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HomeMy WebLinkAboutRoyal Golf Club Residential Dev Comment Ltr MnPCA Minnesota Pollution Control Agency 520 Lafayette Road North I St.Paul,Minnesota 55155-4194 1 651-296-6300 800-657-3864 1 Use your preferred relay service I info.pca@state.mn.us I Equal Opportunity Employer November 23, 2016 Mr. Stephen Wensman Planning Director City of Lake Elmo 3800 Laverne Avenue North Lake Elmo, MN 55042 Re: Royal Golf Club Residential Development Environmental Assessment Worksheet Dear Mr. Wensman: Thank you for the opportunity to review and comment on the Environmental Assessment Worksheet (EAW) for the Royal Gulf Club Residential Development project (Project) located in the city of Lake Elmo, Washington County, Minnesota.The Project consists of the preparation of 222 acres of land for residential development. Regarding matters for which the Minnesota Pollution Control Agency(MPCA) has regulatory responsibility and other interests,the MPCA staff has the following comments for your consideration. Permits and Approval Required (Item 8) The table in this section of the EAW does not include the MPCA 401 Water Quality Certification. Water Resources(Item 11) • Specific in-water best management practices such as silt curtain,construction during low flow or winter conditions, cofferdam, or check-dams, etc. should be included in the EAW. Please note that isolated wetlands remain under MPCA jurisdiction as waters of the state and mitigation may be required. Wetland evaluation is on a case-by-case basis. • It appears that the golf course will continue to use groundwater for potable, irrigation, fire protection, and maintenance use. It is important to note that the location of this development lies within known areas of aquifer contamination.The development overlies a perfluorochemical groundwater plume that has impacted groundwater quality in each of the primary drinking water aquifers present. Recent groundwater monitoring in the area of Horseshoe Lake has indicated the presence of perfluorochemicals at levels in excess of U.S. Environmental Protection Agency (EPA) health advisory levels. Less than 1 mile to the north and east of the development lies the Trichloroethene (TCE) groundwater plume associated with the Baytown Township Groundwater Plume Site.The TCE plume has impacted groundwater quality in each of the primary drinking water aquifers present. Mr. Stephen Wensman Page 2 November 23, 2016 Care should be exercised when using groundwater in this region for potable and irrigation purposes.The EPA recently issued significantly lower health advisory levels for several perfluorinated substances. Because the specific configuration of the groundwater plumes in the area are not well understood and likely vary over time, it is not possible to accurately predict whether a well that has been clear of contamination in the past will remain clear of contamination in the future. Lake Elmo, Horseshoe Lake, several small drainage ponds, and ditches within the golf course area and further downstream have been shown to be contaminated with perfluorochemicals at levels in excess of EPA health advisory levels. Care should be exercised when using surface water from these areas for irrigation purposes so as to minimize the potential for human and environmental exposure to these contaminants. Contamination/Hazardous Materials/Wastes(Item 12) This section refers to a natural gas pipeline that runs across part of the site.The Project proposer should contact the Office of Pipeline Safety to determine the appropriate setbacks for this structure. The Investigation History refers to a "Possible on-site disposal area that was later confirmed to be located on the adjoining property to the southeast..." This disposal area is not identified on any maps. Please clarify if the disposal area has been reported to the MPCA or State Duty Officer. Please provide the location of the disposal area. The section regarding "PFCs and Area Groundwater Contamination" does not capture the potential risks posed by groundwater contaminated by the PFC sources. The plume of groundwater contaminated with perfluorochemicals appears to extend beneath the site and further toward the east. The golf course well sampling results referred to do not comply with routine compliance sample results reporting protocols.There is no indication regarding any quality control aspects of the results. If this data is intended to be used for this report, please provide an adequate presentation of the data. A summary table deep within an appendix is not an appropriate presentation of such data. Assuming that this is an oversight,the results do indicate that there are a number of perfluorochemicals present in the samples. However,the regulatory limits referred to are no longer current. The EPA issued revised drinking water criteria in 2016. The EAW does not discuss how soil contaminated with materials other than agricultural chemicals will be handled. The MPCA recommends that the site be entered into the MPCA Brownfield Program (formerly called the Voluntary Investigation and Cleanup Program) in order to provide regulatory oversight with regard to non-agricultural related contamination issues. Accidental spills or releases from on-site equipment, buried rubble, municipal solid waste, buried demolition waste, etc. are situations regulated by the MPCA.The Brownfield Program provides technical assistance and issuance of various liability assurance letters to promote the investigation, cleanup, and redevelopment of property that is contaminated with petroleum and/or hazardous substances. Mr. Stephen Wensman Page 2 November 23, 2016 We appreciate the opportunity to review the Project. Please provide the notice of decision on the need for an Environmental Impact Statement. Please be aware that this letter does not constitute approval by the MPCA of any or all elements of the Project for the purpose of pending or future permit action(s) by the MPCA. Ultimately, it is the responsibility of the Project proposer to secure any required permits and to comply with any requisite permit conditions. If you have any questions concerning our review of this EAW, please contact me via email at Karen.kromar@state.mn.us or via telephone at 651-757-2508. Sincerely, all Karen Kromar Planner Principal Environmental Review Unit Resource Management and Assistance Division KK:bt cc: Dan Card, MPCA, St. Paul Bill Wilde, MPCA, St. Paul Greg Small, MPCA, St. Paul Teresa McDill, MPCA, St. Paul