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Delhi Mercury Spill

All POL/SITREP's for this site Delhi Mercury Spill
Ann Arbor, MI - EPA Region V
POLREP #2
Progress
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Delhi Mercury Spill - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V

Subject: POLREP #2
Progress
Delhi Mercury Spill
C54E
Ann Arbor, MI
Latitude: 42.2940870 Longitude: -83.8190560


To: 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

From: Elizabeth Nightingale, OSC
Date: 9/25/2014
Reporting Period: 9/24/14-9/25/14

1. Introduction
  1.1 Background
   
Site Number: C54E    Contract Number:  
D.O. Number:      Action Memo Date:  
Response Authority: CERCLA    Response Type: Emergency
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 9/22/2014    Start Date: 9/22/2014
Demob Date:      Completion Date:  
CERCLIS ID:    RCRIS ID:
ERNS No.:    State Notification: MDCH
FPN#:    Reimbursable Account #:

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. 

2. Current Activities
  2.1 Operations Section
   

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      x
 Mercury  Liquid  One 5 gal pail      
           


  2.2 Planning Section
    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


  2.3 Logistics Section
    No information available at this time.

  2.4 Finance Section
    2.4.1 Narrative
Cost information is not yet available.

   
Estimated Costs *
  Budgeted Total To Date Remaining % Remaining
Extramural Costs
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%
Intramural Costs
 
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.


  2.5 Other Command Staff
    No information available at this time.

3. Participating Entities
  3.1 Unified Command

3.2 Cooperating Agencies
Washtenaw County
Michigan Department of Community Health

4. Personnel On Site
  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

5. Definition of Terms
 
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


6. Additional sources of information
  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.

7. Situational Reference Materials
  No information available at this time.

POLREP #2 Last Updated 10/2/2014