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

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

3. Allendale Elementary School Located in Pittsfield, MA Located in Pittsfield, MA Built in early 1950s on land adjacent to GE landfill (Hill 78) Built in early 1950s on land adjacent to GE landfill (Hill 78) Soil used to level school property taken from GE property 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 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 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 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 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 In October, contacted by BOH, which relayed concerns MDPH/CEH first conducted indoor environmental testing at Allendale School in November/December 2005: MDPH/CEH first conducted indoor environmental testing at Allendale School in November/December 2005: Collected wipe, vent filter, and air samples Collected wipe, vent filter, and air samples Results showed no detectable levels of PCB Aroclors 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) 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 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 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 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) 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 USEPA provided technical assistance

9. Indoor Environmental Sampling Workgroup From January until May, convened several meetings and conference calls From January until May, convened several meetings and conference calls Composed a draft sampling and analysis protocol Composed a draft sampling and analysis protocol Outlined sample locations, types of samples, etc Outlined sample locations, types of samples, etc Discussed using three laboratories to analyze samples for both Aroclors and congeners Discussed using three laboratories to analyze samples for both Aroclors and congeners Released to the public for comment in late May Released to the public for comment in late May Protocol revised; final protocol and response to comments included in report 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 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 MDPH/CEH contracted with ECS, an environmental consulting firm, to collect samples Timing Timing Second and Third week of June Second and Third week of June Most optimal weather conditions Most optimal weather conditions GE Disposal Site active GE Disposal Site active EPA monitoring ambient air EPA monitoring ambient air

11. Types of Environmental Samples Surface Wipes Surface Wipes Air (Indoor, and for comparison, Outdoor) Air (Indoor, and for comparison, Outdoor) Carpet Dust Carpet Dust Vacuum Cleaner Bag Dust Vacuum Cleaner Bag Dust Unit Ventilator Filters 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 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 Split samples are those collected and then divided into portions for multiple laboratories to analyze Air Samples Air Samples Dust from Vacuum Cleaner Bags 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 Co-located samples are samples collected in close proximity to each other when split samples are not possible Surface Wipe Samples Surface Wipe Samples Carpet Dust Samples Carpet Dust Samples Unit Ventilator Filter Samples Unit Ventilator Filter Samples

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

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

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

16. Vacuum Cleaner Bag Dust Samples Two vacuum cleaners used to clean throughout school Two vacuum cleaners used to clean throughout school New vacuum cleaner bags installed on Monday and removed on Friday New vacuum cleaner bags installed on Monday and removed on Friday Total of 2 split samples Total of 2 split samples Consultant maintained possession of vacuum cleaners when not in use 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 Unit ventilators provide classrooms with outside air and circulate inside air Two classrooms Two classrooms Total of 6 co-located samples Total of 6 co-located samples

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

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

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

21. Sample Evaluation For each Aroclor and congener, laboratories have detection limits For each Aroclor and congener, laboratories have detection limits Detection limit is minimum level that can be quantified with confidence 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) 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 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 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 LaboratoryAnalysis Detects/ Samples Max Result ND=0 Max Result ND=1/2 SAIAroclor0/27NDND SWRIAroclor1/270.1440.294 SWRICongener2/270.070.28 SUNYCongener23/270.0400.047 Cleanup Guideline: 0.1 (CA)Cleanup Standard: 10 (USEPA)

23. SAI Indoor Air Results for Aroclors LocationResultND=0ResultND=1/2 Screening Value Room 21 A 0.0005660.000654 0.01 (ATSDR) Room 21 B 0.0005880.000676 Room 28 A 0.0005900.00069 Room 28 B 0.0006420.000734 Results in µg/m 3

24. SWRI Indoor Air Results for Aroclors LocationResultND=0ResultND=1/2 Screening Value Room 21 A 0.001810.00220 0.01 (ATSDR) Room 21 B 0.001800.00219 Room 28 A 0.002320.00277 Room 28 B 0.002910.00333 Results in µg/m 3

25. SWRI Indoor Air Results for Congeners LocationResultND=0ResultND=1/2 Screening Value Room 21 A 0.0004500.000934 0.01 (ATSDR) Room 21 B 0.0004500.000964 Room 28 A 0.0009880.00135 Room 28 B 0.001090.00148 Results in µg/m 3

26. SUNY Indoor Air Results for Congeners LocationResultND=0ResultND=1/2 Screening Value Room 21 A 0.006880.00704 0.01 (ATSDR) Room 21 B 0.004910.00507 Room 28 A 0.01120.0114 Room 28 B 0.008640.00879 Results in µg/m 3

27. Indoor Air Results SAI and SWRI results did not exceed any screening values SAI and SWRI results did not exceed any screening values One sample, at 0.0114 µ g/m 3 from Classroom 28, was similar to an ATSDR screening value (0.01 µ g/m 3 ) One sample, at 0.0114 µ g/m 3 from Classroom 28, was similar to an ATSDR screening value (0.01 µ g/m 3 ) SUNY reported detections in QA/QC blank analyses for air SUNY reported detections in QA/QC blank analyses for air SUNY concentrations may be overestimates of actual concentration SUNY concentrations may be overestimates of actual concentration Opportunities for exposure not expected to result in health concerns under the most conservative exposure assumptions Opportunities for exposure not expected to result in health concerns under the most conservative exposure assumptions Sample was lower than levels cited in literature Location Max (µg/m 3 ) Comment Allendale School 0.0114Congener New Bedford High School 0.051 Investigative, Congener New Bedford Area Homes 0.061 Investigative, Congener Cape Cod Homes 0.0247 Investigative, 3 Congeners Only Outside New Bedford Area 0.051 Background, Congener N. Carolina child care centers 0.246 and 0.258 Background, 20 Congeners Only

28. SAI Outdoor Air Results for Aroclors LocationResultND=0ResultND=1/2 Screening Value Outside A 0.0004120.000496 0.01 (ATSDR) Outside B 0.0003410.000425 Results in µg/m 3

29. SWRI Outdoor Air Results for Aroclors LocationResultND=0ResultND=1/2 Screening Value Outside A 0.001430.00181 0.01 (ATSDR) Outside B 0.001520.00190 Results in µg/m 3

30. SWRI Outdoor Air Results for Congeners LocationResultND=0ResultND=1/2 Screening Value Outside A 0.0003920.000707 0.01 (ATSDR) Outside B 0.0004320.000751 Results in µg/m 3

31. SUNY Outdoor Air Results for Congeners LocationResultND=0ResultND=1/2 Screening Value Outside A 0.01160.0117 0.01 (ATSDR) Outside B 0.007790.00793 Results in µg/m 3

32. Outdoor Air Results One sample reported by SUNY at 0.0117 µg/m 3 was similar to an ATSDR screening value One sample reported by SUNY at 0.0117 µg/m 3 was similar to an ATSDR screening value SUNY reported detections in QA/QC blank analyses for air SUNY reported detections in QA/QC blank analyses for air SUNY concentrations may be overestimates of actual concentration SUNY concentrations may be overestimates of actual concentration Opportunities for exposure not expected to result in health concerns under the most conservative exposure assumptions 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 Samples analyzed by laboratories were similar to or less than BCC background and EPA Allendale School samples for outdoor air LocationMaxComments Allendale School 0.0019 µg/m 3 Aroclor Allendale School- EPA 0.0059 µg/m 3 Aroclor Berkshire Community College 0.0035 µg/m 3 Aroclor

33. SAI Carpet Dust Results for Aroclors LocationResultND=0ResultND=1/2 Screening Value Room 19 0.05920.238 0.4 (ATSDR CREG) 1 (ATSDR Child EMEG) 10 (ATSDR Adult EMEG) 2 (MDEP) Results in mg/kg

34. SWRI Carpet Dust Results for Aroclors LocationResultND=0ResultND=1/2 Screening Value Room 19 NDND 0.4 (ATSDR CREG) 1 (ATSDR Child EMEG) 10 (ATSDR Adult EMEG) 2 (MDEP) Results in mg/kg

35. SWRI Carpet Dust Results for Congeners LocationResultND=0ResultND=1/2 Screening Value Room 19 0.07620.526 0.4 (ATSDR CREG) 1 (ATSDR Child EMEG) 10 (ATSDR Adult EMEG) 2 (MDEP) Results in mg/kg

36. SUNY Carpet Dust Results for Congeners LocationResultND=0ResultND=1/2 Screening Value Room 19 0.1080.111 0.4 (ATSDR CREG) 1 (ATSDR Child EMEG) 10 (ATSDR Adult EMEG) 2 (MDEP) 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 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) 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 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 LocationAverageComments Allendale School 0.526 mg/kg (Max) Congeners New Bedford Area Homes 1.4 mg/kg Investigative, Congeners North Carolina Child Care Centers 1.05 and 7.69 mg/kg Background, Congeners

38. SAI Vacuum Dust Results for Aroclors LocationResultND=0ResultND=1/2 Screening Value Bag A 0.2851.285 0.4 (ATSDR CREG) 1 (ATSDR Child EMEG) 10 (ATSDR Adult EMEG) 2 (MDEP) Bag B 0.2921.292 Results in mg/kg

39. SWRI Vacuum Dust Results for Aroclors LocationResultND=0ResultND=1/2 Screening Value Bag A NDND 0.4 (ATSDR CREG) 1 (ATSDR Child EMEG) 10 (ATSDR Adult EMEG) 2 (MDEP) Bag B NDND Results in mg/kg

40. SWRI Vacuum Dust Results for Congeners LocationResultND=0ResultND=1/2 Screening Value Bag A 0.06870.534 0.4 (ATSDR CREG) 1 (ATSDR Child EMEG) 10 (ATSDR Adult EMEG) 2 (MDEP) Bag B 0.06010.502 Results in mg/kg

41. SUNY Vacuum Dust Results for Congeners LocationResultND=0ResultND=1/2 Screening Value Bag A 0.05130.0559 0.4 (ATSDR CREG) 1 (ATSDR Child EMEG) 10 (ATSDR Adult EMEG) 2 (MDEP) Bag B 0.06660.0709 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 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 When ND=0, all levels are lower than any available screening value Opportunities for exposure not expected to result in health concerns Opportunities for exposure not expected to result in health concerns Levels are lower than those found in other locations Levels are lower than those found in other locations LocationMaxComments Allendale School 1.292 mg/kg Aroclor Cape Cod Homes 35.3 mg/kg Investigative, 3 Congeners Only North Carolina Child Care Centers 1.99 and 3.15 mg/kg Background, 20 Congeners Only

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 LaboratoryAnalysis Detects/ Samples Max Result ND=0 Max Result ND=1/2 SAIAroclor0/2NDND SWRIAroclor2/20.1050.255 SWRICongener2/20.09070.278 SUNYCongener2/20.07420.0786 Results in µg/vent

44. Room 21- Air Samples Lab and Analysis LocationResultND=0 ResultND=1/2 Screening Value SAI-Aroclor Room 21 A 0.0005660.000654 0.01 (ATSDR) Room 21 B 0.0005880.000676 SWRI-Aroclor Room 21 A 0.001810.00220 Room 21 B 0.001800.00219 SWRI-Congener Room 21 A 0.0004500.000934 Room 21 B 0.0004500.000964 SUNY-Congeners Room 21 A 0.006880.00704 Room 21 B 0.004910.00507 Results in µg/m 3

45. Room 24- Surface Wipe Samples Lab and Analysis LocationResultND=0 ResultND=1/2 SAI-Aroclor Room 24 S NDND Room 24 W NDND Room 24 WP NDND Room 24 WS NDND SWRI-Aroclor Room 24 S NDND Room 24 W NDND Room 24 WP NDND Room 24 WS NDND SWRI-Congener Room 24 S NDND Room 24 W NDND Room 24 WP NDND Room 24 WS NDND SUNY-Congener Room 24 S 0.00020.0126 Room 24 W 0.000110.0126 Room 24 WP NDND Room 24 WS 0.001880.0139 Cleanup Guideline: 0.1 (CA)Cleanup Standard: 10 (USEPA) Results in mg/kg

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. 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. 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. 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. 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. 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 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. 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. 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.