[CPEO-BIF] Providence, Rhode Island schools

[Lenny Siegel]

[The following report may be downloaded as a formatted 3.5 MB PDF file 
with photos from http://www.cpeo.org/pubs/ProvidenceSchools.pdf. - LS}


Providence, Rhode Island Schools
By Lenny Siegel
October, 2006

On September 29, 2006 I visited a number of brownfield sites in 
Providence, Rhode Island. My host was Steve Fischbach, an attorney with 
Rhode Island Legal Services (RILS). Below I describe the two school 
sites we visited, the occupied Pell Complex and the un-named high school 
under construction at the former Gorham Silver property. I have added 
information about the Gorham site from neighborhood activist Robert Dorr 
as well as from a draft Health Consultation recently released by the 
federal Agency for Toxic Substances and Disease Registry (ATSDR).1

The Pell Complex demonstrates the difficulty inherent in building 
schools on contaminated property. Now that it's in use, not enough is 
being done to check that students and faculty are safe. The Gorham site 
is even worse. If ATSDR's calculations are correct, students there will 
be exposed indoors to volatile organic vapors at levels that most 
states, including Rhode Island, consider unsafe.

Pell Complex

The Senator Claiborne Pell complex consists of the Carnevale Elementary 
School and Del Sesto Middle School, on Springfield Street. Built in 
1999-2000, these two campuses at first appear attractive and clean. 
Closer inspection, however, shows what happens when schools are built on 
former garbage dumps.

Construction plans were first announced in February, 1999, and concerned 
residents brought in Rhode Island Legal Services. RILS filed suit in 
August, but the elementary school opened that September. After a 
week-long hearing on an emergency motion to keep the schools from 
opening, the court ordered that Middle School construction not take 
place while elementary students were arriving or leaving school, and 
that windows be closed, and it required further sampling in the presence 
of the community's expert.  But it did nothing further to address 
long-term problems at the site.

The middle school building is constructed on pilings, because the site 
is a historic wetlands as well as a dump site. Thus, the classrooms and 
other interior spaces are in good shape. But the surrounding land has 
subsided, as one might expect on a dump site. Evidence of this 
subsidence surrounds the buildings. There are tripping hazards, and the 
wheelchair ramp into the middle school from the school parking lot no 
longer serves its intended purpose.

In recognition that methane from the former landfill posed a risk of 
ignition or explosion, the buildings have active soil gas collection 
systems underneath. That is, pipes attached to a vacuum system extract 
landfill gases and release them adjacent to the buildings. The approved 
remediation plan for the site required the installation of soil gas 
monitoring wells, but the quarterly monitoring of those wells only 
involves the screening of samples with a photo ionization detector 
(PID), capably only of measuring the total concentration of volatile 
organic compounds (VOCs). That is, the PID does not indicate the 
concentration, or even the presence, of highly toxic compounds such as 
trichloroethylene (TCE) or vinyl chloride. Similarly, indoor air 
sampling has been conducted using the same PID meters, incapable of 
determining the presence and concentrations of specific, highly toxic VOCs.

Gorham Silver Site

The Gorham Company was for decades the nation's pre-eminent producer of 
silver products and bronze statuary. The manufacturing complex on 
Mashapaug Pond, near Providence's border with Cranston, began production 
in 1890. At its height, the 38-acre facility was the largest silver 
manufacturer in the world. It operated three shifts of 1,000 workers 
each. Textron purchased Gorham in 1967, hoping to integrate its silver 
capabilities into its electronics division. The plant was closed in 1986.

After closure, the property was sold and re-sold. When the second buyer 
defaulted on its property taxes, the city of Providence assumed 
ownership. The city leases one third of the property to a shopping 
center currently anchored by Stop & Shop. Recently, without explanation, 
Stop & Shop announced plans to close the store at the end of October 
2006. The city is building a new high school on four acres of the tract, 
and there are plans to construct a new YMCA containing a day care center.

Neighbors, concerned that the city was not doing enough to clean the 
site, went to the Rhode Island Department of Environmental Management 
(RIDEM) to compel action. RIDEM took the city to court and implemented a 
cease and desist order against the city. To join the RIDEM as plaintiff 
the community began working with Rhode Island Legal Services (RILS). In 
response, the courts compelled the city and Textron to undertake 
additional investigation and remediation. Activists believe that the 
investigations are still fragmented and incomplete, and that the 
response remains grossly inadequate.

While in operation, Gorham used a 4-acre company-owned cove on 70-acre 
Mashapaug Pond as a waste lagoon. Initially, the cove was ignored and 
the responsible parties did nothing to investigate that area-after all, 
no construction was planned in the pond. Since then dioxins and PCBs 
have been found in sediment and fish tissue. Perhaps more important, 
activists discovered a massive slag pile, with high levels of lead and 
copper, on the banks of the cove. Under court order, Textron has removed 
much of the slag pile, but it has not yet backfilled the pit with stone, 
reportedly because regulators are not yet convinced that it has removed 
all the contamination.

There is a large perchloroethylene (PCE) groundwater plume under the 
Stop & Shop parking lot. The source of the plume is less than 150 feet 
southeast of the high school site. Unremediated, the ground water will 
continue to flow across the school parcel. The plume is being addressed 
as part of the commercial parcel, but activists believe the full extent 
of groundwater contamination, downgradient under the high school site, 
has not been defined. Furthermore, efforts to treat the PCE in situ with 
permanganate injections have proven ineffective, probably because the 
magnitude of contamination is not yet fully understood.

But the greatest impending risk is from groundwater contamination 
already detected directly beneath the new high school's buildings. ATSDR 
reports significant concentrations of several toxic VOCs, including 
trichloroethylene (TCE), 1,1,1-trichloroethane (TCA), PCE, and two forms 
of dichloroethylene (DCE). The maximum concentration of TCE in shallow 
groundwater under the school is 4,850 parts per billion (ppb); the 
maximum concentration of TCA is 3,450 ppb.

I will focus my analysis on TCE, because it is considered the most toxic 
of the reported compounds as well as the most prevalent, but a thorough 
risk evaluation would examine cumulative risk from multiple chemical 
exposures.

ATSDR also reports soil gas sampling results. Though far from perfect, 
soil gas concentrations are generally considered a better predictor of 
vapor intrusion-the migration of subsurface volatile compounds into 
overlying structures-than groundwater data. The maximum concentration of 
TCE in soil gas was 748 parts per billion by volume (ppbV), equivalent 
to 4,018 micrograms per cubic meter (µg/m3).

Aerial photo from draft ATSDR Health Consultation shows Stop & Shop on 
right side and Mashapaug Pond, including the cove, on the left.

Using the widely accepted Johnson-Ettinger model, ATSDR projects that 
the soil gas concentrations of TCE would attenuate to 34 ppbV (182.6 
µg/m3) in a building with no sub-slab ventilation system in place to 
mitigate vapor intrusion. However, the builders of the high school have 
incorporated an active sub-slab depressurization system into the design. 
With a mitigation system in operation, ATSDR estimates that the indoor 
air levels of TCE would be reduced to a maximum of 6.8 ppbV (36.5 µg/m3).

ATSDR's evaluation appears reasonable through this point. In fact, its 
report does a good job of describing how vapor intrusion works. But in 
establishing a safety threshold of 100 ppbV (537 µg/m3) for TCE in 
indoor air, it is shockingly unprotective. This is two orders of 
magnitude above the action levels currently being utilized by most 
states and EPA regions, and four orders of magnitude above screening 
levels calculated from EPA's controversial 2001 draft Human Health Risk 
Assessment for TCE. That is, in giving the school a potentially clean 
bill of health, ATSDR is off the scale compared to the approach that 
regulatory agencies are using to protect the public from vapor 
intrusion. Most important, RIDEM is currently using a standard of 1 µg/m3.
Based on the ongoing debate over TCE's toxicity, including the recent 
National Academy of Sciences report, I remain unconvinced that even 1 
µg/m3 of TCE in indoor air is safe. This level is particularly 
questionable for schoolchildren who are required to remain in buildings 
where exposure occurs. Yet it's the current regulatory threshold, so it 
serves as the starting point for determining the proper response.

This school should not be opened unless and until it is demonstrated 
that the TCE concentration in indoor air is below 1 µg/m3, and that the 
other contaminants fall below their regulatory limits as well. That is, 
once the exterior structures-walls, roofs, doors, and windows-are 
complete, the indoor air should be sampled, along with sub-slab soil gas 
and ambient (nearby outdoor) air at least twice, during two different 
seasons. Summa canisters or real-time instruments such as EPA's Trace 
Atmospheric Gas Analyzer should be used to measure VOCs in each and 
every distinct airspace, since vapors can collect under large slabs and 
make their way into buildings through the path of least resistance.

If, as ATSDR projects, the TCE level ends up above the regulatory safety 
threshold, even with mitigation, then further response is necessary. 
While it is sometimes possible to optimize mitigation systems, it's 
quite possible that mitigaion won't do the job. Significant resources 
will likely be required to remediate the source-that is, to reduce 
subsurface concentrations to levels that do not cause unacceptable vapor 
intrusion-and that may take years.

It may seem wasteful to prevent the opening of an attractive, modern 
campus, but whoever approved school construction before contamination 
was fully characterized and remedies were in place made a huge mistake. 
It's a travesty that should not be placed on the shoulders (or in the 
lungs) of the students for whom the school is being erected.

Finally, Gorham Silver a severely contaminated, complex site, where 
vulnerable populations are likely to be exposed to unsafe levels of 
toxic contamination. This is the type of property that the federal 
Comprehensive Environmental Response, Compensation, and Liability Act 
(CERCLA, or Superfund law) was designed to address. Though many 
Superfund cleanups have been hamstrung by the depletion of the actual 
Superfund fund, this project need not depend upon tax-generated dollars. 
The Gorham site has a viable responsible party, Textron, with the 
resources to conduct a proper cleanup. Only the commitment is missing.

Therefore, U.S. EPA should act quickly to evaluate the Gorham site for 
inclusion on the Superfund National Priorities List (NPL). NPL listing 
would not only bring in EPA's technical expertise and enforcement clout 
in dealing with vapor intrusion, but it would mandate a level of public 
involvement activity-including the availability of a grant of technical 
assistance-that is currently not in place.

Somehow, the vapor intrusion risks at the Gorham high school site in 
Providence have slipped through the cracks. Action must be taken 
immediately to ensure that students are not exposed to unsafe levels of 
TCE and other toxic vapors in their own school.

1 Greg Zarus and Tammie McRae, "Health Consultation, Providence High 
School Parcel B: Providence, Rhode Island," Agency for Toxic Substances 
and Disease Registry, September, 2006 draft


-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel at cpeo.org>
http://www.cpeo.org