Emerging Issues for Health Officers

1. Emerging Issues for Health Officers MassDEP/ MHOA Winter Seminars 2014

2. Topics to Cover Vapor Intrusion to Indoor Air Trichloroethylene (TCE) Upcoming changes to Waste Site Cleanup rules Soil Management Manganese

3. Trichloroethylene in Indoor Air • EPA Toxicity Information • Implications for Even Short-term Exposure • MassDEP Waste Site Cleanup requirements for “Imminent Hazards” • MassDEP Approach to Quickly Reduce Exposure • Working with Local Boards of Health

4. Vapor Intrusion

5. Breathing: 20,000 Liters/Day Drinking: 2 Liters/Day Why Indoor Air Exposures are Important

6. 2013 TCE Update • In 2011 EPA released new “Reference Concentration” or RfC of 2 µg/m3for TCE • 2 µg/m3 is safe for short- and long-term exposure • RfC considers developmental effects (fetal cardiac malformations) that may occur after exposure during pregnancy • RfC based on animal studies with supporting human epidemiology

7. Update Since Last Year’s Seminar • Question we needed to answer: “At what point above 2 µg/m3 is TCE exposure a concern for pregnant women?” • USEPA has not yet developed guidance for evaluating short-term TCE exposure with new RfC • MassDEP raised the issue with its Health Effects Advisory Committee • Short-term levels of concern identified for • Women who may be in first 8 weeks of pregnancy • General population • Residential settings & • Workplace settings

8. TCE Short-term Levels of Concernfor Sensitive Receptors • MassDEP is working with DPH on recommendations for situations where TCE is detected well above Imminent Hazard criteria. • MassDEPis also working with DPH on public risk communication materials that will be posted soon.

9. Implications for Waste Site Cleanup Program • Rules: Massachusetts Contingency Plan (MCP),310 CMR 40.0000 • “Vapor Intrusion” = migration of contaminants into indoor air from soil or groundwater • In MCP, “Imminent Hazard” are conditions posing a significant risk for even a short period of time • TCE in indoor air may pose an “Imminent Hazard” requiring immediate action

10. Required Response to “Imminent Hazards” • Must be reported to DEP within 2 hours • Triggers Immediate Response Action (IRA) to eliminate or reduce exposures • MassDEP approves (oral/written) IRAs • IRAs include notice to Chief Municipal Officer and Board of Health • IRAs include notice to “Affected Individuals”

11. 2013 TCE Cases in NERO • Thirteen 2-hour notifications (Imminent Hazard) for TCE in indoor air • Seven 72-hour notifications for TCE sites for vapor intrusion less than Imminent Hazard or for high levels of TCE in GW near building • Nineteen 120-day notifications where TCE was detected above DEP Reportable Concentrations

12. Response to TCE Imminent Hazards • Actions put on accelerated schedule, including: • Immediate implementation: • Ensure appropriate Fact Sheets are provided to Affected Individuals; • Vent the basement or lowest level of the building by opening windows; • Seal cracks/utility annular spaces in bottom floor of building and subsurface walls; and • Enclose and passively vent sumps.

13. Response to TCE Imminent Hazards • Implemented as soon as possible, but which may require several days to two weeks to arrange: • Adjust the HVAC system • Install carbon filtration on HVAC system; and • Bring portable air-purifying units (APUs) to the affected building

14. Response to TCE Imminent Hazards • Implementation as soon as possible, but which may require several weeks to two months to design, construct and test: • Installation of a sub-slab depressurization system • Installation of air-to-air heat exchanger to over-pressurize the basement • Installation of a soil vapor extractionsystem

15. Sub-slab Depressurization System(essentially the same as a radon mitigation system)

16. Upcoming Changes to the Massachusetts Contingency Plan • Based upon Governor’s Regulatory Reform Initiative • Public Hearings held in Spring 2013 • Final rules expected Spring 2014

17. Upcoming Changes to the Massachusetts Contingency Plan • Updating and streamlining of cleanup rules based on 20 years of experience, including • Describing closures in plain English:“Permanent Solutions” & “Temporary Solutions” • Adding closure options to better addressVapor Intrusion sites. • & much more…

18. MCP Closure Provisions Endpoints Formerly Known As RAOs (Response Action Outcomes)

19. TEMPORARY SOLUTIONS PERMANENT SOLUTIONS NOTHING FEASIBLE Working TowardsPermanent Solutions PERMANENT SOLUTION With NO CONDITIONS PERMANENT SOLUTIONWith CONDITIONS NATURALBACKGROUND RESIDENTIAL NO AUL REQUIRED ACTIVITY & USE LIMITATION AUL & ENGINEERED BARRIER

20. TEMPORARY SOLUTIONS PERMANENT SOLUTIONS NOTHING FEASIBLE Working TowardsPermanent Solutions PERMANENT SOLUTION With NO CONDITIONS PERMANENT SOLUTIONWith CONDITIONS NATURALBACKGROUND RESIDENTIAL NO AUL REQUIRED ACTIVITY & USE LIMITATION Use of BMPs for Gardening AUL & ENGINEERED BARRIER Anthropogenic Background Contamination in a Right-of-Way Future Building may have VI Concerns

21. Closure for Vapor Intrusion Sites Permanent Solutions with Active Exposure PathwayMitigation Systems (e.g., sub-slab depressurization systems)

22. Active Exposure Pathway Mitigation Measure • May be part of a Permanent Solution with Conditions; • An Activity and Use Limitation (AUL) is required • Remote telemetry required; • Affected parties in buildings must be notified if shutdown extends beyond 30 days • Applies to both SSD systems (vapor intrusion) and point of entry/point of use systems on private drinking water supplies

23. Soil Management Developments:New Similar Soils Policy • BWSC’s “Similar Soils Policy” is FINAL • Available online in “Site Cleanup Final Policies”http://www.mass.gov/eea/agencies/massdep/cleanup/regulations/site-cleanup-policies-guidance.html#1 • Facilitates Implementation of 310 CMR 40.0032(3) (often referred to as the “anti-degradation” provision of the MCP)

24. Similar Soils Policy • When/how soil can be managed without sampling receiving location • Defines what it means to be “not significantly less than” (i.e., established comparison methodology including multiplying factors) • Tables 2 & 3 list allowable concentrations for RCS-1 and RCS-2 Receiving Locations (respectively) • Discusses sampling considerations andperformance standards

25. Soil…What’s Next?? We now have clarity for managing soil that: • Is Hazardous Waste • Contains Solid Waste • Is Remediation Waste • Meets “Similar Soil” Requirements Need clarity for soil that may be safely re-used but does not meet “Similar Soil” provisions: Define & Describe Re-Use of“Reclamation Soil”

26. Manganese in Drinking Water Massachusetts Department of Environmental Protection Drinking Water Program February 2014

27. What is Manganese? • Naturally-occurring mineral in water, soil and air • Present in many common foods including infant formula • Essential nutrient in our diets • Found in both surface water and groundwater • Found in proximity to iron • Found throughout Massachusetts and the US

28. Where is Manganese found? USGS Map of Mn in groundwater in the US

29. Existing Regulation of Manganese in Drinking Water • EPA National Primary Drinking Water Regulations • Secondary Maximum Contaminant Level (SMCL) of 0.05 mg/L (For Mass. See 310 CMR 22.07D) • Aesthetics: taste, odor, color or staining laundry • MassDEP may require PWS to take action on SMCL per 310 CMR 22.07D if warranted by health concerns • EPA Health Advisory Level and MassDEP ORSG Level established

30. Summary Table of Mn EPA Health Advisory (HA) Values MassDEP ORSG Levels Note: At Mn concentrations greater than 0.3 mg/L, parents are advised to use bottled or treated water for their children, in particular to make formula .

31. The Problem with Manganese • Adverse health effects from over-exposure (neurotoxin) • Recent studies have shown an association between intellectual impairment and consumption of manganese in drinking water by school age children. • Concern especially for children under the age of 1 and infants on formula.

32. Manganese Health Effects on Children Water Manganese Exposure and Children’s Intellectual Function in Araihazar Bangladesh”  by Wasserman e al. in EHP 2006

33. Children and Manganese2010 Canadian Study Findings • Ingestion of Mn from water is small compared to ingestion from food. 3 orders of magnitude! • 3.5 ug/kg/month versus 2335 ug/kg/month • Metabolized differently • Levels of manganese found in children’s hair increased with consumption of Mn in water but not food

34. MassDEP CERO Pilot Project on Manganese • Central Region has 809 Public Water Supply sources • All sources have conducted some form of baseline monitoring with most conducting ongoing monitoring for manganese. • Approximately 130 sources (16%) located in the Central Region use treatment technologies capable of removing manganese. In many cases, water treatment plays dual roles, addressing both SMCLs (iron, manganese) and primary MCLs such as arsenic, uranium, nitrate etc. • 4% of sources remain with manganese levels above 0.3 mg/L (300 ppb) and 1.5% with levels above 1.0 mg/L (1000 ppb). • CERO continues to work cooperatively with PWSs

35. MassDEP Strategy - Timeline • October 2013, letters were sent to: • Public Water Suppliers • Medical professionals caring for infants and pregnant women (in conjunction with the Mass Dept of Public Health) • Boards of Health, information is relevant for private well owners • Manganese was put on the sampling schedules for all PWS for the 2014-2016 period

36. Addressing Elevated Manganese for Private Well Owners Treatment • Home water filter unit that is capable of removing dissolved metals Also pitcher filters (some brands) Alternative water supply for sensitive consumers: • Bottled Water • Treated water from another Public Water Supplier Do Not Boil the Water Consumer Q&A on the MassDEP website

37. Bottled Water Regulated by the Massachusetts Department of Public Health (MDPH) • Water Quality Standard for manganese of 0.05 mg/L • All In-state and Out-of-State bottled water sold in Mass must meet Water Quality Standard • Data on each brand is available on MDPH website • A few Mineral Waters are above 0.05 mg/L • Note: Mineral waters are held to a different standard

38. Questions? MassDEP Manganese Contacts