Soo Line Garden MPRB Response to Environmental Conditions Q&A

1. When did the Minneapolis Park and Recreation Board (MPRB) assume ownership of the site?
   • The MPRB assumed ownership of the Soo Line Garden site in 2010. It previously was tax forfeited land owned by Hennepin County.
2. Was it already being used as a garden when the MPRB accepted ownership?
   • According to the Soo Line Community Garden web site, it has been used continuously as a community garden since 1991.
3. What was on the Soo Line Garden site before it was a garden? o The site was previously occupied by railroad uses and a grain storage, both of which are known for the use of products now considered to be hazardous. These uses commonly result in soil contamination. At some point, the site was partially filled with bricks, concrete, and other urban rubble.
4. How is Hennepin County involved now?
   • Hennepin County initiated a proposal to build a Midtown Greenway access ramp project at the site of the Soo Line Garden. As part of that proposal, the county hired Landmark Environmental to conduct an environmental review of the site, including the collection and analysis of soil samples in areas where the proposed trail would be located.

1. Who tested the soil most recently at Soo Line Gardens?
   • Landmark Environmental, hired by Hennepin County.
2. When was it tested?
   • On December 21, 2023 a preliminary on-site screening detection was performed, and soil samples were collected and submitted to a testing laboratory.
   • On February 8, 2024, the preliminary laboratory results were delivered to Hennepin County.
   • On February 28, 2024, the final investigative report was delivered to Hennepin County.
3. Why is the soil being tested now?
   • Hennepin County is required to conduct an environmental review as part of its proposed access ramp to Midtown Greenway through this location.
4. What were the test results?
   • Analysis of the collected samples show two materials of concern at various locations and varying depths of collection. Specifically, Landmark found levels of Diesel Range Organics (DRO) and Polycyclic Aromatic Hydrocarbons (PAHs) that exceed thresholds set by the Minnesota Pollution Control Agency (MPCA). The county compiled its current soil investigation with two past investigations, the aggregate of which show similar contamination widely distributed through the site (not just along the route of the proposed trail).
5. When did MPRB find out about contamination?
   • Hennepin County provided an update to MPRB on December 22, 2023 indicating concrete debris was encountered during on-site investigations, no contamination was detected onsite from the preliminary screening detection tool, and the samples had been submitted to a laboratory for comprehensive analytical testing.
   • Hennepin County provided preliminary findings on February 12, 2024 indicating buried debris was encountered, and attached a map showing sampling locations and results associated with each location. Several contained some levels of DRO and PAHs.
   • Hennepin County met with MPRB on February 27, 2024 to discuss its proposed trail design and, as a part of that discussion, shared the preliminary results of its environmental review.

Hennepin County emailed MPRB both full reports of findings on February 28, 2024. On the same day, MPRB forwarded the reports to Braun Intertec, a full-service geotechnical, environmental consulting and testing firm, requesting an independent review of the materials provided by the county.

Braun Intertec provided its initial findings to MPRB on March 11, 2024.

6. When was the last time testing was done?
   • Soil investigations were conducted in 1999 and 2001, before MPRB acquired the site. While the testing at that time met standards for use of the site for gardening, the investigations demonstrated the presence of soil contamination similar to the results of the Landmark Environmental investigation.
7. Why hasn’t there been soil testing since 2001?
   • The Soo Line Garden property was transferred to MPRB as a garden. The MPRB considers this garden to be a “legacy garden,” meaning that the Soo Line Community Garden is responsible for managing the garden. Perpetuation of the garden occurs through an annual permit, which requires the gardening entity to provide all administrative services including selecting gardeners, maintaining liability insurance, and conducting soil testing. The MPRB has agreements with organizations allowing four such “legacy gardens” in the park system. All other gardens are managed directly by the MPRB.
8. How could the site be found suitable for gardening in 2001 but have soil contamination in 2023? What changed?
   • In 1999 and 2001, the MPCA allowed soil tests to be averaged across a site, or for composite samples (soils mixed from several locations) to be used in determining suitability for a particular use. Averaging as a means of determining suitability is no longer a commonly used practice by the MCPA.

1. Is there a danger for those who have gardened in the soil?
   • The MPRB’s independent consultant notes DRO and PAHs should be considered hazardous substances. MPCA notes that some PAHs, either individually or combined, can cause adverse health effects, including cancer. Inhaling high levels of PAHs has caused respiratory effects and suppressed immune system in humans. Direct contact with DROs can also cause adverse health effects.
2. Is there a danger for those who have consumed produce grown in the soil?
   • DROs bind strongly to soil particles so are not easily absorbed by plants. PAHs may be absorbed by plant roots and leaves. Beyond that, the MPRB does not know enough to determine the actual hazard. The MPRB is continuing its work with Braun Intertec to better define impacts.
3. Where can I find reputable information on DROs and PAHs in urban gardening settings?
   • https://www.pca.state.mn.us/pollutants–and–contaminants/polycyclic–aromatic–hydrocarbonspahs
   • https://www.health.state.mn.us/communities/environment/hazardous/topics/gardurbsoil.html o https://www.minneapolisparks.org/wp–content/uploads/2024/03/Unregulated–pdf
4. Will gardening be allowed at the Soo Line Garden site in 2024?
   • The MPRB has determined the issues at the garden should be approached with an abundance of caution. As a result, there will be no gardening at the site in 2024.
5. Where can the Soo Line plot holders garden in 2024?
   • The MPRB is researching other nearby areas that may be suitable for a temporary garden.
6. How does this impact Hennepin County’s proposal for an accessible path?

• Resolution 2024–54 to prepare a cooperative construction agreement with Hennepin County to design and construct an accessible bike and pedestrian trail through the Soo Line Gardens site will be taken up at the March 20, 2024 board meeting. Next steps

What happens next?

While nothing is definitive at this point, the MPRB will, most likely enroll in MPCA’s Voluntary Investigation Cleanup program. As a non-responsible party, the MPRB can gain technical assistance related to methods of addressing contamination by participating in the VIC program. A Response Action Plan and Construction Contingency Plan will result. The former describes the process of addressing known contamination; the latter addresses the proper methods of dealing with materials revealed during the soil replacement. Work will proceed as quickly as practicable once proper procedures have been defined. A timeline will be shared publicly when the necessary actions are better known.

1. What does “remediation of the site” mean? o Under consultation with soil scientists and the MPCA, the MPRB will most likely remove soil to a depth necessary to provide for safe gardening, install a membrane as a “warning” to limit deeper future excavation, and replace soils with material suitable for gardening.
2. When will the Soo Line Garden be ready for gardening? o The MPRB will take actions necessary to return the site to its gardening use as soon as practicable.
3. What will happen to Hennepin County’s proposed accessible connection to the Greenway?
4. The MPRB’s primary goal is to understand the process for safe remediation of the garden and to take action to return it to garden use as soon as practicable. As the MPRB does that, it will establish an engagement process to determine if features like the accessible connection should be a part of the garden.
5. Who pays for cleanup costs?
6. The MPRB will apply for a funding to support remediation through Hennepin County’s Environmental Response Fund and other sources as necessary and appropriate.