1. Managing Mercury Contamination During Demolition and Renovation
Michael Austin

2. Goal of presentation
Explain how we fit mercury assessment into our overall environmental procedures plan
Show how we developed standards for mercury

3. New stadium area, East Gateway is upper right
East Gateway Area 1962

5. Conflict Before Process
Conflict between DEHS and Capital Planning
Role with contaminated land understood
Responsibility for managing contaminated buildings not understood
Conflict within DEHS over standards of care
Differences in risk assessment
Differences over sampling method
Conflict with the MPCA
NOVs related to disposal of Hg contaminated debris – agency required test data
High conflict lead to change

6. Jones Hall ca. 1903
Built as physics building before Tate was built

7. Jones Hall (2004 – 2005)
Mercury discovered on sub-floor after maple strips salvaged for reuse
500 sq. ft. recovered from Deconstruction Services:
3 of 90 bundles tested above background for mercury but below residential clearance level
2,300 sq. ft. found in a customers barn.
Ambient readings were less than MDH residential standard 500 ng/m3.
Puddle of Hg found, also found during other phases including under window sill

8. Metrics Milligram (mg) 1/1,000 (thousands)
Microgram (ug) 1/1,000,000 (millions)
Nanogram (ng) 1/1,000,000,000 (billions)
To make comparisons easier we use nanograms / cubic meter as a reference for concentration in air

9. Lab testing of wood
Wood sample from the second floor in the area of the mercury release: 11 mg/kg
Wood samples taken from six bundles of recovered 2,800 sq. ft. with testing of shavings of tops, bottoms and sides only: mg/kg
Wood samples (same six bundles) taken from the entire thickness of the wood: mg/kg
Wood samples analyzed from the cores (e.g., sides and top and bottom removed) of same six bundles of wood: 0.19 to 2.2 mg/kg
All passed TCLP ( all < 0.01 mg/L)
Hg permeated the wood

10. Field Testing of finished installed flooring
Five homes tested – < 100 ng/m3 in air at finished floor surface
Discussed standards and health effects
Offered to replace flooring
No one accepted offer
Roger Wegner, CPPM, Pat Martin, Haz Mat Supv., Mike Austin, DEHS visited homes
Script developed with U Relations, CPPM called to make appointments
We imagined the worst but everyone was quite happy that we were concerned and were polite

11. Mercury Clean-up Guidelines Work Team
Members included the U of M Department of Environmental Health and Safety and faculty from two departments, and staff from the MPCA and the Minnesota Department of Health.
The task force has reached consensus about procedures for assessing contamination and classifying debris.
These procedures could serve as a model for other entities.
Following Jones Hall we set up task force to determine standards

12. Goals Minimize human exposure to mercury
Set health standard
Prevent or minimize human exposure
Informed consent
Mercury clean up criteria
Minimize release to the environment
Prevent or minimize release to the environment
SOPs to screen waste for mercury

13. Mercury containing devices are very common.
Devices include: fluorescent light bulbs, thermometers, light switches, pressure sensing devices and bubblers.
These items have occasionally broken and caused low levels of contamination on floors and walls.
A high percentage of demolition debris from old buildings is contaminated with trace amounts of mercury.

14. Why we care about mercury
Mercury and compounds are toxic
Damage to brain
Damage to kidneys
Neurological development of a fetus, infant or child can be impacted

15. How we are exposed Ingestion of mercury Inhalation of vapor
Contaminated fish – mercury is bioaccumulated in fish
Methyl mercury ingestion is the greatest source of mercury exposure
Average intake is 50 ng/Kg/day
Inhalation of vapor
Natural degassing of mercury from the earth
Release of mercury by burning coal and wood
Dental amalgams
Mike A 5,000 ng/day – maybe more when I eat fish, my mouth about 500 ng/m3
Largely excreted in urine, about 1000 ng/ L, 5,000 ng/day in feces UMD must clean pipes to prevent exceeding permit

16. Mercury Health Standards
200 ng/m3 chronic MRL – US Dept HHS ATSDR
300 ng/m3 RfC - EPA IRIS
300 ng/m3 - Minnesota Dept. of Health chronic exposure criterion for schools (breathing zone)
500 ng/m3 - Minnesota Dept. of Health residential standard
25,000 ng/m3 - American Conference of Government Industrial Hygienists (ACGIH TLV)
50,000 ng/m3 - MN OSHA PEL (a rule)
50,000 ng/m3 - NIOSH REL
Lowest Observable Adverse Effect Level (LOAEL) is about 25,000 ng/m3 for health workers – chlor-alkali workers who make bleach, chlorine, potassium hydroxide from salt
Other standards make assumptions about age, health status, diet, duration of exposure, uncertainty of data

17. U of MN health based spill cleanup goals
Based on task force discussions including MN Dept. of Health
Visible mercury always removed
500 ng/m3 in residential occupancies
850 ng/m3 in other public areas (residential exposure adjusted for time)
25,000 ng/m3 in work places with expectation of exposure

18. Federal Rules for Disposal
40 CFR Sec (2)(i) Definition of hazardous waste
40 CFR Sec Toxicity characteristic. Reference to TCLP method 1311 Table mg/L of mercury
40 CFR 302.4, Table List of Hazardous Substances and Reportable Quantities Mercury - 1 pound

19. Federal test for contaminated debris
The leaching test (TCLP) directly evaluates the potential for mercury to leach out of a land fill.
Mercury binds tightly to concrete and other debris

20. Minnesota Statute
Minn. Stat. Sec. 115A.932 “A person may not place mercury or a thermostat, thermometer, electric switch, appliance, gauge, medical or scientific instrument, or electric relay or other electrical device from which the mercury has not been removed for reuse or recycling: (1) in solid waste; or ….” See also Minn. Stat. Sec Mercury emissions reduction
Agency argued first 0 mg/m3 – I pointed out that the SRV was 0.7 mg/kg for day care soil
Second they asserted 0.7 mg/m3 – KOB met with MPCA commissioner
Andy Phelan and I met with MPCA supervisor and staff
Third they asserted 4 mg/m3
Resulted in our debris being sent to WI – waste of fuel, no benefit to environment

21. MPCA adopted policy decision
Allows lined landfills to accept debris containing mercury.
Less than 4 mg/m3 no special handling
4 – 10 mg/m3 if immediately covered
More than 10 mg/kg of total mercury requires written agency pre-approval with conditions
In adopting this policy, the MPCA recognized that the legislature intended the statute to be limited to regulating disposal of mercury-containing devices.
Janet Dalgleish was able to dispose of old track at MN landfill by pre-appoval
Track was made with Hg catalyst

22. Environmental Procedures Plan
Establishes processes and service levels
Defines roles and responsibilities
Capital Planning Project Manager
Drives the project to completion and ensures scope, schedule and budget.
Chairs project meetings
DEHS
Communicates and coordinates EHS review
Coordinates with consultants and agency representatives
Describes conflict resolution process
Janet Dalgleish has this on her work plan

23. E P Plan – Processes Real Estate Property Purchases Phase I and II
Environmental Assessment
Historical Property Records
Historical Aerial
Site Inspections
Env. Screening Geotech Borings
DEHS Property Assessments
Historical Data Review &
Sample Collection
(if needed)
University
Owned
Properties
Update Plans
New Construction
& NPDES Permits
DEHS Stormwater Planning
Campus Wide Stormwater Plans
Real Estate Purchases for Development
U Owned Property Development
Stormwater Plans
Air quality permits
Facility management Waste Abatement
Soil and Groundwater impacts Assess and remediate all known env. Impacts while construction plans and specifications are being developed.
Review the existing data and fill in the gaps where additional data are required.
DEHS Air Quality Permits
Campus Wide Plans and Permits
Update Campus Air Quality Models when New Sources Added
FMHMP - Asbestos, Lead Paint
Mercury, Other heavy metals Abatement
Project Specific Testing Prior to all Demolition or Remodeling Projects

24. Capital Planning and Project Management

25. Initial Environmental Site Assessment
Intent to identify the potential environmental risks for a given property.
Includes records analysis, site reconnaissance, and interviews.
May also include, as recommended by DEHS or a QEC, non-invasive testing.
Data used to develop scope of work for Phase ll testing

26. Initial Environmental Assessment Hazards:
Asbestos
Pesticides
Heavy Metals, including but not limited to lead and mercury
Storage tanks and petroleum
Water infiltration and mold
Radiation closeout surveys/decontamination
Hazardous chemicals
Biohazardous agents
CFCs
PCBs
Where past or present use of the facility suggests that mercury may be present, the initial environmental site assessment will incorporate the University’s procedures for identifying and addressing past mercury releases in University facilities.

27. DEHS Construction Oversight
CPPM/DEHS
Review and Oversee Work of FMHMP and Env. Consultants
FMHMP Staff are on site during asbestos and other material abatement
Participate in Decision Making w/
Env. Consultant & CPPM
Track Air Quality
Permits Process
Remove and Abate Hazardous Materials
When Discovered
Periodic Site
Inspections
Soil Quality
SWPPP
On-Site Contractor
Education
- Env. Awareness
Weekly Construction
Meeting

28. Sampling Data - MRRC

29. Minerals Research Resources Center
To Education Sciences
Transformation of Minerals Research Resource Center to Ed. Sci
1924
College of Education and Human Development that pursue research and outreach in the areas of reading and literacy, special education, accountability and assessment, and early childhood education: 1) the department of Educational Psychology, 2) the Center for Applied Research and Educational Improvement (CAREI), and 3) the Center for Early Educational Development (CEED). These three units are currently located in four different buildings on the Minneapolis East Bank Campus.

30. Chemistry Building Remodeling

31. Cleanup After Cabinets Removed

32. Globs Under Cabinets

38. Initial Environmental Site Assessment
Records analysis, site reconnaissance, and interviews focusing on identifying hazards including mercury
Development of appropriate response action plan
Implementation
Consultation with affected employees