Free Motion for Discovery - District Court of Federal Claims - federal


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Case 1:05-cv-01020-MMS

Document 39-16

Filed 01/05/2007

Page 1 of 51

SUMKR2' AND CCMPARXSCM CP TMD-BOUR BASELINE CHIOREftNE

AIR SftM>UNS RESULT HCM AIR POBCE MIUTORy
13 May 1975

EAMny

HOUSINS (AF MPH)

Prepared Pea:
HEftDQUftREHS UNITED STATES AIR PORCT/SGPA

ttASHEGTC^, D. C. 20314

Prepared By
OFFICE OF THE SURGEON
HEADQUARTERS AIR FORCE IOGISTICS CCWAND

MRIOTP-PATTERSON AIR FORCE BASE, OHIO 45433

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LIST CF ABBREVIATIONS
Abbreviation/ Syrrfaol
fC

EEFINTTIOM
AiAome Chlcarfane Ccaicentration
Airborne Chlordane Ooaioentraticsi Abcwe Trace

ACCAT

AF
AFB

Air Force

Air Force Base Air Force Logistics Oonmand
Air Force Manual
Chlordane Action Group

AFLC
AFM

cac
C3NUS

Continental United States

cy

Calendar Year

DE
GCD
BiL

Directorate of Engineering
Department of Defense
BTvironmental Health Laboratory Fahrenheit Fiscal Year

F
Fit

WH NA

Military Family Housing
Not Applicable

PRE
PCS

Programs, Resources, Engineering

Report Control Symbol

SG

Surgeon
United States Air Force

LEAF
WP

Mright-Patterson AFB

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LIST CF ABBREVICTOB (cont'd)

Afcbreviation/ Syntool
A

LKb'lNiTlON

standard deviation of sanple peculation
mean value of sanple population

5?
W

microgram
microgram per cubic meter of air

pg/M3

i^/ft2
<

microgram per square foot of surface area
less than

>

greater than
equal to

11

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WJS CF OOMTEKES
Paragraph

Title Introduction and Background
References and Scope of Work

Page
1
3

1

2
3

Location and Description
Treatirent

c

Houses and ChLDrdane

5

Sanpling Procedures, Personnel, and Results
Discussion of Results for AE* MPH Units ty Groups of Sources

6 9

Sunroary of Results, Discussion Between Groups,
and Conclusions

17
21

Reccronendations
Attachment I

Detailed Results By AF Bases of Sanpling for Airborne Chlordane Concentrations in AP MFH Detailed Statistics and DistriJaution of Airborne Chlordane Concentrations ty Source (s) of AF MFH Units from Sanpled AF Bases'

Attachment 2

LIST CF TaBUS

Number
1

Title

Page
7

Summary of Data on AF S'2'H Units from Which TwoHour Baseline Chlordane Air Sanples Were Collected Sunroary of *Rro-Hour Baseline Chlordane Air Sairpling Results frcm Air Force Military Family Housing
Range of Statistical Values for Sources of Data Within Groups of Air Force Military Family Housing Units

10

12

Attachment I

1-la
1-lh

Recap ty Area of Houses With Baseline Air Sanples Taken
l^o-Hour Air Sanples Collected 20 Ncv 74

1-1
1-17

1 Apr 75 fron Page Manor, Wright-Patterson AFB Military Family Housing

ill

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LIST OF TBBLES (cont*d)

Attachment 1
1-2
1-3

Title
'l\ro-Hour Living Boon Air Samples Collected 25-26 March 1975 from Andrews AFB Military Family Housing

Page
1-18 1-39 1-20

'Kro-Hour Living Itocm Air San^il^ n-l]wt^ ?fi-?7 March 1975 from Langley AFB Military Family Housing
ThD-Haiir living RTCTII Air- San^l^ r^Ha^ed 28 March 1975 from Pease AFB Military Family Housing

1-4
1-5 1-6

'ftro-Hour Livuig Rcan Air Samples Collected 31 March2 April 1975 from Offutt AFB Military Family Housing

1-21
1-23
1-24

IVo-Hour Living Roan Air Samples Collected 3 April 1975 frcm Mt Home AFB Military Family Housing
l^o-Hour Living BOOB Air Samples Collected 21

1-7
Attachment 2

23 April 1975 from Hill AFB Military Family Housing

2-1 2-2

Qiloa-dane Concentrations

in Air of Pretreated

2-1

Single Story AF MFH
Chlordane Concentrations in Air of Pretreated 'Rro-Story AF MFH
Chlordane .Concentrations in Air of Pressure Injected AF MFH

2-4
2-8

2-3

LIST OF FIGURES
Number

Title
Three Typical Heating Duct Details for Houses In Which T^o-Hour Baseline Airborne Chiordane Samples Were Taken

Page
8

1

Mean Value of Airborne Chlordane Concentrations in AF MFH Units by Source (s) Within Each Corparable Group
Relationships of Airborne Chlordane Concentration Values to Percent of Samples Greater Than Trace in A Sa-nple Population
iv

18

20

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LIST OP FIGURES (cont'd)
Attachrent 2
2-la

Title Distribution of Chlordane Concentrations Above for Trace in Pretreated Single Story AP MFH Each Source Distribution of Chlordane Concentrations Above for 'Trace in Pretreated Single Story AF MFH Combined Source (s)

Page

2-2

2-lb

2-3

2~2a

Distribution of Chlordane Concentrations Above Trace in Pretreated 'E^o-Story AF MFH for Each Source
Distribution of Chlordane Concentrations Above Tcace in Pretreated Iwo-Stacy AF WH for Corbined Source (s) Distribution of Chlordane Concentrations Above Trace in Pressure Injected 1X Distribution of Chlordane Concentrations Above Irace in Pressure Injected 'I\*)o-Story AF VSV. for Combined Source (s)

2-6

2~2b

2-7

2-3a

2-9

2-3b

2-10

v

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A,
1.

SUM-ftRy

AND COMPARISON CF 1WO-H3UR BASELINE CHD3RDANE AIR SAMPLING RESULTS FRCM AIR FORCE MILITARY EAHILSf HOUSIMS (AF MFH)

Introduction and Background.

a. Oilordane is widely used in cavil construction practice as a preventive soil/house foundation treatment against subterranean termite infestation and damage. Chlordane is applied for this use in the Air Force per Department of Defense Guide Specification for Military Family Hausing, "Soil tteataent for termite Control," DOD Spec 4270.21, 1 July 1966, and AEM 91-16, "Military Bitonology Handbook," Dec 1971 (fonnerly AEM 85-7, Jun 1965). Topically a chlordane solution is applied to the occpacted subsoil or to the pea gravel granular fill layer of the foundation prior to pouring the concrete

^ ^

\\

^^^

slab.

*\ b. IXjring construction.o^M^8^8ft|+/-s known as Woodland Hi 11^ at W-P AFB, j-'^-'^^a^^SBa^KEaasigtofaiiar^S^^^t^^^ggga^^^^^ water enulsion NTi'i^'tSfgPggsTiTFi^n rvn ^-f^ryTSt3^)ay?m^y"^^ in DOD Spec 4270.21. Ihe chlordane solution was prepared fcy diluting three gallons of a 46 percent active ingredient chlordane enulsifiable concentrate with 97 gallons of tap water.' This solution is defined as a l^s percent by weic^it active ingredient chlordane solution. Approximately 500 gallons of this solution was applied to a typical 1800 square foot slab foundation which typically has a foundation perimeter of about 180 feet. Ihis equated to an overall application rate of approxinately 0.035 pounds of active ingredient chlordane per square foot of slab area,
c. After chlordane application, the granular fill was cpverea by. polwinyl moisture barrier before the slab was poured.,S|^^^^B@^^(R)B

giSurM iSvSrteSanE. These su&"sTaB'T3ucts^^ exf.eri.or grade elevation, ^^^^'"fWllim^ff3 and were constructed of six and eight inch dlj^+f>r IT I'^^TyjiB^^^P5^^^*^^^^^^'^^
d. Construction of the first increment of these housing units began during the ^S^SSSSSSafffkh initial occupancy occurring during SeptenberOctober 1972. The first indication of -the presence of chlordane in these houses was observed in '^^-IfllMffff^lffft^h^n an "organic odor" was noticed within a house on IXipont Way. Investigation of normal sources for such odors (sewer system, gas leaks, and leaking motor oils) proved negative as causes for the odors. A review of the housing construction and chlordane S(C)li^,y2n.of ateost a year earlier indicated was being volatilized by and was being distributed into the house to cause the odors. Subsequent swipe sanpling of four contiguous

^^MSS^^^^^ff'^^^43^^

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the houses on Dupont W&y Showed cfalordane floors? however, these chlordane levels were a^affi^"'eo pose no risk to habitation and the houses were, therefore, occupied.
e. Until mid-July 1974 there were no known occpiaints of unexplainable odors except at a single Woodland Hills house on 9 April 1973 and again on 27 March 1974. Surface swipes and air sanples were collected on both dates for chlordane analyses and results indicated an apparent increase in the chlordane levels in this house. Consequently, swipe sanples were collected during May 1974 from eleven randonly selected Woodland Hi "MR houses to assess the extent of chlordane levels in the houses. Surface chlordane found. By 24 Sep 1974 conplaints of unexplainl<3w>i a :'nfi"^'klj^^^ able f^-^^^^^^^^SS^^m occupants of four other houses and surface chlordane 3ere^^E3raaB^a^(R)^Bffl?rwe^^ found in them. An additional randonly selected and sailed. While fifteen all "cccplaint" houses had surface chlardane levels ranging from 30.0 to 39.0 pg/ft~ only taao of the twenty-six "non-complaint" houses had such levels and the other 24 "non-ccnplainfc" houses had surface levels lower than 5.1 pg/ft2.

lewe^l^l^^^^^o11

-rCT^^^a^S^aEere

In September 1974, fSlC/SG conducted a ccnprehensive review of all previous data concerning chlordane levels iji the 300 military family housing (WH) units Imown as Woodland Hills at Wright-Patterson AEB, Ohio. Blis review was coordinated with AETC Headquarters/ USftF Medical Center Wcight-Pattersari, and 2750 Air Base Wing representatives from Medical Service, Civil Qigineering, Judge Advocate, Office of Information, and Base Oamander's Office. Due to the cooplexity of the problem and the considered' potential that these chlordane levels in WSS may present a longterm chronic bsalth hazard, these representatives formed a Qilordane Action Group (CTG) chaired ty AFLC^SG to centralize, direct, and review local activities and appropriately ijiplement local and HQ USaF recannended protocols which ware being developed to determine the existing chlordane levels and evaluate methods of controlling/reducing these levels. Activities of the CBG have been multifaceted and it is beyond the scope of this report to present them all; however, the following brief suoaary of certain CTG activities is pertinent to the background of this report:
f.

^^ (

(1) Initial environmental sanpling from late Septentoer 1974 through early December 1974 was centered around collecting and analyzing floors and wall swipe sanples for chlordane in Woodland Hills housing. These data were considered to be sore expedient than air sanpling to determine the extent of chlordane infiltration into the houses. Approximately 280 of the 300 houses in Woodland Hills, 62 of the newly occupied "500 Area" houses contiguous to Woodland Hills, and four of the new and yet iroccupied "500 Area" houses in Area A of Wright-Patterson were swipe sanpled. Additionally, tile sanples from the floors; slab and underslab core borings; hunu.dLfcsr water sarrples; and limited air sairples frann the face

^

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of the duct registers, in certain rooms, and ambient outdoor air were also collected. Results of these samples confirmed that;

and that the mode of entry the sub-slab .precS'eiBUlSeiiil- fcA'TaLmirosTSai^ into the houses was via the sub-slab heatina/air conditioning ductsboth

^g^ Qilordane WoodlariBfflls and new

levels were consistently widespread through 500 area houses at Kright-Patterson AFB.

Aixborne chlordane seBples should be taken to totally evaluate the wwrornaental levels, support needs for evaluating any engineering fixes to stop the entry of chlordane into the houses, and better assess the es^osure levels to tiie occupants.

^BSS

From mid-November 1974 through mid-April 1975 environnental sampling Wrighfc-Patterson MPHs was primarily concerned with taking air samples from Wcignt-Patteraon's Woodland Hins 300 houses, .New 500 Area houses. Page Manor houses, airi four Woodland H-JTI* test houses ^ich had received various focas of heating system Biodificaticns and cleaning/ tile renewal actions. After evaluatJuig theae data? the CSG in conjunction with AFLC staff and USM*/SGARE concluded that these data needed to be oczqpared to airborne chlordane levels in ofchar cmpnirably constructed and termite treated Air Force MEH. The purpose and objective of this report is to summarize and compare all of these airborne chlordane levels and reccranend actions needed to resolve the situation.
(2)
ui

2.

References and Scope of Mark.
a.

AFIC/DE/SG 102100Z March 1975 message to CSftF/SG/PRE.

b. AFLC/SG 101700Z March 1975 message to USftFEHL, Kelly/CC and W-P Msd Cen/SGA (Info copy provided CSftF/S(3*A).

c.

CSftF/SG 131325Z

March 1975 message to fiFLC/SG.

d. CSAF/SG 1416502 March 1975 message to AFLC/SG).

TOC/OC (Info copy provided

e. CSfiF/SG 141651Z March 1975 message to CINCSfiC/CC (Info copy provided AFIT/SG).

f. CSAF/SG 141652Z March 1975 message to HQ CCMD/CC (Info copy prodded AFLC/SG).

g.

CSftF/SG 181517Z March 1975 message to AHr/SC^/DE.

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h. AFLC/SC(R) 2119102 March 1975 message to USAFEHL, tfcClellan/OC (Info ccpy provided CSftF/SGPA).

i.

CSftP/SOA 161704Z April 1975 nessage to AETX/SG.

j. AFLC/S(R) 211610Z April 1975 message to W-P Med Cen/SGB/ Hill HospitaVSGB, and USAPEHL, McClellan/CC (Info copy provided CSftP/S(a>A).
k. Reference "2a" requested HQ USftF coordiiiation and arprwal for AETC to collect and analyze air sanples for chlordane fron Air Force Military Family Housing units which were similarly constructed and have had chlordane treatment like the wits existing at Wcighfc-Patterson MB. H2 USM* concurred with -tMs request and references "2b" throuc^ "2h*1 .inplonented the collecticn of sanples fram other bases and USftFEHL, MsClellan's analyses of thero.
1. In reference "Si," HQ OSSP/SGPA requested that AFLC/SG arrange for collect inn and analyses of baseline air sanples for chlordane from 20-30 Air Force WHs ^duch had never been treated with chlordane during construction or subsequently ty Civil Bagineering. These data were needed to establish a "control group" of household airborne chlordane concentraticns that may exist solely as a result of an occupant's pest control activities indoors and/or outdoors or any Civil Biglneering pest control activities oufcaoors. Reference ''2h'1 implemented this program for obtaining the "control ^roug)" air saqplirig.
m. HQ USAF/T?REM canvassed all OCNUS Air Force WH and determined that 1347 units among five bases met the following criteria for ooreparability to the various 842 units at Wrighfc-i>atterson:

(1) (2)

Slab-on^grade construction with heating and air conditioning
Treated for termite control with chlordane:

ducts under the slab/ and

(a)

Under slab during construction, or

(b) Had had chlordane pressure injected under the slab during the last five to six years.
n. AFLC/DSM determined that 24 units at Hill ?3 were the only such units within AFIC that met the requirements for the "control group" sanpluig. Construction of these units did not have to be coiparable to those at Wright-Patterson AFB.

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3.

location and Description of Houses and

Qilordane 'Qreatroent:

a. HQ USfiF/^REN's survey details were limit-pd and determined only the approximate nurrber of houses at each base which met the criteria for

comparison to W-P housing and the apprcodiaate fiscal or calendar year the houses were constructed. Additional details for ccnparison ware needed and requested ty AFLC/S(R) and HQ USftF/SGRA. 'therefore/ each base identified fcy HQ USftF/PRai and Hi 11 AFB also verified frcm available base records and submitted the following additional data to AFLC/S(R):
(1)
I^ntoer of available houses that ware single and two^story.

(2) lype of chlordane treatment per DOD Spec 4270.21, 1 July 1966, or AEM 91-16 (fonnerly AEM 85-7) depending upon date of construction and/or treatment.
(3)
Nams of agency that applied the chlordane treatment (s).

(4) location of chlordane applied to the houses and coded as follows in. this report: (a)

location, could If verified ty records as:

not^^^Sied by available records S^BiSSSSSSSiSi^
,
iinr
Sub~slab injection

treatment -type "2."

(5)

As-built construction plans of the heating duct details,

(6) Sumnary of all Civil Bigtneering and occupant pest control activities either by self or contractor and products applied in houses.
b. Based upon receipt and evaluation of the above data, MFH units that were distinguishable from others by date of construction, number of stories in the unit, type of chlordane treatment, and base ware considered as separate "sources." Sources that had a canton type of chlordane treatment and nuntoers of stories in the units were "grouped." To facilitate identifying and discussing the sources of sample data, the following abbreviations were used throughout this report:

Base/Calendar or fiscal year of construction/Type of chlordane
treatment.

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c. All of these pertinent data for the houses identified ty HQ USAF/PKEN are lisfpd in 'fable 1 ty base in descending percent of the total number of such houses. Sajnilar data are aiar> included in lable 1 for the control group of houses at Hill AFB selected for sanpling ty AH/ysGB. Figures la, Ib, and Ic present the three typical heating duct details found among the sources of houses and lists those houses having a particular heating duct.
4.

Sampling Procedures, Personnel, and Results;

(1 0.1) chromosorb sanpling tubes were pr "a standard procedure developed fcy that laboratory. The sanpling tube inlet air peart'was always located six to twelve inches above the ground floor in either the living/family roan, off-kitchen dining area -or )d.tchen. 'niis sanpling tube location was considered to provide a "worst case" chlordane concentration since earlier sarples had Shown that chlordane levels on floor surfaces were typically ten times greater than on any wall or ceiling locations above the floor. An additional reason for selecting this sanpling location was that it was within the breathing zone of infants and snail children. The selection of the room for sanpling was dependent upon the length of the punp's power cord and the availability of a grounded electrical outlet. All two-hour baseline chlordane_a3.r sanples were collected while the house thermostat was set at 72CF. P53^^ ^SiMEiagaUMa^^a^M^B^^^S^^^^^tnuSr insuring that a house's heating systenrhad^^^^^^^K^^rdu^ a period prior to and during the sanple collection.

a. Procedures. *"Bro-hour baseline" chlordane air sanples were collected by drawing air through.^^^^(R)(R)^ at a ratejS^(R)

extensiv^^^

b. Personnel. USAF tfedical Center/Sioenvironmental Engineering Services collected all "two-hour baseline" chlordane air sanples from within Wright-Patterson MFH. Sgt David Mueller of that office and Capt Shelton Birch of USAFEHL Kelly collected all subject air sanples from Andrews, Langley, Pease, Offutt, and Mt. Home AFBs. Using identical instructions and sanpltng procedures provided in reference "2j^" Lfc. George New, MSgt Robert Moore and TSgt Earl Valentine, USAF Hospital, Hill/SGB, collected the control group sanples frcm Hill AFB. All subject

Case 1:05-cv-01020-MMS
TABLE 1:
SCMKMQf

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OF DATA ON AF MPH UNITS FBDM WHICH TWO-TOR BASELINE CHICRDANE

AIR SAMPLES MERE COLUaCTD
Awalilable

Type of
Air Force Base

Qilordane Date c)f Houses 2 Stco-y AvailabIe Construction Treatment+ OCMPARAEX^ CONS'TRUCTED MS3D CHL3RDANE T^EKOED TOWKEGHT-1PATTERSON AF MPH* '/fright-Patterson 842 38.5 CT 52 (2) 42 Page tenor 0 40 Woodland Rifis 300 FY 72 (la) 260 FY 75 (la) 84 292 New /&iarters 500 16 108 W

Houises** 1 Story/

total

Percent of Total Houses

Offutt

587

i6.8
18.3

FY 63 EY 72

(Ib)

^

"OST
(1) (1)

40 180
0

247

120

Andrews

406
EY 66
ry 68
250 6

144
300 13.7 176 100 37 1.7
1.0

Langley

cx
Pease

66 cy 70

W
1

(Ib)

24
0

FY 58
Mfc. Hcne

0 0 11 401

37
23

Late 50s FX 60
TOTM,

M

(2)

12
0

1,788

2,189

100.0

CCNTBOL GROUP CF HOUSES WHICH HAVE NEVER RECEIVED ANy CHLaRDftNE T3?EA3MaCT

Hill

24

NA

CX 62/63

(0)

24

0

*
under slab during construction or had chlordane pressure injected under slab during last 5-6 years, acception to this identification is the control group houses at Hill AFB which have never received any chlordane treatment and were selected ty AETC/SGB for sailing. Khiordane Treatment Code: (0) Never received any type of chlordane treatment. (1) Sub-slab treated with chlordane prior to pouring slab at time of construction per DOD Spec 4270.21, 1 JU1 66, or JffM 91-16. <1) (a) same as (1) but denoting that chlordane was applied onto the gravel fill. (1) (b) sane as (1) but denoting that chlordane was ^ylied on top of the conpacted sub-soil before placing the gravel fill. (2) Treated by injecting chlordane under pressure through holes drilled through floor slabs. Treatment done at various tames after occupancy due to termite problems. Solid underlined treatments denote heating ducts coctpletely^g Dotted underlined treatments denote heating ducts ^rffiEy^Siiel^^^^ete beneath ths slab. Mo underlined treatments denote ducts beneath slabs are not encased in concrete. **Available houses were defined as those meeting USAF/PREN specification airi for which available base records verified the specification. W-P Page Manor available houses were defined as those which had been treated, unoccupied at time of sanpling, and not yet under contractor modification.

h:C^c^et^fc?e^R3E^rl&^

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Sources of Houses with This Detail
Heat Duct With No Encasement Beneath Stab
WP/Page Manor/CY 52/2 WP/WH 300/FY 72/la WP/ New 500/FY 75/1 a and Ib Andrews/FY 66/1 Andrews/FY 68/1

Z }

/-

.* Concrete '
Stab

Vapor Barrier^
0.
f\

4'

ft >^ \^

^ Visqueen Wrapping ^^^^firTW <
(or equal)

^l^^a.jS^

.o
>-"7
'/ /

Gravel Fill

c?%0K=^,
f

tf

^.Compacted / r f / f y f / f f f Duct(nater-ia'I optional)

f7T7^yff/ /

-T^ft W Sub-soil

o]

(1242 AF MFH Units)

Heat Duct Partially Encased Beneath Slab
Concrete
Vapor Barrier-3.
Stab

>00^ <0^

F?'

>Visqueen Wrapping''

l^^ ; ^; /
(or equal)

^y ^^

s

^T

Gravel Fill.
^W^^W'

^
e^QA

Pease/FY

58/J_

( 37 AF MFH Units)

Heat Duct Completely Encased Beneath Slab
Offutt/FY 63/ 1b Offutt/FY 72/3b_ Langtey/CY 66/ 1b Langley/ CY 70/ 1b Mt Home/ Late 'loT/J. Mt. Home/FY 60/_2_ ( 910 AF MFH Units)

UUCL

Vapor

Barrier^

^l^).
a
9

.4

S1ab

<

'

Visqueen Wrapping.

-'(or equal)
c.

-,-r

a_ a^ iL. ^'''T^^^TT^^TT^

0

g-A-g-^-J

Figure 1:

Three Typical Heating Duct Details for Houses In Which Two Hour Baseline Airborne Chlordane Samples Were Taken

f

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air sanples from all seven bases were analyzed ty USftFEHL McClellan per established techniques previously reported in our monthly PCS: HaF-SS* (M)7404 reports 15 January through 18 April 1975.
c.

Results:

Above an absolute chlordane mass analytical sensitivity was to the nearest five-hundredths SSro^ran. However, due to analytical variance and reproducibility, the eDxxmt (nass) of chlordane was reported to the nearest 0.1 Tm'<'!n'xjTaniB above 0.2 micrograns. For a sai^le causing an instrument response below 0.2 micrograns, the mass of chTnn3ane was reported as ?(R)g^^or<0.2 nacrogr.TmB. Sanples which caused no instrunent response were reported as IgR^Ffe^iCT^S8*- *<0.2 micrograns. lie concentration of chlordane in the saicpled air volume was calo.il ated to the nearest tenth of a miczogram per cubic mpter and reported with a less than sign if the chlordane mass in the sanple was "trace" and with an asterisk preceding a less than sign if the chlordane mass in the sa^^jMas

^^te^fe^^^^"

(2) Results of all subject samples collected and analyzed as of 28 April 1975 are sunnarized in Table 2. 'fable 2 also lists some brief calculations of the suamarized data and groups ths data ty type of unit and chlordane treatment received- Detailed results for each base (HrightPatterson, Andrews, Langley, Pease, Offutt, Mfc. HTmc and mil AEB are listed, respectively, in Tables 1-1 through 1"7 of Attachnent 1. The data in "fable 1-la are orly the two-hour baseline, sampj^results and,
therefore,

ir/4U4 report- inrs'Tts report listed all wnqt iline air sanple data independent of sanpling time (sanple
volume).

rurffi'Sw'-^ffrjimm.^ir^

5. Discussion of Results for AF MFH Units ly Groups of Sources (Houses ^hat Received the Same lype of Chlordane 'D^atment and Had the Same Nurrfaer of Stories).
a. From a subjective evaluation and ocnparison of the data in Tables 1 and 2 and Attachment 1, it appeared that in most cases the percent of airborne chlordane concentrations above trace (AOCAT) and their range (distribution) of values may be related:

(1)

Directly to the:

(a)

Nimber of stories in a MPH unit

Case 1:05-cv-01020-MMS Of
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Case 1:05-cv-01020-MMS

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Case 1:05-cv-01020-MMS

Document 39-16

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(b) Type of chlordane treatment applied fcy the Air Force for termite control, and
(c)
(2)
Details of heating duct encasement beneath the slab.

IndEpendently of the:
(a)
Base sanpled,

(b)

Date of any Air Force applied chlordane treatment for

termite control, and

(c) An/ limited spot treateent of pesticide^ including chlordane, ty the occupants or Civil Engineering inside or outside the housed.
b. To objectively evaluate these observations, statistical values and probability distributions were calculated for each separate source of data in table 2 which had at least six samples above trace* Except

for Wcight-Patterson/Page Manor 2-story/cy52/2 data, probability distributions between 30 and 90 percentile were found to have good fits to a log normal distribution. Statistical values were, therefore, calcniafpd for log base ten values of each airborne chlordane concentration and the antilog of each statistic was taken to convert the statistic back to its original unit of measurement. Each source of statistical values was grouped ty nmtoer of stories in the WH and type of chlordane treatment- The sniali range of these statistical values ("fable 3) indicated that each source's data was from comparable distributions ana that each source' could be cocpared to others within that group. Detailed results of each source's statistics and plots of distributions of values within each group are presented in Tables 2-1 through 2-3 and Figures 2-1 through 2-3b, respectively, in Attaclment 2.

TABLE 3:

Range of Statistical Values for Sources of Data Within Groups of Air Force Military Family Housing Units (AF KFH)

Groups of Data Dependent
Narber of

Ch Type of
Qilordane

Stories

Treatment*
la or Ib l,la,lb or Ib Two(Pease) 2 2 TwoCW-P

Percent-iles of Goodness of LogNormal Fit

Range of Standard

..-i

Deviation

1.6 1.6

Standard Error of Msan

(yq/M5)**

Single

30-90 30-90 20-90 None

1.6-2.1 1.3-2.1

1.1-1>2 1.1-1.3 1.1
1.1

TV-0

*See Definition in Table 1 or Table 2 **Rounded off to nearest tenth
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Case 1:05-cv-01020-MMS

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and of these houses at Hill AFB.

As presented in Table 1-7 were collected at twenty-two

^^^^^^^^^^^^^^^^^^^^^^^^^^'^^^^^^^B^^ w^W^JTTP'^^"'^ '^c^^aiT^r^^]
had never used any pesticides which contained chXordane or heptachlor;

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therefore, oonparability of airborne chlordane analyses between these and treated test houses was considered to be independent of oomparabilij of de-'-^'ig of construction or heating ducts betwsen the houses. less than trace airborne chlordane concentraiSsSn^'SSSKBSjag^ the seven houses Whose exterior yards had been chlordane treated fcr ant control by Civil Bigineering from 1969 through 1972. Additionally, two aAient air samples, each collected jji a chlordane treated yard, contained no detectable levels of chlordane. These data indicated that any exterior chlordane treatments or any previous occupant interior spot treatments with chlordane did not produce any interior airborne chlordane concentrations above detectable levels. Considering these data, one would deduce, that such treatments made no contributions to airborne chlordane concentrations a&ve trace (ACCATS*! in other houses specifically sub-slab treated with chlordane for termite control.

^fSSi^

Air sampling from such AF MFH units was ^fflm^ff^iy'fi^^n^TC^^^^^^ for a single sample which was less than trace concentration and collected from a Langley AFB/Cf 66/lb unit. Data were, thus, insufficient to ccrqpare directly to WP*s WH 121 thi6 group, 'fable 2-1 and Figures 2-la and 2-lb present the statistical values and graphical plots for the 87 to 96 percent AOCAT's 'of WP WH sanples. While WP/Mew 500/lEY75/la mean ACCAT, ^,^^1^^^^^^ higher than HP/New 500/EY 75/lb irean ACCAT; different when conpared at a 90 percent confidence level, this indicated that chlordane applied sub-slab on conpacted soil or on the gravel fill around unencased heat ducts had not produced any significantly different airborne chlordane concentrations (AOC) within these houses which were otherwise constructed in the same manner and during the same tilae period. These single story WP/Mew 500/Fy 75/la and Ib AOSAT's were, therefore, corbined and ccrrpared to single story MP/WH 300/EY 72/la ACCAT's. At a 90 percent confidence, this comparison showed that airborne chlordane concentrations between these houses were significantly different. Reasons for this observed difference are unknown but the difference indicated -that:

(1) Date of construction and chlordane treatment did not cause lower levels to be observed in older houses.

(2) Chlordane application rates may have been higher in WP/WH 300/ FY 72/la houses.
(3) Unknown minor differences in installation of optionally selected heat duct materials and geological features may have contrilxited to causing the different ACCAT's.

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This group contained the largest naifcggTOMMTOS^^^ ths largest mi^er (1697) of coiparably oonstructed/dhlotdane treated houses within CCNUS. the following discussion is divided into two parts in order to distinguish between those sources of houses which had distinctly different percentages of AOCAT samples:

(1) Offutt AEB houses and the Langley/CT 66/jb houses within this sub-group had equal to or less than four percent ACCAT samples. Ihe number of houses (IS to 30) sampled fron each of these sources was adequate to determine, with 901 statistical confidence, the airborne chlordane concentrations within these houses. When these data and housing details were cccpared to other houses in this group, the following deductions and a defensible reason for the arall niyriipr of AGCAT sarples were indicated:

(a) Date of construction and chlordane treatment did not cause lower levels to be observed in older houses. (Offutt/EY 72/lh had less than trace levels coqparable to OffuttAY 63/lb and Langley/CY 66/lb. In fact, the only ACCAT sample (1.1 m/VS-) was fram the oldest source,

Offutt/EY 63/Ob).
(b) Chlordane application rates may have been lower in this sub-group of houses than in other sources within this group.

m construction techniques most not have been a significant contributor in causing different ACCKT's sinoe single and two-story Offutt/EY 72/JLb and WP/Kew 500/PY 75 la and 2b houses were constructed fcy the sane contractor following otherwise almost identical specifications,

(d) Unknown minor differences in geological features may have contributed to the almost non-existent ajirbome chlordane concentrations in these houses. However, this was considered an unlikely contributor since both the Langley/CT 66/lb arai WP/ttH 300/EY 72/la houses are located in areas of similarly poor drainage.
(2) Statistical values and distributions of ACCST's fron all other sources in this group are presented in 'fable 2~2 and Figures 2-2a and 2-2b, respectively, An evaluation of the statistical values in 'Rtble 2-2 showed that. at the 90% confidence level, AOCar*s from the following sources could be carbined: Andrews/FY 68/1, WP/ttew 500/TY 75/lh, Langley/CY 70/lb and Andrews/eY 66/1. Data occrbined from these sources ware significantly different from each of the other two significantly different WP sources. within this group; i.e., WP/New 500/tY 75/la and WP/WH 300AY 72/la. Ccrparisons of these data and housing details among this group revealed the following deductions and reasons for the differences:

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(a) Date of construction and chlordane treatment did not cause lower levels to be observed in older houses. Sane houses constructed fran 1966 through 1975 had statistically the same airborne chlordane concentrations. The highest observed levels were in the WP/ttH 300/EY 72/la source which was three years older than the next highest source.
(b)
Chlordane ftr'pUcirtian rates may have been higher in the

WP/^H 300/TY 72/la houses than in other houses in this sub-group.

encased Langley ducts was not considered representative of any other such chlordane pretreated, ericased ducts for the following reasons:

^. These were the only such encased ducts found to have had a history of water intrusion into than. Wet ducts in these Langley/GC 70/lb houses have historically been a significant problem in far greater proportion than an infrequent wet duct in the geographically adjacent Langiey/ CX 66/Jh group. Langley AFB Civil aigineering (construction) reported that both Langley housing sources were constructed under the same specifications, adjacently located on the same geological terrain, and their ducts differed only in whatever the contractor optionally selected for duct material and any minor differences in details of duct installation. Thus, whatever the exact reason, the frequent wetness of Langley/CT 70/lb ducts TWC^C them unique since wetness of eaicased ducts has only occasionally been observed at any of the other sampled bases.
'[he Langley/CT 70/lb soisrce of houses was the only 2. one of five sampled sources which contained such ducts and had mare than 4% ACCAT sanples.

(d) Unknown minor differences in geological features may have contributed to the highest AXKT's being found in WP/WH 300/EY 72/la houses since this housing area has a history of subterranean drainage problems and wet slabs have been consistently observed in approximately 8% of these houses .However, if one considered Langley/CT 70/lb duct encasement to be of such poor integrity as to allow chlordane entry into the ducts, then Langley/CY 70/^b slab wetness should have caused ACCAT's comparable to those found in wet slab MP/WH 300/tY 72/la houses. These source's ACCAT's were significantly different and, thus, based on these limited data, any relationship of slab wetness to expected AOCAT's could not be deduced directly or substantiated.
the

g^^ii^^-y^^ ^i

records revealed that ^^^^^^I^BEr^^^^vailablegroup ever received anynone of ^^j^ t)^.s chlordane

^^^

15

Case 1:05-cv-01020-MMS

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pretreatment. accept for Pease Ara/tY 58/2 and, to a "liimte^ extent W-P/ Page Manor/CY 52/2, the nwtoer of AOCAT's were not large enough to provide a valid statistical ocnparison to each other. The nmber and range of AOCaT's were large enough only at Pease AEB to define the type of distribution and the Pease/tY 58/2L distribution was found to be log normal, Considering the results within the other groups, there was no reason to believe the AOCAT's fron HP/Page Manor/CT 52/2 and Mt Hane/EY 60 and late 50's/^ pressure injected group had other than log normal distributions.
(1) Single Story Houses, Ctaly eleven of these houses were single story and all were located at Mt Hone AFB. Pour of these were air sampled and all were below detectable chlordane concentrations.

|^

(2) Two-Story Bouses. All the houses at Pease and WP and twelve of the Mfc Hone houses in this group were two-story. Statistical evaluation plots of distributions of ACCAT's could be done only for Pease and Wrightsee Table 2-3 and Figures 2-3a and 2-3b. Pattfirson results in this group Although HP data weze not definitively determined to have a log normal distribution, they were assured to be. Resultant statistical conparisons between these Pease and Mright-Patterson data indicated that their distributions were not significantly different at the 90% confidence level and could be combined as shown in Figure 2-3b. The curve in Figure 2-3b indicated that the combined distribution of WP and Pease ACCftT's nay not have been log normal but have been bunodal with about 35% of the values below 1.0 pg/M3, 20% above 1.5 pg/M", .and the remaining 45% of the valises averaging about 1.3 (+ 0.1) pg/W.
Comparisons of the data from these WP, Pease, and Mt Hane houses (Tables l~lb, 1-4, and 1-6) revealed that no consistent relationships y existed between observed airborne chlordane concentrations and:
(3) (a)
(b)
Date of pressure injection,

d

Volume or concentration of chlordane solution injected,
Base on which the houses were treated,

(c)
(d)
(e)

Nirrtoer of stories in the treated house, or

Type of sub-slab duct encasement.

All but the last two relationships above were consistent with those deduced from the data on pretreated houses. The two differences ware probably due to the more localized and peripheral treatment characteristics of pressure injection which may or may not have deposited chlordane near or in sub-slab ducts. Thus, with the uncertainty of injected chlordane *s proximity to a sub-slab duct, any airborne chlordane concentration may be observed and te independent of duct encasement. The four ACCAT's at Mt Hone indicated that

16

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Case 1:05-cv-01020-MMS

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the 15-20~year old vemiculite concrete dact encasement may not have the structural integrity to preclude chlordane intrusion into these ducts.
6.

Sunnery of Results, Discussion Between Groups, and Conclusions:

a. Known usages of chlordane in yards of non-chlordane treated ("control group") AF MRi units did not cause any interior airborne chlordane concentrations (flCC's) above detectable levels. Possible interior use of chlordane fcy previous occupants in these control group houses and known interior chlordane spot treatments in two Mb Hcroe and one Offutt house since February 1975 produced no interior A3C's above detectable levels when sampled in early April 1975, Siese data thus indicated that any chlordane spot treatments on exposed interior or exterior surfaces probably nade no significant contributions to any airborne chlnrrtane concentrations above trace (AOCAT's) found in chlordane pretreated or sub-slab injected houses.
b. Statistical carparisons of each source of ACC*s within the three groups of chiordane treated AP WHs revealed those sources which could be ccnbined with 90% confidence, those that were frcro similar population groups, and those which were distinct from others. These groupings with associated data are graphically presented in Figure 2. Based upon the statistics within each group and the percent of AXftT sanples within the source (s) of each group, the airborne chtedane concentrations within each group were, at 90% confidence, considered distinct from those in other groups.

"
17

c. Airborne chlordane concentrations (including "trace" results) from pretreated two-story MFH lanyley/CT 66/lh and both Offutt/lb sources averaged arprcodjnately *0.6 w/W snd were ~^E& lowest values oBserved for comparable houses within the pretreated two-story group. Oonparison of ant of the sub-slab ducts g^Mft therefore, if

(Langley/CT 66/lh) had been sampled fron these sources, the average AOC's frcm these single story units would most probably have been within the same range of values as for the two-story units from these sources. Although Mfc Bane's duct encasement in venniculite concrete may be of poorer structural integrity, the encasenent barrier and limited sanpling indicated that ACC's at Mt Heine roost probably would have averaged $0.6 pg/>T. Ihus, fron tha sanpled ana "nost probably" data groupings in Figure 2, ACC*s were consistently lowest in houses having ccnpleted encased sub-slab ducts except for Langley/CT 70/lb houses. This source of Langley houses was, however, considered atypical of encased ducts since they were the only such ducts in the sarapled houses which consistently had water infiltration into them.

d. Considering the source frcm a given base, pretreated single story houses having unencased sub-slab ducts had ACCAT's which averaged 2.1 to

Case 1:05-cv-01020-MMS
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3-FniT-i s5uspT3U03 ^06 3B snTBA UPSN 30 3T^n .iSrto'1 pu^ -isddn (gW/S")mM JV UT .ITV "T suo-p3Banu33Uoo suBp.io-i:H3 au-nss^g .inoH OAJ,

Case 1:05-cv-01020-MMS

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and were about twice as high as the average ACCTT observed in 4.5 their respective prefcreated two-story houses, 'this difference inost likely resulted from the fact that pretreated single story houses have about twice the ground floor slab area and thus about -brice the length of heating ducts beneath the slab than do two^steory units. Based upon this rationale, the pretreated sijagle story Andrews/tY 68/1 houses most probably had AOC's $2.0^ag/M3/ i.e., equal to or less than twice the average A3CAT value (1.0 w/y^} of san^led two-story Andrcws/SY 68A houses.
e. Except for two-story MP/Page Manar/CX 52/2 and W/New 500/SY 75/lb houses, the A3CATS in all UP WH units were significantly higher than those from comparable sources at other bases* Baaed upon the mean values, HP chlordane concentrations were 4 to 7.5 times higher than other comparable pretreated single story units, and 1.7 to 2,6 timpfi highpr than other comparable pretreated two-sfcory units. Pressure injected WP/^age Manor houses had a mean chlordane concentration which was 75% of, but not statistically different frcm, cooparable Pease AFB houses.

m/f^

f. As presented in Figure 3 an excellent direct correlation existed betwsen the percent of airborne chlordane concentrations above trace (AOCAT's) and the average ACQT and the 90% probability AXAI values from a sanpled source. Thus the higher the AOCAT's found in a sanpled source, one would expect more prevelant airborne chlordane concentrations and a higher mean ACCAT from that source.

g. The cause(s) far all observed differences in ACC's among comparably constructed and chlordane treated houses could not be ascertained frora all available records on the houses. However, deductions based on cccparisons of sampling data and the house records indicated how the following items related to probably cause the differences:
(1) Length of time since construction, pretreatanent, or pressure injection was not consistently related to observed A3C*s.

(2)

For houses having unencased sub-slab ducts:
(a)
Increased ratio of ground floor area to interior volume

of house caused higher AOC*s; i.e., single .story versus two-story AF MFH

units.

(b) Houses pretreated with chlordane on corcpacbed soil beneath the gravel fill apparently caused some houses to have 50% lower, but not always siqnificantly different, ACCAT's frcm houses which had been pretreated with chlordane on the gravel fill.
(3) Conplete encasement of sub-slab ducts undoubtedly precluded chlordane entry into the ducts and produced the lowest observed ACC's

19

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Probability that 902 of the concentrations will -0-(&-,be equal to or less than the graphical value.

-0-B-Mean value of sample population.

'9.0

8.0

7.0

6.0

Values of Airborne Chlordane Concentrationsin AF

5.0

"MFH
4.0

(ug/M3)

3.0

2.0

1.0

0.0

with a correlation coefficient8' 0.88

20 80 40 60 Percent of Saaples Above Trace In Sample Population

100

Figure

i

Relationships of Airborne Chlordane Concentration Values Tc Percent of Samples Greater Than Trace in A Sample Population

20

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4% AO^AT's) in pretreated two-story houses. However, due to ACCAT ( findings in langley/CY 70/lb houses, the following particular details of encasement sust be thoroughly defined to preclude chlordane entry into the ducts:

(a)
(b)

'lype and strength of encasing concrete,

Type of duct mflt-prial,

(c)

Joining/installation of duct material.

(4) Duct encasement in the Offutt/EY 63 and FY 72 houses showed the best success rate in preventing chlordane intrusion into the ducts. (5) While wet slabs say have contributed to chlordane infiltration into unencased sub-slab ducts, the data were too 1 inn tfd to determine any direct relationship. Observed ATCAT's in "dry" slab houses showed that chlordane infiltration into the house was not dependent on slab wetness. (6) Unknown differences in the applied active ingredients of chlordane per unit slab area may have contributed to causing the different
observed AOC's.

(7) Due to uncertain proximity of injected chlordane to encased or unencased sub-slab ducts, AOC's in pressure injected houses were variable and independent of all relationships deduced for pretreated houses.
7.

Reconiierriations:
a.

That HQ

IBAF/SG/PKE in conjunction with others:

Determine safe airborne chlordane concentrations for human habitation of these Air Force MFH units.
b. Advise as to whether or not these units should be reducted to seal off the source of chlordane entry into the houses, and if so, which units.

Establish definitive modifications to future Air Force housing designs to prevent sub-slab applied pesticides from entering the houses via airborne modes.
c.

21

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Detailed Results By AF Bases of Sanpling for Airborne

Chlordane Concentrations la AF WH

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MEMO FOR RECORD

13 ^V 1975

Supplemental Information

to "Detailed Results of Sampling for Airborne Concentrations by AF Bases Chlordane

Attached data represents the results of two hour baseline air samples from inside military family housing (MFH) units at Wright-patterson, Andrews, Langley, Pease, Offutt, and Mt. Home AFB's, The data were collected from mid- November 1974 through 21 April 1975. Housing units that were distinguishable from others by date of construction, number of stories in the house, type of chlordane treatment, and base were considered as separate sources. Each of these sources that had a common type of chlordane treatment and numbers of stories were grouped.
The following various codes were used to identify the sources and, for Wright-patterson AFB samples, the locations of the samples collected from within the houses:

Base/ calendar or fiscal year of construction/ Type of chlordane treatment by code (1), (la), (Ib), or (2) as defined below:
(1)
Sub-slab treated with chlordane prior to pouring slab at time of construction per DoD Specification 4270.21, 1 July 1966, or AFM 85-7 or 91-16 dependent on date of construction. If base could not verify from records that the chlordane was applied to the sub-soil or the travel fill, then that source was coded (1) for chlordane treatment. Same as (1) but denoting that base records verified that chlordane was applied onto the gravel fill. Same as (1) but d-enoting that base records-verified that chlordane was applied onto the compacted sub-soil beneath the gravel fill. Treated by injecting chlordane under pressure through holes drill through floor slabs. Treatment done at various times after occupancy due to termite problems. (NOTE: all houses that had received this type of treatment had never been pretreated at time of construction. All such sub-slab injections were performed by Base Entomology Shops.)

(la)
(Ib)

(2)

Sample location codes for Wright-patterson samples listed in Table 1-a:
First Letter

Definition of Location Downstairs in two story or bilevel house. Single story house. Upstairs in two story or bilevel house.

D S U
Second Letter

A

D

Ambient air sample in rooa. Duct or face of register air sample in room

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Wright-Patterson AFB two hour baseline air samples are presented In Table 1-a. This table is divided into sections by Wright-Patterson base housing areas. Data in each area show how many houses have been two-hour baseline air sampled, how many of certain location types of these samples have been collected in the houses, and results of each location type of two hour baseline air sample. Note that sample results are presented in numerically ascending order from left to right across the page.

^B

^^'

Analytical detection limit was 0.2 micrograms of chlordane per sample. Calibration standards were run at least twice daily using EPA standard chlordane as well as technical grade chlordane. Results were quantitated on five to Floor waxes seven primary chlordane peaks and reported as "total chlordane" have not presented any analytical interferences since they elute 10 to 20 minutes after the last chlordane peak. Additionally, typical patterns of known poly chlorinated byphenyls (PCB) have not been observed during analyses of these samples. Tracings have not indicated any PCB*s and the computer ignores all peaks that arise from PCB's Aroclor 1242 and 1248.
Air sample results have been recorded as less than the quotient of 0.2 micrograms divided by the cubic meters of air samples; i.e.
"non-detectable"

concentrations,

CHARLES W. BULLOCK, Capt, USAF, BSC Staff Bioenvironmental Engineer Office of the Surgeon

lc^u T^^W

1-ii

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TABLE l-la
RECAP BY AREA OF HOUSES WITH BASE LINE AIR SAMPLES TAKEN +
AS OF 21 APR 75

PREPARED FOR THE COMMAND SURGEON (AFLC) BY THE MEDICAL COMPUTER SYSTEMS GROUP U.S.A.F. MEDICAL CENTER, URIGHT-PATTERSON (AFLC)

+ Excludes all baseline air samples that were not equal to or greater than 120 (j_ }0) minutes sampling time at 3.2 (fO.1) liters per minute.

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TABLE 1-1 a: cont'd
RECAP BY AREA OF HOUSES WITH BASE LINE AIR SAMPLES TAKEN

AREA
222
207 i5

WOODLAMD HILLS
HOUSES HAD AIR SAMPLES TAKEN HOUSES HAD AT LEAST ONE SAMPLE GREATER THAN TRACE HOUSES HAD ALL AIR SAMPLES TRACE OR NON-DETECTABLE
HOUSES HAD SA' SAMPLES HOUSES HAD AT"LEAST ONE 'SA' SAMPLE HOUSES HAD ALL 'SA SAMPLES > TRACE

25 25 25

>

TRACE

27

2.00 5.20 5.60 5.50 8.70
0

S^ SAMPLES WERE
2.10

3.40 4.00 5.90 10.50

TRACE 2.70 3.40 4.30
6.90 10.90

2.90 3.50 4.40 7.30

5.10 3.60 4.60 7.80

3.20 3.60 5.40 7.90

0

^' "SA'

SAMPLES WERE TRACE SAMPLES WERE NON-DETECTABLE

0 0

0
0

HOUSES HAD 'SD SAMPLES HOUSES HAD AT~LEAST ONE 'SD HOUSES HAD ALL "SD SAMPLES

>

SAMPLE TRACE

>

TRACE

0 0

S^ SAMPLES WERE 'SO' SAMPLES WERE 'SD' SAMPLES WERE
HOUSES HAD

>

TRACE

TRACE

NON-DETECTABLE

i96 181 79
1S6

HOUSES HAD AT LEAST ONE

"D^'

SAMPLES

HOUSES HAD ALL

'DA'
>

SAMPLES
TRAC:

"D^'

SAMPLE TRACE

>

TRACE

DA

SAMPLES WERE

1-2

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TABLE 1-1 a: cont'd

95fl
0 0

'$D' 'DD'

SAMPLES WERE TRACE

SAMPLES WERE NON-DETECTABLE

0 0 0

HOUSES HAD 'Ufi' SAMPLES HOUSES HAD AT LEAST ONE 'j^A HOUSES HAD ALL 'UA SAMPLES
UA

>

SAMPLE TRACE

>

TRACE

0
0
0 0 0 0
0 0

SAMPLES WERE

>

TRACE

'UA'

SAMPLES WERE TRACE

'UA' SAMPLES WERE

NON-DETECTABLE

HOUSES HAD 'UD' SAMPLES HOUSES HAD AT LEAST ONE 'UD' SAMPLE HOUSES HAD ALL 'UD' SAMPLES > TRACE

>

TRACE

JJD

SAMPLES WERE

>

TRACE

''^D'
'UD'

SAMPLES WERE TRACE

0

SAMPLES WERE NON-DETECTABLE

1-4

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TABLE 1-1 a: cont'd

9,50
0

0

^'

SAMPLES WERE TRACE

'DD'

SAMPLES WERE NON-DETECTABLE

0 0 0

SAMPLES HOUSES HAD HOUSES HAD AT LEAST ONE 'UA' SAMPLE HOUSES HAD ALL "UA SAMPLES > TRACE

'Ufi'

>

TRACE

0
0
0 0 0 0 0 0
0

UA' "UA" 'UA'

SAMPLES WERE

>

TRACE

SAMPLES WERE TRACE SAMPLES WERE NON-DETECTABLE

HOUSES HAD UJ) SAMPLES HOUSES HAD AT LEAST ONE HOUSES HAD ALL "UD" SAMPLES

'^D'

>

SAMPLE TRACE

>

TRACE

^

"UD'

SAMPLES WERE

>

TRACE

'^JD'
"UD"

SAMPLES WERE TRACE
SAMPLES WERE NON-DETECTABLE

1-4

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TABLE 1-1 a: cont'd
0.40 0.60 0.80 0.90 .00 .10 .20 .30 .30 .40 .60 1.70 1.70
1,80

1.80 1.90 2.00 2.10 2.30 2.30 2.50 2.50 2.70 2.90 3.00 3.30 3.60 4.20 5.10 6.10 7.50 26.10
5

0.40 0.70 0.80 0.90 1.00 1.13 1.20 1.30 1.30 1.50 1.60 1.70 1.70 1.80 1.80 1.90 2.00 2.20
2,30

2.40
2,50

2.50 2.70
2.90

3.10 3.40 3.70
4.40

5.10 6.20 8.10 30.00

0.50 0.70 0.80 0.90 1.00 .10 .20 .30 .40 .50 60 .70 .70 .80 .90 2.00 2.10 2.20 2.30 2.40 2.50 2.60 2.70 2.90 3.10 3.40 3.80 4.40 5.50 6.50 9.30 34.00

0.53 0.80 0.90 0.90 00 .10 .20
,30

0.50 0.80 0.90 0.90 .00 .10 .20

0.60 0.S0 0.90 1.00 (.10 1.10 1.20

C

.40 .50 .60 70 .80 .80 .90 2.00 2.10
2,20

.30 .40 .50 .60 .70 .80 80
1,90

1.30
1.40 1.60 1.60 1.70 1.80 1.80 1.90 2.00 2.10

2.00 2.10
2,30

2.30
2.30 2.40 2.50 2.60 2.80 3.00 3.30 3.60 4.00 4.60 6.00 7.40 22.10

2.30 2.40 2.50 2.60
2,80

2.90 3.20
3,40

3.90
4,40

5.50
6.S3

17.40

2.30 2.40 2.50 2.60 2.80 3.00 3.20 3.50 3.90 4.40 5.80 6.90 19.40

r V

DA SAMPLES WERE TRACE 00.50 00.50 00.60

00.60 00.50 00.60

00.60 00.50 00.70

11

SAMPLES WERE NON-DETECTABLE 00. 50 00.40 00.50 00.50 00.50

00770
4
4 4

'DA'

HOUSES HAD 2P SAMPLES HOUSES HAD AT LEAST ONE 'DD' SAMPLE HOUSES HAD ALL "DD' SAMPLES > TRACE

>

TRACE

7

3.40

^D

SAMPLES WERE
4.40

>

TRACE 4.70

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TABLE 1-la: cont'd
RECAP 3Y AREA OF HOUSES WITH BASE LINE AIR SAMPLES TAKEN

TREATMENT TYPE la (Pretreated sub-slab on gravel fin)
AnA
NEW QUARTERS

155 146
49

HOUSES HAD AIR SAMPLES TAKEN HOUSES HAD AT LEAST ONE SAMPLE GREATER THAN TRACE HOUSES HAD ALL AIR SAMPLES TRACE OR NON-DETECTABLE

30 27 28
28

HOUSES HAD 'S^' SAMPLES HOUSES HAD AT LEAST ONE "SA HOUSES HAD ALL 'SA' SAMPLES

SAMPLE
>

>

TRACE

TRACE

'SA' SAMPLES WERE 07^0 0.50
l.i33

>

TRACE
0.80 2.00 2.80 3.80 6.30 0.80
2,10

2.6.3 3.6^ 5.20
1 2

1.60 2.70 3.80 6.03

0.80 2.20
3,40

5.40 4.53 8.80

4.70

30.53

'^A'

SAMPLES- WERE TRACE

'SA' SAMPLES WERE
J.y~?0

NOM-DETECTABLE

33.60

3 2 J

HOUSES HAD 'S$ SAMPLES HOUSES HAD AT LEAST ONE 'SD HOUSES HAD ALL 'SD' SAMPLEl

SAMPLE
>

>

TRACE

TRACE

J
3

'^2'

SAMPLES WERE

>

TRACE

J

'3^'SA1PLES

'^'

SAMPLES WERE TRACE

WERE NON-DETECTABLE

1-55
'3

16

HOUSES HA^ SAMPLES H"J3^ Hfn AT'LEAST ONE '3A HOUSES HAD ALL SAMPLE

'^A

'^'

>

SAMPLE TRACE

>

TRACE

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TABLE 1-1 a: confd

16

'DA'
3.40 0.53

SAMPLES WERE
0.-50 0.53 0.60 3.80 0.90 1.00
1,00

>

TRACE
3. 50 0. 50 0. 63 0. 80 a. 90
00

0 50
3 50

0.60 0.70 0^83
0.93

0 60 0 83
0 90

1 00
1 00

1.00 .10 .20 .30 .40 .50 .60 .80 2.10 2.23 2.53 2.80 3.63 4.70 15

00

1.10
l<20

10
20

.30 .40 .50 .60
.S0

30 50 50
60

2.20 2.23 2.53 2.90 3.80 5.00

80 2. 20 2. 30

2. 50 3, 10 3. 80 5.20

1 1 1 1 1 1 1 2 2 2 3

10
20 30 50 50 60 90 20

43 60 10 4 40 8 20

0.50 0.50 0.70 0.80 0.90 .00 .00 .10 .30 .30 .50 .60 .70 .90 2.20 2.50 2.60 3.20 4.40 10.00
00,50 00,50

0.50 0.50 0.73
0.S0
0,90

1.00 1.10 1.10

1.30
1.40 1.50 1.60 1.70 2.00 2.20 2.50 2.70 3.30 4.60

SAMPLES WERE TRACE 00. 50 00.50 00.40 00. 50 03.53 03.50 00. 63 33.63 33.53

'DA'

00 50 03 50

00.53 00.53

36

'DA'
03.13 00.43 33.53

SAMPLES WERE NON-DETECTABLE
03.13 30.40

00.50 30.53 03.68
3 3 3

00.53 33.50 30.50 03.60

00. 40 00. 40 00. 50 00. 50 00. 50 00. 60

00 40

00 40 00 53 03 5d 03 53 00 63

03.40 00.40 00.50
00,50

03.40 00.40 00.53

00.50
00.50 00.60

33.50 00.60

SAMPLES HOUSES HAD HOUSES HAD AT LEAST ONE 'DD HOUSES HAD ALL 'DD SAMPLE

^

SAi.lPLE TRACE

>

TRAC;

3
-1

'55' '22'

SAMPLES WERE

>

TRACE

-3A---PLE3 U=:RE TRAC1

^
i:

'^'

SAMPLES WERE NON-DETECTABLE

HOUSES HAD

'UA

SAMPLES
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TABLE 1-la: cont'd
3

0
0
0

HOUSES HAD AT LEAST ONE 'UA HOUSES HAD ALL 'UA SAMPLES

>

SAMPLE TRACE

>

TRACE

fl

'-JA'

'^' ^'

SAMPLES WERE

>

TRACE

SAMPLES WERE TRACE SAMPLES WERE NON-DETECTABLE

3
0 0

HOUSES HAD ]JJ) SAMPLES HOUSES HAD AT LEAST ONE 'UD' SAMPLE HOUSES HAD ALL "UD' SAMPLES > TRACE

>

TRACE

0
0 0

'^D' '^D'

SAMPLES WERE

>

TRACE

SAMPLES WERE TRACE

'U3' SAMPLES WERE NON-DETECTABLE

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TABLE 1-1 a: cont'd
RECAP BY AREA OF HOUSES WITH BASE LINE AIR SAMPLES TAKEN TREATMENT TYPE 1b

(Pretreated sub-slab on compacted soil beneath gravel fill)
AREA
120 59 61
16 14 14

NW QUARTER

HOUSES HAD AIR SAMPLES TAKEN HOUSES HAD AT LEAST ONE SAMPLE GREATER THAN TRACE HOUSES HAD ALL AIR SAMPLES TRACE OR NON-DETECTABLE: HOUSES HAD S^ SAMPLES HOUSES HAD AT LEAST ONE HOUSES HAD ALL 'SA SAMPLES

'S^'
>

SAMPLE TRACE

>

TRACE

14

'S^' 0.8fl
307^3

SAMPLES WERE 3.80 2.5i3 2.60 4.43 4.60

>

TRACE
1,00

2.60
TRACE

1.00 3.30

1.50
4.20

2
0

'SA' SAMPLES WERE
03.50

'SA

SAMPLES WERE NON-DETECTABLE

0

0

a
0

HOUSES HAD 'SD SAMPLES HOUSES HAD A'T~LEAST ONE 'SD HOUSES HAD ALL 'SD' SAMPLE^

SAMPLE
>

>

TRACE

TRACE

Sfi

SAMPLES WERE

>

TRACE

3

'S^'

SAMPLES WERE TRACE

^
104
45 45
4<

'S2' SAMPLES WERE NON-DETECTABLS
HO'JSES HAD DA SAMPLES HOUSES HAD ATlEAST ONE 'DA' SAMPLE SA^PLli TRACE HOUSES HA!) ALL

TRACE

'^'

r'T^.i

'^'

SA^PL^S WERE

TRACE
0.4J

0.4.3

0.50

0.53

1.8

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TABLE 1-1 a: cont'd
0,50

0.50
0.50

0.50 0.50 0.80
0,83

0*53
0.80 0.80

1.10 1.80
61

1.50
1.80

0.53 0.53 0.60 0.80 3.83 1.30 3.00
00.53 00.50 00.50 00.50 00.50 00.50 00.50 00.50 00.50 00.50

0.50 0.50 0.60 0.80 0.80 1.60 3.!0
00.50 00.53 00.53 00.50 00.53 00.50 00.50 00.50 00.50 00.60

0.50 0.53 0.70 0.80 1.00 1.60

0.50
fl.50 0.80 0.ffa 1.00 1.80

00733

'DA'

SAMPLES WERE TRACE
00.50 03.50 00.50 03.50 00.53 00.50 00.50 00.50 00.50 00.50

0*5.50 00.50 00.50 00.53 00.50 03.50
00,50

00.50 00.50 00.50
00.50 00.50 00.50

00.50
00,,50

00.50 00.50 00.60
2

00.50 00.50 00.50 00.60

03..50 00,.50 00.,50 00.50 00.>50 00.>53 00,.50 00,.60

307?3

'DA'

SAMPLES WERE NON-DETECTABLE
00.50

0
0

3

HOUSES HAD DD SAMPL HOUSES HAD AT LEAST HOUSES HAD ALL 'DD

^

'DD
LES
>

SAMPLE TRACE

>

TRAC;

0

0

'53' '25'
'DD'

SAMPLES WERE

>

TRACE

SAMPLES WERE TRACE

^
0 3
Q

SAMPLES WERE NON-DETECTABLE

HOUSES HAD U^ SAMPLES HOUSES HAD AT LEAST ONE 'UA HOUSES HAD ALL 'UA SAMPLES

>

SAMPLE TRACE

>

TRAC

0 3 0

'^' 'YA'
'^A'

SAMPLES WERE