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HEALTH CONSULTATION

NEW BEARD ELEMENTARY SCHOOL
(a/k/a PROPOSED BEARD STREET SCHOOL)
DETROIT, WAYNE COUNTY, MICHIGAN


SUMMARY

The Detroit Public Schools system has recently completed construction of the New Beard Elementary School on a 6.45-acre property in Detroit, Michigan. The property has a long history of industrial use that left contaminants in the soil including arsenic, lead, polychlorinated biphenyls (PCBs), and volatile and semi-volatile organic compounds. Much of the contamination has been removed during site remediation and construction activities. However, some contaminants, primarily arsenic, remain in soil at the property under an extensive site cap, paved areas, and the school building itself.

Under both current and foreseeable future site conditions, the New Beard Elementary School property poses no public health hazard. While contaminated soil remains on-site, extensive barriers have been installed that will prevent human exposure now and in the foreseeable future. The Detroit Public Schools have developed a plan that includes monthly inspections of the site cap, paved areas, the concrete building floor, and other exposure barriers to ensure that unacceptable exposures will not occur in the future.


BACKGROUND AND STATEMENT OF ISSUES

The Michigan Department of Environmental Quality (MDEQ) has asked the Michigan Department of Community Health (MDCH) to evaluate the health risks associated with the new Beard Elementary School as part of the Brownfields Redevelopment Assessment of the property.

The Beard Elementary School property is located at 7036 Chatfield Street,(1) Detroit, Michigan (AKT 1999). The property covers approximately 6.45 acres between Chatfield Street, Beard Street, Green Street, and an elevated railroad track (Figure 1). Past occupants of the property include various metalworking companies (before 1950), a U.S. Army tank and ordnance center (1951-1964), and a training center for the Detroit Public Schools (1965-1985). The Detroit Public Schools (DPS) holds title to the property, which had been vacant since 1985. There were 11 industrial buildings on the property, all of which were removed by 1989. There are records of several underground storage tanks on the property, some, but not all, of which were removed by 1999 (AKT 1999).

Due to the history of the site, the Wayne County Brownfield Redevelopment Authority (WCBRA) initiated site assessment activities in 1999 that included both Phase I and Phase II Environmental Site Assessments (ESA). A brief overview of the ESA and site remediation activities follows.

  • Between June and August 1999, a contractor conducted a Phase I ESA that consisted of a search of records and a visual inspection of the property (AKT 1999).

  • In July 1999, the contractor conducted Phase II of the ESA, collecting samples of subsurface soil and completing a limited geophysical survey of the property. Arsenic, lead, polycyclic aromatic hydrocarbons (PAHs), and polychlorinated biphenyls (PCBs) were detected in subsurface soil samples. The geophysical survey located two underground storage tanks along the east side of the property (AKT 2000).

  • In June of 2000, the MDEQ conducted a radiation survey of the site. The results of the survey indicated that levels of radiation detected at the site do not exceed those allowed by the MDEQ guidelines (MDEQ 2000b).

  • In July 2000, the contractors removed the two underground storage tanks (USTs) as well as discolored and apparently contaminated soil from around the tanks. Soil was also removed from ten locations identified during the Phase II ESA as having concentrations of arsenic, lead, PAHs, and PCBs that exceeded MDEQ criteria (NTH 2001).

  • School construction and site remediation activities began in July 2000. A site cap that would prevent direct contact with potentially contaminated soil would be installed on all areas of the property not covered by the elementary school building or pavement.

  • On October 25 and 26, 2000, the contractor for the DPS collected 28 soil samples from 14 locations within the footprint of the proposed school building to determine if contaminants in soil immediately under the proposed building could pose a risk to indoor air. Trichloroethylene and tetrachloroethylene were detected in some of these samples, but at concentrations far less that the MDEQ cleanup criteria protective of indoor air (NTH 2001).

  • In February 2001, two previously undetected heating oil USTs were discovered during site excavation activities. Both tanks were removed. Confirmation samples taken from the surrounding soil did not indicate any contaminants at concentrations exceeding MDEQ generic residential cleanup criteria (NTH 2001).

  • A second geophysical survey was conducted in April 2001. All objects detected in the survey were near the surface and estimated to weigh less than ten pounds and were removed during installation of the cover at the property (NTH 2001).

  • During construction of the property cap in the spring and summer of 2001, the existing surface soil was removed to an elevation of seven to twenty-six inches below the final grade and was disposed of off-site. After this removal, but before the site cap was installed, 76 soil samples were collected to characterize the soil contamination that would remain immediately under the cap. Eight samples were collected from the kindergarten play area and five from the pre-school play area (Figure 2). Ten of the remaining samples were focused on areas where intense site activity was expected such as the team bench areas of the ball fields, goal areas on the soccer field, and the base locations on the baseball field. Analysis of these samples indicated that PCBs were present at two locations at levels exceeding the MDEQ residential cleanup criterion for soil. The area surrounding the location where elevated PCB levels were found was excavated and additional samples were taken to confirm that affected soils had been removed (NTH 2001).

  • On August 1, 2001, three additional areas in the baseball field (Figure 2) were excavated to remove PCBs detected in soil samples taken by the MDEQ in June 2001. Removal of the completed site cap was required to access the affected soils. Additional soil samples were taken before the cap was replaced to confirm that affected soils had been removed (Innes and Spalding 2001).

On March 28, 2001, the MDCH issued a written Public Health Consultation (PHA) for the Proposed Beard Street School. In the PHA, MDCH determined that the property posed an indeterminate public health hazard. While subsurface soil samples at the site contained contaminants at levels potentially of health concern, only limited data were available on surface soil contamination. The MDCH recommended additional sampling to determine if contaminant levels in surface soil could pose a public health risk.

The present PHA presents MDCH's findings based on the additional soil data made available from environmental sampling at the New Beard Elementary School during the summer of 2001.


DISCUSSION

The sampling results discussed in this consultation were taken from the available investigations of the property and are not adjusted for limitations or bias in the sampling programs.

Chemicals of concern for this consultation were selected from those that were detected in soil at the property at a concentration above the MDEQ Generic Cleanup Criteria (MDEQ 2000a) for residential land use.

Environmental Contamination And Other Hazards

During Phase II of the ESA in July 1999, the contractors collected subsurface soil samples from 28 borings on the property. Both shallow (0-2 or 1-3 feet deep) and deep (5-7, 6-8, or 8-10 feet deep) samples were collected at each boring. Arsenic, lead, and PCBs were detected in shallow samples at concentrations above MDEQ Generic Residential Soil Direct Contact Criteria (DCC). One deep sample contained benzo(a)pyrene and dibenz(a,h)anthracene at concentrations above the MDEQ Residential DCC. A single shallow sample contained carbon tetrachloride at a concentration above the MDEQ Generic Residential Soil Volatilization to Indoor Air Criteria (SVIIC) (AKT 2000, MDEQ 2000a). Contaminants that exceeded MDEQ criteria are summarized in Table 1.

In July of 2000, ten separate excavations were performed at locations identified during the Phase II ESA where contaminant concentrations exceeded MDEQ criteria. Soil was removed from thirty-foot square areas, centered on the borings where the high concentrations were found, and 4 to 10 feet deep, depending on the depth where the contaminants were found. The impacted soil was removed and disposed of off-site. Confirmatory samples were taken from the walls and floors of the excavations to determine whether all the contaminated soil had been removed (NTH 2000). While most of the contaminants listed in Table 1 were removed, the arsenic concentration in nearly all the verification samples exceeded MDEQ Residential DCC (Table 2). In addition, chloromethane was detected in one sample at a concentration above the MDEQ Residential SVIIC (MDEQ 2000a, NTH 2000). However, this sample was taken from an area outside the footprint of the proposed building and, therefore, does not present an indoor inhalation hazard.

Soil samples were collected in October 2000 from within the footprint of the proposed building and analyzed for volatile organic compounds (VOCs) to determine if contaminants in soil immediately under the proposed building could pose a risk to indoor air. The results of these analyses are presented in Table 3. No VOCs were detected in 25 of the 28 samples. Tetrachloroethylene was detected in two samples at a maximum concentration of 140 µg/kg. Trichloroethylene was detected in one sample at a concentration of 400 µg/kg (NTH 2001). These concentrations do not exceed the MDEQ criteria for these compounds.

During construction of the school building, soil samples were collected in utility excavations. All samples were analyzed for arsenic and some samples were analyzed for VOCs, PAHs, and PCBs. One sample was found to contain arsenic at a concentration exceeding the MDEQ cleanup criteria. The location of this sample has now been covered by the building's slab foundation.

Soil samples collected prior to installation of the cap for the property were analyzed for the complete list of 126 U.S. Environmental Protection Agency (EPA) priority pollutants plus an additional 62 compounds. The analysis included VOCs, semi-volatile organic compounds (SVOCs), PCBs, 13 metals, pesticides, cyanide, asbestos, and dioxin. The results indicated that PCBs were present at two locations at concentrations exceeding the MDEQ criterion. These locations were excavated and confirmatory samples indicated that PCBs were no longer present at concentrations exceeding cleanup criteria. Three additional areas where PCBs had been detected at concentrations exceeding the MDEQ criteria were excavated and removed in August 2001.

All areas where PCBs have been detected to date above the applicable MDEQ residential cleanup criteria have been excavated. PCB contaminated soil was removed and disposed of off-site. Concentrations of contaminants detected through the course of site investigation and remediation activities that remain on-site at concentrations greater than the applicable MDEQ cleanup criteria are shown in Table 4. The list of contaminants includes arsenic, benzo(a)pyrene, benzene, chloromethane, and cyanide.

Human Exposure Pathways

To determine whether people are or could be exposed to contaminants associated with a property, ATSDR and MDCH evaluate the environmental and human components that lead to human exposure. An exposure pathway contains five major elements: 1) a source of contamination, 2) contaminant transport through an environmental medium, 3) a point of exposure, 4) a route of human exposure, and 5) an exposed population.

The property will be used as a public elementary school and the exposure pathways described in the table below are consistent with this use. An exposure pathway is considered a complete pathway if there is evidence that all five of these elements are, have been, or will be present at the property. An exposure pathway is considered a potential pathway if it is likely that the pathway will be complete in the future.

Exposure Pathway Source Environmental Transport and Media Chemicals of Concern Exposure Point Exposure Route Exposed Population Time Frame Status
Drinking Water Contaminated Soil Soil Leaching to Ground Water Tables 1 & 2 Groundwater used as a Potable Water Source Ingestion
Dermal Contact
School Children
School Workers
School Visitors
Off-Site Receptors
Past Incomplete
Present Incomplete
Future Incomplete
Direct Contact with Soil Contaminated Soil Direct Contact Tables 1 & 2 On-Site Incidental Ingestion
Dermal Contact
School Children
School Workers
School Visitors
Past Incomplete
Present Incomplete
Future Incomplete
Soil to Indoor Air Contaminated Soil Volatilization from Soil to Indoor Air Table 3 School Buildings On-Site Inhalation School Children
School Workers
School Visitors
Past Incomplete
Present Incomplete
Future Incomplete
Soil to Ambient Air Contaminated Soil Emissions from Soil to Ambient Air Table 1 & 2 On-Site and Near-By Land Uses Inhalation School Children
School Workers
School Visitors
Off-Site Receptors
Past Incomplete
Present Incomplete
Future Incomplete

Groundwater is not used as a source of potable water in the Detroit area. Groundwater in the area is rare, generally brackish and unusable for drinking. The Detroit municipal system supplies the property and all its vicinity with drinking water from Lake Huron and the Detroit River. Therefore, exposure to groundwater that could be affected by soil contamination at the property is an incomplete pathway both on-site and for any near-by land use.

Direct contact with soil and the soil to ambient air pathways are incomplete at the New Beard Elementary School because all areas of the property are covered by either pavement, the elementary school building itself or by the property cap. The cap is divided into three zones based on the type and intensity of activity expected to occur in these areas. Details of the cap for each area are described below.

  • Landscaped Areas - A geotextile layer separates the existing site soil from the cap. Four inches of compacted crushed concrete were placed on top of the geotextile layer and covered with eight inches of topsoil. Grass and other landscaping were installed in the topsoil.

  • Baseball and Soccer Fields - A geotextile layer separates the existing soil from the cap. Eight inches of compacted crushed concrete were placed on top of the geotextile layer and covered with eight inches of topsoil. On the baselines of the baseball field, eleven inches of crushed concrete were placed on top of the geotextile layer, followed by five inches of stone dust.

  • Kindergarten and Preschool Play Areas - The cap in these areas is more conservative because young children, who are potentially more sensitive to chemical exposures, will frequent this area. The cap consists of six inches of sand, a four-inch thick poured concrete slab with reinforcement rod, followed by four inches of pea gravel, covered by twelve inches of wood fiber as a cushioned barrier. An eight-inch concrete wall tied into the four-inch concrete slab surrounds each play area to keep the surrounding soil out and retain cover materials.

Paved areas include the parking lots, curbs, sidewalks and the basketball court. Each area is underlain with four inches of aggregate and topped with either four inches of paved concrete or three inches of asphalt.

Inhalation of chemicals that could volatilize from soil and into the school building is an incomplete pathway of exposure at the New Beard Elementary School property. VOCs were detected in only three locations in soil immediately under the building slab and at low concentrations that did not exceed the MDEQ criteria protective of this pathway. There are no basements in the school building. In addition, a vapor barrier was installed under the building foundation that greatly reduces the likelihood that VOCs volatilizing from soil could enter indoor air in the school building.

A Due Care Plan(2) was prepared for the New Beard Elementary School property to ensure that the site cap and other site features installed to prevent or limit exposure to contaminants left on-site will remain effective in the future. The Plan includes monthly inspections of the site cap, paved areas, the concrete building floor, and other exposure barriers. Should future site construction or maintenance require breach of these barriers, construction crews will be informed of the contaminants left in place and any potential public health hazards. Health and safety plans will be developed as needed to minimize exposure for construction crews, school children and staff, and the general public. The DEQ affirmed the adequacy of the DPS Due Care compliance activities in a letter dated December 10, 2001.

Toxicological Evaluation

Table 4 lists the contaminants that remain in soil on-site at the New Beard Elementary School property at concentrations that exceed the applicable MDEQ residential cleanup criteria. These criteria are protective of long-term, frequent exposure to soil contaminants under likely exposure scenarios. Therefore, contaminants at concentrations less than these conservative levels do not pose a public health risk for any land use including an elementary school where young children will be present. Concentrations that exceed these levels warrant further consideration to determine if public health hazards are likely.

Arsenic was frequently detected at concentrations exceeding the MDEQ Residential DCC both in subsurface confirmatory soil samples following site excavation activities and at surface soil sampling locations that underlie the site cap. The DCC are levels in soil that protect people from unacceptable exposures through incidental ingestion of soil or dermal contact with soil. The locations where arsenic was detected are now covered by the site cap, pavement, or the school building. While this contaminant appears to be present throughout site soils, exposure to arsenic is unlikely as long as the cap and other exposure barriers are properly maintained.

Benzo(a)pyrene was found at concentrations exceeding the MDEQ DCC at five sampling locations that are now covered by the site cap. Exposure to benzo(a)pyrene is unlikely as long as the cap is properly maintained.

An elevated concentration of cyanide was found at a concentration exceeding the MDEQ DCC at only one location, now covered by the site cap. Exposure to cyanide at this location is unlikely as long as the cap is properly maintained.

Benzene and chloromethane were detected in only one sample each at a concentration exceeding the MDEQ Residential SVIIC (MDEQ 2000a). The SVIIC are levels in soil that protect people from unacceptable exposure to indoor air contaminants that can migrate from soil into buildings (MDEQ 1998). Since these detections were only in very limited areas, it is unlikely that there is a sufficient quantity of these compounds present on-site to pose a risk to indoor air. In addition, both compounds were found at locations removed from the school building and are now covered by the site cap (NTH 2000).

ATSDR Child Health Initiative

Children may be at greater risk than adults from exposure to hazardous substances at sites of environmental contamination. They engage in activities such as playing outdoors and hand-to-mouth behaviors that may increase their intake of hazardous substances. They are shorter than most adults; therefore, they breathe dust, soil, and vapors closer to the ground. Their lower body weight and higher intake rate results in a greater dose of hazardous substance per unit of body weight. The developing body systems of children can sustain permanent damage if toxic exposures are high enough during critical growth stages (ATSDR 1998).

The New Beard Elementary School property will be used as a public elementary school for the foreseeable future. It is expected that children will be present throughout the school year and may use the outdoor playgrounds and other facilities even when school is not in session. Children's activities on the school property may be intense, resulting in the potential for increased exposure to soil contaminants. However, the installation of the exposure barriers described above including an extensive site cap, pavement, and the school building itself will prevent children from making contact with the contaminated soil that remains on-site.


CONCLUSIONS

Under both current and foreseeable future site conditions, the New Beard Elementary School property poses no public health hazard. While contaminated soil remains on-site, extensive barriers have been installed that will prevent human exposure now and in the foreseeable future. However, the Detroit Public Schools must ensure that the Due Care Plan, including the provisions for monthly inspections of the site cap, paved areas, the concrete building floor, and other exposure barriers, is carried out as proposed.


RECOMMENDATIONS

Carry out the provisions of the Due Care Plan including monthly inspections of the site exposure barriers to ensure that unacceptable exposures to school workers, children, and other site visitors will not occur.

Prevent future activities on the Beard Elementary School property that would compromise the integrity and protectiveness of the site exposure barriers.

Comply with the applicable requirements of Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended.

Provide health education to inform concerned community members of the measures taken to safeguard public health and prevent exposure to contaminants that remain on-site.

New environmental data or information concerning the future use of this property may require future health consultations.

Public Health Action Plan

The Detroit Public School system is responsible for implementing the Due Care Plan, maintaining the site exposure barriers, and complying with Part 201, Environmental Remediation, of the Michigan Natural Resources and Environmental Protection Act, 1994 PA 451, as amended.

The MDCH will conduct activities as appropriate to provide concerned citizens with health education information. These activities may include a poster presentation to be displayed at a public location, site-specific fact sheets, or attendance at public meetings.

The MDCH will be available to consult on the appropriateness and efficacy of future remedial actions.

If any citizen has additional information or health concerns regarding the Beard Street School property, please contact the Michigan Department of Community Health, Environmental Epidemiology Division, at 1-800-648-6942.


REFERENCES

AKT. 1999. AKT Environmental Consultants, Inc., for Wayne County Brownfield Redevelopment Authority. Phase I Environmental Site Assessment Report, Detroit School Board Property, Green, Beard, & Chatfield Streets, Detroit, Michigan. August 16, 1999.

AKT. 2000. AKT Environmental Consultants, Inc., for Wayne County Brownfield Redevelopment Authority. Subsurface Investigation Report. March 20, 2000.

ATSDR. 1998. Agency for Toxic Substances and Disease Registry, Division of Health Assessment and Consultation. Guidance on Including Child Health Issues in Division of Health Assessment and Consultation Documents. July 2, 1998.

ATSDR. 2000. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Arsenic, Update. September 2000.

Innes, Steve and Spalding, Philip. 2001. Personal communication to Ms. Patricia Thornton, MDEQ dated August 1, 2001.

IRIS. 1998. U.S. Environmental Protection Agency. Integrated Risk Information System, Article on Arsenic. At <http://www.epa.gov/iris/subst/0278.htm Exiting ATSDR Website>. April 10, 1998. Accessed March 7, 2001.

MDEQ. 1998. Michigan Department of Environmental Quality, Environmental Response Division. Part 201 Generic Groundwater and Soil Volatilization to Indoor Air Inhalation Criteria: Technical Support Document. August 31, 1998.

MDEQ. 2000a. Michigan Department of Environmental Quality. Memorandum to ERD staff, subject: Interim Environmental Response Division Operational Memorandum #18: Part 201 Generic Cleanup Criteria Tables. June 7, 2000. At <http://www.michigan.gov/deq/0,1607,7-135-3311_4109_9846-20527--,00.html Exiting ATSDR Website>.

MDEQ. 2000b. Correspondence from Russell B. Rotta, MDEQ Drinking Water and Radiological Protection Division, to Patricia A. Thornton, MDEQ Environmental Response Division. July 3, 2000.

NTH. 2000. NTH Consultants, Ltd., for Detroit Public Schools. Environmental Assessment, Remediation, and Due Care Compliance Activities. New Beard Elementary School, 7036 Chatfield Street, Detroit, Michigan 48209. September 12, 2000.

NTH. 2001. NTH Consultants, Ltd., for Detroit Public Schools. Revised Report on: Environmental Assessment, Remediation, and Due Care Compliance Action, New Beard Elementary School, 1551 Beard, Detroit, Michigan 48209. July 24, 2001.

Thornton. 2001. Thornton, P., MDEQ. Personal communication. January 10, 2001.


FIGURES

Site Location
Figure 1. Site Location

Site Features
Figure 2. Site Features


PREPARERS OF REPORT

Michigan Department of Community Health

Linda D. Larsen, Ph.D.
Principal Investigator, Toxicologist
Toxicology and Response Section

Robin Freer, M.A.
Geographic Information System Specialist
Toxicology and Response Section


ATSDR Regional Representative

Mark Johnson
Office of Regional Operations, Region V


ATSDR Technical Project Officer

Alan W. Yarbrough
Division of Health Assessment and Consultation
Superfund Site Assessment Branch


TABLES

Table 1. Concentrations of chemicals of concern in subsurface soil samples collected from the New Beard Elementary School property (July 13, 1999).

Chemical Depth of Sample Maximum Concentration (ppm) No. of positive detections / No. of samples analyzed MDEQ Residential DCC (ppm) MDEQ Residential SVIIC (ppm)
Arsenic S 303 28 / 28 7.6 NLV
D 25.2 27 / 28
Benzo(a)anthracene S 2 20 / 28 20 NLV
D 25 8 / 28
Benzo(a)pyrene S 1.8 20 / 28 2.0 NLV
D 20 7 / 28
Carbon tetrachloride S 0.428 1 / 28 96,000 0.19
D ND 0 / 28
Dibenzo(a,h)anthracene S 0.53 13 / 28 2.0 NLV
D 5.7 5 / 28
Lead S 979 28 / 28 400 NLV
D 257 28 / 28
PCBs (total) S 48 13 / 28 4.0 3,000
D 0.31 11 / 28

Reference: AKT 2000, MDEQ 2000a

S ' Shallow samples, from 0-2 or 1-3 feet deep

D ' Deep Samples, from 5-7 to 8-10 feet deep

ND ' Not Detected

NLV = Chemical is not likely to volatilize, therefore SVIIC are not applicable.


Table 2.Concentrations of chemicals of concern in subsurface soil samples collected from the New Beard Elementary School property after the removal (July 10, 2000).

Chemical Maximum Concentration (ppm) No. of positive detections / No. of samples analyzed MDEQ Residential DCC (ppm) MDEQ Residential SVIIC (ppm)
Arsenic 210 37 / 37 7.6 NLV
Chloromethane 7.4 1 / 14 1,100 2.3

References: NTH 2000, MDEQ 2000a

ND = Not Detected

NLV = Chemical is not likely to volatilize, therefore SVIIC are not applicable.


Table 3.Sampling results from soil samples collected under the footprint of the New Beard Elementary School building (October 2000).

Chemical Depth Maximum Concentration (ppb) No. of positive detections / No. of samples analyzed MDEQ Residential SVIIC (ppb)
Tetrachloroethylene Shallow* 140 1/14 11,000
Deep** ND 0/14
Trichloroethylene Shallow ND 0/14 7,100
Deep 400 1/14
All other VOCs Shallow ND 0/14 Variable
Deep ND 0/14

References: NTH 2001, MDEQ 2000a

ND ' Not Detected

* Shallow samples were taken from 0-1 foot below the building pad.
** Deep samples taken from 4 to 12 feet below the building pad.


Table 4.Chemicals of concern that remain in soil at the New Beard Elementary School property at concentrations that exceed the applicable MDEQ cleanup criteria (July 24, 2001).

Chemical Maximum Concentration (ppm) MDEQ Residential Soil Direct Contact Criteria (DCC) (ppm) MDEQ Residential Soil Volatilization to Indoor Air (SVIIC) Criteria (ppm)
Arsenic 210 7.6 NLV
Benzene 2.4 180 1.6
Benzo(a)pyrene 2.7 2.0 NLV
Chloromethane 7.4 1,100 2.3
Cyanide (total) 23 12 NLV

References: NTH 2001, MDEQ 2000a

Shading indicates MDEQ Criterion exceeded.

NLV = Chemical is not likely to volatilize, therefore SVIIC are not applicable.


APPENDIX A: RESPONSIVENESS STATEMENT

The MDCH released a draft of this Public Health Consultation for public comment on November 2, 2001. The initial comment period lasted until December 7, 2001, and was extended to March 15, 2002, to allow time for review and comment on a Spanish language translation of the Consultation. Comments received are addressed below. Where practical, similar comments from several sources have been combined.

  1. Comment: The consultation incorrectly states that the purpose of the Phase I and II ESA was to determine if the site could be redeveloped into an elementary school.
  2. Response: This error has been corrected in the revised consultation.

  3. Comment: The consultation incorrectly states that the DPS contracted for the Phase I and II ESA.
  4. Response: This error has been corrected in the revised consultation.

  5. Comment: The July 1999 geophysical survey conducted as part of the ESA should be described as "limited."
  6. Response: MDCH agrees that the July 1999 geophysical survey was limited in scope and has revised the consultation accordingly.

  7. Comment: The consultation incorrectly states that 7 to 26 inches of surface soil were removed and disposed of off-site.
  8. Response: This error has been corrected in the revised consultation.

  9. Comment: The consultation incorrectly states, "All areas where PCBs have been detected to date have been excavated..."
  10. Response: The consultation has been revised to state that, "All areas where PCBs have been detected to date above the applicable MDEQ residential cleanup criteria have been excavated."

  11. Comment: The crushed concrete component of the site cap should be described as "compacted."
  12. Response: This descriptor has been added to the section that provides details of the site cap.

  13. Comment: The concrete wall surrounding the Kindergarten and Preschool play areas should be described as "a six-inch thick concrete wall that is tied into the four-inch concrete slab."
  14. Response: This description of the concrete wall surrounding the Kindergarten and Preschool play areas is not consistent with that given on page 31 of NTH 2001. However, MDCH has obtained construction details for the concrete wall surrounding the play areas which indicate that concrete wall is actually eight inches thick and that it is tied into the four-inch concrete slab with reinforcement rod. The revised consultation reflects this change.

  15. Comment: The concentration of carbon tetrachloride listed in Table 1 should be revised to 0.428 ppm.
  16. Response: This error has been corrected in the revised consultation.

  17. Comment: The consultation minimizes the presence of contaminants other than arsenic.
  18. Response: The consultation focused on the potential hazards associated with arsenic because this contaminant was found throughout site soil at concentrations far exceeding the MDEQ cleanup criteria. While some detected concentrations of other contaminants exceeded criteria, these exceedances were generally less frequent and of lesser magnitude.

  19. Comment: You describe the barrier used as an "extensive" one. Over most of the area it is actually a simple barrier consisting of a semi-permeable fabric liner, a layer of crushed concrete and a layer of fresh soil of varying depths depending on use of the area.
  20. Response: The use of the adjective "extensive" was intended to convey the concept that the barrier is large in area not depth, meaning that it covers much of the school property, and was not intended to describe the thickness or any other characteristic of the barrier.

  21. Comment: The final Due Care Plan has not been approved by the MDEQ.
  22. Response: The DEQ affirmed the adequacy of the DPS Due Care compliance activities in a letter dated December 10, 2001.

  23. Comment: The monthly inspections are visual only and will not detect contaminant migration through or sub-surface damage to the barrier.
  24. Response: It is true that the inspections are to be visual only. More aggressive measures that could detect sub-surface damage would likely compromise the integrity of the site cap. Sampling to detect contaminant migration through the barrier is unnecessary as long as the cap remains intact.

  25. Comment: Safety concerns and contaminants related to the elevated railroad track have not been addressed.
  26. Response: The focus of the consultation was the potential for public health hazards associated with exposure to chemical contaminants in soil at the school property.

  27. Comment: Former occupants of the property have been left out of the list of former uses. The list implies inclusiveness in the language used.
  28. Response: The list of past occupants was not intended to be comprehensive, but rather to illustrate the type of activities that have occurred on the property in the past.

  29. Comment: Soil was removed from only 10 of the 12 locations identified during the Phase II ESA.
  30. Response: This comment is correct. Contaminant concentrations at two of the 12 locations originally identified in the ESA were below the applicable MDEQ cleanup criteria; therefore no excavation was completed at these locations. This error has been corrected in the revised consultation.

  31. Comment: "Cap" has a specific meaning in remediation language which implies impermeability.
  32. Response: While "cap" may have specific meaning under some laws or regulations, it is not defined under Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. "Cap," as used in this consultation, has its common meaning as "something that limits or restrains."

  33. Comment: There could be more underground storage tanks or leaking barrels on the property. Some objects in shallow soil may not have been removed since some areas have as little as 7 inches of soil removed.
  34. Response: In February 2001, NTH consultants performed a geophysical survey of the entire property. This survey did not detect additional buried tanks or barrels. If smaller metal objects were not removed during construction, these objects are now covered by the building, pavement, or the site cap and do not, therefore, present a public hazard.

  35. Comment: The August 1, 2001 soil test indicated four, not three areas in the baseball field where the exposure barrier was breached to remove PCB contaminated soil.
  36. Response: The consultation states that, "On August 1, 2001, three additional areas in the baseball field (Figure 2) were excavated to remove PCBs detected in soil samples taken by the MDEQ in June 2001." Two of the four areas where PCBs were detected were combined into a larger excavation area for a total of three excavations.

  37. Comment: Breaching of the exposure barrier on the baseball field had to affect its integrity.
  38. Response: While the geotextile demarcation layer of the barrier was breached to remove underlying contaminated soils, it has been replaced and is covered by eight inches of compacted crushed concrete and another eight inches of topsoil. It is unlikely that people using the baseball field will be exposed to underlying soils.

  39. Comment: There are two areas of PCB contaminated soil on the baseball field that could be harmful to children if they come into contact with them. The baseball field was not comprehensively remediated and it is very likely that more PCBs are present in this area.
  40. Response: While some impacted soil remains under the barrier, the concentrations of PCBs in the soil are below the Part 201 residential soil direct contact criteria and would be considered safe for unlimited contact. In addition, these soils are covered by an exposure barrier consisting of a geotextile demarcation layer, eight inches of compacted crushed concrete and another eight inches of topsoil. It is unlikely that people using the baseball field will be exposed to the underlying soils.

  41. Comment: Trees and shrubs would penetrate the barrier allowing contaminants to be exposed. How will children 20 years from today know that they shouldn't plant a tree or a prairie?
  42. Response: The Detroit Public Schools has the responsibility to ensure that future site activities will not result in unacceptable exposures.

  43. Comment: MDEQ criteria do not fully protect children.
  44. Response: The MDEQ criteria use an age-adjusted formula to account for greater potential exposure for children. In addition, the MDEQ uses toxicological information about the effects of chemicals on children in the calculation of cleanup criteria when that information is available.

  45. Comment: It may be that over time toxic gases will make their way to the surface from unidentified underground tanks or barrels.
  46. Response: No additional unremoved underground tanks or barrels were found during a geophysical survey that covered the entire site.

  47. Comment: DPS must be required to yearly inform parents of the conditions which exist on the Beard School site.
  48. Response: MDCH does not have the authority to require that DPS inform parents of the site conditions.

  49. Comment: We hope that MDCH will provide displays and fact sheets in Spanish and English during enrollment periods and at Open House events. A community meeting in which you explain your report findings would be beneficial.
  50. Response: The MDCH has provided a Spanish version of the Public Comment Release of the Health Consultation. No comments have been recieved from the Spanish-speaking community. There are no plans at this time for a community meeting.

  51. Comment: It is important that a schedule of testing be established to ensure that no contaminants migrate to the playground surface or the indoor air of the school.
  52. Response: Since volatile contaminants were detected only infrequently and at very low concentrations, it is unlikely that contaminants will migrate into indoor air of the school. Properly maintained, the exposure barriers installed on the playground will prevent migration to the surface soil.

  53. Comment: MDCH should review the adequacy of the investigations conducted on site. Due to the nature of the sampling on the site, contaminated "hot spots" may remain.
  54. Response: The MDCH has reviewed the adequacy of the investigations. Seventy-six soil samples were collected prior to installation of the exposure barriers and these samples were analyzed for a wide variety of contamiants. Only PCBs were detected above the Part 201 residential cleanup criteria and these areas have been excavated. The MDCH is satisfied that the site investigations have been adequate.

  55. Comment: MDCH fails to acknowledge that initial testing showed elevated levels of VOCs, including TCE and carbon tetrachloride, as well as lead, arsenic, polyaromatic hydrocarbons and PCBs.
  56. Response: Only those contaminants exceeding MDEQ residential cleanup criteria are included in the list of chemicals of concern for this site. Properties on which contaminant levels do not exceed these criteria are considered safe for all uses. The "Environmental Contamination And Other Hazards" section provides a description of the contaminants found during the Phase II ESA that exceeded the applicable MDEQ criteria. Carbon tetrachloride exceeded its MDEQ criteria in one sample as indicated in this section and in Table 1. While TCE (trichloroethylene) and other VOCs were detected during the Phase II ESA at low concentrations, these chemicals were not found at concentrations exceeding their applicable MDEQ criteria and are not considered to be chemicals of concern at this site.

  57. Comment: MDCH suggests that the site cap was planned from the outset.
  58. Response: Remedial choices for a site cannot be determined until all site investigations are complete. The MDCH did not mean to suggest that a site cap was planned during early phases of the investigation.

  59. Comment: MDCH did not question the data, or the effectiveness or durability of the soil barrier installed at this site.
  60. Response: The MDCH conducted a complete review of all the available data and is satisfied that the barriers installed at the site will be effective if properly maintained.

  61. Comment: VOCs present in soils adjacent to the building might also be drawn into the school.
  62. Response: VOCs were detected only infrequently and at very low concentrations. It is unlikely that vapors will be drawn into the school building from surrounding soils.

  63. Comment: MDCH is simply repeating assertions made by DPS' consultant without looking behind those statements. We urge MDCH to analyze the effectiveness of the barriers installed on site before reaching its final conclusions about the public health threats posed by this site.
  64. Response: The MDCH has confirmed the information presented in the consultant's reports with the MDEQ.

  65. Comment: We do not believe MDCH can accurately state that the direct contact pathway is incomplete. MDCH provides absolutely no explanation for its assertion that the soil to ambient air pathway is incomplete.
  66. Response: As stated in the consultation, the direct contact with soil and the soil to ambient air pathways are incomplete at the New Beard Elementary School the property is covered by either pavement, the elementary school building itself or by the property cap.


CERTIFICATION

This New Beard Elementary School Health Consultation was prepared by the Michigan Department of Community Health under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the health consultation was begun.

Alan W. Yarbrough
Technical Project Officer, SPS, SSAB, DHAC, ATSDR


The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health consultation and concurs with the findings.

Roberta Erlwein
Chief, State Program Section, SSAB, DHAC, ATSDR


1 The property in question includes parcels with addresses 1501, 1505, 1547, 1645, and 1651 Beard Street, 7036, 7038, 7050, 7058, 7060, 7104, and 7124 Chatfield Street, and 1510 Green Street (AKT 1999).
2 Part 201 of the 1994 Michigan Natural Resources and Environmental Protection Act, P.A. 1994, as amended, requires that a person who owns or operates a property that is a 201 facility prepare a Due Care Plan to ensure that site activities will not exacerbate existing conditions, to mitigate unacceptable exposures, and take reasonable precautions against the acts of third parties and any consequences of those acts.


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