmental contaminants. By identifying clusters of diseasethat may be linked to chemical exposures, sometimes areas can be targeted for furtherinvestigation.

Care should be taken in evaluating such health data, however, especially if there is asignificantdifference in the size of the population at risk of exposure to site contaminants and the size ofthe smallest population unit for which health outcome data are available. For example, likelyadverse health effects caused by site contaminants would not be apparent if the number of at-riskpeople in the community is 100, but the smallest group for which data is available for is basedon a group of 100,000. With careful evaluation, the data can provide general occurrences ofdiseases in an area.

At RMA, there have been numerous site-specific activities conducted by several differentagencies. A variety of investigations, activities, and population-specific exposure studies havebeen conducted to investigate whether adverse health effects have occurred and whether thoseadverse health effects might possibly be related to past exposure to RMA hazardous substancesthrough drinking water and inhaling wind-dispersed substances that have or may have migratedfrom RMA.

The following is a list of activities/investigations that have occurred or are on-going at, oradjacent to, RMA (see the Health Outcome Data Evaluation section of this assessment foradditional information on these studies):

  1. Health Consultation on Rocky Mountain Arsenal (completed).

    Health Consultation on Rocky Mountain Arsenal. Agency for Toxic Substances & Disease Registry. 1988. (ATSDR, 1988a)

  2. Preliminary Health Assessment for Rocky Mountain Arsenal(completed).

    Preliminary Health Assessment for Rocky Mountain Arsenal. Agency for ToxicSubstances & Disease registry. December 1988. (ATSDR, 1988b)

  3. Second Health Consultation on Rocky Mountain Arsenal (completed).

    Final Health Consultation on Rocky Mountain Arsenal Basin F. Agency for ToxicSubstances & Disease Registry. July 20, 1989. (ATSDR, 1989)

  4. Investigations Addressing Complaints from Residents Northwest of RMA(completed).

    Medical Evaluations of Irondale Trailer Park Residents - Unpublished Data. Memo fromDr. Ellen Mangione, Colorado Department of Public Health & Environment, DatedMarch 31, 1989. (CDPHE, 1989)

    Survey of Health Complaints - Unpublished Data. Tri-County Health Department.December - January 1989. (TCHD, 1989)

    Risk Calculations - Unpublished Data. Colorado Department of Public Health &Environment. 1989. (ATSDR, 1993a)

  5. Cancer Incidence in the Northeastern Denver Metro Area (completed).

    Cancer Incidence in the Northeastern Denver Metro Area: Report of the Ad Hoc Panel. Colorado Department of Public Health & Environment, Disease Control andEnvironmental epidemiology Division. August 1993. (CDPHE, 1993a)

  6. Cancer Incidence in the Montbello Community (completed).

    Cancer Incidence in the Montbello Area, Denver, Colorado. Colorado Department ofPublic Health & Environment (CDPHE). Letter from Michael P. Wilson, CDPHE. August 9, 1993. (CDPHE, 1993b)

  7. The RMA Exposure Study (1989-1991): Parts I (completed) and II (draft forpubliccomment; final pending).

    Final Report - Rocky Mountain Arsenal Pilot Study, Part I: Analysis of Exposure toArsenic and Mercury. Agency for Toxic Substances & Disease Registry, Division ofHealth Studies and Colorado Department of Public Health & Environment, Division ofDisease Control and Environmental Epidemiology. September 1993. (ATSDR, 1993a)

    Draft for Public Comment - Rocky Mountain Arsenal Pilot Study, Part II: Analysis ofExposure to Diisopropylmethylphosphonate, Aldrin, Dieldrin, Endrin, Isodrin andChlorophenylmethylsulfone. Agency for Toxic Substances & Disease Registry, Divisionof Health Studies; Colorado Department of Public Health & Environment, Division ofDisease Control and Environmental Epidemiology; and Colorado State University,Department of Environmental Health. September 1995. (ATSDR, 1995)

  8. Reproductive, Neurobehavioral, and Other Disorders in CommunitiesSurroundingthe RMA (in draft).

    Draft for Public Comment - Reproductive, Neurobehavioral and Other Disorders inCommunities Surrounding the Rocky Mountain Arsenal. Colorado State University,Department of Environmental Health. September 1995. (CSU, 1995)

  9. Mortality Among Workers at Shell's Pesticide Manufacturing Plant at RMA(completed).

    Mortality Among Workers at a Pesticide Manufacturing Plant. Amoateng-Adjepong, etal. Jour. of Occupational and Environmental Medicine, v. 37, n. 4, p. 471 - 478. April1995.


Identifying and addressing community health concerns about hazardous waste sites is animportant part of the public health assessment process. This part of the document identifiescommunity concerns about possible site-related health effects. ATSDR is not empowered,however, to investigate or make recommendations on other community concerns dealing withproperty values or legal liability issues.

Community health concerns about RMA were gathered during two separate PublicAvailabilitySessions. During January 29 - February 1, 1993, ATSDR met with citizens in the Montbelloneighborhood; thirty-two citizens attended. About half of those persons came seekinginformation on the SQI IRA and the possible environmental or health effects of that action. Throughout the drafting of this Assessment, ATSDR has inquired about and identified healthconcerns from discussions with our ATSDR Regional Representatives, Tri-County HealthDepartment, Colorado Department of Public Health & Environment, EPA, and other localofficials.

During November 1-4, 1993, ATSDR held eight PublicAvailability Sessions in Commerce City,Cherry Creek, Montbello, and Henderson. Although those sessions were publicized through ourregional representatives, newspapers, radio, television, and approximately 1800 flyers, onlyseventeen citizens attended those sessions. After those sessions, ATSDR contacted localphysicians and health professionals to follow up on specific health conditions and concerns. Atthe sessions, there were specific health concerns mentioned as well as concerns about the currentstatus of SQI, DIMP in groundwater, present air quality, and future effects from remediation ofon-site soils. ATSDR will continue to address additional community health concerns as they areidentified through our ATSDR Regional Representatives in Denver, Colorado.

The Army asked Tri-County Health Department to establish a public telephone "hotline" toprovide the public an easy way to express their health concerns associated with the startup andoperation of the RMA Submerged Quench Incinerator (SQI; Dan Collins, TCHD, Dec. 13, 1993,Personal Communication). The "hotline" was established on December 15, 1993. ATSDR hasreviewed the Tri-County Health Department SQI Hotline records for additional health concernsrelated to RMA.

The community health concerns listed below have been brought to ATSDR's attention. Thesecommunity health concerns are evaluated in the Public Health Implications section of thisAssessment.

Remediation Concerns:

  • What are the possible offpost health effects from onpost soil cleanup activities?
  • What are the possible offpost health effects from SQI emissions?
  • Will RMA remediation activities result in adverse health effects from diminished air quality in the Montbello neighborhood, directly south of RMA?
  • Will SQI be used for non-RMA hazardous wastes?

Specific Health Concerns:

  • Is there an excess of lupus in the Montbello community?
  • Is there an excess of cancer incidence in the Montbello neighborhood?
  • Is it safe to eat vegetables grown in gardens irrigated by private well water in Commerce City or north or RMA?
  • Are there elevated levels of learning disabilities in the children residing in Commerce City, near the western boundary of RMA?
  • Has Diabetes been linked to the chemicals detected in private wells north or northwest of RMA? Could it be linked to prenatal exposure to those chemicals?
  • Has Multiple Chemical Sensitivity been associated with Arsenal chemicals?
  • Have respiratory conditions such as asthma been associated with Arsenal chemicals?
  • Has breast cancer been associated with Arsenal chemicals?
  • Has throat cancer been associated with Arsenal chemicals?
  • Has stomach cancer been associated with Arsenal chemicals that have been detected in wells north, northwest, or west of RMA?
  • Is there an excess of kidney cancer north, northwest, or west of RMA?

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