US EPA RECORDS CENTER REG ON 5

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MEMORANDUM

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5

77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590

REPLY TO THE ATTENTION OF:

SUBJECT: Action Memorandum: Request for approval of an Emergency Removal Action at the Lowe Road Mercury Site (SSID # C5FA) located in Fowlerville, Livingston County, Michigan 48836

FROM: Stephen Wolfe, On-Scene Coordinator Emergency Response Section 1

THRU: James Augustyn, Chief Emergency Response Section 1

TO: Jason H. El-Zein, Chief Emergency Response Branch 1

I. PURPOSE

The purpose of this Action Memorandum is to request and document your approval of the selected removal action taken at the Lowe Road Mercury Site located in Fowlerville, Livingston County, Michigan 48836 (the Site) and a ceiling amount not to exceed $130,000. The response action was necessary to mitigate the imminent threat to public health, welfare, and the environment posed by the release of elemental mercury at a residential home which had the potential to be tracked into the environment.

On January 23, 2017, Section Chief, Mathew Mankowski verbally approved $10,000 to mobilize the Superfund Technical Assistance and Response Team (START) contractor to the Site. On January 24, 2017, Branch Chief, Jason El-Zein verbally approved an initial ceiling of $50,000 for the Emergency Response and Rapid Services (ERRS) contractor to initiate response actions (AR#3). On January 31, 2017, Branch Chief, Jason El-Zein verbally approved a ceiling increase of $50,000 for ERRS to continue response actions (AR#4). On February 2, 2017, Section Chief, James Augustyn verbally approved a ceiling increase of $10,000 for the START contractor (AR#5). On March 2, 2017, Branch Chief, Jason El-Zein verbally approved a ceiling increase of $10,000 for the START contractor (AR#6)

This Action Memorandum, if approved, will serve as authorization for the expenditures by the Environmental Protection Agency (EPA), as the lead technical agency, for the actions described herein to abate the imminent and substantial endangetment posed by hazardous substances at the Site. The response actions were conducted in accordance with Section 104(a)(1) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C. § 9604(a)(1), and 40 C.F.R. § 300.415 of the

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National Oil and Hazardous Substances Pollution Contingency Plan (NCP) to abate the immediate threats posed to public health and/or the environment.

The presence of unsecured hazardous substances (elemental mercury) present at the Site required that this action be classified as an Emergency Removal action. The project required approximately 22 on-site working days to complete.

There are no nationally significant or precedent setting issues associated with the Site, and the Site is not on the National Priorities List (NPL).

II. SITE INFORMATION

A. Site Description

Site Name: Lowe Road Mercury Site Superfund Site ID: C5FA EPA ID: MIK 369 999 279 Location: Lowe Road, Fowlerville, MI 48836 Latitude: degrees north Longitude: degrees west Category: Emergency Response Removal Start Date: January 24, 2017

B. Site Background

1. Removal Site evaluation

On January 20, 2017, homeowners renovating their house discovered elemental mercury underneath the padding of carpeting. The homeowners had been living in the house for 3 years and were remodeling a bedroom for a nursery. After removing the carpet and carpet padding, they discovered the mercury on the sub-floor. They were able to gather a portion of the mercury into a small jar (estimated at more than a tablespoon) and contacted the Livingston County Health Department (LCHD) stating there was still visible mercury present that the residents could not collect. (AR#2).

On January 23, 2017, The LCHD Director of Environmental Health screened the residence with a Lumex mercury vapor analyzer. Ambient mercury vapor levels within the breathing zone (BZ) throughout the house ranged between 12,000 — 15,000 nanograms per cubic meter (ng/m3). In the identified source area, mercury vapor levels within the BZ peaked at 80,000 ng/m3. (AR#2).

The wife is pregnant LCHD, in conjunction with the Michigan Department Health and Human Services (MDHHS), evacuated the family from the home on January 23, 2017. MDHHS contacted EPA for assistance on January 23, 2017 (AR#2).

On January 24, 2017, EPA arrived at the vacated residence and conducted an initial assessment to document and confirm the initial mercury vapor readings LCHD obtained. Visible beads and 'micro' beads of mercury were visible in the bedroom that the residents were renovating for a

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nursery. The homeowners had stated they discovered the mercury after removing the carpet and associated carpet padding. EPA and the START contractor screened the home with a Lumex RA 915 Light Mercury Vapor Analyzer (Lumex) to monitor the BZ within the 'source' bedroom. The initial readings peaked at 34,000 ng/m3. Initial ambient air readings throughout the main floor of the residence ranged up to 10,000 ng/m3 and readings in the basement ranged up to 7,700 ng/m3.

Based on the high mercury vapor concentrations throughout both levels of the house and the visibly remaining mercury beads, the OSC determined the release was larger than what a homeowner could reasonably be expected to mitigate safely and mobilized the Emergency Response and Removal Contractors (ERRS) on January 24, 2017. Additionally, EPA requested that the homeowners contact their insurance company to determine if financial coverage was available.

2. Physical location and Site characteristics

The Site is located at Lowe Road, Fowlerville, Livingston County, Michigan 48836. Coordinates are degrees north, and degrees west. The Site is located in a rural area and is bordered by other residential properties and farm fields. The closest farm field and the nearest neighboring residential property each lie approximately 200' away.

An Environmental Justice (EJ) analysis for the Site is contained in Attachment 1. Screening of the surrounding area used Region 5's EJ Screen Tool. Region 5 has reviewed environmental and demographic data for the area surrounding the Site and determined there is a high potential for EJ concerns at this location.

3. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant

Mercury is a hazardous substance, as defined by Section 101(14) of CERCLA, and is specifically listed as a hazardous substance at 40 C.FR. §302.4. Mercury also exhibits the characteristic of toxicity D009, and is therefore a hazardous waste under the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. §§ 6901 et seq., as amended, and 40 C.F.R. § 261.24, if it exceeds 0.2 mg/L using the Toxicity Characteristic Leaching Procedure (TCLP). The mercury was released at a residential home and was tracked into the environment when the homeowners removed the contaminated carpet. The elemental mercury still present in the home could be further tracked into the environment via shoes and the dog.

III. THREATS TO PUBLIC HEALTH OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES

A. Nature of Actual or Threatened Release of Hazardous Substances, Pollutants or Contaminants.

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Loose uncontained, elemental mercury was identified within a residential home and had the potential to be tracked into the environment. No entity other than EPA had the ability to respond and prevent further release.

Mercury is a listed hazardous substance and has many and varied effects on the human body. According to the Agency for Toxic Substances and Disease Registry (ATSDR), Metallic Mercury — ToxFAQs information sheet (AR #1), the nervous system is sensitive to metallic mercury. Exposure to very high levels of metallic mercury vapor can cause brain, kidney, and lung damage and may seriously halm a developing fetus. Exposure to mercury vapor concentrations high enough to produce such serious effects might also cause coughing, chest pains, nausea, vomiting, diarrhea, increases in blood pressure or heart rate, skin rashes, and eye irritation. Exposure to lower levels of airborne mercury for prolonged periods of time would produce more subtle effects, such as irritability, sleep disturbances, excessive shyness, tremors, coordination problems, changes in vision or hearing, and memory problems.

B. Applicable factors (from 40 C.F.R. § 300.415) which were considered in determining the appropriateness of a removal action:

The conditions at the Site presented a substantial threat to the public health or welfare, and the environment, and met the criteria for an emergency removal action as provided for in the NCP, 40 C.F.R. § 300.415(b)(2). These criteria include, but are not limited to, the following:

1) Actual or potential exposure to nearby human populations, animals or the food chain from hazardous substances or pollutants or contaminants [40 C.F.R. § 300.415(b)(2)(i)] ; and

2) The [lack of] availability of other appropriate federal or state response mechanisms to respond to the release [40 C.F.R. § 300.415(b)(2)(vii)].

IV. ENDANGERMENT DETERMINATION

Given the Site conditions, the nature of the known hazardous substances on-site, and the potential exposure pathways described in Sections II and III above, actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the response actions selected in this action memorandum, may have presented an imminent and substantial endangerment to public health, or welfare, or the environment.

V. SELECTED REMOVAL ACTIONS AND ESTIMATED COSTS

A. Situation and Removal Actions to Date

1. Current Situation

Removal is complete.

2. Removal activities to date

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At the request of MDHHS, EPA responded on January 24, 2017, to conduct a Removal Action.

Between January 25 and February 4, 2017, EPA removed suspected contaminated personal items from the residence (mattress, clothing, etc.) for Lumex screening. In order to remediate the house, EPA and ERRS vacuumed all floors of the residence with a mercury vacuum, utilized heating and venting techniques (using portable propane heaters) to volatize mercury, and removed impacted structure of the residence (cold air return, sub flooring, and drywall). As a final step to complete the home remediation, a primer/sealer paint was painted on exposed surfaces (subfloor, wall studs, etc,). Heating and venting techniques continued for a 24-hour operation.

In addition to the inside of the residence, EPA and ERRS vacuumed mercury beads from the garage floor (where the resident placed removed carpeting) and performed limited soil removal where the resident eventually placed the carpet.

On February 5, 2017, EPA and the START contractor collected air samples for mercury analysis using the NIOSH 6009 method. Air samples were collected from the master bedroom, nursery, and kitchen. Air sample results were received on February 6, 2017, and all results fell below the standard set by MDHHS.

All personal items EPA removed from the residence were screened with a Lumex. Any item that exhibited mercury vapor concentrations greater than 10,000 ng/m3 was documented and placed in the roll-off box for disposal. All items below 10,000 ng/m3 were placed in an ERRS trailer designed to heat and vent small items, and re-screened. EPA returned these items to the homeowner on February 6, 2017.

One 30-yard roll-off box of mercury-contaminated items was removed from the affected area and was treated and disposed of at a facility in compliance with the EPA Off-Site Rule, 40 C.F.R. § 300.440. Final disposal occurred on February 7, 2017.

EPA initiated restoration activities (drywall replacement) on February 7, 2017, and completed them by February 10, 2017. On February 20, 2017, at the request of the homeowner, EPA's START contractor returned to the site to re-screen the home and detected mercury vapor readings at 800 ng/m3 in the living area and 1,200 ng/m3 in the basement. EPA returned to the site on February 25, 2017, to investigate the cause of the increased readings, and determined that dust from the final construction work performed by the homeowner was contaminated.

EPA and their contractors returned to the site on February 28, 2017, to clean the contaminated dust in the living area and the basement. In addition, they sealed the basement ceiling with a primer/sealer paint. Two drums of mercury-contaminated items were removed from the site and were treated and disposed of at a facility in compliance with the EPA Off-Site Rule, 40 C.F.R. § 300.440. Final disposal occurred on March 8, 2017.

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On March 8, 2017, EPA hired an independent contractor to assist with locating the source of mercury vapors. The contractor collected wipe tests off the basement floor and detected readings above 50,000 ng/m3. After the contractor performed a small cleaning test on the basement floor, further wipe tests showed a reduction in mercury vapor down to 1,000 ng/m3. EPA's contractor cleaned the basement floor with a degreaser on March 9, 2017, and returned to the home on March 10, 2017, to conduct mercury screening. It detected mercury vapor readings at 200 ng/m3 in the living space and 400 ng/m3 in the basement.

EPA's START contractor returned to the home on March 13, 2017, and collected air samples for mercury analysis using the NIOSH 6009 method. Mercury vapor readings were approximately 120 ng/m3 throughout the home during the sampling. The Air sample results EPA received on March 14, 2017, fell below the laboratory's detection limit of 210 ng/m3.

The response actions described in this memorandum directly addressed actual or potential releases of hazardous substances on-site, which may have posed an imminent and substantial endangeiment to public health, or welfare, or the environment. Specific removal activities included:

1) Developing and implementing a Site Health and Safety Plan;

2) Conducting mercury monitoring and air sampling;

3) Characterizing, removing, and properly disposing of mercury contaminated items in accordance with EPA's Off-Site Rule (40 C.F.R. § 300.440);

4) Heating and venting the home to reduce mercury vapors as well as sealing exposed subfloor/wall studs with a primer/sealer;

5) Cleaning mercury contaminated dust and the basement floor; and

6) Conducting restoration activities.

EPA conducted the removal action in a manner not inconsistent with the NCP. The OSC initiated planning provisions for post-removal site control consistent with the provisions of section 300.415(1) of the NCP. No post-removal site controls were necessary.

This response action did not impose a burden on the affected property that was disproportionate to the extent to which that property contributed to the conditions being addressed.

3. Enforcement

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For administrative purposes, information concerning the enforcement strategy for this site is contained in the Enforcement Confidential Addendum.

The total EPA costs for this removal action based on full-cost accounting practices that will be eligible for cost recovery are estimated to be $242,940.

Direct Costs = $150,000 ($130,000 contractor cleanup costs + $20,000 for Agency costs)

Indirect Costs = $92,940 ($150,000 x Indirect rate of 61.96%)

Total Estimated EPA Costs = $242,940 ($150,000 + $92,940)

B. Planned Removal Actions

1. Proposed action description

N/A

2. Contribution to remedial perfoimance

No further Action is required for this Site as the removal action completed the cleanup.

3. ARARs

Removal Actions conducted under CERCLA are required to attain applicable or relevant and appropriate requirements (ARARs) to the extent practicable considering the exigencies of the situation. In determining whether compliance with ARARs is practicable, the OSC may consider appropriate factors, including the urgency of the situation and the scope of the removal action to be conducted. EPA complied with all ARARs of Federal and State laws to the extent practicable considering the emergency exigencies of the circumstances.

The OSC consulted (telephonically) with the Livingston County Health Department and the Michigan Department of Health and Human Services for a cleanup goal. Since one of the residents was pregnant, a cleanup goal of 300 ng/m3 was requested. The OSC met the cleanup goal (less than 230 ng/m3 using the NIOSH 6009 analytical method).

4. Project Schedule

These removal activities required approximately 22 working days to complete.

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C. Estimated Costs

REMOVAL ACTION PROJECT CEILING ESTIMATE Extramural Costs: $100,000 Regional Removal Allowance Costs: Cleanup Contractor Costs Other Extramural Costs Not Funded from the Regional $ 30,000 Allowance: START Subtotal $130,000 10% Contingency $ 0

Total Removal Project Ceiling* $130,000

*1 Direct Costs include direct extramural costs and direct intramural costs. Indirect costs are calculated based on an estimated indirect cost rate expressed as a percentage of site-specific direct costs, consistent with the full cost accounting methodology effective October 2, 2000. These estimates do not include pre-judgment interest, do not take into account other enforcement costs, including Department of Justice costs, and may be adjusted during the course of a removal action. The estimates are for illustrative purposes only and their use is not intended to create any rights for responsible parties. Neither the lack of a total cost estimate nor deviation of actual total costs from this estimate will affect the United States' right to cost recovery.

An Independent Government Cost Estimate is included in Attachment 3.

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

Given the conditions at the Site including the nature of the hazardous substances and pollutants or contaminants documented on-site, the potential exposure pathways to nearby populations described in Sections II, III and IV above, and the actual or threatened release of hazardous substances and pollutants or contaminants from the Site, failing to take or delaying action may have presented an imminent and substantial endangerment to public health, welfare or the environment by increasing the potential that hazardous substances would have been released, thereby threatening the adjacent population and the environment.

VII. Outstanding Policy Issues

None.

VIII. Approvals

This decision document represents the selected removal action for the Lowe Road Mercury Site (SSID # C5FA) located in Fowlerville, Livingston County, Michigan 48836, developed in accordance with CERCLA as amended, and not inconsistent with the NCP. This decision is based on the administrative record for the Site (Attachment 2).

Conditions at the Site met the criteria set forth in section 300.415(b)(2) of the NCP for a removal action, and I recommend your approval of the completed removal action documented in this Action Memorandum.

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The total project ceiling, if approved will be $130,000, of which an estimated $100,000 was used for cleanup contractor costs. You may indicate your approval by signing below.

APPROVE: DATE: 9_ 3

Jason H. El-Zein, Chief Emergency Response Branch 1

DISAPPROVE: DATE: Jason H. El-Zein, Chief Emergency Response Branch 1

Enforcement Addendum

Attachments I. EJ Analysis IL Administrative Record Index III. Independent Government Cost Estimate

cc: B. Schlieger, U.S. EPA HQ (email. Brian Schlieger/DC/USEPA/US) L. Nelson, U.S. Department of Interior, w/o Enf. Addendum (email. Lindy Nelson@ios.doi.gov) Heidi Grether, Director, MDEQ, w/o Enf. Addendum (email: GretherH@michigan.gov) Bill Schuette, Michigan Attorney General, w/o Enf. Addendum (email: SchuetteB@Michigan.gov)

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BCC PAGE HAS BEEN REDACTED

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ENFORCEMENT ADDENDUM

HAS BEEN REDACTED – THREE PAGES

ENFORCEMENT CONFIDENTIAL

NOT SUBJECT TO DISCOVERY

FOIA EXEMPT

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ATTACHEMNT I

EJ ANALYSIS

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El Index for MIA. Diesel PM 1B 27 la El index for NATA* Air Toxic s Cancer Risk 19 25 22

El Index for NATA. Respiratory Hazard Index ID 18 15

El Index for Traffic Proximity and Volume 21 18 13

El Index for Lead Paint Indicator 31 34 211

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144.TA. Diesel PM ;perrill 0.58e 0.728 45 0.931 , <50h 0.937 <50th

HATA. Cancer Rld lifetime risk aernalion a 31 34 34 <50th 40 <50th

NATA. Respiratory Hazard Index 1.5 1.3 84 1.7 ‘r 150-80th 1.8 <50th

Traffic Proximity and Volume (ualy =Mc anna'aiAance ta 5150 1511 570 52 370 82 590 58

Lead Paint Indicator l'i F7t-i961:1 Htr-Siril 0.16 11.39 28 039 28 0.3 45

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1.0tc Income population 31% 35% 47 33% 52 35%. 48

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Population with Less Than High school Education 7% • 11%; 39 11% ! 40 14% 4'

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ATTACHMENT II

U.S. ENVIRONMENTAL PROTECTION AGENCY REMOVAL ACTION

ADMINISTRATIVE RECORD FOR THE

LOWE ROAD MERCURY SITE FOWLERVILLE, LIVINGSTON COUNTY, MICHIGAN

ORIGINAL

MARCH 2017

NO. SEMS ID DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES

1 922741 3/1/01 ATSDR Public ToxFAQs Fact Sheet - 2 Metallic Mercury

2 933024 1/23/17 Quiggle, L., MD1E-IS

Mankowski, M., U.S. EPA

Email re: Mercury Spilled in Home - Public Health has

2

Evacuated the Home (Redacted)

3 933025 1/24/17 Wolfe, S., U.S. EPA

Peterson, S., U.S. EPA

Email re: Mercury ER Particulars (Redacted)

2

4 933026 1/31/17 Augustyn, J., U.S. EPA

El-Zein, J., U.S. EPA

Email re: Lowe Road Mercury Site Ceiling

2

Increase

5 933027 2/2/17 Wolfe, S., U.S. EPA

Augustyn, J., U.S. EPA

Email re: Ceiling Increase for START TDD

6 933028 3/1/17 Wolfe, S., U.S. EPA

Augustyn, J., U.S. EPA

Email re: Second Ceiling Increase for START TDD

2

7 Wolfe, S., U.S. Guerriero, M., Action Memorandum re: EPA U.S. EPA Request for an Emergency

Removal Action at the Lowe Road Mercury Site (PENDING)

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ATTACHMENT III

DETAILED CLEANUP CONTRACTOR ESTIMATE

AND

INDEPENDENT GOVERNMENT COST ESTIMATE

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NOT RELEVANT TO SELECTION

OF REMOVAL ACTION