U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Delhi Mercury Spill - Removal Polrep

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #2
Progress
Delhi Mercury Spill
C54E
Ann Arbor, MI
Latitude: 42.2940870 Longitude: -83.8190560
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To:
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Mark Johnson, ATSDR
Valencia Darby, Department of Interior
Dan Wyant, MDEQ
Bill Schuette, Michigan Department of Attorney General
Rodney Stokes, Michigan DNR
Wayne Babcock, U.S. Department of Interior
Robert Burr, U.S. Department of Interior
Carolyn Bohlen, U.S. EPA
Sam Borries, U.S. EPA
Yolanda Bouchee-Cureton, U.S. EPA
Mark Durno, U.S. EPA
Jason El-Zein, U.S. EPA
HQ EOC, U.S. EPA
Sherry Fielding, U.S. EPA
Charlie Gebien, U.S. EPA
John Glover, U.S. EPA
Sharon Jaffess, U.S. EPA
Matt Mankowski, U.S. EPA
Thomas Marks, U.S. EPA
Mike Ribordy, U.S. EPA
Carol Ropski, U.S. EPA
Annette Trowbridge, U.S. Fish & Wildlife
Jaime Brown, U.S. EPA
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From:
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Elizabeth Nightingale, OSC
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Date:
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9/25/2014
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Reporting Period:
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9/24/14-9/25/14
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1. Introduction
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1.1 Background
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Site Number: |
C54E |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
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Response Authority: |
CERCLA |
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Response Type: |
Emergency |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
9/22/2014 |
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Start Date: |
9/22/2014 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
MDCH |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Emergency Response
1.1.2 Site Description
Single family residence in a suburban neighborhood.
1.1.2.1 Location
Ann Arbor, Michigan.
1.1.2.2 Description of Threat
On 9/22/14, MDCH filed an NRC Report (# 1096105), indicating
that a furnace repair technician had identified a mercury spill from a switch
on the furnace while completing a service call. The County Health Department screened
the site with a Lumex, and reported ambient mercury levels of up to 50,000 (nanograms per cubic meter) ng/m3 near the furnace and 34,000 ng/m3 in the basement. After opening windows
and ventilating the house, levels were generally reduced to less than 1,000
ng/m3. MDCH and the County Health Department requested EPA assistance to address the situation.
Mercury is a characteristically hazardous waste under the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. 6901 et seq., as amended, and 40 CFR 261.24. Mercury exhibits the characteristic of toxicity (D009), and is therefore a hazardous substance under Section 101 (14) of CERCLA, 42 U.S.C. 9601(14).
The health effects of mercury are detailed by the ATSDR as follows:
The nervous system is very sensitive to all forms of mercury. Exposure to high levels of metallic, inorganic, or organic mercury can permanently damage the brain, kidneys, and developing fetus. Effects on brain functioning may result in irritability, shyness, tremors, changes in vision or hearing, and memory problems. Short-term exposure to high levels of metallic mercury vapors may cause effects including lung damage, nausea, vomiting, diarrhea, increases in blood pressure or heart rate, skin rashes, and eye irritation.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
EPA mobilized to the site at approximately 5:00 PM on
9/22/14 and met with the County Health Department representative, and later with the homeowner. The homeowner requested that we return the next
morning to conduct monitoring and cleanup work. The homeowner planned to stay
in the home overnight, with the windows open to maintain ventilation. EPA and
START arrived on site at 8:00 AM on 9/23/14. The team closed windows and
screened all rooms in the house with the Lumex. Mercury vapor concentrations were below the acceptable concentrations
for most sensitive people (less than 1,000
ng/m3) in the breathing zone in all areas of the house except right near the furnace. Mercury vapors
were roughly 2,000 ng/m3 there. Visible beads of
mercury were present in the furnace. As these conditions presented an imminent and substantial endangerment to public health, welfare, or the environment, ERRS was mobilized and a removal action was initiated at the site.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
Planned response
activities on-site include:
a)
Assessing the site;
b) Securing, staging
characterizing spilled mercury and mercury contaminated waste;
c) Consolidating and packaging all materials containing
hazardous substances, pollutants and contaminants for transportation and
off-site disposal; and
d) Transporting and disposing of all
characterized or identified hazardous substances, pollutants, wastes, or
contaminants that pose a substantial threat of release at a Resource
Conservation and Recovery Act/CERCLA-approved disposal facility in accordance
with EPA’s Off-site Rule (40 C.F.R. § 300.440).
2.1.2 Response Actions to Date
9/23/14
ERRS mobilized to the site on 9/23. The laundry
room area (that contains the furnace) was isolated from the rest of the house
with poly sheeting and tape. Porous materials within the room were bagged for
screening. A mercury vacuum was used to remove most visible mercury beads from
the furnace. Some beads could not be accessed readily - work will continue on
this effort tomorrow. The floor of the laundry room was inspected, and visible
beads were removed from flooring, from behind molding and from under the hot
water heater. Surfaces were cleaned with DI water. A ventilation system was set
up in the laundry to vent the room overnight. EPA monitoring has not identified
elevated mercury in other areas of the house to date - however investigation in
ongoing.
9/24/14
Remediation activities continued within the laundry room (identified point
source) to confirm the absence or presence of elemental mercury, mercury vapors
and mercury impacted materials. Mercury vapor surveys also continued on
the main level of the property.
EPA activities concentrated on the removal of visible mercury beads embedded
within the metal tapered seams of the furnace. Removal activities
included the disassembly of furnace components in order to access areas where
mercury beads could be removed, utilization of mercury HEPA vacuum, ventilation
of main work area, application of deionized rinse water to impacted furnace,
and internal furnace components. Unfortunately, after extensive work to
recover mercury beads from within the furnace, mercury vapors being emitted
from the furnace still exceeded 4,000 ng/m3. Therefore, rather than continue
costly recovery efforts within the furnace further, the OSC decided to remove
the contaminated furnace and replace it.
Bagged clothes and
personal items were allowed to heat up in the sun, then screened. Most bags
were found to be contaminated (per criteria below). Contents with low levels of
contamination removed from bags and allowed to air out prior to re-bagging and
screening.
Cleanup operations for
the day concluded with the furnace/laundry room being sealed off from the rest
of the second level basement with poly vinyl sheeting and placing a portable
heater and ventilation blower within the room.
No other areas of
contamination have been identified within the residence.
Over the day and at the
end of the day mercury vapor levels were surveyed periodically throughout the
house (windows open). Vapor levels did not exceed 1,000 ng/m3.
9/25/14
Today, team efforts
focused on removing the contaminated furnace and packaging and staging it for
disposal. After removal of the furnace and thorough cleaning of the furnace
footprint area, mercury vapors averaged about 200 ng/m3 in the furnace footprint
area and about 400 ng/m3 in the breathing zone of the laundry room. These
results indicate that the laundry room is now safe
for occupancy by sensitive persons (per criteria detailed below). The ploy
sheeting isolating this room from the rest of the house was removed.
Bagged clothes and
personal items with low levels of contamination were again allowed to heat up
in the sun, then screened. All but one bag were still found to be contaminated.
All contaminated personal items were inventoried and photographed and staged
for disposal as mercury contaminated debris.
All mercury and mercury
contaminated waste was collected and staged for proper disposal.
Over the day and at the
end of the day mercury vapor levels were surveyed periodically throughout the
house (windows open). Vapor levels did not exceed 1,000 ng/m3.
Mercury Action Levels
According to the Agency for Toxic Substances and
Disease Registry (ATSDR) and the Michigan Department of Community Health, a
residential structure is safe for occupancy by sensitive persons when mercury
levels are below 1,000 nanograms/cubic meter (ng/m3), in the breathing zone. On this response, the
site will be considered cleaned up at this site when the visible mercury has
been removed, and mercury levels in the breathing zone are less than 1,000
ng/m^3. Both of these goals were achieved on 9/25/14.
For screening objects, and debris, ATSDR recommends that objects with
mercury levels above 10,000 ng/m3 be
disposed of outright. Objects with mercury levels between 10,000 and 6,000
ng/m^3 may aired out to reduce levels, and objects with mercury levels below 6,000
ng/m^3 may be kept. At this site, debris that was suspected to be contaminated
with mercury was bagged and mercury levels within the bags was measured. If the
mercury level of the bagged debris exceeded 6,000 ng/m^3, and level did not
reduce after airing out, the debris was disposed of outright as mercury
contaminated debris.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties
(PRPs)
Investigation into potentially responsible
parties is ongoing.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Mercury Contaminated Debris |
Solid |
Five 55 gal drums |
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| Mercury |
Liquid |
One 5 gal pail |
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2.2 Planning Section
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2.2.1 Anticipated Activities
The bulk of the response work has been completed.
2.2.1.1 Planned Response Activities
The team will complete furnace replacement and arrange for and complete proper disposal of staged waste.
2.2.1.2 Next Steps
Verification samples will be collected to verify that screening results are accurate.
2.2.2 Issues
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2.3 Logistics Section
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No information available at this time.
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2.4 Finance Section
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2.4.1 Narrative
Cost information is not yet available.
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Budgeted |
Total To Date |
Remaining |
% Remaining |
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Extramural Costs
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| ERRS - Cleanup Contractor |
$25,000.00 |
$0.00 |
$25,000.00 |
100.00% |
| TAT/START |
$15,000.00 |
$0.00 |
$15,000.00 |
100.00% |
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Intramural Costs
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| Total Site Costs |
$40,000.00 |
$0.00 |
$40,000.00 |
100.00% |
* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.
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2.5 Other Command Staff
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No information available at this time.
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3. Participating Entities
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3.1 Unified Command
3.2 Cooperating Agencies
Washtenaw County
Michigan Department of Community Health
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4. Personnel On Site
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Personnel on site on 9/24/14:
EPA: 1
Washtenaw County: 0
START: 1
ERRS: 3
Personnel on site on 9/25/14:
EPA: 1
Washtenaw County: 0
START: 1
ERRS: 3
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5. Definition of Terms
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| ATSDR |
Agency for Toxic Substances and Disease Registry |
| BZ |
Breathing Zone |
| CERCLA |
Comprehensive Environmental Response, Compensation, and Liability Act |
| CERCLIS |
Comprehensive Environmental Response, Compensation, and Liability Information System |
| DNR |
Department of Natural Resources |
| EPA |
Environmental Protection Agency |
| ERNS |
Emergency Response Notification System |
| ERRS |
Emergency and Rapid Response Service |
| MDCH |
Michigan Department of Community Health |
| MDEQ |
Michigan Department of Environmental Quality |
| NG/M^3 |
nanograms per cubic meter |
| NCP |
National Oil and Hazardous Substance Pollution Contingency Plan |
| NOAA |
National Oceanic and Atmospheric Administration |
| NPL |
National Priorities List |
| NRC |
National Response Center |
| OSC |
On Scene Coordinator |
| PPE |
Personal Protective Equipment |
| PPM |
Parts per million |
| RCRIS |
Resource Conservation and Recovery Act Information System |
| RP |
Responsible Party |
| RRT |
Regional Response Team |
| START |
Superfund Technical Assessment and Response Team |
| US FWS |
United States Fish and Wildlife Service |
| USCG |
United States Coast Guard |
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6. Additional sources of information
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6.1 Internet location of additional information/report
epaosc.net/delhi
6.2 Reporting Schedule
A final report will be issued after disposal has been completed and final sampling results are available.
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7. Situational Reference Materials
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No information available at this time.
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POLREP #2 Last Updated 10/2/2014
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