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Asbestos Issues at Schenley vs. Other School Buildings January - April 2009 In response to an article in the Post-Gazette (http://www.post-gazette.com/pg/09012/941299-100.stm), a January 12, 2009 memo from Superintendent Mark Roosevelt suggests that there are “major differences” between asbestos issues at Schenley and those at other school buildings. Below are the differences noted in the memo, followed by PURE Reform’s responses in bold. “1. Schenley has asbestos containing material much of it mixed with plaster throughout its walls, ceilings & flooring, duct and pipe insulation. Most of the plaster has aged, is delaminating and in poor condition.” RESPONSE: Astorino’s 2006 report on Schenley states that “The plaster, overall, is in good to excellent condition, with the exception of areas of the third floor ceiling plaster where water damage was observed.” AGX’s reports from the fall of 2007 state that “the majority of the plaster is in good condition.” Less than 1% of the plaster at Schenley has required repair. “2.The asbestos plaster at McKelvy (Miller School), Vann and Woolslair are in sound condition, with occasional failures attributed to known causes (e.g. water leaks). At Schenley, the aging and bubbling plaster failures are simply unpredictable. It should be emphasized that most PPS buildings built prior to the 1970’s have asbestos containing material and abatement is conducted promptly whenever there is a failure or potentially hazardous condition.” RESPONSE: Unlike most Pittsburgh public schools, Mckelvy, Vann and Woolslair have pervasive asbestos containing plaster throughout their walls, ceilings & flooring, duct and pipe insulation, except that McKelvy’s asbestos containing ceiling has been removed. These buildings and their plaster are of the same vintage as Schenley. A 1994 report shows that rather than remaining sound, even at that time a long list of rooms at McKelvy had 5-25% damaged plaster and needed repair. The main causes of plaster failure are well known: water damage, weather/humidity, and age, exacerbated by movement. In most cases records of plaster repair work at Mckelvy, Vann and Woolslair do not mention a water leak and so likely involved plaster bubbles and other unpredictable damage resulting from weather or age. “3. A typical asbestos abatement repair project (e.g. plaster failure, floor tile removal or pipe insulation abatement done over a week-end or after hours generally involve between 3 to 5 certified individuals for 8 to 10 hours of work. Costs for most of these repairs range from a few thousand dollars to under ten thousand dollars.” RESPONSE: AHERA records show an 8 hour, 8 person crew doing abatement work at Vann in October 2008. Another abatement project at Vann cost almost $15,000 in November 2008. Conversely, there are records of small repair projects at Schenley. To make any meaningful comparison of ongoing maintenance work at the various buildings, it would be necessary to compare the cost of abatement work per square foot (to take into account building size) for a given time period, whether the same standard for maintenance was applied to all of the buildings, and whether damage can be prevented (for example by improving ventilation). “4. At Schenley during the summer of 2007, the following was required for asbestos repairs…[list of work done] 5. By any standards, the above repair work required quick action from the PPS Board, massive mobilization and the costs for these repairs exceeded $750,000.” RESPONSE: To make any meaningful comparison between building repair costs, it would be necessary to know whether a similarly aggressive program to identify and repair plaster cracks and bubbles was undertaken at each school building with extensive asbestos plaster. Reportedly, almost every square foot at Schenley was inspected for possible loose or soft plaster. Conditions which most likely developed over a long period of time were then repaired in a very short time frame, requiring considerable overtime. It should also be noted that because the Schenley plaster apparently had to withstand higher humidity due to a poor choice of windows, correcting ventilation issues could well prevent expenses of this scale in the future. “6. The magnitude of the potential danger, the enormous tasks and expenses involved alone pose a huge risk to the occupants and all others included. A liability of this magnitude simply does not exist at other schools.” RESPONSE: Potential danger, tasks, expenses and liability will of course be of greater magnitude at a larger building than a comparable smaller building. To make any meaningful comparison it would be necessary to know 1) whether potential danger, etc. is considered to be greater in a space of a given size at Schenley than in a space of the same size at McKelvy, Vann and Woolslair, and 2) what measures, such as improving ventilation, might eliminate any disparities. “7. During the right-sizing initiatives, all affected schools were reviewed for potential asbestos hazards and accordingly any abatement work necessary were made part of the planned renovation projects. All school buildings where such renovation (including asbestos abatement) work was completed were inspected by Allegheny County officials and deemed safe for occupancy.” RESPONSE: No difference between Schenley and the other schools is noted. All of the asbestos plaster schools including Schenley were apparently deemed safe for occupancy even though all suffer occasional plaster failure. “8. The historically beautiful Schenley building, however, has major interior, infrastructure deficiencies to include an inadequate ventilation system, dated heating, electrical and plumbing systems all of which involve asbestos abatement, which in turn makes much needed improvements extremely expensive.” RESPONSE: No difference between Schenley and the other schools is noted. There is no indication that systems at Mckelvy, Vann and Woolslair have been updated recently and yet Mckelvy and Vann were chosen for expansion as part of the Right Sizing Plan. Note that heating, electrical and plumbing systems needing repair are generally accessed through a crawl or access space rather than by cutting walls. And, according to the Astorino report on Schenley, “The sub-basement’s main use is for the mechanical systems. There does not appear to be any wall or ceiling plaster located in the sub-basement.” “In brief the infrastructure and asbestos issues at Schenley are a major liability, costly to fix or repair, difficult to manage or maintain, with no alternative available other than a full and complete remediation and renovation, at considerable costs to the District.” RESPONSE: No difference between Schenley and the other schools is noted. There is no evidence that foot for foot the Schenley building is any more or a liability, any more costly to fix, or any more difficult to manage than other buildings with asbestos plaster, and it is not clear why only the Schenley building would require “a full and complete remediation and renovation.” If renovation was desired, however, the Task Force convened to examine this issue recommended a $42 million project that addressed the concerns raised in this memo. This “Scope 3B” recommendation involved removal of most of the ceilings; installation of new mechanical, electrical and plumbing systems in a manner that allowed access to the systems without the need for asbestos abatement; encapsulation of remaining asbestos containing materials; installation of air conditioning and a sprinkler system; and ADA accessibility. Students would have been displaced from the building for only one year. Members of the Task Force devoted countless hours to developing a well thought out and economical proposal, only to have their efforts and the proposal disregarded. If nothing other than complete removal of all asbestos plaster would suffice, committee members should not have been asked to waste their time on alternative proposals. In conclusion, while it appears that the Schenley building would benefit from better ventilation, the Superintendent’s memo does not show major differences between asbestos issues at Schenley and those at Mckelvy, Vann or Woolslair. The memo does not explain why Schenley’s plaster and the building in general could not be managed in the same manner and at a similar cost per area as they are managed at Mckelvy, Vann or Woolslair. Further, in claiming that the only alternative is complete remediation and renovation, the memo ignores the plan recommended by the Schenley High School Task Force to minimize asbestos hazards and update mechanical, electrical and plumbing systems for about half the cost of full remediation. Attachment A: Outstanding questions raised at the January 12, 2009 public hearing ATTACHMENT A: At the January 12, 2009 public hearing PURE Reform presented testimony and raised questions about asbestos issues at Pittsburgh public schools McKelvy/Miller, Vann and Woolslair. Below are the district's answers, PURE Reform's responses, and follow up questions. 1) PURE Reform Question: How was it determined that the history of plaster failure in the McKelvy/Miller building did not amount to a warning of a potentially dangerous situation? District response: Most of the plaster issues at Miller@McKelvy have been isolated, minor problems; traceable to specific causes or events like roof or plumbing leaks which resulted in damage to specific areas of plaster. In contrast, the plaster problems at Schenley cannot be attributed to isolated causes, such as water damage, and are scattered throughout the entire building. Schenley’s issues, unlike McKelvy, are frequent, building-wide and stem from a combination of plaster age, building environment and unknown causes. The two distinct situation at Miller and Schenley are simply not comparable. PURE Reform response: AHERA Reports for McKelvy/Miller going back 20 years show frequent, substantial, and building wide plaster issues. If plaster issues have been isolated and minor, it is difficult to understand why all of the ceiling plaster would have been removed. As to the wall plaster, even 15 years ago an AHERA inspection showed a long list of rooms throughout the building with damage such as “gym walls 10% damage, plaster walls near window in room 210 < 10% damage, plaster walls near window in room 204 < 5% damage, walls in the generator room, off of room 7, have > 25% damage, plaster walls in coat closet in kindergarten have 10% damage.” Over the past 5 years AHERA reports show repairs to deteriorating wall plaster in Rooms 2C, 4, 7, 10, 13, 113, 202, 203, “various classrooms,” the cafeteria, auditorium, men’s room, laundry, rear main entrance vestibule and “various locations on all levels of the school.” AHERA reports on the wall plaster issues described above do not mention specific causes or events like roof or plumbing leaks and certainly do not rule out age, building environment or unknown causes for these issues. If all of this wall plaster damage has been caused by roof or plumbing leaks, a question is raised as to whether infrastructure issues at this facility are beyond the capacity of the district to manage or maintain. At the Schenley facility an “Asbestos Potential Hazard Inspection” was done in July 2007 after two small asbestos plaster failures earlier that month on the third floor. Consultants’ reports specifically state that plaster on the third floor had been damaged by water from a leaking roof which was then replaced. FOLLOW UP QUESTION: Would it not be wise to have an “Asbestos Potential Hazard Inspection” conducted at the McKelvy, Vann and Woolslair facilities, as was done at the Schenley facility? District response: Two separate environmental consultants have been engaged to conduct room-by-room inspections of Miller (McKelvy), Vann and Woolslair. These inspections will be completed by the end of May 2009. PURE Reform comment: We applaud the district for arranging these inspections. However, facilities options are set to be presented by facilities consultant DeJong on May 13 and 14. It is not clear how plans can be made for the above three schools if the results of the inspections by the environmental consultants are not complete at that time. 2) PURE Reform question: Why was an outside consultant’s opinion obtained for Schenley but not for McKelvy/Miller? District response: The wall plaster issues at Miller@McKelvy are limited and usually attributed directly to water infiltration. Ceiling plaster has been previously abated in this building. PURE Reform response: As noted above, wall plaster issues at Miller/McKelvy have occurred building-wide. It is not clear who has “usually attributed [plaster issues at McKelvy] to water infiltration.” More importantly, the intent of this question was not to ask about a consultant’s opinion as to the cause of plaster failure, but rather to ask why an outside consultant’s opinion as to whether the McKelvy/Miller building is safe for students and staff has not been obtained, given the opinions as to safety expressed in the Astorino letter dated October 19, 2007 and the Kimball letter dated November 16, 2007. Note also that per the district’s January 31, 2006 “Schenley High School Evaluation Study” ceiling plaster abatement had been planned for Schenley. The school’s plaster ceilings were scheduled to be removed and lighting replaced at a cost of $2.3M budgeted under the 2004 Capital Program. If removal of ceiling plaster was not a sufficient solution for Schenley, it cannot be assumed to be a sufficient solution for McKelvy/Miller. FOLLOW UP QUESTION: Would it not be wise to obtain a consultant’s opinion as to the potential for asbestos danger at the McKelvy/Miller building? District response: The two consultants conducting the inspections mentioned in the response to Question #1 above have been requested to provide their professional opinion. This information will be included in the Right to Know response referenced [above in 2A] [NOTE: The response the district labeled 2A is to question 4 below]. PURE Reform comment: We applaud the district for arranging these inspections. However, facilities options are set to be presented by facilities consultant DeJong on May 13 and 14. It is not clear how plans can be made for the above three schools if the results of the inspections by the environmental consultants are not complete at that time. 3) PURE Reform question: With Miller middle school students slated to attend University Prep next year anyway why not eliminate the asbestos plaster risk entirely by returning the K-5 program to the Miller Street facility, a building which reportedly has special historic significance to the African American community? District response: McKelvy is a much larger facility, and is also designated as a historic building in the Hill District. PURE Reform response: With grades 6-8 moving out of the Miller program is a much larger facility still needed or even desirable, especially given that this larger facility has no gymnasium? More important, does the added size of the McKelvy building offset the added asbestos danger of that building? Further, although McKelvy/Miller may be a historic building, the Miller Street building reportedly has unique significance as the first school to accept homeless African American students. 4) PURE Reform question: How did the district determine that it was safe for students to return to Vann in 2008 and that it will be safe for students to return to Vann in 2009? District Response: L.R. Kimball conducted a survey of Vann prior to the beginning of the 2008 school year and found no indications of environmental problems. Additionally, the asbestos air sampling that have been conducted since 2005 has never indicated any problems or hazardous conditions. Vann in scheduled to be inspected by qualified personnel prior to the start of the 2009 school year. The monthly asbestos air sampling program will be continued at this location. PURE Reform response: It is not clear whether the survey of Vann addressed only existing problems or whether it addressed potential problems as well. As Superintendent Roosevelt noted last summer, “You don’t close a school, when the air readings tell you there is asbestos in the air. You don’t wait for that point.” Accordingly, even though asbestos air sampling had never shown a problem at the Schenley facility, consultants’ opinions were obtained as to the potential for asbestos danger at that facility. FOLLOW UP QUESTION: A) May we have a copy of the Kimball survey of Vann done prior to the start of the 2008 school year and B) Would it not be wise to obtain a consultant’s opinion as to the potential for asbestos danger at the Vann facility? District response: A) Your request has been forwarded to the District’s Law Office as a Right to Know request. You will be hearing directly from them. B) The two consultants conducting the inspections mentioned in the response to Question #1 above have been requested to provide their professional opinion. This information will be included in the Right to Know response referenced above in 2A [in this document it is referenced in question 4]. PURE Reform comment: A) PURE had already submitted a Right to Know request for the Kimball report on Vann and received in late March a “Final Report, Asbestos & Hazardous Materials Inspection” for Vann, copyright August 2008. Rather than stating that there are or are not environmental problems at the Vann building, the report summarizes what hazardous materials Kimball found and where they are located. It states that 88,500 square feet of original surfacing should be assumed to contain asbestos and seems to suggest that at least some of this surfacing is friable (meaning that someone could crumble a piece of the material and release asbestos fibers into the air). Hazards also include thermal insulation containing high levels of asbestos. In one respect the Kimball report is very odd. Page 10 of the repot indicates that in 2004 AGX performed a plaster survey and found that 84 of 93 samples contained greater than 1% asbestos. As part of its inspection Kimball also did a plaster survey and found that only 3 of 145 samples contained greater than 1% asbestos. Since asbestos in plaster does not disappear, this enormous disparity in the plaster surveys suggests a difference in methodology between the Kimball and AGX, or between the testing laboratories, or both. B) Facilities options are set to be presented by facilities consultant DeJong on May 13 and 14. It is not clear how plans can be made for the above three schools if the results of the inspections by the environmental consultants are not complete at that time. FOLLOW UP QUESTION: To what does the district attribute the disparities in the plaster surveys and which of the two surveys will the district and facilities consultants rely on in making decisions about the Vann building? 5) PURE Reform question: How does the district determine whether there is a significant risk of danger from falling plaster or asbestos being released into the air? District response: Evaluations of plaster or asbestos risk at any school would be made on the basis of a number of criteria: a) Repeated reports of plaster failure from custodial and building staff. b) Confirmed existence of asbestos in the plaster. c) Plaster problems being reported throughout the building or occurring in large areas, not just isolated areas. d) Plaster failures not directly linked to known or discovered causes. Each case would be individually evaluated to assess the existing plaster’s age and cause for failure. e) General and overall visual deterioration of the surface of the plaster and lack of adherence to other surfaces. PURE Reform response: Asbestos plaster has been confirmed and repeated reports of plaster failure have occurred throughout the McKelvy/Miller, Vann and Woolslair facilities. It is not clear whether the cause for all instances of plaster failure is known and in any event it would seem that just knowing the cause of plaster failure would not significantly mitigate risks if the cause was for example age, or if the district is unable to manage repeated incidents of water infiltration. 6) PURE Reform question: Under what circumstances does the district seek a consultant’s opinion as to the safety of a building with asbestos plaster? District response: Consultants may be hired to supplement the District’s in-house architectural, engineering, and environmental staff whenever manpower is unavailable, whenever staff determines confirmation of their observations is warranted, when a “second” opinion seems prudent, or where staff alone can not make a reasonable determination of the existing conditions. PURE Reform comment: We are pleased to learn that the district has decided to seek the opinion of outside environmental consultants regarding the McKelvy/Miller, Vann and Woolslair buildings, although coordination with the timing of upcoming facilities recommendations is an issue. 7) PURE Reform question: Under what circumstances is the adhesion of plaster tested? District response: Adhesion tests are generally not conducted unless the building has shown evidence of widespread and or chronic plaster failure or where an incident related failure, like broken piping, has caused severe damage. PURE Reform response: See PURE Reform’s response to answer # 1 above for a list showing widespread plaster failure at McKelvy/Miller. At Vann, AHERA reports mention plaster problems over the past 5 years in rooms 6, 103, 104, 110, 201, 202, 209, 210, 211, 212, 213B, 215, “various classrooms,” the teachers’ lounge, auditorium, stairwell behind the auditorium, hallways, fan room and “various areas.” And, the ceiling collapses at Woolslair in late 2007 and early 2008 involved a much larger area of plaster failure than the two July 2007 incidents that drew attention to the Schenley building. Adhesion testing does not seem to be a major project- WJE’s adhesion analysis for Schenley involved only four samples. FOLLOW UP QUESTION: Would it not be wise to perform adhesion tests on plaster samples from McKelvy/Miller, Vann and Woolslair? District response: We do not have enough information to address this question at this time. However, firms capable of conducting such specialized tests are being explored by Facilities. We anticipate a report on Friday, March 27, 2009 on the findings. PURE Reform comment: PURE will submit a Right to Know request for this report. 8) PURE Reform question: At which buildings has an enhanced asbestos monitoring and maintenance program been adopted, and as of what date? PURE Reform comment: PURE will submit a Right to Know request for this report. District response: The monthly air monitoring program was instituted in 2005 for the following schools: Pittsburgh Student Achievement Center, Manchester, McKelvy, Schenley, Vann and Woolslair. PURE Reform response: This question was not intended to refer to the air quality monitoring done at the above schools since 2005. Rather, it was intended to refer to the enhanced monitoring and maintenance program adopted at the Schenley facility per the district’s November 14, 2007 News Release (http://www.pps.k12.pa.us/14311051715526407/lib/14311051715526407/District_Adjust_Year_2_HS_Reform_11.14.07.pdf). FOLLOW UP QUESTION: At what Pittsburgh public school buildings has the type of enhanced monitoring and maintenance program described in the above news release been adopted? District response: The conditions at the other locations do not warrant such extreme measures. The following monitoring program has been instituted in March, 2009 for Manchester, Miller/McKelvy, Vann and Woolslair: Two separate environmental consulting firms have been engaged to inspect the building each month. Air sampling will be done on a monthly schedule. The frequency of the inspections and or air sampling may be increased based upon the findings of the consultants and building conditions. 9) PURE Reform question: Is there any reason not to promptly schedule a test of the Schenley ventilation system? District response: Testing of the ventilation system at Schenley would not contribute any new information. The operational issues with the system are already known and, in the best estimation of our mechanical engineers, will only contribute further to the current problems. The problems with the existing system will further escalate building overheating and possible humidity issues and as in the past, contaminate the building with an “unknown black dust”. This could be further compounded by its lack of activity over the past few years which may have allowed for some asbestos dust to settle into the ductwork. In the long run, this would only create the need for an immediate re-cleaning of the entire building and its contents and not move any closer to solving its current problems. PURE Reform response: The facilities staff’s report on “Major Facilities Issues at Schenley High School” (January 31, 2006) gives this explanation as to operational issues: “Existing system consists of a series of ducts that are located within corridor walls that bring fresh air into each classroom. These ducts have asbestos insulation and are also contaminated with dirt and dust. They have not been operated for at least 10 years due to these problems. Past attempts to properly clean these ducts have been unsuccessful.” FOLLOW UP QUESTION: What attempts to clean the ducts were made, when were those attempts made and why were attempts unsuccessful? Were attempts unsuccessful because potential HVAC cleaning companies refused a district requirement of certification that no asbestos fibers would be released? Could the system be operated w/ HEPA filters to catch any stray asbestos particles that may have settled into the duct work? District response: Schenley High School was built in 1913. Complete historical records are not available. We can verify that some duct cleaning work was completed in 1985. Patches observed in the supply ductwork confirm that access to the interior of the ductwork was provided for during such cleaning. This cleaning was considered unsuccessful as evidenced by the “black soot and dust” that was distributed from time to time throughout the building and hence contributed to the shutdown of the ventilation system. The system was not operated with HEPA filters because the installation of HEPA filters would so increase the static pressure of the ventilation system that it would then be incapable of providing the airflow that it was designed for. The result would have been insufficient fresh air delivered to the classrooms. Also, operating the existing ventilation system without first addressing the system control lines (buried in asbestos-containing plaster) would have resulted in additional overheating problems thus contributing to discomfort in the building. PURE Reform comment: Patches may be the result of repairs rather than cleaning. More important, incidents of black soot do not necessarily indicate that any duct cleaning that may have been done was unsuccessful. Once ducts are clean it is necessary to keep the intake area clean. At one time there was a system in place so that before reaching the intake area, air would pass through a fine mist that would both humidify the air and cause solid particulates to settle out. That system is no longer operational but presumably could be repaired without impacting plaster. Failure to keep the intake area clean is the most likely explanation for the incidents of black soot which contributed to shutdown of the ventilation system. Regarding operation with HEPA filters, the follow up question should have specified that the filters would be used as part of a test of the system, mainly to check if the fan motors worked to propel air through the system and to protect against distribution of soot during testing. The next step would be to clean the ducts, put into place a system to keep the intake area clean, and again test the system with the filters in place before finally removing them. Note however that even if filters caused the system to be “incapable of providing the airflow that it was designed for,” that airflow could still be more than sufficient because the system was designed to provide 100% fresh air. Applicable codes require and modern systems supply a much smaller percentage of fresh air. Further, more powerful fans could supply additional force to overcome the “static pressure” of the system. Finally, regarding the system controls (ie, the pneumatic controls with small air lines that run from the thermostats of each room to the duct dampers and steam controls in the basement), there are alternatives to disrupting the plaster in which the controls are embedded. The existing controls could be abandoned in the walls and the pneumatic controls replaced with electronic controls running outside the walls (involving cutting just one spot in each room). Alternatively the ventilation system air pumps could be set so that all of the incoming fresh air is heated at a uniform temperature rather than being controlled room by room. Adjustments to the temperature in individual rooms would instead be made by using the thermostats to control the radiators in each room. 10) PURE Reform question: Further, we request a response as to whether the recommendation in the Schenley High School Task Force Report dated June 23, 2006 for Scope 3B renovation adequately addresses district concerns about asbestos exposure; liability; and ventilation, heating, electrical and plumbing systems at the Schenley building (with the understanding that allocating the $42 million for repairs is a separate issue that would need to be discussed in the context of particular proposed uses of the building). District response: It is difficult to understand this question and would appreciate a clarification as to what specific information is requested regarding Scope 3B of the June 23, 2006 report. PURE Reform response: The superintendent’s January 12, 2009 memo “Asbestos Issues in Schenley vs. Other School Buildings” states that “[T]he infrastructure and asbestos issues at the Schenley facility… are difficult to manage or maintain with no alternative available other than a full and complete remediation and renovation at considerable costs to the District.” The district has indicated that the cost of a full and complete remediation exceeds $76 million. The information requested is, would the $42 million Scope 3B renovation as modified/elaborated in the Task Force Report adequately address infrastructure and asbestos issues at the Schenley facility and so provide an acceptable alternative to a full and complete remediation and renovation of the Schenley facility, and if not, in what way would the renovation recommended by the Task Force fail to adequately address such issues? District response: The Scope 3B option proposed by the consultants involves limited abatement of asbestos containing materials (ACM) only in areas directly impacted by the removal of the building systems. This leaves ACM in the remainder of the building and does not accommodate the expansion and/or reconfiguration of the existing classrooms to meet current state requirements, curriculum needs or future programming. Leaving ACM in place would further complicate all future renovation/remodeling projects making them even more expensive and time-consuming in the future. Concerns for safety/health/liability would continue to exist. PURE Reform comment: The Schenley building’s classrooms met changing curriculum and programming needs for almost 100 years. The extent to which the classrooms may fail to meet current state requirements is unclear. However, it is important to note that many if not most of the district’s school buildings are unlikely ever to be remodeled to meet all of the requirements adopted after those schools were constructed. It would seem more reasonable to list the renovation cost as $42M with an asterisk indicating that for an additional $40M the building could be made easier to renovate again in the future. Finally, with any building there will be reasons for concerns for safety/health/liability. It is not clear what the safety/health/liability concerns for the Schenley building after a Scope 3B renovation would be. However, the fact that the McKelvy/Miller, Vann, Woolslair and Manchester buildings remained open for the 2008-2009 school year demonstrates that when it comes to asbestos, the district does not require elimination of all possible risk of safety/health/liability issues. QUESTION RAISED AT THE FEBRUARY 16, 2009 PUBLIC HEARING At the February public hearing PURE Reform observed that plaster ceilings had been removed at the McKelvy/Miller building and that removal of asbestos plaster ceilings at Schenley had been included as part of the 2004 capital budget ($2.3M). PURE asked “What if we were now to remove the ceilings and, as with McKelvy, monitor the wall plaster and repair it as needed? District response: The removal of the plaster ceilings at Schenley would be a multi-million dollar project, with asbestos abatement representing only a portion of the total costs. New ceilings and lighting would be required, and the electrical/fire alarm/PA/computer/communications/security systems might also require replacement. Millions of dollars could be spent to repair only a portion of the overall problem; and one would still be left with the concerns of asbestos containing walls, floors, thermal insulation and an inadequate, malfunctioning ventilation system. PURE Reform comment: It is true that the Schenley ceiling removal project budgeted in 2004 was for a multi-million dollar amount ($2.3M). However, compared to many other renovation projects planned or recently completed by the district this is a relatively small cost for a large amount of space. Presumably when the project was budgeted in 2004 the need for new ceilings, lighting and necessary systems was taken into account. A new ceiling and lighting and necessary systems would also have been required at McKelvy/Miller. While money would be spent to repair only a portion of the overall problem that was the case at McKelvy/Miller as well, where the remainder of the problem has been addressed through monitoring and maintenance. Regarding the floors, asbestos containing floor tiles are found in many if not most Pittsburgh public schools but are usually not a problem because floor tiles generally do not become friable. And, while a number of schools have asbestos containing thermal insulation, at Schenley most of that insulation has reportedly already been replaced with fiberglass insulation. Regarding the ventilation system, please see question 9 above. PETITION PRESENTED AT THE FEBRUARY 16, 2009 PUBLIC HEARING Also at the February 2009 public hearing, PURE Reform presented a petition signed by 150 city residents (and later signed by an additional 50+ residents) that stated as follows: WE, the undersigned citizens of the City of Pittsburgh, hereby petition the School Board for the Pittsburgh Public Schools for an asbestos plaster inspection and opinion of risks, dangers and relative condition of such plaster by an independent expert, of four school buildings: Schenley, McKelvy, Vann, and Woolslair. District response: Two separate environmental consultants have been engaged to conduct room-by-room inspections of Miller (McKelvy), Vann and Woolslair. These inspections will be completed by the end of May 2009. The two consultants conducting the inspections mentioned in the response to Question #1 above have been requested to provide their professional opinion. This information will be included in the Right to Know response referenced above in 2A. PURE Reform comment: No explanation is given as to why the environmental consultants retained by the district should not also inspect and provide an opinion as to the Schenley building, including the requested opinion as to the condition of the plaster in the Schenley building relative to the plaster in the McKelvy/Miller, Vann and Woolslair buildings. This information is relevant to the current facilities planning process, which includes the Schenley building. Further, as noted in the comments to Question #4, above, surveys done by two different sets of consultants have yielded widely different results. For consistency, the same consultants must inspect and evaluate all four buildings. FOLLOW UP REQUEST: PURE Reform requests that the environmental consultants inspecting and evaluating the McKelvy/Miller, Vann and Woolslair buildings also inspect and evaluate the Schenley building and provide an opinion on condition of the plaster in the Schenley building relative to that in the other three buildings. PURE Reform also requests the names of these environmental consultants and information on how it was determined that these consultants are “independent.”

Asbestos Issues at Schenley vs. Other School Buildings

January - April 2009

In response to an article in the Post-Gazette (http://www.post-gazette.com/pg/09012/941299-100.stm), a January 12, 2009 memo from Superintendent Mark Roosevelt suggests that there are “major differences” between asbestos issues at Schenley and those at other school buildings. Below are the differences noted in the memo, followed by PURE Reform’s responses in bold.

“1. Schenley has asbestos containing material much of it mixed with plaster throughout its walls, ceilings & flooring, duct and pipe insulation. Most of the plaster has aged, is delaminating and in poor condition.”

RESPONSE: Astorino’s 2006 report on Schenley states that “The plaster, overall, is in good to excellent condition, with the exception of areas of the third floor ceiling plaster where water damage was observed.” AGX’s reports from the fall of 2007 state that “the majority of the plaster is in good condition.” Less than 1% of the plaster at Schenley has required repair.

“2.The asbestos plaster at McKelvy (Miller School), Vann and Woolslair are in sound condition, with occasional failures attributed to known causes (e.g. water leaks). At Schenley, the aging and bubbling plaster failures are simply unpredictable. It should be emphasized that most PPS buildings built prior to the 1970’s have asbestos containing material and abatement is conducted promptly whenever there is a failure or potentially hazardous condition.”

RESPONSE: Unlike most Pittsburgh public schools, Mckelvy, Vann and Woolslair have pervasive asbestos containing plaster throughout their walls, ceilings & flooring, duct and pipe insulation, except that McKelvy’s asbestos containing ceiling has been removed. These buildings and their plaster are of the same vintage as Schenley. A 1994 report shows that rather than remaining sound, even at that time a long list of rooms at McKelvy had 5-25% damaged plaster and needed repair. The main causes of plaster failure are well known: water damage, weather/humidity, and age, exacerbated by movement. In most cases records of plaster repair work at Mckelvy, Vann and Woolslair do not mention a water leak and so likely involved plaster bubbles and other unpredictable damage resulting from weather or age.

“3. A typical asbestos abatement repair project (e.g. plaster failure, floor tile removal or pipe insulation abatement done over a week-end or after hours generally involve between 3 to 5 certified individuals for 8 to 10 hours of work. Costs for most of these repairs range from a few thousand dollars to under ten thousand dollars.”

RESPONSE: AHERA records show an 8 hour, 8 person crew doing abatement work at Vann in October 2008. Another abatement project at Vann cost almost $15,000 in November 2008. Conversely, there are records of small repair projects at Schenley. To make any meaningful comparison of ongoing maintenance work at the various buildings, it would be necessary to compare the cost of abatement work per square foot (to take into account building size) for a given time period, whether the same standard for maintenance was applied to all of the buildings, and whether damage can be prevented (for example by improving ventilation).

“4. At Schenley during the summer of 2007, the following was required for asbestos repairs…[list of work done]

5. By any standards, the above repair work required quick action from the PPS Board, massive mobilization and the costs for these repairs exceeded $750,000.”

RESPONSE: To make any meaningful comparison between building repair costs, it would be necessary to know whether a similarly aggressive program to identify and repair plaster cracks and bubbles was undertaken at each school building with extensive asbestos plaster. Reportedly, almost every square foot at Schenley was inspected for possible loose or soft plaster. Conditions which most likely developed over a long period of time were then repaired in a very short time frame, requiring considerable overtime. It should also be noted that because the Schenley plaster apparently had to withstand higher humidity due to a poor choice of windows, correcting ventilation issues could well prevent expenses of this scale in the future.

“6. The magnitude of the potential danger, the enormous tasks and expenses involved alone pose a huge risk to the occupants and all others included. A liability of this magnitude simply does not exist at other schools.”

RESPONSE: Potential danger, tasks, expenses and liability will of course be of greater magnitude at a larger building than a comparable smaller building. To make any meaningful comparison it would be necessary to know 1) whether potential danger, etc. is considered to be greater in a space of a given size at Schenley than in a space of the same size at McKelvy, Vann and Woolslair, and 2) what measures, such as improving ventilation, might eliminate any disparities.

“7. During the right-sizing initiatives, all affected schools were reviewed for potential asbestos hazards and accordingly any abatement work necessary were made part of the planned renovation projects. All school buildings where such renovation (including asbestos abatement) work was completed were inspected by Allegheny County officials and deemed safe for occupancy.”

RESPONSE: No difference between Schenley and the other schools is noted. All of the asbestos plaster schools including Schenley were apparently deemed safe for occupancy even though all suffer occasional plaster failure.

“8. The historically beautiful Schenley building, however, has major interior, infrastructure deficiencies to include an inadequate ventilation system, dated heating, electrical and plumbing systems all of which involve asbestos abatement, which in turn makes much needed improvements extremely expensive.”

RESPONSE: No difference between Schenley and the other schools is noted. There is no indication that systems at Mckelvy, Vann and Woolslair have been updated recently and yet Mckelvy and Vann were chosen for expansion as part of the Right Sizing Plan. Note that heating, electrical and plumbing systems needing repair are generally accessed through a crawl or access space rather than by cutting walls. And, according to the Astorino report on Schenley, “The sub-basement’s main use is for the mechanical systems. There does not appear to be any wall or ceiling plaster located in the sub-basement.”

“In brief the infrastructure and asbestos issues at Schenley are a major liability, costly to fix or repair, difficult to manage or maintain, with no alternative available other than a full and complete remediation and renovation, at considerable costs to the District.”

RESPONSE: No difference between Schenley and the other schools is noted. There is no evidence that foot for foot the Schenley building is any more or a liability, any more costly to fix, or any more difficult to manage than other buildings with asbestos plaster, and it is not clear why only the Schenley building would require “a full and complete remediation and renovation.” If renovation was desired, however, the Task Force convened to examine this issue recommended a $42 million project that addressed the concerns raised in this memo. This “Scope 3B” recommendation involved removal of most of the ceilings; installation of new mechanical, electrical and plumbing systems in a manner that allowed access to the systems without the need for asbestos abatement; encapsulation of remaining asbestos containing materials; installation of air conditioning and a sprinkler system; and ADA accessibility. Students would have been displaced from the building for only one year. Members of the Task Force devoted countless hours to developing a well thought out and economical proposal, only to have their efforts and the proposal disregarded. If nothing other than complete removal of all asbestos plaster would suffice, committee members should not have been asked to waste their time on alternative proposals.

In conclusion, while it appears that the Schenley building would benefit from better ventilation, the Superintendent’s memo does not show major differences between asbestos issues at Schenley and those at Mckelvy, Vann or Woolslair. The memo does not explain why Schenley’s plaster and the building in general could not be managed in the same manner and at a similar cost per area as they are managed at Mckelvy, Vann or Woolslair. Further, in claiming that the only alternative is complete remediation and renovation, the memo ignores the plan recommended by the Schenley High School Task Force to minimize asbestos hazards and update mechanical, electrical and plumbing systems for about half the cost of full remediation.

Attachment A: Outstanding questions raised at the January 12, 2009 public hearing

ATTACHMENT A:

At the January 12, 2009 public hearing PURE Reform presented testimony and raised questions about asbestos issues at Pittsburgh public schools McKelvy/Miller, Vann and Woolslair. Below are the district's answers, PURE Reform's responses, and follow up questions.

1) PURE Reform Question: How was it determined that the history of plaster failure in the McKelvy/Miller building did not amount to a warning of a potentially dangerous situation?

District response: Most of the plaster issues at Miller@McKelvy have been isolated, minor problems; traceable to specific causes or events like roof or plumbing leaks which resulted in damage to specific areas of plaster. In contrast, the plaster problems at Schenley cannot be attributed to isolated causes, such as water damage, and are scattered throughout the entire building. Schenley’s issues, unlike McKelvy, are frequent, building-wide and stem from a combination of plaster age, building environment and unknown causes. The two distinct situation at Miller and Schenley are simply not comparable.

PURE Reform response: AHERA Reports for McKelvy/Miller going back 20 years show frequent, substantial, and building wide plaster issues. If plaster issues have been isolated and minor, it is difficult to understand why all of the ceiling plaster would have been removed. As to the wall plaster, even 15 years ago an AHERA inspection showed a long list of rooms throughout the building with damage such as “gym walls 10% damage, plaster walls near window in room 210 < 10% damage, plaster walls near window in room 204 < 5% damage, walls in the generator room, off of room 7, have > 25% damage, plaster walls in coat closet in kindergarten have 10% damage.” Over the past 5 years AHERA reports show repairs to deteriorating wall plaster in Rooms 2C, 4, 7, 10, 13, 113, 202, 203, “various classrooms,” the cafeteria, auditorium, men’s room, laundry, rear main entrance vestibule and “various locations on all levels of the school.” AHERA reports on the wall plaster issues described above do not mention specific causes or events like roof or plumbing leaks and certainly do not rule out age, building environment or unknown causes for these issues. If all of this wall plaster damage has been caused by roof or plumbing leaks, a question is raised as to whether infrastructure issues at this facility are beyond the capacity of the district to manage or maintain.

At the Schenley facility an “Asbestos Potential Hazard Inspection” was done in July 2007 after two small asbestos plaster failures earlier that month on the third floor. Consultants’ reports specifically state that plaster on the third floor had been damaged by water from a leaking roof which was then replaced.

FOLLOW UP QUESTION: Would it not be wise to have an “Asbestos Potential Hazard Inspection” conducted at the McKelvy, Vann and Woolslair facilities, as was done at the Schenley facility?

District response: Two separate environmental consultants have been engaged to conduct room-by-room inspections of Miller (McKelvy), Vann and Woolslair. These inspections will be completed by the end of May 2009.

PURE Reform comment: We applaud the district for arranging these inspections. However, facilities options are set to be presented by facilities consultant DeJong on May 13 and 14. It is not clear how plans can be made for the above three schools if the results of the inspections by the environmental consultants are not complete at that time.

2) PURE Reform question: Why was an outside consultant’s opinion obtained for Schenley but not for McKelvy/Miller?

District response: The wall plaster issues at Miller@McKelvy are limited and usually attributed directly to water infiltration. Ceiling plaster has been previously abated in this building.

PURE Reform response: As noted above, wall plaster issues at Miller/McKelvy have occurred building-wide. It is not clear who has “usually attributed [plaster issues at McKelvy] to water infiltration.” More importantly, the intent of this question was not to ask about a consultant’s opinion as to the cause of plaster failure, but rather to ask why an outside consultant’s opinion as to whether the McKelvy/Miller building is safe for students and staff has not been obtained, given the opinions as to safety expressed in the Astorino letter dated October 19, 2007 and the Kimball letter dated November 16, 2007.

Note also that per the district’s January 31, 2006 “Schenley High School Evaluation Study” ceiling plaster abatement had been planned for Schenley. The school’s plaster ceilings were scheduled to be removed and lighting replaced at a cost of $2.3M budgeted under the 2004 Capital Program. If removal of ceiling plaster was not a sufficient solution for Schenley, it cannot be assumed to be a sufficient solution for McKelvy/Miller.

FOLLOW UP QUESTION: Would it not be wise to obtain a consultant’s opinion as to the potential for asbestos danger at the McKelvy/Miller building?

District response: The two consultants conducting the inspections mentioned in the response to Question #1 above have been requested to provide their professional opinion. This information will be included in the Right to Know response referenced [above in 2A] [NOTE: The response the district labeled 2A is to question 4 below].

PURE Reform comment: We applaud the district for arranging these inspections. However, facilities options are set to be presented by facilities consultant DeJong on May 13 and 14. It is not clear how plans can be made for the above three schools if the results of the inspections by the environmental consultants are not complete at that time.

3) PURE Reform question: With Miller middle school students slated to attend University Prep next year anyway why not eliminate the asbestos plaster risk entirely by returning the K-5 program to the Miller Street facility, a building which reportedly has special historic significance to the African American community?

District response: McKelvy is a much larger facility, and is also designated as a historic building in the Hill District.

PURE Reform response: With grades 6-8 moving out of the Miller program is a much larger facility still needed or even desirable, especially given that this larger facility has no gymnasium? More important, does the added size of the McKelvy building offset the added asbestos danger of that building? Further, although McKelvy/Miller may be a historic building, the Miller Street building reportedly has unique significance as the first school to accept homeless African American students.

4) PURE Reform question: How did the district determine that it was safe for students to return to Vann in 2008 and that it will be safe for students to return to Vann in 2009?

District Response: L.R. Kimball conducted a survey of Vann prior to the beginning of the 2008 school year and found no indications of environmental problems. Additionally, the asbestos air sampling that have been conducted since 2005 has never indicated any problems or hazardous conditions. Vann in scheduled to be inspected by qualified personnel prior to the start of the 2009 school year. The monthly asbestos air sampling program will be continued at this location.

PURE Reform response: It is not clear whether the survey of Vann addressed only existing problems or whether it addressed potential problems as well. As Superintendent Roosevelt noted last summer, “You don’t close a school, when the air readings tell you there is asbestos in the air. You don’t wait for that point.” Accordingly, even though asbestos air sampling had never shown a problem at the Schenley facility, consultants’ opinions were obtained as to the potential for asbestos danger at that facility.

FOLLOW UP QUESTION: A) May we have a copy of the Kimball survey of Vann done prior to the start of the 2008 school year and B) Would it not be wise to obtain a consultant’s opinion as to the potential for asbestos danger at the Vann facility?

District response:

A) Your request has been forwarded to the District’s Law Office as a Right to Know request. You will be hearing directly from them.

B) The two consultants conducting the inspections mentioned in the response to Question #1 above have been requested to provide their professional opinion. This information will be included in the Right to Know response referenced above in 2A [in this document it is referenced in question 4].

PURE Reform comment:

A) PURE had already submitted a Right to Know request for the Kimball report on Vann and received in late March a “Final Report, Asbestos & Hazardous Materials Inspection” for Vann, copyright August 2008. Rather than stating that there are or are not environmental problems at the Vann building, the report summarizes what hazardous materials Kimball found and where they are located. It states that 88,500 square feet of original surfacing should be assumed to contain asbestos and seems to suggest that at least some of this surfacing is friable (meaning that someone could crumble a piece of the material and release asbestos fibers into the air). Hazards also include thermal insulation containing high levels of asbestos. In one respect the Kimball report is very odd. Page 10 of the repot indicates that in 2004 AGX performed a plaster survey and found that 84 of 93 samples contained greater than 1% asbestos. As part of its inspection Kimball also did a plaster survey and found that only 3 of 145 samples contained greater than 1% asbestos. Since asbestos in plaster does not disappear, this enormous disparity in the plaster surveys suggests a difference in methodology between the Kimball and AGX, or between the testing laboratories, or both.

B) Facilities options are set to be presented by facilities consultant DeJong on May 13 and 14. It is not clear how plans can be made for the above three schools if the results of the inspections by the environmental consultants are not complete at that time.

FOLLOW UP QUESTION: To what does the district attribute the disparities in the plaster surveys and which of the two surveys will the district and facilities consultants rely on in making decisions about the Vann building?

5) PURE Reform question: How does the district determine whether there is a significant risk of danger from falling plaster or asbestos being released into the air?

District response: Evaluations of plaster or asbestos risk at any school would be made on the basis of a number of criteria:

a) Repeated reports of plaster failure from custodial and building staff.

b) Confirmed existence of asbestos in the plaster.

c) Plaster problems being reported throughout the building or occurring in large areas, not just isolated areas.

d) Plaster failures not directly linked to known or discovered causes. Each case would be individually evaluated to assess the existing plaster’s age and cause for failure.

e) General and overall visual deterioration of the surface of the plaster and lack of adherence to other surfaces.

PURE Reform response: Asbestos plaster has been confirmed and repeated reports of plaster failure have occurred throughout the McKelvy/Miller, Vann and Woolslair facilities. It is not clear whether the cause for all instances of plaster failure is known and in any event it would seem that just knowing the cause of plaster failure would not significantly mitigate risks if the cause was for example age, or if the district is unable to manage repeated incidents of water infiltration.

6) PURE Reform question: Under what circumstances does the district seek a consultant’s opinion as to the safety of a building with asbestos plaster?

District response: Consultants may be hired to supplement the District’s in-house architectural, engineering, and environmental staff whenever manpower is unavailable, whenever staff determines confirmation of their observations is warranted, when a “second” opinion seems prudent, or where staff alone can not make a reasonable determination of the existing conditions.

PURE Reform comment: We are pleased to learn that the district has decided to seek the opinion of outside environmental consultants regarding the McKelvy/Miller, Vann and Woolslair buildings, although coordination with the timing of upcoming facilities recommendations is an issue.

7) PURE Reform question: Under what circumstances is the adhesion of plaster tested?

District response: Adhesion tests are generally not conducted unless the building has shown evidence of widespread and or chronic plaster failure or where an incident related failure, like broken piping, has caused severe damage.

PURE Reform response: See PURE Reform’s response to answer # 1 above for a list showing widespread plaster failure at McKelvy/Miller. At Vann, AHERA reports mention plaster problems over the past 5 years in rooms 6, 103, 104, 110, 201, 202, 209, 210, 211, 212, 213B, 215, “various classrooms,” the teachers’ lounge, auditorium, stairwell behind the auditorium, hallways, fan room and “various areas.” And, the ceiling collapses at Woolslair in late 2007 and early 2008 involved a much larger area of plaster failure than the two July 2007 incidents that drew attention to the Schenley building. Adhesion testing does not seem to be a major project- WJE’s adhesion analysis for Schenley involved only four samples.

FOLLOW UP QUESTION: Would it not be wise to perform adhesion tests on plaster samples from McKelvy/Miller, Vann and Woolslair?

District response: We do not have enough information to address this question at this time. However, firms capable of conducting such specialized tests are being explored by Facilities. We anticipate a report on Friday, March 27, 2009 on the findings.

PURE Reform comment: PURE will submit a Right to Know request for this report.

8) PURE Reform question: At which buildings has an enhanced asbestos monitoring and maintenance program been adopted, and as of what date?

PURE Reform comment: PURE will submit a Right to Know request for this report.

District response: The monthly air monitoring program was instituted in 2005 for the following schools: Pittsburgh Student Achievement Center, Manchester, McKelvy, Schenley, Vann and Woolslair.

PURE Reform response: This question was not intended to refer to the air quality monitoring done at the above schools since 2005. Rather, it was intended to refer to the enhanced monitoring and maintenance program adopted at the Schenley facility per the district’s November 14, 2007 News Release (http://www.pps.k12.pa.us/14311051715526407/lib/14311051715526407/District_Adjust_Year_2_HS_Reform_11.14.07.pdf).

FOLLOW UP QUESTION: At what Pittsburgh public school buildings has the type of enhanced monitoring and maintenance program described in the above news release been adopted?

District response: The conditions at the other locations do not warrant such extreme measures. The following monitoring program has been instituted in March, 2009 for Manchester, Miller/McKelvy, Vann and Woolslair: Two separate environmental consulting firms have been engaged to inspect the building each month. Air sampling will be done on a monthly schedule. The frequency of the inspections and or air sampling may be increased based upon the findings of the consultants and building conditions.

9) PURE Reform question: Is there any reason not to promptly schedule a test of the Schenley ventilation system?

District response: Testing of the ventilation system at Schenley would not contribute any new information. The operational issues with the system are already known and, in the best estimation of our mechanical engineers, will only contribute further to the current problems. The problems with the existing system will further escalate building overheating and possible humidity issues and as in the past, contaminate the building with an “unknown black dust”. This could be further compounded by its lack of activity over the past few years which may have allowed for some asbestos dust to settle into the ductwork. In the long run, this would only create the need for an immediate re-cleaning of the entire building and its contents and not move any closer to solving its current problems.

PURE Reform response: The facilities staff’s report on “Major Facilities Issues at Schenley High School” (January 31, 2006) gives this explanation as to operational issues: “Existing system consists of a series of ducts that are located within corridor walls that bring fresh air into each classroom. These ducts have asbestos insulation and are also contaminated with dirt and dust. They have not been operated for at least 10 years due to these problems. Past attempts to properly clean these ducts have been unsuccessful.”

FOLLOW UP QUESTION: What attempts to clean the ducts were made, when were those attempts made and why were attempts unsuccessful? Were attempts unsuccessful because potential HVAC cleaning companies refused a district requirement of certification that no asbestos fibers would be released? Could the system be operated w/ HEPA filters to catch any stray asbestos particles that may have settled into the duct work?

District response: Schenley High School was built in 1913. Complete historical records are not available. We can verify that some duct cleaning work was completed in 1985. Patches observed in the supply ductwork confirm that access to the interior of the ductwork was provided for during such cleaning.

This cleaning was considered unsuccessful as evidenced by the “black soot and dust” that was distributed from time to time throughout the building and hence contributed to the shutdown of the ventilation system.

The system was not operated with HEPA filters because the installation of HEPA filters would so increase the static pressure of the ventilation system that it would then be incapable of providing the airflow that it was designed for. The result would have been insufficient fresh air delivered to the classrooms. Also, operating the existing ventilation system without first addressing the system control lines (buried in asbestos-containing plaster) would have resulted in additional overheating problems thus contributing to discomfort in the building.

PURE Reform comment: Patches may be the result of repairs rather than cleaning. More important, incidents of black soot do not necessarily indicate that any duct cleaning that may have been done was unsuccessful. Once ducts are clean it is necessary to keep the intake area clean. At one time there was a system in place so that before reaching the intake area, air would pass through a fine mist that would both humidify the air and cause solid particulates to settle out. That system is no longer operational but presumably could be repaired without impacting plaster. Failure to keep the intake area clean is the most likely explanation for the incidents of black soot which contributed to shutdown of the ventilation system.

Regarding operation with HEPA filters, the follow up question should have specified that the filters would be used as part of a test of the system, mainly to check if the fan motors worked to propel air through the system and to protect against distribution of soot during testing. The next step would be to clean the ducts, put into place a system to keep the intake area clean, and again test the system with the filters in place before finally removing them. Note however that even if filters caused the system to be “incapable of providing the airflow that it was designed for,” that airflow could still be more than sufficient because the system was designed to provide 100% fresh air. Applicable codes require and modern systems supply a much smaller percentage of fresh air. Further, more powerful fans could supply additional force to overcome the “static pressure” of the system.

Finally, regarding the system controls (ie, the pneumatic controls with small air lines that run from the thermostats of each room to the duct dampers and steam controls in the basement), there are alternatives to disrupting the plaster in which the controls are embedded. The existing controls could be abandoned in the walls and the pneumatic controls replaced with electronic controls running outside the walls (involving cutting just one spot in each room). Alternatively the ventilation system air pumps could be set so that all of the incoming fresh air is heated at a uniform temperature rather than being controlled room by room. Adjustments to the temperature in individual rooms would instead be made by using the thermostats to control the radiators in each room.

10) PURE Reform question: Further, we request a response as to whether the recommendation in the Schenley High School Task Force Report dated June 23, 2006 for Scope 3B renovation adequately addresses district concerns about asbestos exposure; liability; and ventilation, heating, electrical and plumbing systems at the Schenley building (with the understanding that allocating the $42 million for repairs is a separate issue that would need to be discussed in the context of particular proposed uses of the building).

District response: It is difficult to understand this question and would appreciate a clarification as to what specific information is requested regarding Scope 3B of the June 23, 2006 report.

PURE Reform response: The superintendent’s January 12, 2009 memo “Asbestos Issues in Schenley vs. Other School Buildings” states that “[T]he infrastructure and asbestos issues at the Schenley facility… are difficult to manage or maintain with no alternative available other than a full and complete remediation and renovation at considerable costs to the District.” The district has indicated that the cost of a full and complete remediation exceeds $76 million. The information requested is, would the $42 million Scope 3B renovation as modified/elaborated in the Task Force Report adequately address infrastructure and asbestos issues at the Schenley facility and so provide an acceptable alternative to a full and complete remediation and renovation of the Schenley facility, and if not, in what way would the renovation recommended by the Task Force fail to adequately address such issues?

District response: The Scope 3B option proposed by the consultants involves limited abatement of asbestos containing materials (ACM) only in areas directly impacted by the removal of the building systems. This leaves ACM in the remainder of the building and does not accommodate the expansion and/or reconfiguration of the existing classrooms to meet current state requirements, curriculum needs or future programming. Leaving ACM in place would further complicate all future renovation/remodeling projects making them even more expensive and time-consuming in the future. Concerns for safety/health/liability would continue to exist.

PURE Reform comment: The Schenley building’s classrooms met changing curriculum and programming needs for almost 100 years. The extent to which the classrooms may fail to meet current state requirements is unclear. However, it is important to note that many if not most of the district’s school buildings are unlikely ever to be remodeled to meet all of the requirements adopted after those schools were constructed. It would seem more reasonable to list the renovation cost as $42M with an asterisk indicating that for an additional $40M the building could be made easier to renovate again in the future. Finally, with any building there will be reasons for concerns for safety/health/liability. It is not clear what the safety/health/liability concerns for the Schenley building after a Scope 3B renovation would be. However, the fact that the McKelvy/Miller, Vann, Woolslair and Manchester buildings remained open for the 2008-2009 school year demonstrates that when it comes to asbestos, the district does not require elimination of all possible risk of safety/health/liability issues.

QUESTION RAISED AT THE FEBRUARY 16, 2009 PUBLIC HEARING

At the February public hearing PURE Reform observed that plaster ceilings had been removed at the McKelvy/Miller building and that removal of asbestos plaster ceilings at Schenley had been included as part of the 2004 capital budget ($2.3M). PURE asked “What if we were now to remove the ceilings and, as with McKelvy, monitor the wall plaster and repair it as needed?

District response: The removal of the plaster ceilings at Schenley would be a multi-million dollar project, with asbestos abatement representing only a portion of the total costs. New ceilings and lighting would be required, and the electrical/fire alarm/PA/computer/communications/security systems might also require replacement. Millions of dollars could be spent to repair only a portion of the overall problem; and one would still be left with the concerns of asbestos containing walls, floors, thermal insulation and an inadequate, malfunctioning ventilation system.

PURE Reform comment: It is true that the Schenley ceiling removal project budgeted in 2004 was for a multi-million dollar amount ($2.3M). However, compared to many other renovation projects planned or recently completed by the district this is a relatively small cost for a large amount of space. Presumably when the project was budgeted in 2004 the need for new ceilings, lighting and necessary systems was taken into account. A new ceiling and lighting and necessary systems would also have been required at McKelvy/Miller. While money would be spent to repair only a portion of the overall problem that was the case at McKelvy/Miller as well, where the remainder of the problem has been addressed through monitoring and maintenance. Regarding the floors, asbestos containing floor tiles are found in many if not most Pittsburgh public schools but are usually not a problem because floor tiles generally do not become friable. And, while a number of schools have asbestos containing thermal insulation, at Schenley most of that insulation has reportedly already been replaced with fiberglass insulation. Regarding the ventilation system, please see question 9 above.

PETITION PRESENTED AT THE FEBRUARY 16, 2009 PUBLIC HEARING

Also at the February 2009 public hearing, PURE Reform presented a petition signed by 150 city residents (and later signed by an additional 50+ residents) that stated as follows:

WE, the undersigned citizens of the City of Pittsburgh, hereby petition the School Board for the Pittsburgh Public Schools for an asbestos plaster inspection and opinion of risks, dangers and relative condition of such plaster by an independent expert, of four school buildings: Schenley, McKelvy, Vann, and Woolslair.

District response: Two separate environmental consultants have been engaged to conduct room-by-room inspections of Miller (McKelvy), Vann and Woolslair. These inspections will be completed by the end of May 2009. The two consultants conducting the inspections mentioned in the response to Question #1 above have been requested to provide their professional opinion. This information will be included in the Right to Know response referenced above in 2A.

PURE Reform comment: No explanation is given as to why the environmental consultants retained by the district should not also inspect and provide an opinion as to the Schenley building, including the requested opinion as to the condition of the plaster in the Schenley building relative to the plaster in the McKelvy/Miller, Vann and Woolslair buildings. This information is relevant to the current facilities planning process, which includes the Schenley building. Further, as noted in the comments to Question #4, above, surveys done by two different sets of consultants have yielded widely different results. For consistency, the same consultants must inspect and evaluate all four buildings.

FOLLOW UP REQUEST: PURE Reform requests that the environmental consultants inspecting and evaluating the McKelvy/Miller, Vann and Woolslair buildings also inspect and evaluate the Schenley building and provide an opinion on condition of the plaster in the Schenley building relative to that in the other three buildings. PURE Reform also requests the names of these environmental consultants and information on how it was determined that these consultants are “independent.”