1. Laboratory Decommissioning : Essential Tools and Lessons Learned 2002-2007 Jim Carscadden Division of Environmental Protection Office of Research Facilities Development and Operations National Institutes of Health U.S. Department of Health and Human Services June 5, 2007

2. Background Laboratories space at biomedical research facilities are inherently safe environments where hazardous material are commonly used but with safeguards that protect human health and the environment. Laboratories space at biomedical research facilities are inherently safe environments where hazardous material are commonly used but with safeguards that protect human health and the environment. –Institutional safety precautions such as training, knowledge of risks and safe handling procedures. –Engineering safety precautions such as ventilation and physical protections

3. HOWEVER Laboratory renovations and associated demolition activities often remove safety features and can result in serious exposures to hazardous substances – workers (NIH and non-NIH), patients, laboratory animals. Laboratory renovations and associated demolition activities often remove safety features and can result in serious exposures to hazardous substances – workers (NIH and non-NIH), patients, laboratory animals. Disposal of construction debris can and has resulted in serious environmental consequences if not handled appropriately. Disposal of construction debris can and has resulted in serious environmental consequences if not handled appropriately. Future occupants of the area being renovated may be exposed to potentially toxic levels of residual contaminants if not properly addressed during renovation. Future occupants of the area being renovated may be exposed to potentially toxic levels of residual contaminants if not properly addressed during renovation.

4. Regulatory Drivers leading to development of NIH Decommissioning Protocol OSHA Demolition Standard [29 CFR 1926.850(e)]: “It shall also be determined if any type of hazardous chemicals, gases, explosives, flammable materials or similarly dangerous substances have been used in any pipes, tanks, or equipment on the property. “When the presence of any such substances is apparent or suspected, testing and purging shall be performed and the hazard eliminated before demolition is started.” Hazardous waste determination. [CFR40§262.11] “A person who generates a solid waste, as defined in 40 CFR 261.2, must determine if that waste is a hazardous waste …”

5. NIH Decommissioning Protocol I- Initial Facility Assessment Determine potential contaminants by reviewing historical records, interviews, observations. II -Facility Characterization Assessment If indicated by results of initial assessment - conduct sampling and analysis to determine if potential contaminants are present, estimate extent of contamination. III -Decontamination and Remediation IV -Final Status Survey required for property transfer or lease terminations

6. Definitions Decommissioning – those processes necessary to ensure a facility meets all applicable Environmental Health & Safety requirements (as specifically established by Agency policy or Federal, State or local law). Decommissioning may or may not include decontamination. Decommissioning – those processes necessary to ensure a facility meets all applicable Environmental Health & Safety requirements (as specifically established by Agency policy or Federal, State or local law). Decommissioning may or may not include decontamination. Decontamination - the process to reduce risk from “known” hazardous substances to an acceptable level. Decontamination - the process to reduce risk from “known” hazardous substances to an acceptable level.

7. Source of Contaminants Wastes and therefore contaminants have been separated into two major divisions for a number of reasons RESEARCH RELATED – hazardous chemicals or residues left behind as a direct result of research activities – mercury, silver, selenium, cadmium INTRINSIC - building construction related such as asbestos, lead paint, PCB’s etc

8. HISTORY AT NIH NIH’s decommissioning protocol for laboratory renovations was first presented at the DHHS Environmental Workshop in 2002. NIH’s decommissioning protocol for laboratory renovations was first presented at the DHHS Environmental Workshop in 2002. Since that time it has been used for 3 major building renovations or demolitions and many laboratory renovations (ranging from a single module to a 10 module suite of laboratories) Since that time it has been used for 3 major building renovations or demolitions and many laboratory renovations (ranging from a single module to a 10 module suite of laboratories) Thru this history of past use, we have been able to fine tune the process and to better understand and characterize the NIH waste stream. Thru this history of past use, we have been able to fine tune the process and to better understand and characterize the NIH waste stream. The “lessons learned on all of these projects are the subject of this presentation. The “lessons learned on all of these projects are the subject of this presentation.

9. Project Types And Decommissioning –Large projects (building/floor etc) Decommissioning included in the overall project scope, schedule and budget. Decommissioning included in the overall project scope, schedule and budget. –Small projects (labs and/or lab suites) Decommissioning currently funded through Division of Environmental Protection. Decommissioning currently funded through Division of Environmental Protection. –Leased Facilities termination of lease requires final report. termination of lease requires final report. Require “clean bill of health” as condition of new leases Require “clean bill of health” as condition of new leases –Pilot Project(s) decommissioning and demolition of small projects handled together as a separate package decommissioning and demolition of small projects handled together as a separate package

10. Essential Decommissioning Tools An established procedure by which all renovations/demolitions are addressed An established procedure by which all renovations/demolitions are addressed Standards to provide answers to “how clean is clean”. These can be agency driven or regulatory. Standards to provide answers to “how clean is clean”. These can be agency driven or regulatory. A knowledgeable contractor with proven capability; A knowledgeable contractor with proven capability; Proper techniques (where to look) Proper techniques (where to look) Proper tools – instruments. Proper tools – instruments.

11. MERCURY STANDARDS - AIR.

14. Mercury in lead expansion anchors found under vinyl asbestos tile

15. Proper Tools - instruments MERCURY DETECTION Portable AA spectrophotometer with Zeeman background correction Portable AA spectrophotometer with Zeeman background correction High powered light (million candlepower or better) High powered light (million candlepower or better) Lumex Model Ra-915+

16. Assessement/Comparison of Field Measurement techniques for Mercury Direct Vapor Concentrations – Ohio Lumex Direct Vapor Concentrations – Ohio Lumex Field TCLP using Ohio Lumex Field TCLP using Ohio Lumex Field Measurements of total mercury Field Measurements of total mercury Surface total mercury using wipe samples Surface total mercury using wipe samples X-Ray Fluorescence of Mercury X-Ray Fluorescence of Mercury

17. Lessons Learned - flexibility Initial Facility Assessment should be performed for all projects Initial Facility Assessment should be performed for all projects Need for additional steps depends on results of the Initial Facility Assessment Need for additional steps depends on results of the Initial Facility Assessment All protocol phases may be adjusted or combined to meet needs of specific projects. All protocol phases may be adjusted or combined to meet needs of specific projects. Contamination assessment and remediation phases may be separate or concurrent with other construction activities Contamination assessment and remediation phases may be separate or concurrent with other construction activities

18. Lessons Learned - contaminants Mercury is perhaps the most ubiquitous research related contaminant in laboratory facilities and most costly of all contaminants. Mercury is perhaps the most ubiquitous research related contaminant in laboratory facilities and most costly of all contaminants. Mercury decontamination has become the major component of total decommissioning costs. Mercury decontamination has become the major component of total decommissioning costs. Adherence to simple minimization techniques significantly reduces mercury waste generation and disposal costs. Adherence to simple minimization techniques significantly reduces mercury waste generation and disposal costs. Age of the building is not a guarantee against research related contaminants Age of the building is not a guarantee against research related contaminants

19. Lessons Learned - contaminants Asbestos and lead paint are the most commonly found intrinsic contaminants in older buidlings. Asbestos and lead paint are the most commonly found intrinsic contaminants in older buidlings. Neither as costly as mercury. Neither as costly as mercury.

20. Lessons Learned Combining decontamination with demolition of laboratories may be more efficient than attempting to delineate and treat specific surfaces or features only to find “hidden” sources. Combining decontamination with demolition of laboratories may be more efficient than attempting to delineate and treat specific surfaces or features only to find “hidden” sources.