Allendale Elementary School Indoor Environmental Sampling

1. Allendale Elementary School Indoor Environmental Sampling Massachusetts Department of Public HealthCenter for Environmental HealthEnvironmental Toxicology Program December 13, 2006

2. Overview • Background • Establishing Protocols to Conduct Sampling • Sample Collection Process • Analytical Laboratories and Analyses • Environmental Results/Discussion • Conclusion • Recommendations

3. Allendale Elementary School • Located in Pittsfield, MA • Built in early 1950s on land adjacent to GE landfill (Hill 78) • Soil used to level school property taken from GE property • 1990- MDEP conducted soil testing and detected elevated levels of PCBs in surface and subsurface soil • Throughout 1990s, various remedial actions taken involving school soil

4. Hill 78 Landfill • Located approximately 800 feet from school building and 300 feet from school property • According to GE/EPA/Pittsfield Consent Decree, hazardous waste from the GE sites would be placed in Hill 78

5. Area Map

6. View from Rear of School

7. Background on MDPH Involvement • In October, contacted by BOH, which relayed concerns • MDPH/CEH first conducted indoor environmental testing at Allendale School in November/December 2005: • Collected wipe, vent filter, and air samples • Results showed no detectable levels of PCB Aroclors • MDPH/CEH subsequently learned of 2 unit ventilator filter samples from the school collected by a community resident and analyzed by a lab in New York (SUNY) that found low levels of PCBs using different analytical technique (PCB congener method) • To best address continuing concerns, MDPH/CEH conducted add’l sampling in collaboration with all interested parties • At request of some members of Allendale community, offered to conduct blood testing for PCBs

8. Indoor Environmental Sampling Workgroup • Prior to indoor environmental testing, MDPH/CEH formed a workgroup to assist in protocol development • Composed of representatives from MDPH, MDEP, Pittsfield BOH, Housatonic River Initiative, Allendale School Task Force, State University of New York at Albany (SUNY), Southwest Research Institute (SWRI), and Spectrum Analytical, Inc. (SAI) • USEPA provided technical assistance

9. Indoor Environmental Sampling Workgroup • From January until May, convened several meetings and conference calls • Composed a draft sampling and analysis protocol • Outlined sample locations, types of samples, etc • Discussed using three laboratories to analyze samples for both Aroclors and congeners • Released to the public for comment in late May • Protocol revised; final protocol and response to comments included in report • Primary mission to have comprehensive/uniform results to address concerns of Allendale School community

10. Environmental Sample Collection • MDPH/CEH contracted with ECS, an environmental consulting firm, to collect samples • Timing • Second and Third week of June • Most optimal weather conditions • GE Disposal Site active • EPA monitoring ambient air

11. Types of Environmental Samples • Surface Wipes • Air (Indoor, and for comparison, Outdoor) • Carpet Dust • Vacuum Cleaner Bag Dust • Unit Ventilator Filters

12. Environmental Sample Collection • In order for three laboratories to analyze similar samples, the samples needed to be split or co-located • Split samples are those collected and then divided into portions for multiple laboratories to analyze • Air Samples • Dust from Vacuum Cleaner Bags Samples • Co-located samples are samples collected in close proximity to each other when split samples are not possible • Surface Wipe Samples • Carpet Dust Samples • Unit Ventilator Filter Samples

13. Surface Wipe Samples • Set Locations • Four classrooms • Window pane • Window sill • Bookcase • Wall opposite outside door • Walls on both sides of two main corridors • Gymnasium windowsill • Locations Chosen On-Site • Health office ceiling vent • Inside unit ventilator • Ceiling fan blade • Storage bin cover • Ceiling pipe • Top of VCR • Total of 81 co-located samples collected

14. Air Samples • Two classrooms • One outside location in rear of building \ • Two sampling rounds of 24/hr each • Total of 6 split samples collected

15. Carpet Dust Sample • Kindergarten room • Total of 3 co-located samples collected

16. Vacuum Cleaner Bag Dust Samples • Two vacuum cleaners used to clean throughout school • New vacuum cleaner bags installed on Monday and removed on Friday • Total of 2 split samples • Consultant maintained possession of vacuum cleaners when not in use

17. Unit Ventilator Filter Samples • Unit ventilators provide classrooms with outside air and circulate inside air • Two classrooms • Total of 6 co-located samples

18. Sample Analysis • PCBs • PCBs is a term used to describe a group of chemicals • Congeners are individual PCBs; there are 209 of them • Aroclors are commercially produced mixtures of PCB congeners • PCBs were used in electrical transformers • PCBs are ubiquitous • Samples were tested for both PCB Aroclors and PCB congeners to best address comparability of techniques • SWRI (Aroclor and congener) • Spectrum Analytical (Aroclor) • SUNY (congener)

19. Sample Methods • SWRI: Aroclors and congeners • Modified USEPA Method TO-4A and SWRI TAP • Aroclors- GC/ECD • Congeners- GC/MS • SAI: Aroclors • USEPA Method TO-4A and USEPA Method SW846:8082 • GC/ECD • SUNY: Congeners • Two research papers published by SUNY • GC/MS

20. Sample Evaluation • Health-based Screening Values • Used to determine whether chemicals found at a location need further evaluation • Specific to each chemical and each environmental medium (soil, air) • Generated by ATSDR, U.S. EPA, etc • Scientifically peer-reviewed or based on scientifically peer-reviewed values • Available for PCBs in air and soil (dust) • Clean-up Standards and Guidelines • Used to determine whether chemicals need to be cleaned/removed • Available for PCBs in surface wipes

21. Sample Evaluation • For each Aroclor and congener, laboratories have detection limits • Detection limit is minimum level that can be quantified with confidence • When laboratories do not detect a quantifiable level, it is reported as a non detect (ND) • In instances where laboratories report both quantifiable levels and ND, health assessors can evaluate the results assuming that non detects represent levels that were present at ½ the detection limit

22. Surface Wipe Results Cleanup Guideline: 0.1 (CA) Cleanup Standard: 10 (USEPA) • Three samples, two collected from the gymnasium windowsill and one from the nurses room ceiling vent, were slightly above a CA recommended cleanup guideline but well below the EPA cleanup standard • Two of these samples slightly exceeded the CA recommend cleanup guideline when total PCBs are summed assuming ND= ½ DL • The gymnasium windowsill and ceiling vent locations were visibly dirty • Importantly, opportunities for exposure not expected to result in health concerns under the most conservative exposure assumptions

23. SAI Indoor Air Results for Aroclors Results in µg/m3

24. SWRI Indoor Air Results for Aroclors Results in µg/m3

25. SWRI Indoor Air Results for Congeners Results in µg/m3

26. SUNY Indoor Air Results for Congeners Results in µg/m3

27. Indoor Air Results • SAI and SWRI results did not exceed any screening values • One sample, at 0.0114 µg/m3 from Classroom 28, was similar to an ATSDR screening value (0.01 µg/m3) • SUNY reported detections in QA/QC blank analyses for air • SUNY concentrations may be overestimates of actual concentration • Opportunities for exposure not expected to result in health concerns under the most conservative exposure assumptions Sample was lower than levels cited in literature

28. SAI Outdoor Air Results for Aroclors Results in µg/m3

29. SWRI Outdoor Air Results for Aroclors Results in µg/m3

30. SWRI Outdoor Air Results for Congeners Results in µg/m3

31. SUNY Outdoor Air Results for Congeners Results in µg/m3

32. Outdoor Air Results • One sample reported by SUNY at 0.0117 µg/m3 was similar to an ATSDR screening value • SUNY reported detections in QA/QC blank analyses for air • SUNY concentrations may be overestimates of actual concentration • Opportunities for exposure not expected to result in health concerns under the most conservative exposure assumptions • Samples analyzed by laboratories were similar to or less than BCC background and EPA Allendale School samples for outdoor air

33. SAI Carpet Dust Results for Aroclors Results in mg/kg

34. SWRI Carpet Dust Results for Aroclors Results in mg/kg

35. SWRI Carpet Dust Results for Congeners Results in mg/kg

36. SUNY Carpet Dust Results for Congeners Results in mg/kg

37. Carpet Dust Results • One analysis found a level (0.526 mg/kg) slightly above one soil screening value, when total PCBs are summed assuming ND = ½ DL, but less than DEP soil standard for residential homes • Screening value derived based on lifetime exposure (70 years) • Continuous exposure to this level is not expected to result in health concerns in children or faculty Maximum level at Allendale (0.526) lower than average levels found in indoor dust elsewhere

38. SAI Vacuum Dust Results for Aroclors Results in mg/kg

39. SWRI Vacuum Dust Results for Aroclors Results in mg/kg

40. SWRI Vacuum Dust Results for Congeners Results in mg/kg

41. SUNY Vacuum Dust Results for Congeners Results in mg/kg

42. Vacuum Dust Results • Two laboratories detected PCBs (0.502 and 0.534, and 1.285 and 1.292 mg/kg) at levels higher than soil screening values when total PCBs are summed assuming ND= ½ DL, but less than DEP soil standard for residential homes • When ND=0, all levels are lower than any available screening value • Opportunities for exposure not expected to result in health concerns • Levels are lower than those found in other locations

43. Unit Ventilator Filter Results • Levels of PCBs detected by SWRI and SUNY • No health-based screening values or cleanup standards • Review levels found in other samples from those classrooms Results in µg/vent

44. Room 21- Air Samples Results in µg/m3

45. Room 24- Surface Wipe Samples Results in mg/kg Cleanup Guideline: 0.1 (CA) Cleanup Standard: 10 (USEPA)

46. Conclusions • Results from indoor environmental PCB testing at the Allendale School did not reveal unusual opportunities for PCB exposures to the Allendale School community. • One sample (out of 98) had detections of either Aroclors or congeners exceeding any available screening guideline or regulatory standards. This sample was taken from a windowsill in the gymnasium located 10 feet from the floor. This sample result was slightly higher than the CA clean-up guideline, however, well below the USEPA cleanup standard for wipe samples. • While 2 of 98 samples slightly exceeded the CA clean-up guideline assuming non-detectable Aroclors or congeners were present at one-half the detection limit, these concentrations under conservative exposure assumptions would not be expected to result in health effects. • Two air samples were measured at the ATSDR screening level. SUNY reported that these concentrations were likely overestimated due to contamination in the blanks. • Results of indoor environmental samples reported in the Allendale School were lower than those reported in other studies in Massachusetts and North Carolina for indoor environments, including schools, day care centers, and homes.

47. Recommendations • MDPH/CEH recommends that more aggressive cleaning of surfaces not routinely cleaned (e.g., windowsills) be undertaken and regularly conducted. • MDPH/CEH will respond to any public comments received on this public comment release report and prepare a final report that includes responses to all comments received. • At the request of the Pittsfield Board of Health and/or community residents, MDPH/CEH will evaluate any ambient air results of testing being conducted by the US EPA that may be of concern.