Environmental Resources Management Capitol Tower April 1, 2010 206 Eas" Stet Suite 1700 Mr. Curtis E. Shaw 12) 453-4700 Director Austin Independent School District 1111 West Sixth Street, B300 Austin, TX 78703-5399 (512) 459-4711 (fa) Project No. 0112071 Subject: Summary of Preliminary Evaluation of Potential Risks from Existing Coal Tar Sealant Dear Mr. Shaw: This letter presents the results of ERM’s preliminary evaluation to assist AISD in responding to concerns regarding the use of coal tar containing products to seal asphalt at AISD properties and the potential release of polycyclic aromatic hydrocarbons (PAHs) into the environment. The conclusion of this letter includes ERM’s recommendations for the next steps in assisting AISD develop strategies to manage any potential risks and be receptive to community interest on this issue This preliminary evaluation of the potential environmental implications of existing coal tar sealant at AISD properties included the following components: * a review of scientific studies and other relevant documents relating to the fate and transport of coal tar substances in the environment; «preliminary discussions with several key stakeholders in the scientific and regulatory communities; and * development of a relevant conceptual site model identifying potential release pathways and potential exposure intervals or ecological receptors. SUMMARY OF DOCUMENT REVIEW ERM has assembled a document library containing 41 documents, including scientific studies, scientific reviews, news articles, municipality communications, fact sheets and regulations. Table 1 provides a list of the documents compiled asa well as brief summary of the key points. The document review has provided:Environmental ‘April, 2010 Resources AlsD_ Management ‘A4122 Ltr Rpt Apr Loe Page? * scientific studies demonstrating the potential for the release of PAHs into the environment; © scientific studies demonstrating the potential exposures pathways; © scientific studies demonstrating methods for evaluating the wearing over time of coal tar sealants on paved surfaces; and * insight into actions undertaken or proposed by municipalities to reduce the release of PAHs into the environment through the use of coal tar sealants. Some additional observations from the document review include: * scientific studies since the City of Austin (CoA) ban on coal-tar based sealants have supported the connection between coal-tar sealant use and elevated concentrations of PAHs in the environment; © little to no research has been published directly addressing potential human health risks related to the use of coal-tar parking lot sealants; * since the CoA ban, additional municipalities (mainly in the mid-east or eastern US) have also banned use of coal-tar based sealants, and others have proposed a ban or investigations into the issue; and + in these municipalities, there is little evidence of existing management plans that address parking lot surfaces with existing coal tar sealant, The results of the document review used in the development of the conceptual site model and will be relied upon for the future development of a management strategy. CONCEPTUAL SITE MODEL A conceptual site model describes the suspected sources of chemicals, the fate and transport mechanisms that distribute the chemicals within the environment, the potentially exposed human populations, and the potentially complete exposure pathways. The conceptual site model (CSM) presents only a hypothesis of possible future exposure pathways, which may not represent actual exposure and/or effects on future receptors, For the purposes of this assessment, the exposure media of concern include air, asphalt, soil, sediment and stormwater —as flakes or particulate matter from the coal-tar sealant may be released into rainfall runoff or the wind. Figure 1 presents an example elementary school and indicates asphalt areas, presumably sealed with coal tar containing material. Figure 2 presents the conceptual site model, and identifies the applicable potentially complete exposure pathways. Identification of Suspected Sources of Chemicals Asphalt pavement sealed with a coal-tar based product s the suspected source of chemicals of potential concern (COPCs). Our evaluation of risk will focus on polycyclic aromatic hydrocarbons (PAHs) known to be present in coal-tar based sealants. Our example school has asphalt on approximately 20% of its property, There are two typical main areas considered as suspected sources: (1) a bus lane and parking lot approximately 30 feet fromEnvironmental ‘Apel, 2010 Resources als Management ‘A122 Ltr Rpt Apr Loe Bt Pages the school building, and (2) a playground blacktop approximately 60 feet from the school building. An additional asphalt walkway may contribute as a source area but is not necessarily utilized as frequently as the two highlighted areas. Figure 1 illustrates the site features of the example school. Identification of Fate and Transport Mechanisms PAHs can be found in dust or particulate matter from coal-tar sealed asphalt, which flakes off as the sealant weathers. Weathering followed by wind or rainfall runoff are the primary and secondary release mechanisms (Figure 2). Coal tar sealant dust or flakes can be encountered from direct contact with the asphalt pavement, in outdoor air due to wind, or in stormwater after rainfall accumulates and flows across asphalt areas, Direct contact with asphalt, wind transport, or rainwater transport of PAH-containing dust/PM to adjacent soil areas on the school property and off-site drainage conveyances are be considered. Figure 2’ example school illustrates a creek approximately 30 feet away from the school property boundary, Identification of Potentially Exposed Populations The identification of people that could potentially be exposed to chemicals at the example AISD site involves consideration of current and future land uses of a typical school. Currently identified exposed populations include: staff, students and recreational users. In addition, a generic ecological receptor can be considered with respect to stormwater drainage off of the school property to an adjacent creek or ecological area. The site is use is anticipated to remain the same (school use) with some potential expansion or growth of the school's footprint and staff/ student body. The future land use scenario assumes the same potentially exposed populations, The risks associated with exposure to chemicals depend not only on the concentration of the chemicals in each media, but also on the frequency and duration of exposure to those media. Exposure duration should be modeled after the typical school calendar. For example, students and staff are at the school for 8 hours a day, 5 days a week for 36 weeks per year (during fall, winter and spring); furthermore we can assume a student's average stay at an example school is 4 years (1) and a staff member's is 10 years. If needed, risk calculations can indicate a theoretical risk to a student, staff member or recreational user, which can be evaluated to determine if exposure risk is within acceptable levels, If any risk calculations are endeavored based on this site conceptual model, use of “residential” type assumptions is suggested; as applicable for the toxicity and transport of COPCs