Mercury Lamp Drum-Top Crusher Study


U.S. EPA Headquarters Library
     Mail Code 3404T
1200 Pennsylvania Avenue, NW
   Washington DC 20460
  .-    202-566-0556
     Mercury Lamp


   Drum-Top Crusher


          Study

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            Mercury Lamp Drum-Top Crusher Study
                         TABLE OF CONTENTS

1.   EXECUTIVE SUMMARY	1
    1.1  Study Overview	1
    1.2  Observations	3
2.   SCOPE OF STUDY	5
    2.1  Mercury Fluorescent Lamp Disposal	5
    2.2  Study Overview	5
        2.2.1  Study Location	5
        2.2.2  Containment Structure	6
        2.2.3  General Procedures	8
        2.2.4  Study Components	9
        2.2.5  Equipment	10
    2.3  Testing Locations and Study Chronology	13
3.   DATA COLLECTION METHODOLOGY	15
    3.1  Analytical Air Samples	16
        3.1.1  Performance Validation Study	19
        3.1.2  Extended Field Test #1	21
        3.1.3  Extended Field Test #2	;	22
        3.1.4  Extended Field Test #3	24
    3.2  Jerome Mercury Vapor Analyzer Samples	26
    3.3  Bulk Samples	27
        3.3.1  Unbroken Spent Lamps	27
        3.3.2  Pollution Control Media	28
        3.3.3  Crushed Lamps	28
    3.4  Wipe Samples	29
    3.5  Test Protocol Deviations and Modifications	30
4.   RESULTS AND DATA EVALUATION	4	32
    4.1  Exposure Evaluation Criteria	32
    4.2  Background Air Samples	...33
    4.3  Blank Air Samples	36
    4.4  Performance Validation Study	;	37
        4.4.1  Performance Validation Study - Phase 1	37
        4.4.2  Performance Validation Study - Phase II	40
        4.4.3  Comparison of Performance Validation Study Phases I and II	43
    4.5  Extended Field Test Study	...45
        4.5.1  Extended Field Test #1	45
        4.5.2  Extended Field Test #2	50
        4.5.3  Extended Field Test #3	55
                                   E
        4.5.4  Comparison of Extended Field Tests	59
    4.6  Box Tests	!~	61
        4.6.1  AERC Melbourne Box Test	62
        4.6.2  AERC Ashland Box Test	63
    4.7  Overnight Samples	63
    4.8  U-TubeTest	65

                                   ii

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5.   MASS BALANCE STUDY	.....'.	66
    5.1  Mass Balance Equation	'.	66
    5.2  Estimating Total Mercury Content of Unprocessed Lamps (Hgi)	66
    5.3  Estimating Mercury Mass Captured in the DTC Devices (Hgc)	69
    5.4  Estimated Mercury Released To The Ambient Air (HgR)	72
    5.5  Mass Balance Results	73
    5.6  Mass Balance Discussion	74
         5.6.1  Mercury Mass in Crushed Lamps	74
         5.6.2  Mercury Mass in Air Filtration System Elements	75
         5.6.3 'Mercury Mass Adhering to Surfaces	77
         5.6.4  Mercury Mass in Ambient Air	77
    5.7  Mass Balance Study Observations	.'	77
6.   LIMITATIONS	79
    6.1  Background Levels of Mercury	*.	79
    6.2  Experimental Conditions	80
    6.3  Contamination from Lamps Broken During Shipment	:	80
    6.4  Contamination from Lamps Broken During DTC Device Operation	81
7.   DISCUSSION	82
    7.1  Summary of Results	82
         7.1.1  Exposures during Routine Crushing Operations	83
         7.1'.2  Exposures during Routine Drum and Filter Changes	84
         7.1.3  Exposures'Resulting From DTC Device Malfunction	84
         7.1.4  Changes in DTC Performance over Time	85
         7.1.5  Overnight Tests	;.86
         7.1.6  U-TubeTest	86
         7.1.7  Exposures Resulting from Lamp Breakage	86
    7.2  Safety Concerns when Operating DTC Devices	.87
         7.2.1  Operator Safety	87
    7.3  Potential DTC Design Modifications	89
    7.4  Future Areas for Study	90
    7.5  Conclusions	91

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                             LIST OF FIGURES

Figure 3.1: Sampling Locations for the Performance Validation Study and Extended
    Field Test #3	21
Figure 3,2: Sampling Locations for Extended Field Test #1	22
Figure 3.3: Sampling Locations for Extended Field Test.#2	23
Figure 3.4: Box Test Configuration, AERC Melbourne	24
Figure 3.5: Box Test Configuration, AERC Ashland	25
Figure 4.1: Analytical Air Sampling Results, Performance Validation Study I	.39
Figure 4. 2: Analytical Air Sampling Results, Performance Validation Study II	41
Figure 4.3: Jerome Results - Inside Containment, Performance Validation Study II42
Figure 4.4: Analytical Air Sampling Results, Performance Validation Study - Phases
    I&II....	;..43
Figure 4. 5: Analytic Air Sampling Results, All Devices, Extended Field Test #1	48
Figure 4. 6: Jerome Results - Inside the Containment,  Extended Field Test #1	49
Figure 4. 7: Analytic Air Sampling Results, All Devices, Extended Field Test #2	53
Figure 4.8: Jerome Results - Inside the Containment,  Extended Field Test #2	54
Figure 4.9: Analytical Air Sampling Results, AH Devices, Extended Field Test #3 ..57
Figure 4.10: Jerome Results - Inside the Containment, Extended Field Test #3 .......58
Figure 4.11: Analytical Air Sampling Results, Extended Field Test Study -
    Manufacturer A	60
Figure 4.12: Analytical Air Sampling Results, Extended Field Test Study -
    Manufacturer B	...60
Figure 4.13: Analytical Air Sampling Results, Extended Field Test Study -
    Manufacturer C	61
Figure 4.14: Jerome Results - Inside Containment, AERC Melbourne Box Test	62
Figure 4.15: Overnight Test Sample Results	64
Figure 4.16: U-tube Test Sample Results	65

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                         LIST OF PHOTOGRAPHS
Photograph 2.1:
Photograph 2. 2:
Photograph 2.3:
Photograph 2.4:
Photograph 2.5:
Photograph 2. 6:
Photograph 2.7:
Photograph 2.8:
Photograph 3.1:
Photograph 3.2:
Photograph 3.3:
Photograph 3.4:
Photograph 3.5:
Photograph 3. 6:
Photographs. 7:
    DTC Device
Photograph 3.8:
Photograph 7.1:
AERC Ashland Facility - Containment Structure - First Visit	7
EPSI Phoenix Facility - Containment Structure	7
AERC Melbourne Facility - Containment Structure	7
AERC Ashland Facility - Containment Structure - Second Visit	7
Manufacturer A Device.'..;	;.10
Manufacturer B Device.....	:	10
Manufacturer C Device	11
Manufacturer D Device	1	11
Air Sampling Pumps and Jerome Mercury Vapor Analyzer	15
Sensidyne Air Sampling Pumps	16
Feeding Bulbs into the Manufacturer A Device	18
Feeding Bulbs into the Manufacturer B Device	18
Feeding Bulbs into the Manufacturer G Device	18
Crushing of U-Tubes - Manufacturer C Device	26
Placement of Air Sampling Pump & Jerome Analyzer in Relation to
	:	27
Wipe Sample Media	;	29
Clearing Jammed Feed Tube of Manufacturer A Device	88

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                             LIST OF TABLES

Table 2.1: DTC Device Equipment Operating Manual Comparison	11
Table 2.2: Order of Device Testing for DTC Device Study	:.	14
Table 3.1: Analytical Air Samples Collected during the Performance Validation
    Study	20
Table 3. 2: Air Samples Collected during Extended Field Test #1	21
Table 3. 3: Air Samples Collected during Extended Field Test #2 and #3	23
Table 3.4: Air Samples Collected during U-rube Evaluation	26
Table 4.1: Background Mercury Results - Analytical Air Samples	34
Table 4. 2: Background Mercury Results - Jerome Analyzer Measurements	..34
Table 4.3: Trip Blank Results	'......-	36
Table 4.4: Field Blank Results	.36
Table 4. 5: Total Lamps Processed in Each Device, Performance Validation Study 138
Table 4. 6: Jerome Analyzer Measurements - Inside Containment, Performance
    Validation Study I	39
Table 4. 7: Total Lamps Processed in Each Device, Performance Validation Study II
    	40
Table 4.8: Jerome Analyzer Measurements - Inside Containment, Performance
    Validation Study II	42
Table 4.9: Performance Validation Study Air Sampling Data Comparison a-b	44
Table 4.10: Total Lamps Processed in Each Device, Extended Field Test #1	46
Table 4.11: Jerome Analyzer Measurements, Extended Field Test #1	47
Table 4.12: Total Lamps Processing in Each Device, Extended Field Test #2	50
Table 4.13: Jerome Analyzer Measurements, Extended Field Test #2	51
Table 4.14: Total Lamps Processed in Each Device During Extended Field Test #3 55
Table 4.15: Jerome Analyzer Measurements, Extended Field Test #3	,..56
Table 4.16: Mean Background Mercury Concentrations, Extended Field Test Study
    	59
Table 4.17: Results for AERC Ashland Box Test	63
Table 5.1: Mass of Mercury in Philips Lighting Alto® Fluorescent Lamps	:	67
Table 5. 2: Total Mercury in Spent Philips Lighting Alto® Fluorescent Lamps a	68
Table 5.3: Mass of Mercury Processed for Each DTC (HgT)	69
Table 5.4: Samples Collected for the Mass Balance Study	69
Table 5.5: Mass Balance Study Sample Results	70
Table 5.6: Total Weights, Areas, and Blank Mercury Concentrations of Bulk Sample
    Media	71
Table 5. 7: Estimated Mercury Mass Captured inside DTC Devices (Hgc)	71
Table 5.8: Mercury Released from DTC Devices (Hgi?)	72
Table 5.9: Summary of Mercury Mass Contributions, By Source	73
Table 5.10: Mass Balance Calculation Results	73
Table 5.11: Spike and Blank Analytical Results for Pollution Control Media	76

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                         LIST OF APPENDICES

Appendix A: Air and Wipe Sample Results
Appendix B: Air Sampling Data Forms
Appendix C: Data Chem Laboratories Reports
Appendix D: Drum-Top Crushing Device Sampling and Study Plan
Appendix E: Laboratory Methods and Modifications
Appendix F: Wipe Sample Data and Discussion
Appendix G: Sampling Error and Correction Efforts for Mass Balance Study
Appendix H: Procedure for Collection of Samples from Pollution Control Media
Appendix I:  Letter from EPA Documenting Problems with Manufacturer D Device
Appendix J:  Peer Review of Mercury Lamp Drum-Top Crusher Study: Response to
            Comments

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                         ACKNOWLEDGEMENTS

DTC Study Team
  Paul Abernathy, ALMR
  Catherine Bodurow, National Academy Institute of Medicine
  Noah Borenstein, EPA Region 3
  Alexis Cain, EPA Region 5
  Stephen Coffee, CIH, Booz Allen Hamilton
  Cathy Davis, EPA Office of Solid Waste  ,
  Suzanne Davis, California EPA Department of Toxic Substance Control
  Mark Hanrahan, Bboz Allen Hamilton
  Greg Helms, EPA Office of Solid Waste
  Jordan Murphy, Booz Allen Hamilton
  Wayne Naylor, EPA Region 3
  Tad Radzinski, EPA Region 3
  Betty Ann Quinn, EPA Region 3
  John Wesnousky, California EPA Department of Toxic Substance Control

Lamp Crushing Facilities
  AERC Recycling Solutions
  Earth Protection Services, Inc.

Equipment Manufacturers
  Rick Beierwaltes, Air Cycle Corporation
  Scott Beierwaltes, Air Cycle Corporation
  Edward Domanico, Hazardous Material Specialist
  David Dougall, Dextrite, Inc.
  Albert Greene, Dextrite, Inc.
  Don Seiler, Resource Technology, Inc.
  Mike Seiler, Resource Technology, Inc.

Philips Lighting
  Steve McGuire, Philips Lighting

Peer Reviewers
  Dr. Carl Hebrandson, Minnesota Department of Health
  Dr. Steven Lindberg, Oak Ridge National Laboratory
  Michael McLinden, CIH, New Jersey Department of Environmental Protection

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                              ACRONYMS

ACGIH    American Conference of Governmental Industrial Hygienists
ANOVA    Analysis of Variance
cc/min     Cubic Centimeters per Minute
DTC       Drum Top Crusher
EFT        Extended Field Test
EFTS       Extended Field Test Study
EPA       Environmental Protection Agency
EPSI       Earth Protection Services, Inc.
Hg        Mercury
LOEL      Lowest Observed Effect Level
MCE       Mixed Cellulose Ester
mg        Milligrams
mg/m3     Milligrams per Cubic Meter
min        Minutes
mm        Millimeters
NA        Not Applicable
ND        Not Detected
NIOSH     National Institute for Occupational Safety and Health
OSHA     Occupational Safety and Health Administration
PEL        Permissible Exposure Limit
PPE   •    Personal Protective Equipment
PVS        Performance Validation Study
RCRA     Resource Conservation and Recovery Act
REL        Recommended Exposure Limit
RfC        Reference Concentration
TLV       Threshold Limit Value
TSDF       Treatment, Storage, and Disposal Facility
TWA       Time Weighted Average
ug         Microgram

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1. EXECUTIVE SUMMARY

The increasingly wide-spread use of energy-efficient, fluorescent lamps has had
tremendous environmental benefits. However, mercury, a toxic chemical, is an
essential component of fluorescent lamps: When lamps are broken, whether during
storage, transport, disposal, or crushing, a substantial portion of the mercury
contained in the lamp is released as mercury vapor. If the mercury vapor is not
controlled or contained, it could be readily inhaled by anyone in the area and be
hazardous to the health of those exposed individuals. Additionally, mercury
released from broken lamps is persistent in the environment, where it can be
chemically transformed to methylmercury, which is more toxic than elemental
mercury and which bioaccumulates up the food chain.

When lamps are disposed of in a landfill, rather than recycled, a substantial
percentage of the lamps are broken and virtually all of the mercury contained in the
lamps is released into the environment. In addition, lamps may be broken during
collection, shipping, or handling. Therefore, in order to protect human health and
the environment, the Environmental Protection Agency (EPA) strongly encourages
the safe handling and recycling of fluorescent lamps.

Lamp recycling can be done either by sending whole, boxed lamps to a recycler or
by using a drum top crusher (DTC) device at the point where lamps are removed
from service. DTC devices are designed to fit on the top of a 55 gallon drum in order
to prevent the release of mercury vapors while crushing the fluorescent lamps into
the drum below. These devices are used to reduce the volume of waste lamps so as
to improve storage and handling and reduce shipping costs associated with
fluorescent lamp recycling. Each method of recycling has potential benefits and
draw-backs. This report examines DTC devices only and does not address whole
lamp recycling or disposal of lamps.

As part of ongoing efforts to encourage safe management of mercury-containing
equipment and fluorescent lamps, EPA conducted the Mercury Lamp Drum-Top •
Crusher Study (the Study). The objective of the Study was to evaluate the ability of
four DTC devices to contain the mercury released from crushed lamps in terms of
preventing worker exposure to adverse levels of airborne mercury resulting from the
operation of these devices. The scope of the Study did not include evaluating other
lamp handling methods or comparing other lamp handling methods to the use of
DTC devices. This report presents the findings of the Study; the purpose of this
report is not to endorse or discourage the use of DTC devices.

1.1 Study Overview

The original study design called for testing of four DTC devices from four different
manufacturers: A, B, C, andD.1 However, the Manufacturer D device was removed
from the Study after two rounds of testing because of its inability to maintain
The focus of the Study was on DTC devices in general, it was not the intent of the study team to find the "best"
manufacturer or to recommend a certain device. The manufacturers tltat participated in the Study may choose to
identify themselves; however, for the purposes of this report. Manufacturer A, B, C, and D will not be identified.

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mercury vapor concentrations below the Occupational Safety and Health
Administration (OSHA) permissible exposure limit (PEL) of 0.1 milligrams per cubic
meter (mg/m3) during device operation (refer to Section 3.5.3 and Appendix]).
Therefore, the executive summary focuses primarily on the three other DTC devices
that completed the entire Study. A large amount of data was collected and analyzed
throughout the Study. To fully understand the information gained, this report
should be reviewed in its entirety.

Testing of the DTC devices was performed in a confined space, constructed for the
Study, at three separate commercial lamp recycling facilities (the AERC Recycling
Solutions facility in Ashland, VA, was used twice during the Study). Lamp recycling
facilities were used as the sites for the Study to ensure compliance with all state
requirements, to take advantage of the availability of spent lamps that were sent to
them for recycling, and to facilitate appropriate recycling of the lamps crushed
during the Study. The containment structure was used in order to isolate the Study
from background mercury present in the facilities due to regular lamp recycling
operations (refer to Sections 4.2 and 6.1 for information about background mercury levels)
and also to test a "worst-case" scenario for the type of environment in which a DTC
device may be operated (i.e., a room with low ventilation rates). Operator exposures
would be expected to be lower than found in this Study if a DTC device is operated
in a room with higher ventilation rates than used in this Study:'

Concentrations of mercury in the air were measured using two Jerome Mercury
Vapor Analyzers (Jerome analyzers) and using National Institute for Occupational
Safety and Health (NIOSH) Analytical Method N6009 and Draft Analytical Method
N9103 (refer to Appendix E).  Surface wipe samples (from the inside of the
containment structure), unbroken lamps, and bulk samples of crushed lamps and
pollution control media were also collected and analyzed for mercury using
procedures described in Appendix E. A number of observations about possible
mercury exposure, DTC operation, and operational problems with the devices tested
were made based on data collected over a range of conditions, including:

   -  Operational period - normal crushing
   -  Operational period - drum changes and filter changes
   -  Operational period - improper assembly/leakage of seals
   -  Non-operational period - broken lamps staged for crushing
   -  Non-operational period - overnight (full, or partially-full, 55-gallon drum)

After the Study was completed, each manufacturer was able to review the results
specific to their device. The purpose of this was to make it possible for the
manufacturers to consider the results of the Study and make any modifications to
their devices based on these results.

In September 2004, EPA prepared a draft report for the Study, and RTI International,
under contract to EPA, arranged for an independent review of the draft report, by
recognized technical experts. This review was conducted by letter format in a
manner consistent with EPA's Office of Research and Development and Science
Policy Council Peer Review Handbook (December 2000). Many substantive comments

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were made by the reviewers. As a result of these comments, EPA extensively
revised this report (refer to Appendix Jjbr the peer review comments and EPA's responses
to the comments).

1.2 Observations

All three of the devices that completed the Study usually maintained mercury levels
below the OSHA PEL within the containment structure and in the operator
breathing zone, and one device generally maintained mercury levels below the
American Conference of Governmental Industrial Hygienists (ACGIH) threshold
limit value (TLV) of 0.025 mg/m3 during normal lamp crushing operations.2
However, this Study also demonstrated that during operation of a DTC device,
under the operating conditions that existed during the Study, the operator can be
exposed to levels of mercury above the TLV and the PEL. Specifically:

• Operator exposure only remained below the OSHA PEL and ACGIH TLV values
when the three well-designed DTC devices were operated optimally. That is,
when a sub-standard device was used, and when the well-designed devices were
not performing optimally or were improperly assembled, operator exposures
. increased above these levels. (Note: In most of the cases of potential mercury
exposure experienced in this Study, the operator only realized that the device
being used was not effectively containing mercury because a real-time mercury
vapor monitor, equipped with an alarm, was used. The exception to this was
that when one of the DTC devices was incorrectly assembled and was, therefore,
releasing much more mercury than it would have under normal operating
conditions, the operator noted white powder coming out of the connection
between the feed tube and the main device assembly that was missing a seal.)

« Measurable concentrations of mercury were detected in the air in the lamp
recycling facilities (background air sample results ranged from 0.00052 mg/m3 to
0.044 mg/m3).

• There is an increased risk of mercury exposure when full drums are replaced
with empty ones, an operation inherent in the use of a DTC device. Drum
changes typically resulted in short-term excursions above the PEL. These high
mercury levels decreased after the drum changes were complete. Several short-
duration, high-volume air samples were taken during drum changes to estimate
maximum possible worker exposure. Over 70 percent of these samples were
above the PEL.

• Performance of DTC devices may change over the lifetime of the device and under
varying environmental conditions. Two of the devices showed a significant
Tltroughout tins report the ACGIH TLV is used as a point of reference with which the analytical air samples are compared.
The TLV is an eight-hour, time-weighted average; however, the analytical air samples generally represent one to three
hour sampling periods (refer to Section 3.1 for a description of the analytical air samples and Appendix A, Table 1 far
individual sample durations). Sample results that are greater than the TLV should not necessarily be interpreted to
indicate that use of one of the DTC devices included in the Study would result in operator exposure above tlie TLV
because exposure would need to be averaged over an eight-hour day and a 40-hour week.

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decrease in their ability to contain mercury after being used to crush eight drums
of lamps. (Note that changes in the test environment, such as increased ambient
temperature, may have had some affect on device performance.)

• Minor mistakes in assembly of a DTC device can significantly affect its ability to
capture mercury. A leak on one device notably raised mercury levels for the
samples in the operator's breathing zone and caused mercury concentrations to
exceed the PEL for the area sample collected near the leak. The leak was located
at one of the seals and was due to improper device assembly.

• Overnight tests, which were performed during non-operational periods, were
inconclusive. Further study would be needed to determine whether or not
drums containing crushed lamps with the DTC device attached to the top of the
drum, but not in operation, would release mercury in quantities that pose a risk.

• Finally, in one test, the operation of the Manufacturer D device resulted in
ambient mercury concentrations of 0.89 mg/m3, nine times the OSHA PEL, even
though exclusively low mercury, Alto® lamps, manufactured by Phillips I
Lighting, were used.3 The results from this test illustrate that mercury vapor can
exceed established levels even if the lamps being crushed in the DTC device (i.e.,
low-mercury lamps) are not identified as hazardous wastes.

Use of DTC devices allows several hundred crushed lamps to occupy the space that
40 or 50 whole lamps would occupy, thereby reducing storage and shipping costs.
This leads to a reduction in recycling costs on a per-lamp basis. Crushing lamps
before shipment also has the advantage of allowing the lamps to be shipped to the
recycler in a well-sealed, durable container that is unlikely to release substantial
amounts of mercury. Shipping whole lamps inevitably leads to some breakage and
potential release; with careful handing, the amount of breakage can be reduced.

The DTC devices evaluated as part of this Study all released some mercury when
used. The mercury released during DTC device use will create certain new mercury
exposure situations.' Exposure will be experienced by the DTC device operator and
any assistants handling lamps or working directly with the DTC device. Less direct
mercury exposures that could be created by DTC device use include anyone working
in or visiting buildings in which DTC devices are used. To eliminate these
unnecessary indirect mercury exposures, the ventilation of the lamp crushing room
would need to be separate from the general building ventilation system, as is done at
industrial lamp recycling facilities.

Additional findings regarding the design and operation of DTC devices, and future
areas of study, are discussed in Chapter 7.
3 The Alto® lamps typically contain three to jive mg of mercury per lamp and are advertised as "TC compliant" by the
manufacturer, meaning that the lamps would generally not be classified as hazardous waste when discarded.

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2. SCOPE OF STUDY .

2.1 Mercury Fluorescent Lamp Disposal

On May 11,1995, EPA adopted new streamlined hazardous waste management
regulations under the Resource Conservation and Recovery Act (RCRA) governing
the collection and management of certain widely generated hazardous wastes
termed "universal wastes" (60 FR 25491). The new hazardous waste management
regulations were designed to facilitate the environmentally-sound collection and
proper management of certain hazardous waste batteries, pesticides, and mercury-
containing thermostats. Hazardous waste lamps were added to the federal list of
universal wastes on January 6, 2000 (64 FR 36465). On August 5,2005, the category
of mercury-containing thermometers was removed from the federal list, and a
broader category, mercury-containing devices, was added to the federal list of
universal waste (70 FR 45508).4 The universal waste regulations are set forth in 40
CFR Part 273.

By introducing flexibility into the storage, transport, and collection of universal
hazardous wastes, the universal waste rule seeks to encourage the development of
programs to reduce the quantity of hazardous wastes going to municipal solid waste
landfills or combustors and to assure that wastes subject to the universal waste
system go to appropriate hazardous waste recycling facilities or treatment, storage
and disposal facilities (TSDF). Handlers of universal wastes are subject to more
flexible standards for storing, transporting, and collecting these wastes than under
full Subtitle C regulation. Hazardous waste lamps are regulated as a universal waste
in order to encourage lamp recycling, facilitate better lamp management, and
improve compliance with the hazardous waste regulations.

2.2 Study Overview .

The Study was performed at three different existing, large-scale lamp recycling
facilities. Four DTC devices were originally included in the Study, but only three of
the devices completed the Study (refer to Section 3.5.3). Analytical air samples were
collected to quantify mercury concentrations inside the containment structure and
operator exposure to mercury, and a Jerome Mercury Vapor Analyzer was
employed to provide real-time measurements of ambient mercury vapor
concentrations. Additional samples were collected for the Mass Balance Study.

2.2.1 Study Location

The Study was conducted at mercury lamp recycling facilities for a number of
reasons. One critical reason was that these facilities are permitted for hazardous
waste lamp processing. Because some states require permits for the use of a DTC
device, reliance on the facilities' existing permits allowed the Study to be conducted
more quickly and inexpensively and was a key factor in the decision to fund and
4 Mercury-containing thermometers are a type of mercury-containing devices, and thus, are still included in the federal list
of universal waste under the broader category.

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conduct the Study. The lamp recycling facilities also provided sufficient numbers of
fluorescent lamps to complete each phase of the Study, as well as valuable assistance
by receiving and storing the DTC devices, providing sufficient space to conduct the
Study, and recycling the crushed lamps generated in the course of the Study.

The disadvantage of conducting the Study at lamp recycling facilities was that each
facility had existing background concentrations of mercury, that could potentially
confound study-results. The detected background concentrations are presented in
Section 4.2, and apparent effects on study results are further discussed in Section 6.1.

In each facility, the office space was segregated from the work area for the industrial
lamp crushing activities. However, the facility layout was different at each study
location, which affected facility background mercury levels. AERC Ashland had two
large bays, one of which housed an industrial lamp crusher while the other bay was
used for the Study. A large doorway separating the two bays was kept closed for
most of the study duration. This allowed the DTC crushing activities to be isolated
from direct mercury emission sources, but fugitive emissions from the industrial
recycling operations were present in the bay used for the Study. AERC Melbourne
provided an isolated bay for the Study, and the door between this bay and the main
bay where AERC operations took place was closed for the duration of the Study. At
EPSI Phoenix, the Study was conducted in the same bay as the facility's industrial-
size lamp crusher, resulting in somewhat higher mercury background
concentrations, as compared to the other test sites (refer to Sections 4.2 and 6.1).

2.2.2 Containment Structure

During the Study, the DTC devices were operated inside a fabricated containment
structure. This structure provided a "worst case" environment in which to evaluate
the performance of each device by minimizing ventilation and containing mercury
emissions in an enclosed space.5 The structure was also intended to isolate the DTC
operations from the background mercury present in the lamp recycling facilities,
although it did so only to a limited extent. The containment structure consisted of a
frame constructed from 3/4 inch PVC tubing and covered with a single layer of four-
millimeter (mm) thick polyethylene sheeting on the walls, floor, and ceiling (refer to
Photograph!. 1, Photograph 2. 2, Photograph 2. 3, and Photograph 2. 4).6
5 Operator exposures would be expected to be lower than/bund in tttis Study if a DTC device is operated in a room with
higher ventilation rates than used in tins Study.
6 Mercury has been shown to sorb onto and permeate through polyethylene. Another material, such as vinyl, may have been
more appropriate for this Study. During the first set of tests in Ashland, VA, the measurements of the containment
structure were 12 feet (ft.) by 12ft. by Wft. high to ensure that there was adequate space to operate each device
properly. The containment structure ceiling height was lowered to 8ft. in Phoenix, AZ, to expedite test set-up. • -
However, three of the devices had feed chutes angled upward, and, as lamps were being fid into the device, they scraped
against the ceiling of the containment area. Therefore, containment structures measuring 10ft. in height were utilized
in Melbourne, FL, and the second set of tests in Ashland, VA.

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         Photograph 2.1: AERC Ashland Facility - Containment Structure - First Visit
               Photograph 2.2: EPSI Phoenix Facility - Containment Structure
 Photograph 2.3: AERC Melbourne Facility -
         Containment Structure
Photograph 2. 4: AERC Ashland Facility •
  Containment Structure - Second Visit
The polyethylene walls, floor, and ceiling were changed before testing each device at
each location. The containment structure used a "flap" door to allow entry and exit
by the operators. This door, which overlapped the walls, limited the amount of air
exchanged between inside and outside the containment structure; however, it was
not possible to entirely eliminate air exchanges.

In the initial parts of the Study, the polyethylene was measured and cut inside the
facility, next to the containment frame. This was done during Phase I of the
Performance Validation Study in Ashland, Virginia and in the first Extended Field

-------
Test in Phoenix, Arizona. However, results from the pre-test wipes of surfaces
within the containment structure (taken prior to crushing any bulbs in the DTC
device) indicated that mercury was detected on the polyethylene sheeting (refer to
Appendix A, Table 2). The field team determined that the mercury contamination on
the sheeting was most likely attributable to measuring and cutting the polyethylene
on the contaminated floor inside the recycling facility, as well as deposition of
background airborne mercury from ongoing facility operations. To reduce the
potential for contaminating the polyethylene sheeting during construction of the
containment structure, staging areas for measuring and cutting the polyethylene
sheets were established in the parking lot outside the facility for the second
Extended Field Test in Melbourne, Florida and used for all of the remaining tests.

2.2.3 General Procedures

At each stage of the Study, the DTC devices were generally operated in conformance
with the manufacturer's operating manual. The only deviation from the operating
manual was mat more lamps than recommended by one manufacturer
(Manufacturer C) were crushed during each round of the Extended Field Test
Study.7 DTC device operations included device assembly and placement on the
drum, routine lamp crushing operations, and drum and filter changes. When the
DTC device manufacturer representatives were available and on-site, they were
allowed to provide further operational instructions specific to their device. In the
first phase of the Performance Validation Study, representatives of the four
manufacturers were required to be present during the operation of their device. For
the remainder of the Study, DTC device representatives were invited to observe, but
their presence was not required to include their device in the Study.

Each DTC device was operated according to the following procedure:

1. Construct the containment structure (described in Section 2.2.2);

2. Calibrate the Jerome analyzer and take background readings;

3. Equip the operator with required personal protection equipment (PPE), Tyvek®
coveralls, respirator, Kevlar® gloves, etc., and personal air samplers;
, i
4. Assemble the DTC device on top of the collection drum inside the containment
structure; .

5. Ensure that the device is properly assembled and the filter is in place;

6. Collect pre-test wipe samples.

7. Bring spent lamps into the containment structure;
The operator's manual for the Manufacture C device specifies that the dance should only be used to crush one drum of
lamps per eight-hour period in order meet with OSHA safety standards.

-------
8. Power up the device (runs off of 110-volt, single-phase service) and ensure
negative pressure inside the device has been activated;

9. Begin feeding lamps (feed rate during the test was between 30 and 40 bulbs per
minute using a two-person crew; for a one-person crew, the rate is expected to be
closer to 20 to 25 bulbs per minute).

10. After filling the prescribed number of drums, collect post-test wipe samples from
the device and from the walls, ceiling, and floor of the containment structure.

The specific methodologies employed during each of the three studies are discussed
in detail in Chapter 3 of this report.

2.2.4 Study Components

The DTC Device Study was divided into three distinct studies.* The basic elements
of each study are described below.

• Performance Validation (FVS) - sought to (1) quantify ambient mercury vapor
concentrations inside the containment structure and personnel exposure during .
the operation of several DTC devices, and (2) establish initial baseline air
concentrations of mercury (Phase I) for comparison to air concentration
measurements after DTC devices have processed enough fluorescent lamps to fill
approximately eight 55-gallon drums (Phase II).

• Mass Balance Study - sought to estimate the overall capture efficiency of each
device by quantifying (1) the total mass of mercury contained in the lamps fed
into the DTC device, and (2) the masses of mercury retained in the drum,
captured by the DTC device's pollution control equipment, and released into the
ambient environment as mercury vapors, aerosols, and particulates containing
mercury. Samples for the Mass Balance Study were collected during Phase I of
thePVS.

• Extended Field Test Study (EFTS) - sought to quantify and compare ambient
mercury concentrations and worker exposure during the operation of the
different DTC devices at several different locations, which represented a range of
potential operating conditions. The;EFTS was designed to evaluate the mercury
vapor capture efficiency of each DTC device in a simulated occupational
environment, with a focus on assessing the potential for human (operator)
• exposure to mercury as a result of DTC use. The following tests were performed
as additional components to the EFTS.

- Overnight Test - was conducted during EFT #1, EFT #2, and EFT #3 and
sought to quantify the amount of mercury that may escape the DTC device
and full drum assembly when the device is not in operation.
8 Because of the exploratory nature of the Study and the desire to maximize data collection while in tlte field, certain ad hoc
..changes to the original sampling plan were introduced not always with the ability to pre-define data quality objectives
such as sample sizes or acceptable error ranges.

-------
   -  "U" Shaped Lamp Test - was conducted during EFT #3 and sought to
      evaluate airborne mercury levels from two DTC devices, while processing
      "U" shaped lamps (U-tubes).

   -  Box Test - was conducted during EFT #2 and EFT #3 and sought to determine
      the degree to which shipping boxes containing broken lamps located inside
      the containment structure contributed to elevated mercury concentrations
      detected during early phases of the DTC Study.

2.2.5  Equipment

The DTC Device Study evaluated crushers from four different manufacturers:

•  Manufacturer A (Photograph 2.5)
•  Manufacturer B (Photograph 2.6)
•  Manufacturer C (Photograph 2. 7)
•  Manufacturer D (Photograph 2. 8)

All manufacturers except Manufacturer A provided new, unused DTC devices for
the Study. Manufacturer A provided a prototype machine that was used prior to the
Study, but was cleaned and decontaminated by the manufacturer before it was sent
for testing in the Study. For reasons that are discussed in Section 3.5.1 of this report,
the Manufacturer D device was tested only during Phase I of the PVS and the first
round of the EFTS.
  Photograph Z 5: Manufacturer A Device
Photograph 2.6: Manufacturer B Device

-------
  Photograph 2.7: Manufacturer C Device
Photograph 2.8: Manufacturer D Device
Table 2.1 summarizes the manufacturer information contained in the operating
manual that was provided with each machine.
            Table 2.1: DTC Device Equipment Operating Manual Comparison
• • .,v- ''< :."'•••',
, Manufacturer A
• Manufacturer B
,•' Manufacturer C
: ' Manufacturer D
Filter Maintenance Change Frequency
Participate Filler
HEPA Filter
Carbon Filter (quantity)
Filter Change
Frequency
Operating Manual has
Filter Change
Instructions or
Procedure For:
Operating Manual has a
Log Form to Document
Filter Maintenance
Change every 100,000
Lamps
NA
851bs
Change After 750,000
Lamps
Paniculate and Carbon
Filter
No
Change Every 2,400
Lamps
NA
Not Specified
(Approx. 13 oz)
Change Every 2,400
Lamps.
Lamp Counter Shuts
Down Motor at Lamp
Count of 2,400
Filter Cartridge
(Contains Particulate
and Carbon)
No
Change Every Full
Drum
Change Every 10
Drums
221bs
No Change Frequency
Specified
Particulate and HEPA
Filter
Yes
Change Every 300
Lamps
Change Every 10
Particulate Filters or
3,000 Bulbs
Not Specified (Approx.
51bs)
Change Annually or
Every 10,000 Lamps
Particulate, HEPA and
Carbon
No
Health and Safety
Operating Manual
Specifies Operational
Time Limits
Operating Manual
Requires/Recommends
Respirator
Operating Manual
Requires/ Recommends
Safety Glasses
No
Required If indicated
by Direct Reading
Mercury Vapor
Instrument Results
Required
No
No
Required
Do not crush more
than one drum per
Eight-Hour Shift
No
Required
No
Required (Half Face
Respirator)
Required

-------
.. -•*>• ; •
Required
No
No
No
Operation
Operating Manual has
Equipment Operating
Instructions or
Procedure
Operating Manual has
Shutdown Instructions
or Procedure
Operating Manual
Shutdown Instructions
or Procedure Requires
use of Vacuum System
During Equipment
Shutdown
Operating Manual has
Drum Change
Instructions or
Procedure
Yes
Yes
Automatic Operation
of Vacuum System
Continuously while
Device is attached to
Drum of Crushed
Lamps
Yes
Yes
Yes
Manually Allow
Disposer to Run for 2
to 3 Minutes When
Finished Using
Machine
Yes
Yes
Yes
Automatic Purge for
10 Seconds after
Shutdown
No
Yes
Yes
NA
Yes
Features and Controls
Device Has a Drum Full
Indicator
Device has Automatic
Lamp Counter
Device has Lid Open
Indicator/ Interlock
Device has
Programmable Logic
Controller (PLC)
Device has Emergency
Stop Switch
Listed Lamp Capacity
Yes
No
Yes
Indicator with
Interlock to Prevent
Motor Start
Yes
Yes - Crushing head
will not engage unless
negative pressure
system is operating
400- 500 Lamps (T8 or
T12type)
No
Yes - Shuts Down
Motor and provides
Audible and Visual
Alarm at 800 Count
No
No
No
800 Four-Foot Lamps
Yes
No
Yes
Indicator with
Interlock to Prevent
Motor Start
No
Yes
NA
No
No
No
No
No
1200 Four-Foot Lamps
Mercury Hazard Information
Operating Manual
Contains Mercury
Hazard Information
and Reference To
OSHA Mercury
Exposure Limits
Mercury Hazard
NA
Mercury Hazard
Mercury Hazard
OSHA
Regulatory Information

-------
$ ••"/'".-•"' 'fj' ~~~''t>" :
Operating Manual
Provides Information
on Universal Waste
Operating Manual
Provides Information
on Lamp Recycling
Operating Manual
Identifies Spent
Pollution Control
Media as Hazardous
Waste
Operating Manual
Provides Disposal
Instructions for Spent
Pollution Control
Media
t Manufacturer A
Yes
Yes (Minimal)
Specified for Filter
and Carbon
General Instruction
^Manufacturer B . ,'• *•
No
No
Not Specified
General Instruction
,. " Manufacturer C "
Yes
Yes (Comprehensive)
Specified for Spent
Particulate and HEPA
Filters Only
Place in Drum for
Disposal with Crushed
Lamps
Manufacturer p . '
Yes
Yes .
Specified for
Particulate, HEPA,
and Carbon Filter
Not Specified
Air Emissions
Operating Manual
Contains a Statement
about the Device's
Ability to Control
Mercury Emissions
Yes
"...is equipped with
state of the art
components to capture
mercury vapors
generated by crushing
lamps to ensure a safe
environment
surrounding your
drum top crusher."
No
Yes
"...will remove
virtually all airborne
powder and mercury
vapor (well over
99%)."
Yes
"Crushes any length of
fluorescent lamp in
seconds into fragments
white recovering 100%
of the hazardous
mercury vapors."
 2.3   Testing Locations and Study Chronology

The Study was conducted at three locations over approximately five months. Table
2.2 provides the order in which the devices were tested at each location. The
following is a chronology of the DTC Device Study:

«    Performance Validation Study, Phase I, AERC Recycling Solutions facility in
     Ashland, Virginia (AERC Ashland), from February 24,2003 through February
     28,2003.

•    Mass Balance Study, AERC Recycling Solutions facility in Ashland, Virginia
     (AERC Ashland), from February 24,2003 through February 28,2003.   •

•    Extended Field Test Study, Test #1, Earth Protection Services, Inc. (EPSI)
     facility in Phoenix, Arizona (EPSI Phoenix), from March 24,2003 through
     March 28,2003.  •

•    Extended Field Test Study, Test #2, AERC Recycling Solutions facility in
   •  Melbourne, Florida (AERC Melbourne), from April 28,2003 through May 2,
     2003.
     Extended Field Test Study, Test #3, AERC Recycling Solutions facility in
     Ashland, Virginia, from June 9,2003 through June 13,2003.

-------
Performance Validation Study, Phase II, AERC Recycling Solutions facility in
Ashland, Virginia, from June 9, 2003 through June 13,2003.

            Table 2.2: Order of Device Testing for DTC Device Study
:4;/:!:U,::.s^y<-l/;4O
Performance Validation I
Extended Field Test #1
Extended Field Test #2
Extended Field Test #3 &
Performance Validation 11
;•:-." Date;'';"";
2/26/2003
2/27/2003
2/27/2003
2/28/2003
3/24/2003
3/25/2003
3/26/2003
3/27/2003
4/29/2003
4/30/2003
5/1/2003
5/2/2003
6/10/2003
6/11/2003
6/12/2003
! , Device • ,
C
A
D
B
A
B
D
C
B"
C
A
• B»
A
• B
C
          a The device from Manufacturer B was tested twice during EFT #2. Refer to Section 3.5.1.

-------
3.    DATA COLLECTION METHODOLOGY

This chapter describes the procedures used to collect the various study samples,
including descriptions of sampling and analysis methods and sample locations.
Airborne mercury was tested using two methods:

•    Analytical Air Samples - known quantities of air drawn through collection
     media designed to capture airborne mercury particulates and mercury vapor
     over extended periods of time and

•    Jerome Analyzer Measurements - direct reading air samples of ambient
     mercury concentrations using the Jerome Mercury Vapor Analyzer.

Air samples were collected in the operator's breathing zone during normal
operation, filter changes and drum changes, and in selected locations within the
containment structure. Jerome measurements were taken both inside and outside
the containment structure. Photograph 3.1 shows the air sampling pump and
Jerome analyzer inside the containment structure.
         Photograph 3.1: Air Sampling Pumps and Jerome Mercury Vapor Analyzer.

Several additional types of samples were collected for the Mass Balance Study.

•   Wipe samples - Wipes of surfaces inside the containment structure were taken
    to characterize the amount of mercury deposited due to DTC device operation.

•   Crushed lamps - Samples were taken out of a full drum after crushing
    operations (approximately eight inches deep into the drum).

•   Pollution control media - Bulk samples were taken of the pollution control
    media (HEPA filter, pre-filter, and carbon filter) of each DTC device.

•   Whole lamps - Samples of the spent unbroken, Phillips Alto® lamps were
    taken.

The sample collection methodology, sample analysis, and sampling locations are
discussed below.  Section 3.1 describes the analytical air samples collected for the
Performance Validation Study (PVS), including air samples used in the Mass Balance
Study, and the Extended Field Test Study (EFTS). Section 3.2 describes the Jerome

-------
analyzer samples for the PVS and the EFTS. Section 3.3 details the methodology
used for collecting the bulk samples used in the Mass Balance Study. Section 3.4
addresses the methodology for measuring surface contamination using wipe
samples. Finally, Section 3.5 describes modifications and deviations to the test
protocol based on operational difficulties encountered during testing.

3.1 Analytical Air Samples

Personal and area air samples were collected at numerous locations at each facility to
support different aspects of the Study. The personal air samples were collected from
the operator's breathing zone during operation and during drum changes, and the
area samples were collected near the feed tube and the exhaust. Background
samples and overnight samples were also collected.
"• • • &
Air samples were collected and analyzed, to measure airborne mercury
concentrations in the aerosol and vapor phases, in accordance with the National
Institute for OccupationalSafety and Health (NIOSH) draft Analytical Method
N91039 and NIOSH Analytical Method N6009,10 respectively The air samples were
collected by drawing a known volume of air through two different media specific to
the collection of mercury in each phase. A 37mm mixed cellulose ester (MCE) filter
was first in line to capture mercury aerosols, and a Hydrar solid sorbent tube was
second in line, attached to the MCE filter, to capture mercury vapors. The reporting
limit for both the MCE filter and the Hydrar tube is 0.01 ug /sample. This reporting
limit is based on the lowest calibration standard analyzed at the laboratory.

Air samples were collected by drawing known volumes of air through the sampling
media using Sensidyne GilAir SRC air sampling pumps equipped with multi-flow
adapters (refer to Photograph 3. 2). •
Photograph 3.2: Sensidyne Air Sampling Pumps,

The Sensidyne pumps were calibrated on site both before and after use, according to
the manufacturers' specifications, using the BIOS DC-Lite calibrator as a primary
standard. The calibratiori'data are contained in Appendix B. During calibration, the
9 At tiie time of this Study, Method N9103 (refer to Appendix E).was in draft form. It is undergoing approval by NIOSH.
10 NIOSH Manual of Analytical Methods, 4<* ed., Method N6Q09, Issue 2,1994. A copy can be found in Appendix E

-------
airflow was adjusted in order to establish a known flow rate. The flow rates of the
pumps varied depending on sample type. Ranges of pump flow rates are listed
below in cubic centimeters per minute (cc/min).

• Background Samples: 136 - 221 cc/min . » -
• On Operator, During Drum Filling: 135 - 212 cc/min
• On Operator, Filter Changes and Drum Changes:11 154 - 261 cc/min
• On Operator, Ceiling Samples: 247 - 260 cc/min
• ' At Exhaust of the Device: 121 - 253 cc/min
•" At Feed Tube of the Device: 125 - 210 cc/min
• Overnight Samples: 100 -163 cc/min

At each facility, three sets of laboratory blanks were prepared at the beginning of
each study. Three MCE filters and three Hydrar-sorbent tubes were labeled and
placed in storage in the calibration room. Two sets of field blanks were prepared for
each day of sampling at each location. Two MCE filters were labeled, the caps were •
opened and replaced, and the filters were placed into storage in the calibration room.
Two Hydrar-sorbent tubes were labeled, the ends of the tubes were broken and
capped, and the tubes were placed into storage in the calibration room.

Upon arrival at each study location, two background area samples were collected
just outside the containment structure. These samples were collected for a period of
time ranging from 3.5 hours to 5 hours before any of the DTC devices were operated.
The purpose of these samples was to provide a measure of background conditions
inside the lamp recycling facility.

Personal and area air samples were collected within the containment structure for
the entire time it took the operator to fill one to two 55-gallon drums with crushed
lamps for each DTC device (approximately 60 to 110 minutes). Personal air samples
were collected by placing the air pumps on the operator's belt and securing the
collection media on the operator's shoulder in order to collect air from within
his/her breathing zone (refer to Photograph 3. 3, Photograph 3. 4, and Photograph 3. 5).
The personal air samples were collected in order to measure the operator's exposure
to airborne mercury during different operational activities.

Groups of personal air samples were also collected separately during the filter
change and drum change processes for each device, as appropriate. Once the filter
change or drum change, which took between two and 10 minutes, had been
completed, the operator remained inside the containment structure to allow at least
12 full minutes for sample collection to ensure that the amount'of mercury captured
in the sample tube was greater than the detection limit (0.01 ug/sample).
11 When a sample is referred to as a "Filter Change Sample," it is a personal air sample taken when the DTC device filter
was changed at a time other than during a drum cliange. This sample is specific to the Manufacturer C and
Manufacturer D devices. The Manufacturer A device did not require a filter change during the Study. For the
Manufacturer B device, the filter was changed at the same time that the drum was changed, so a separate "Filter Change
Sample" was not needed. Personal air samples that were taken when the drum was changed are referred to in this report
as "Drum Change Samples."

-------
             Photograph 3.3: Feeding Bulbs into the Manufacturer A Device
              Photograph 3.4: Feeding Bulbs into the Manufacturer B Device
              Photograph 3.5: Feeding Bulbs into the Manufacturer C Device

During portions of the Study, short-term "ceiling" air samples were taken. The
ceiling samples were another set of personal air samples, which were collected to
attempt to quantify airborne mercury concentrations at the estimated time of

-------
maximum exposure. Readings taken on the Jerome analyzer indicated that
maximum exposure conditions most probably occurred during drum changes.
Thus, the ceiling samples were collected during one of the drum changes for each
device during PVS-Phase II, EFT #2, and EFT'#3. Two samples were collected on the
operator's shoulder, in sequence; each ceiling sample was collected for four minutes.

Area samples were collected by placing the air pumps and collection media on
elevated surfaces in specified areas (refer to Photograph 3.1 and Photograph 3. 7) to
measure the general airborne mercury concentration inside the containment
structure.  During operation of each device, four area samples were collected in each
phase of the PVS, and two area samples were collected in all three parts of the EFTS.

hi addition to the area samples collected during the operation of each device,
overnight samples were collected as part of the EFTS. The purpose of the overnight
samples was to measure the release of mercury when the DTC devices were not
operating, thus simulating a realistic field scenario. At the end of each day of the
EFTS, each DTC device remained inside the containment structure, attached to a
drum containing crushed lamps, once crushing activities for the second drum were
completed. Two to three area air samples were then collected for six to 18 hours. At
EPSI Phoenix, the overnight samples were collected inside the containment
structure, near the device exhaust and device feed tube.  During EFT #2 and EFT #3,
overnight samples were collected outside of the containment structure in addition to
the samples collected at the device exhaust and device feed tube inside the
containment structure.

At the end of each day of sampling, the sampling pumps were removed from the
containment structure and taken to the calibration room to be post calibrated. The
sampling trains were taken apart, and the mixed cellulose filters and Hydrar tubes
were immediately capped on both ends. All information regarding sample duration
and air pump calibrations were recorded on air sampling data forms at that time
(refer to Appendix B). The capped samples were then placed in labeled re-sealable
plastic bags and kept at the facility.

At the completion of the sampling event at each study location, all analytical air
samples were collected, packaged, and shipped via Federal Express to Data Chem
Laboratories, Inc. (Data Chem), along with the completed chain-of-custody forms.
Data Chem is an American Industrial Hygiene Association accredited laboratory
located in Salt Lake City, Utah. Air sampling media were supplied by Data Chem.

The following sections provide details on the sampling protocol used for each stage
of the DTC Device Study.

3.1.1  Performance Validation Study

Phase I of the PVS was conducted February 24-28,2003,  at the AERC facility in
Ashland, Virginia (AERC Ashland), and it included the DTC devices from all four
manufacturers. AERC Ashland  was also the site location for Phase II of the PVS. :
This phase was conducted June 9-13,2003 and included  3 DTC devices

-------
(Manufacturer A, Manufacturer B, and Manufacturer C). (Refer to Section 3.5.3 for a
discussion of the exclusion of the Manufacturer D device.)
V
The PVS was conducted to examine the effectiveness of each device in capturing and
retaining mercury vapors and any potential change in effectiveness over time. The
Study compared the results among the different devices when new, and after a pre-
determined period of operation during which numerous lamps were processed
through each device. The analytical air samples collected for PVS-Phase I were also
used in the Mass Balance Study to calculate the release of mercury from the devices.

Table 3.1 lists the air samples collected for the PVS, and the sampling locations are
shown in Figure 3.1.
Table 3.1: Analytical Air Samples Collected during the Performance Validation Study
."- :: . ; ~ff "° ^ '"•
~",, •,•"*" ' "*.-
Personal
Samples
Area
Samples
•r'^^r^^s^^v^-'fS*:
-• ;;-- ,. v h'f '-•„•:";*•''- if '•^^"^',^-^:,.'-i-~s,'.^-:- •>,*! , •.• i
1 on each shoulder - filling the drum
1 on left shoulder - during drum/ filter change
Near device exhaust
Near device feed tube
r^#.'ofr"'''':
Samples : :
2
l-2«'b
2
2
, \ Approximate,,, :
Duration, (min)
50-115
6-18
50-115
50-115
• Manufacturer A: 1 Drum Change Sample
Manufacturer B: 1 Drum Change Sample
Manufacturer C: 1 Filter Change Sample, 1 Drum Change Sample
Manufacturer D: 1 Filter Change Sample, 1 Drum Change Sample (only Phase I).
b The filter change samples for the Manufacturer C device were taken when the drum was half full (-350 bulbs).

Manufacturer C and Manufacturer D devices required one filter change per drum in
addition to the filter changes performed during drum changes. The personal sample
on the shoulder of the operator during the filter change for the Manufacturer C
device was performed when the drum was half full of fluorescent light bulbs,
equivalent to approximately 350 crushed bulbs. This was true for all filter change
samples collected for the Manufacturer C device throughout the DTC Device Study.

Due to exposure levels significantly above the OSHA PEL, only 276 bulbs were
crushed in the Manufacturer D unit during Phase I of the PVS. The Manufacturer D
device was removed from the study after EFT #1 (refer to Section 3.5.3), so the
samples listed for this device in Table 3.1 were only collected during PVS - Phase I.

-------
Figure 3.1: Sampling Locations for the Performance Validation Study and Extended Field Test #3
          /, \ Air Sample Locations
           1-Area ail sample at feed tube .
           2 - Area air sample at DTC exhaust
           3 - Jerome inside containment
           4 - Jerome outside containment
          JOWipe Sample Locations

           1 - Floor - 2 ft. from device
           2 - Floor - 5 ft from device
           3-Ceiling
           4 - East wall - 4 ft above ground
           5 - West wall - 4 ft above ground
           6 - Side of drum
           7 - Top of DTC device
           8 - Feed tube near operator
           9 - Floor at DTC device exhaust
       AERC Facility
      Ashland, Virginia
North
   I     Entrance     I
	Containment Structure
                          * Not to scale
3.1.2   Extended Field Test #1
                                              t           ^                 *
The EFTS was conducted to examine the ongoing performance of each device during
extended use and over a range of environmental conditions.  EFT #1 was conducted
at the EPSIfacility in Phoenix/Arizona (EPSI Phoenix), March 24-28,2003, and it
included four DTC devices (Manufacturer A, Manufacturer B, Manufacturer C, and
Manufacturer D). Air samples collected during EFT #1 are described in Table 3.2,
and Figure 3.2 shows the sample collection areas.                    .  •  •  .
               Table 3.2: Air Samples Collected during Extended Field Test #1
- >:'; -»';^" „•'.'
Personal
Samples
Area
Samples
Overnight
Samples
.--:• ; Type pf Sample >••.. •'"' ' ,
1 on each shoulder - filling the drum
1 on left shoulder - during drum/ filter change
Near device exhaust
Near device feed tube
Near device exhaust
Near device feed tube
Y #?f
Samples
2
l-3»-b
1
.1
1
1
Approximate
: Duration (min)
125 - 200 ,
12-36
125-200
125 - 200
440-780
420 - 780
» Manufacturer A: 1 Drum Change Sample
 Manufacturer B: 2 Drum Change Samples
 Manufacturer C: 2 Filter Change Samples, 1 Drum Change Sample
 Manufacturer D: NONE
b The filter change samples for the Manufacturer C device were taken when the drum was half full (~350 bulbs).

The Manufacturer D device was removed from the Study during Extended Field
Test (EFT) #1 because Jerome measurements of mercury vapor concentrations in the

-------
containment structure reached 0.59 mg/m3, nearly six times the OSHA PEL. Further
information can be found in Section 3.5.3.
                Figure 3.2: Sampling Locations for Extended Field Test #1
     / \AirSampleLocations
       1 - Area air sample at feed tube
       2 - Area air sample at DTC exhaust
       3 - Jerome inside containment
       4 - Jerome outside containment
       M Wipe Sample Locations

       1 - Floor - 2 ft. from device
       2 - Floor - 5 ft from device
       3-Ceiling
       4 - East wall - 4 ft above ground
       S - West wall  - 4 ft above ground
       6-Side of drum
       7 - Top of DTC device
       8 - Feed tube near operator
       9 - Floor at DTC device exhaust
            EPSI Faculty
          Phoenix, Arizona
                              North
                                                                 Entrance
	Containment Structure
                        1 Not to scale
3.1.3  Extended Field Test #2
Air samples were collected during EFT #2 at the AERC facility in Melbourne, Florida
(AERC Melbourne), April 28 - May 3, 2003, for three DTC devices (Manufacturer A,
Manufacturer B, and Manufacturer C). Short-term ceiling air samples were
introduced into the Study during this round of testing. As described above, ceiling
samples were air samples collected over a short duration in time in an attempt to
quantify airborne concentrations at the estimated time of maximum exposure.
Readings taken on the Jerome analyzer indicated that maximum exposure conditions
most probably occurred during drum changes. Drum change sample results from
EFT #1 showed that the ambient concentration of mercury is sufficiently high during
drum changes such that the samples did not need to be collected for 12 minutes in
order to exceed detection limits.  Thus, two short-term, personal air samples were
collected in sequence during one of the drum changes for each device. The sampling
time was four minutes per sample, for a total duration of eight minutes.
Table 3.3 lists the analytical air samples collected in EFT #2. Sampling locations at
the Florida facility are shown in Figure 3.3.

-------
           Table 3.3: Air Samples Collected during Extended Field Test #2 and #3
i:.:.: V'X,'.!:
Personal
Samples
Ceiling
Samples
Area
Samples
Overnight
Samples
* *".:''' "''' ' ,* ' ' * . ' " ' ,.' • 1
.K • Type of Sample ' ; -, •
1 on left shoulder - filling both drums, filter
changes, drum changes
1 on each shoulder - filling 1st drum
1 on each shoulder - filling 2nd drum
1 on left shoulder - during drum/ filter change
1 on shoulder - samples taken in sequence
during drum change
Near device exhaust
Near device feed tube
Near device exhaust
Near device feed tube
' #of
, Samples
1
2
2
2-4». t>
2
1 .
1
1
1
Approximate \
Duration {nun) .
.100-160
60-80
40-70
12-20
4
100 - 160
100-160
720 - 1080
720-1080
• Manufacturer A: 2 Drum Change Samples
 Manufacturer B: 2 Drum Change Samples
 Manufacturer C: 2 Filter Change Samples, 2 Drum Change Samples
b The filter change samples for the Manufacturer C device were taken when the drum was half full (~350 bulbs).
                 Figure 3.3: Sampling Locations for Extended Field Test #2
       S \AirSampleLocations
         1 - Area air sample at feed tube
         2 - Area air sample at DTC exhaust
         3 - Jerome inside containment
         4 - Jerome outside containment
        AERC FacUity
     Melbourne, Florida
                                 North
        ,"M Wipe Sample Locations

         1 - Floor - 2 ft. from device
         2 - Floor - 5 ft from device
         3-Ceiling
         4 - East wall - 4 ft above ground
         5 - West wall - 4 ft above ground
         6-Side of drum
         7 - Top of DTC device
         8 - Feed tube near operator
         9 - Floor at DTC device exhaust
                                     Entrance
	Containment Structure
                          * Not to scale
3.1.3.1 Box Test
On the first day at AERC Melbourne (EFT #2), the Manufacturer B device was
operated and mercury levels were measured. The Jerome analyzer measured
airborne mercury levels that exceeded the OSHA PEL: (1) while operating the
device to fill the first drum, (2) during the down time taken by the operator after
filling and changing out the first drum, and (3) for the first 20 minutes of device
operation, while filling the second drum. Because the Manufacturer B Device had
previously shown better performance and because mercury levels in the

-------
containment structure had declined during other non-operational periods (i.e.,
periods during the operator break between drums when devices were not operated),
the field team decided to try to evaluate the cause of the high mercury readings.

During Phase I of the PVS and EFT #1 and the beginning of EFT #2, multiple
cardboard boxes of fluorescent lamps were brought into the containment structure
and kept inside to ensure that the operator had an adequate supply of readily
accessible lamps. The field team suspected that the mercury released from the
broken lamps in the boxes was contributing to elevated levels inside the containment
structure.  Based on this concern, testing procedures were revised so that only one -
box of lamps was kept inside the containment structure.

On April 30 (EFT #2), a test was performed to determine whether the boxes
containing broken lamps were contributing to elevated mercury concentrations
inside the containment structure (Box Test). Five boxes containing some broken
lamps were brought into the containment structure. A Jerome analyzer was also
placed inside the containment structure to record the airborne concentrations of
mercury. Figure 3.4 shows the layout of the containment area and sampling
locations for the mercury emission test from broken boxed lamps.
                 Figure 3.4: Box Test Configuration, AERC Melbourne
                           Jerome monil
•0
                      	Containment Structure
                                           •Not to scale
At the end of the week, the decision was made to repeat a portion of the
Manufacturer B device testing, following the new procedure of bringing only one
box at a time into the containment structure. Due to time constraints, the repeat test
included only one drum, not two drums as in the first test at this location.

3.1.4  Extended Field Test #3

The third EFT was conducted at AERC Ashland, during the same time period as
Phase II of the PVS, June 9-13,2003. Three DTC devices (Manufacturer A,
Manufacturer B, and Manufacturer C) were included in this portion of the Study. At
the conclusion of EFT #3 for each DTC device, the containment structure
polyethylene was replaced with new polyethylene, and Phase II of the PVS for that
device began. Table 3. 3 lists the samples collected for EFT #3. Because this test was

-------
conducted at AERC Ashland, the sampling locations are the same for PVS Phase I,
PVS Phase II, and EFT #3 (refer to Figure 3.1).

3.1.4.1 Box Test

A Box Test was also conducted at AERC Ashland in a similar manner to the test at
AERC Melbourne, with the addition of analytical air samples collected on the east
and west sides of the containment structure. Refer to Figure 3.5 for the containment
area layout and sampling areas for the Ashland Box Test. The test was performed at
the conclusion.of EFT #3 and before the beginning of PVS - Phase II for each device
(Manufacturer A/Manufacturer B, and Manufacturer C devices).
                  Figure 3.5: Box Test Configuration, AERC Ashland
                         Analytical air
                         V
                            Jerome rnoi
initfa ^>
                       _ . _ Containment Structure
                                           * Not to scale
3.1.4.2 U-Tube Test

The majority of fluorescent lamps processed in the Study were four-foot straight
tubes. Although the DTC devices included in the Study were designed to process
straight lamps, only two devices (Manufacturer B and Manufacturer C) have
attachments that enable them to process "U" shaped fluorescent lamps (Urtubes), as
well. At the end of EFT #3 at AERC Ashland, a test was conducted to evaluate
airborne mercury levels from the two devices while processing U-tubes. The intent
was for both the Manufacturer B and Manufacturer C devices to process enough U-
tubes to fill a 55-gaIlon drum. However, the facility was only able to collect a limited
number of U-tubes for the U-tube study. Therefore, the total quantity of U-tubes
was divided between the two devices. The Manufacturer B device processed a total
of 85 U-tubes, and the Manufacturer C device processed a total of 89 U-tubes.

Table 3.4 lists the analytical air samples collected during the processing of the U-
tubes. Air sample locations correspond to the locations shown in Figure 3.1;
however, there were no wipe samples collected for the U-tube evaluation.
Photograph 3. 6 shows the crushing of U-Shaped.

-------
               Table 3.4: Air Samples Collected during U-tiibe Evaluation
• K • * ' * *' • '" '' '• '
,;.?:Uf "'•';.;' 'C'"'.-:'A.:.
• 3 "•* ...• , ; 	 :.•*.'.'
Personal Samples
Area Samples
".i <••"• VC' "'X ••">'' ' ." "•„,'
'"'"'•: '.,"~''.»-'Type ofSample^ * .-?.'•
1 on each shoulder - filling the
drum
Near device exhaust
Near device feed tube
..:.,• fof | -
Saniples
2
1
1'
;'• App'rox. •
* Duration.
.»'• (miri) :
12- 14
12-14
. 12-14
Air- Flow"
'Rate
(cc/min)
150
150
150
             Photograph 3.6: Crushing of U-Tubes - Manufacturer C Device

 3.2   Jerome Mercury Vapor Analyzer Samples

In addition to measuring mercury concentrations in the air using sampling pumps,
two factory-calibrated Jerome Mercury Vapor Analyzers (Model 431-X, Arizona
Instrument, LLC) were used to measure real-time mercury concentrations in the
ambient air.  As shown in Figure 3.1, Figure 3.2, and Figure 3.3, one stationary
Jerome analyzer (Jerome #1) remained inside the containment structure (refer to
Photograph 3.1 and Photograph 3. 7), while another Jerome analyzer (Jerome #2) was
placed outside of the containment structure and brought inside at various times.

Both analyzers were used to identify fluctuations in concentrations while the DTC
devices were operated.  The Jerome analyzer accurately measures mercury within +
5% in the sensitivity range of 0.003 to 0.999 mg/m3 mercury. Both analyzers were
equipped with data loggers, to measure and record the mercury concentrations
throughout the day. However, due to problems with the data loggers, the analyzers
had to be checked manually and the concentrations recorded in field notebooks.

Jerome #2 was specifically utilized to identify emissions at the carbon filter exhaust
leaks around the seals, emissions/releases at the feed tube, varying concentrations
within the containment structure, and background conditions outside the
containment structure. This information assisted the operators in determining when
personal protective equipment (PPE) was necessary. The mercury vapor analyzer
alarms were set to activate at 0.05 mg/m3, to alert the operator of the mercury
concentration before the OSHA PEL (0.1 mg/m3) was approached. The project
health and safety plan specified that respiratory protection be used inside the
containment structure if mercury levels reached or exceeded 0.05 mg/m3. It was

-------
common for mercury concentrations to exceed 0.05 mg/m3 during routine operation;
therefore, respiratory protection was employed throughout most of the Study.
Photograph 3.7: Placement of Air Sampling Pump & Jerome Analyzer in Relation to DTC Device
3.3 Bulk Samples

The Mass Balance Study was intended to account for the fate of the mercury
involved in the operation of DTC devices by estimating the total mass of mercury
put into the DTC device via crushed lamps and comparing that quantity to the mass
of mercury retained by the device plus the mass of mercury released. Samples of
unbroken, spent lamps were collected to quantify the average amount of mercury in
different types of fluorescent lamps and estimate the total amount of mercury
processed by each device. Pollution control media samples and samples of crushed
lamps were used in the Mass Balance Study to estimate the amount of mercury
retained within the drum and the device assembly for each device.

3:3.1 Unbroken Spent Lamps

During Phase I of the Performance Validation Study (PVS), several unbroken, spent
fluorescent lamps were submitted to Data Chem for mercury analysis. Alto®
lamps, manufactured by Philips Lighting, were collected and used for this portion of
the Study. Specifically, three Alto® T8 lamps, three T12 34-watt lamps, and two
Alto® T12 40-watt lamps were obtained from AERC Ashland and analyzed.

Data Chem used a low-temperature drill and acid extraction method to collect the
mercury in the lamps, and performed the analysis in accordance with EPA Method
7470. The method used by Data Chem is a non-standardized method based on
discussions between Data Chem and Philips Lighting. Philips Lighting shared
information with Data Chem on experiments performed to extract mercury from an
operating lamp. Data Chem modified the mercury extraction method to extract
mercury from a spent lamp rather than an operational lamp (refer to Appendix Efor a
description of Data Ghent's extraction method).

-------
Briefly, the method involved packing the lamps in dry ice for approximately one
hour, to chill them and condense the mercury vapors inside. A small hole was then
drilled into the end cap, and concentrated nitric acid was introduced into the lamps.
The hole was filled with a wax plug and the lamps were agitated for approximately
15 minutes, to allow the mercury to react with the acid. The acid was removed from
the lamp and analyzed using EPA Method 7470. The results were used to confirm
the amount of mercury reported by Philips Lighting and to calculate the quantities
of mercury for the Mass Balance Study.

3.3.2 Pollution Control Media

During Phase I of the PVS, bulk samples of various pollution control media were
collected from each DTC device after the operator had filled one drum with lamps.
Bulk samples were collected from the filter media prior to removing the device from
the containment structure (refer to Appendix HJbr detailed procedures for the collection of
samples from the pollution control media}.

The bulk samples collected from each of the DTC devices included:

• Three samples of particulates from'the particulate pre-filters from the
Manufacturer B device, Manufacturer C device, and Manufacturer D device
(the Manufacturer A device is not equipped with a particulate pre-filter).

• Three samples of particulates from the HEPA filters from all four devices.
'<-
• Three samples of particulates from the carbon filters from all four devices.

Clean filter media were submitted by the manufacturers to Data Chem for quality
control (QC) samples. These clean materials were used for blank samples and spike
samples so that comparisons could be made to the samples of the used filter media.
The samples were analyzed in accordance with EPA Method.7470 and EPA Method
7471A, modified slightly by Data Chem to accommodate materials other than soil or
sediment, as outlined in Appendix E.

Before the start of lamp crushing operations, the filters (p're-filter, HEPA filter, and
carbon filter) arid'empty drums were weighed for each device. After the drum was
completely full, the drum and filters were re-weighed to determine the amount (by
weight) of crushed lamps in the drum or particulate on the filters.

3.3.3 Crushed Lamps

After the samples from the pollution control media were collected, the DTC device
was removed from the top of the drum. Three samples of crushed lamps were
collected for each device to determine the amount of mercury in a drum'of crushed
lamps for the Mass Balance Study. Approximately 275 to 300 cubic centimeters (cm3)
of crushed lamps was collected from each drum using dedicated, disposable plastic
spoons that had been decontaminated (prior to use) with HgX® in clean water and

-------
allowed to air-dry.I2 The samples were collected from as deep within the drum as
.possible to minimize the potential for low-biased results due to vaporization or
fugitive particulate emissions of mercury. However, due to the density of the
crushed lamps, the sampling depth was limited to approximately eight inches. The
samples were sealed in sample containers provided by Data Chem Laboratories.

                                                              "  N  - •
After collection, all the bulk samples (i.e., unbroken spent lamps, pollution control
media, and crushed lamps) were packaged and shipped via Federal Express to Data
Chem for analysis along with completed chain-of-custody forms that were signed by
the personnel who collected the samples.

  3.4    Wipe Samples

Surface wipe samples were collected inside the containment structure on numerous
surfaces both before and after lamp crushing, as part of the Mass Balance Study. The
wipe samples were collected and analyzed in accordance with N9103 for wipe
samples (refer to Appendix E). Under this procedure, a 100 square centimeter (cm2)
area was wiped using a "Wash N' Dri" towelette (the liquid component of the wipe
is 5 to 10 percent ethanol and 80 to 90 percent water), which was placed into a glass
vial. Wipe sample supplies were provided by Data Chem {refer to Photograph 3. 8).
                        Photograph 3.8: Wipe Sample Media
 Wipe samples were collected prior to the start of each DTC device operation and
 again at the conclusion of the DTC device operation. The pre-test and post-test
 samples were collected in the same general area; however, the post-test wipe
 samples may not have been collected in the exact location of the pre-test wipe
 sample (refer to Figure 3.1, Figure 3. 2, and Figure 3. 3 for sample collection areas).

 For the testing conducted at AERC Ashland during PVS - Phase I, a set of two pre-
 test wipe samples and a set of two post-test wipe samples were collected at each of
 the nine locations shown in Figure 3.1. The purpose of this activity was to assess
 the reproducibility of the results. However, although the testing at AERC Ashland
 indicated, widely divergent values (i.e., orders of magnitude differences), most likely
 12 HgX® is a sulfiding and chelating agent that contains sodium thiosulfate and EDTA.

-------
attributable to the high background level of airborne and surficial mercury
contamination, it was not possible to modify the study design to increase the
number of replicates of wipe samples at the other locations.

After sampling was complete at each of the study locations, the wipe samples were
collected for shipment to Data Chem. Samples were placed in an oversized sturdy
box with packing material to fill voids and protect the samples during shipping. The
chain-of-custody forms were then signed by the sampling personnel and placed in"
the box with the samples. Samples were shipped via Federal Express to the
laboratory!

  3.5    Test Protocol Deviations and Modifications

Due to circumstances encountered in the field, it was not always possible to follow
the initial testing protocol. The following sections describe deviations in device
operation and modifications to testing procedures, which were mainly associated
with difficulties encountered while processing lamps.

3.5.1  Manufacturer B Device

For EFT #1, the vendor provided the operator with a reducer plate to install in the
Manufacturer B device at the carbon filter exhaust. The reducer apparently was
designed to throttle airflow through the unit, and was installed at EPSI Phoenix per
the vendor's instructions. Increased emissions occurred while the DTC device was
being tested/apparently as a consequence of the newly installed reducer. After
processing the first full drum of crushed lamps, a representative from Manufacturer
B was contacted and a decision was made to remove the reducer plate and then to
continue the crushing operations for the second drum without the plate.

3.5.2  Manufacturer C Device

For EFT #1 at EPSI Phoenix, the Manufacturer C device experienced some
operational difficulties that delayed the start of testing and may have had an effect
on the results measured during the operation. After the first lamp was inserted into
the feed tube, the motor 'on the machine stopped. After troubleshooting the
problem, the manufacturer found that the machine would start if the start button
were depressed for approximately 10 seconds.1 Depressing the start button for 10
seconds enabled a safety lock operating off a pressure sensor to be disengaged. The
operator proceeded to crush lamps, and changed a filter after 350 lamps were
crushed. The drum and filter were changed once the first drum was filled with 750
lamps. During crushing operations for the first drum, the operator noted that the
feed tube jammed about every 20 bulbs and had to be cleared by sliding a rod down
the feed tube.

Due to on-going operational problems and elevated mercury levels, testing of this
device was concluded after only 336 bulbs had been crushed in the second drum.
The device was returned to the manufacturer to evaluate the cause of the operational
difficulties. The manufacture installed a new control panel for the device and then

-------
shipped the machine to Melbourne, Florida for EFT #2.. The device was able to
process the required number of lamps during EFT #2, EFT #3, and the PVS.

3.5.3  Manufacturer D Device
                                                                    t
During PVS - Phase I, elevated levels of mercury vapor were detected during testing
of the Manufacturer D'device (refer to Section 4.4.1.2). These levels required the
temporary suspension of the test to allow the operator to don respiratory protection
(after crushing 25-30 fluorescent lamps). The test was permanently .suspended (after
crushing 276 lamps) at this site because mercury concentrations consistently
exceeded the OSHA PEL arid continued to increase. The readings on the Jerome
analyzer peaked at 0.89 mg/m3, nearly 9 times the OSHA PEL.

The Manufacturer D device was shipped back to the Manufacturer D facility at the
manufacturer's request to evaluate the cause(s) of the elevated ambient mercury
measurements. EPA requested that the manufacturer prepare a written report
detailing the problem(s) and the cause(s); the report was also required to confirm the
adequacy of the repairs, including an analysis for mercury vapor by a qualified
industrial hygienist.

The device arrived at.EPSI Phoenix (EFT #1) for the next round of testing visibly
damaged and modified to the extent that it looked like a different device than the
device used for Phase I of the PVS. The overall study design required each DTC
device vendor to provide one unit that would be used throughout the entire test.
Changing the device design violated the study design.  There was also a clearly
visible crack in the vacuum assembly, preventing adequate negative pressure when
the device was turned on, and some of the carbon from the pollution control media
spilled out of device during assembly.  Even though only 16 lamps were crushed
during testing, the ambient mercury concentration inside the containment structure,
measured by the Jerome analyzer, reached 0.406 mg/m3 mercury, more than four
times the PEL.

None of the analytical air samples taken for this device were below the ACGIH TLV.
Eight analytical air samples were collected during PVS - Phase I, and only one was
below the PEL. Only two of the four samples collected during EFT #1 (when only 16
lamps were crushed) were below the PEL. It was determined that the use of the
Manufacturer D device posed a health risk to study personnel, particularly the
operator and assistants. After serious consideration, the unit was eliminated from
further testing because of the unauthorized modifications and because of continued
elevated mercury levels. Further information can be found in Appendix I.

-------
4. RESULTS AND DATA EVALUATION

The overall objective of the DTC Device Study was to gain insights into the abilities
of four different DTC devices to capture and contain mercury, while processing
fluorescent lamps, A variety of air and other samples were collected for distinct tests
that comprise the DTC Study.13 This chapter presents the data collected for the
Performance Validation Study (PVS) and the Extended Field Test Study (EFTS) and
evaluates those results against study objectives. The next chapter (Chapter 5)
presents and evaluates the data collected for the Mass Balance Study. The objectives
for the different studies discussed in this chapter are listed below.

• The PVS was conducted to examine the effectiveness of each device in capturing
and retaining mercury vapors and to identify any potential change in
effectiveness over time. The study compared the results among the different
devices when new and after a pre-determined period of operation during which
numerous lamps were processed through each device (Section 4.4).

• The EFTS was conducted to examine the ongoing performance of each device
during extended use and over a range of environmental conditions (Section 4.5).

• The Box Tests, conducted as part of the EFTS, were performed as an addendum
to the EFTS to determine if the presence of broken lamps inside the containment
structure confounded the study results (Section 4.6).

• The Overnight Tests were performed as part of the EFTS to evaluate releases of
mercury vapor from DTC devices attached to partially filled drums during non-
operational periods (Section 4.7).

• The U-tube Test, conducted as part of the EFTS, examined the performance of
two of the devices when processing U-shaped fluorescent lamps (Section 4.8).

4.1 Exposure Evaluation Criteria

The results from the analytical air samples and the Jerome analyzers were compared
to published mercury exposure limits to assess the performance of the devices in
effectively capturing mercury vapors, while processing fluorescent lamps.

OSHA PEL: The federal Occupational Safety and Health Administration (OSHA)
has established a maximum work-place regulatory permissible exposure limit (PEL)
for inorganic mercury, which is codified in 29 Code of Federal Regulations (CFR)
1910.1000, Table Z-2. The current'mercury exposure limit for workers is 0.1 mg/m3
(ceiling). This regulatory exposure limit is established as a "ceiling" value in the
13 It is important to note that, out of the 199 analytical air samples collected, only eight mercury aerosol (MCE filter)
samples had values above the detection limit, and all blank MCE filter samples were below the detection limit. All of
the mercury vapor (Hydrar tube) samples contained levels of mercury above the detection limit. Because the amount of
mercury aerosol was not high enough to measure, the air results discussed in this chapter only address the Hydrar tube
samples. The results for the MCE filters can be found in Appendix A, Table 1. Future research may be necessary to
determine why aerosols were generally not detected (refer to Section 7.4).

-------
CFR, meaning that exposure to this value is not to be exceeded during any part of
the work day, as opposed to a time weighted average (TWA) that calculates average
exposure over the entire work shift.14 However, in a memo dated September 1996,
it states that OSHA currently implements the mercury PEL as an eight-hour TWA
rather than as a ceiling value.15

ACGIH TLV; The other exposure limit that is referenced in this report regarding
DTC device performance is a published work-place exposure limit, the threshold
limit value (TLV) established by the American Conference of Governmental
Industrial  Hygienists (ACGIH), which is a professional organization for, individuals
in the industrial hygiene and occupational health and safety industry. The ACGIH
TLV is 0.025 mg/m3 and is a TWA (eight hours per day, 40 hours per week).16

EPA has established an exposure limit (a reference concentration, or RfC) of 3.0xl(H
mg/m3 for the general public for chronic exposure to elemental mercury.17

The data from analytical air samples taken in this Study represent average values for
the time periods during which the samples were taken; sampling time was generally
between one and three hours for the samples taken during device operation (refer to
Appendix A, Table I far sample durations). Sample results that are greater than the TLV
value should not necessarily be interpreted to indicate that use of one of the.DTC
devices included in the Study would result in operator exposure  above the TLV
because the device may not be used for eight hours per day,' 40 hours per week. The
analytical air sample results were not normalized to an eight hour workday because
DTC device use patterns may vary significantly (e.g., from a few  minutes to eight or
more hours per day). More information about the actual use patterns of DTC
devices and the mercury exposures experienced by workers during non-operational
periods would be necessary in order to calculate an eight hour TWA accurately for
any specific pattern of use.

  4.2    Background Air Samples

Because the Study was being conducted at commercial lamp recycling facilities,
which were expected to have ambient mercury concentrations above those in
outdoor air, three types of background samples were collected in order to quantify
the mercury present at each site before, during, and after device operation.
14 Refer to 29 CFR 1910.1000(b).
^The PEL for mercury was promulgated as a ceiling value in 1971 (36 FR10505, May 29,1971). A memorandum to •
   OSHA compliance personnel was issued on September 3,1996, that directs compliance officers to issue citations only
   when an averexposure exceeds 0.1 mg/m3 as an 8-hour TWA.
^° ACGIH also has a "skin" notation for elemental mercury, indicating that dermal absorption is another possible exposure
   route. Refer to ACGIH f 19941 1994-1995 Threshold limit values for chemical substances and physical agents and
   biological exposure indices. Cincinnati,  OH: American Conference of 'Governmental Industrial Hygienists.
17 The inhalation Reference Concentration (RfC) is intended to identify a maximum safe level for chronic exposure for the
   general population'and is analogous to the oral RfD. The inhalation RfC considers both toxic effects for the respiratory
   system and toxic effects peripheral to the respiratory system (extrarespiratory effects). In general, tiie RfC is an
   estimate (with uncertainty spanning perhaps an order of magnitude) of a daily inhalation exposure of the human
   population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a
   lifetime. The mercury RfC is based on a human lowest observed effect level (LOEL) of 0.025 mg/m3,. See Integrated
   Risk Information System (IRIS) website (wvw.eva.%ov/iris/index.html) for further discussion.

-------
On the first day at each site, before performing any crushing activities, two
analytical air samples were collected in (he vicinity of the study area, to measure
ambient mercury concentrations in the lamp recycling facility (refer to Table 4. /).

During testing at AERC Melbourne and the second round of testing at AERC
Ashland, one analytical air sample was taken overnight outside the containment
structure at the end of each day of testing (refer to Table 4. 1 for overnight
background results and refer to Section 4.7 far information on overnight tests),

Jerome readings from a Jerome analyzer positioned outside the containment
structure were manually recorded during PVS - Phase II and during the EFTS as
time allowed (rejer to Table 4. 2).
          Table 4.1: Background Mercury Results - Analytical Air Samples
V t * ~ ' * r p
~< ? 7" *•*' -••
Studies
Performance Validation I
Extended Field Test #1


Extended Field Test #2



Extended Field Test #3 &
Performance Validation II

^ t
" ( >S
' Date"_''!
s-
2/25/2003
2/25/2003
3/24/2003
3/24/2003'
4/29/2003
4/29/2003
4/29/2003
4/30/2003
5/01/2003
6/09/2003
6/09/2003
6/10/2003
6/11/2003
6/12/2003
, ,, - ;
/- ^ f *
1 - - .Location t '•
* >•» '" I > "- ^ «„..
Middle of E. bay
E. bay by center bay door
N. of containment in bay
E. of containment in bay
24ft. E. of dock door
18 ft. N. of dock door
Outside containment-night
Outside containment-night
Outside containment-night
Middle of E. bay
E. bay by center bay door
Outside containment-night
Outside containment-night
Outside containment-night
•^4 Mercury fe
Concentration
(mg/rri3)
0.0039
0.0047
0.014
0.0059
0.016
0.012
0.021
0.016
0.017
0.013
0.0086
0.017
0.00052
0.044
r'
Mean
' (mg/m*)
0.0043
0.010


0.0164



0.0166

      Table 4.2: Background Mercury Results - Jerome Analyzer Measurements
> ~ t
w '
Studies

Performance
Validation I
Extended
Field Test #1





i, -^
Date-



3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/25/2003
. J ' H
' Location t ,
' 1 * ~r
No data

Inside containment before crushing
Inside manager's desk
Inside manager's desk
Inside manager's desk
Minimum outside containment during crushing
Maximum outside containment during crushing
Outside containment
- , Mercuryl •,'„, :
Concentration
(mg/nV)
No data

0.020
0.023
0.022
0.023
0.030
0.050
0.040
•> • Vfpari '-\
- -f :lTX.lZCUi *
-------
.^'••f:*..',\'":?*s:
f -, Studies '."••
.i^-Vjt ;-^; ';





Extended
Field Test #2







Extended
Field Test #3
&
Performance
Validation II







p.. ':;..*• ,, .. ' • "'
;.'•" Date •-''" "<
'''- '•'. V '^y"\'.
3/26/2003
3/27/2003
3/27/2003
3/27/2003
4/29/2003
4/29/2003
5/01/2003
5/01/2003
6/10/2003
6/10/2003
6/10/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003

6/12/2003
6/12/2003
6/12/2003
6/12/2003

6/12/2003
6/12/2003
/•<•'>• **;,••;. •;•-••. v -• '<• -'^^''f ' :<;-"»>'?• •"-*,:
;"; :>."v .>.-';:/. ^:.:,;' Location - • .^ •'«'•'..'',,'•

Outside containment
Inside containment before crushing
Minimum outside containment during crushing
Maximum outside containment during crushing
Outside containment
Outside containment
Outside containment
Outside containment
Outside containment-after EFT #3, before PVS-II
Inside containment-after EFT #3, before PVS-II
Inside containment-after EFT #3, before PVS-II
Outside containment during operation
Outside containment during operation
Outside containment during operation
Outside containment during operation
Outside containment during drum change
Outside containment-after EFT #3, before PVS-II
Inside containment-after EFT #3, before PVS-II

Outside containment before starting
Outside containment before starting
Inside containment before starting
Outside containment between drum 1 & 2,
during EFT #3
Minimum outside containment, during PVS-II
Maximum outside containment, during PVS-II
' ;." , Mercury " "; .
Concentration
, (mg/m*)
< 0.003
0.035
0.035
0.045
0.007
< 0.003
0.004
0.017
0.008
0.009
0.012
< 0.003
0.01
< 0.003
0.004
0.017
0.005
0.03

0.013
0.014
0.021
0.014

0.020
0.040
'"•M '' ''
<••-» e,an - ~.
(mg/m3)





00074
\Ji\J\Jf ^









0.014









Each facility had measurable concentrations of mercury in the indoor ambient air.
According to research by Garetano, et al. outdoor mercury vapor concentrations
generally range from 24O6 to 2«lf>5 mg/m3, with higher concentrations in urban/
industrial areas.18  None of the analytical air samples were below the detection limit
(0.01 ug/ sample), and only four of the 31 mercury concentrations taken with the
Jerome analyzer were below the instrument detection limit (0.003 mg/m3).

The samples taken at the end of each day of testing during EFT #2 and EFT #3 were
compared to the background samples taken at the two sites before the DTC device
was operated to determine if the industrial lamp crushing activities at the lamp
recycling facilities created  a significant increase in the background concentration of
mercury throughout the week. Based on the four samples collected before beginning
DTC device operation and six samples collected overnight after DTC device
operation (N=10), there was no significant correlation between the measured
background concentration of mercury and the day of the week that the air sample
was collected. The background mercury concentrations are considered in the results
     to Garetano, Gary; Gochjeld, Michael; and Stern, Alan H. 2006. Comparison of Indoor Mercury Vapor in Common
   Areas of Residential Buildings ivith Outdoor Levels in a Community Where Mercury Is Used for Cultural Purposes.
   Environmental Health Perspectives. 114(1): 59-62.
-------
discussions in this chapter. The overall effect of the elevated background mercury
levels on the Study is discussed in Chapter 6. ''               .   .

 4.3    Blank Air Samples

As described in Section 3.1, NIOSH Analytical Method N6009 was used for mercury
air sampling. Data Chem included in all laboratory air sample reports the fact that
each Hydrar tube was contaminated with 0.035 to 0.045 micrograms (jig) of mercury.

At the beginning of each portion of the Study, three Hydrar sorbent tubes were set
aside as trip blanks.  These tubes were never opened during the field sampling and
were submitted to the laboratory for analysis with the air samples to determine the
level of mercury present in the sorbent material when no air sampling had occurred.

Additionally, at the beginning of each day of sampling, two Hydrar tubes were
removed and designated as field blanks. The ends of the glass tubes were opened for
several seconds to expose the sampling media to the air in the calibration room, and
then were capped and submitted to the laboratory for analysis.

All blank air samples were only handled in the pump calibration room, a room at
each facility that was separate from the areas where lamps were being crushed, such
as a conference room or an office.  The tubes used as blanks were never in the lamp
processing areas. Table 4. 3 summarizes the trip blank data, and Table 4.4
summarizes the field blank data. The means and standard deviations (Std Dev) are
included with the results.
                          Table 4.3: Trip Blank Results
?5;:FH:S^:3PS\^
Performance Validation I
Extended Field Test #1
Extended Field Test #2
Extended Field Test #3 &
Performance Validation II
;;jBlank|;
-------
^:fli--My,sJ?;i;-^

Extended Field Test #2
Extended Field Test #3 &
Performance Validation II
~ *••?•-:«. --r" \;
.. r,:patevv
3/26/2003
3/27/2003
4/29/2003
4/30/2003
5/1/2003
5/2/2003
6/10/2003
6/11/2003
6/12/2003
6/13/2003
;:• Blankl;';
;r:;(ML£
0.28
0.073
0.046
0.045
0.046
0.049
0.039
0.041
0.040
0.036
.Blank 2:
iJ'- 	 '

0.0470
0.0395 -
VSt'd'Dey I;

0.0020
0.0022
The field blank results were similar to the trip blank results for EFT #2 (only 0.7%
relative percent difference) and for EFT #3 (only 3.4% relative percent difference).
The results for the field blanks from EFT #1 (conducted at the EPSI facility) were
much higher than the trip blanks for that test (32% relative percent difference). This
suggests possible contamination of Hydrar tubes at this site and is not surprising
given that background mercury levels, as measured by the Jerome analyzer, were
highest at the EFSI facility.
                                                               *
  4.4    Performance Validation Study

the Performance Validation Study (PVS) was conducted to assess the performance
of DTC devices over time and determine if they lose efficiency in capturing and'
retaining mercury after a specified period of routine operation and crushing a
substantial number of lamps. This section presents the measurements collected
during Phases I and II, and compares these measurements to evaluate .the
performance of each device. Phases I and II are separated by five months, and each
DTC device,'except the Manufacturer D device, was used in the EFTS during this
time, crushing approximately 3,800 - 4,300 lamps at three locations.

4.4.1  Performance Validation Study - Phase I                                  .

Phase I of the PVS was conducted at the AERC facility in Ashland, Virginia (AERC
Ashland) during the week of February 24,2003. As described in Chapter 3,
analytical air samples were collected to measure the concentrations of mercury in the
containment structure during operation of the new DTC devices,19 and the Jerome
analyzer was used to collect direct-reading measurements.

Temperature and humidity in Richmond, Virginia for each day at this study location
were obtained from an online weather service archive. The average outdoor
temperatures during this testing interval ranged between 28.4 and 42.6 degrees
Fahrenheit. The average outdoor relative humidity ranged between 57.5 and 99.3
19 The Manufacturer A device is a prototype and, tlKrejbre, is not considered a new device.
-------
percent  Due to the cold weather conditions, the bay doors to the outside remained -
closed during the tests.20  .

Background measurements of mercury vapor concentrations, as measured using
Hydrar tubes, were 0.0039 mg/m3 and 0.0047 mg/m3. These levels were most likely
due to the ongoing, high throughput volume crushing of fluorescent bulbs
conducted by AERC in the adjacent bay. A large doorway connected the bay where
testing was conducted and the bay where AERC operated its industrial-sized bulb
crusher. .The facility separated the bays by keeping a pull-down door in-between the
two bays closed for the majority of testing; however, live pull-down door was
opened occasionally to move materials back and forth between bays (e.g., lamps
required for the test).  The effect of background concentrations on study results is
further discussed in Section 6.1.

In this phase of the Study, one drum of lamps was processed through each device.
Table 4.5 summarizes the number of Phillips Lighting "Alto®" lamps processed to
fill one drum. The number of lamps is specific to each device.

      Table 4.5: Total Lamps Processed in Each Device, Performance Validation Study I
;^,;X 'Device' -i?/';"'
Manufacturer A
Manufacturer B »
Manufacturer B »
Manufacturer C
Manufacturer D b
Number of tamps Processed
637
611
113
706
276
'.•'/: •- •-••>•'. 'frfype of Lainp';> ' -• v;~V°
T-12 fluorescent (3.5-4.2 mg Kg/lamp)
T-8 fluorescent (3.0 mg Hg/Iamp)
T-12 fluorescent (3.5-4.2 mg Hg/lamp)
T-12 fluorescent (3.5-4.2 mg Hg/lamp)
T-12 fluorescent (3.5-4.2 mg Hg/lamp)
    • Manufacturer B device processed mostly T-8 lamps due to a temporary shortage of T-12 lamps.
    b Manufacturer D device was shut-down before processing a full drum. Refer to Section 3.53.

It is important to note that during PVS - Phase I, all of the lamps processed were
Alto® fluorescent lamps. These lamps were specifically selected for use in Phase I
because these data were also used for the Mass Balance Study, and Alto® lamps are
manufactured with more precise doses of mercury than other lamps.

4.4.1.1 Analytical Air Sample Results

The results of the air samples collected during Phase I of the PVS inside the
containment structure are presented in Figure 4.1. Air sample results for the
Manufacturer A, Manufacturer B, and Manufacturer C devices were generally below
both the OSHA PEL and the ACGIH TLV values. The Manufacturer D device
exceeded the PEL and the TLV values for seven of the eight samples collected.

For a separate  graphical depiction of the analytical air sample results collected for
each DTC device, refer to Appendix A, Figures 1 through 5. To review the actual
results for each analytical air sample, refer to Appendix A, Table 1. The Data, Chem
reports are available in Appendix C.
  Outdoor temperature and humidity data were collected at the request of the EPA Work Group. While indoor data, when
   collected, better characterize the operating environment for the devices, the outdoor data are still significant.
-------
         Figure 4.1: Analytical Air Sampling Results, Performance Validation Study I*
    0.10000
    0.08000
    0.06000
    0.04000-
    0.02000 •
    0.00000
          Operator's
           Shoulder
Operator's
Shoulder
                           Exhaust
                                    Exhaust
Feed tube  Feed tube Filter Change   Drum
                         Change
                                                           PEL
                                                         0.1 mg/m*
                                                          •MMfg. A

                                                          ••Mfg. B

                                                          tsawtg. c

                                                          En Mfg. 0

                                                          —PEL (0.1)

                                                          —TLV (0.025)

                                                          	HydrafBkgd
                                                            (0.0043)
                                                                              TLV
                                                                           0.025 mg/m'
The devices from
Mfg A and B
• During Operation ;
0.005 - 0.009
0.007 - 0.009
<0.003- 0.005
0.44 - O.B*
- /Filter; Change
NA<>
NAd
0.008 b
. No data c
Drum Change
0.005- 0.009 *
0.026"
0.008 «»
No datac
        NA - Not applicable
        •During the drum change, the measurements were at the maximum levels recorded.
        b During the filter change and the drum change, measurements were at the maximum levels recorded.
        cSee paragraph below and Section 3.5.3.
        dThe Manufacturer A and Manufacturer B devices do not have a separate filter change.


The real-time mercury vapor concentrations measured inside the containment
structure using the Jerome analyzer during operation of  the Manufacturer A,
Manufacturer B, and Manufacturer C devices were all below the OSHA PEL and the
ACGIH TLV values (with the exception of the Manufacturer B device during the
drum change, which exceeded the TLV value). The Jerome analyzer readings
-------
collected while operating the Manufacturer D device exhibited a continuous increase
in mercury concentrations.  After processing approximately 25 to 30 lamps, the
Jerome analyzer measured mercury vapor at 0.44 mg/m3, and processing was
suspended to allow the operator to don respiratory protection. Crushing operations
then continued for approximately 45 minutes, until the Jerome analyzer readings
increased to 0.89 mg/m3. Testing of the Manufacturer D device at this facility was
permanently suspended after processing a total of 276 lamps, due to the persistent
TLV and PEL exceedances in the test area. Further discussion of the Manufacturer D
device is provided in Section 3.5.3.

4.4.2  Performance Validation Study - Phase II

Phase II of the PVS was conducted at AERC Ashland during the week of June 9,
2003.  The Manufacturer A, Manufacturer B, and Manufacturer C devices were
tested during Phase'II; as noted earlier, the Manufacturer D device was removed
from the Study due to airborne mercury concentrations consistently above the PEL
during Phase I. The average outdoor temperature during this testing interval ranged
between 70.0 and 79.0 degrees Fahrenheit, and average outdoor relative humidity
ranged between 73:0 and 80.6 percent.  The indoor temperature and relative
humidity were measured using a Velocicalc instrument.

•  Temperatures: ranged between 73.0 and 86.2 degrees Fahrenheit, with a weekly
   average of 81.2 degrees Fahrenheit.

•  Relative humidity:  ranged between 54.5 and 74.4 percent, with an average of 63.1
   percent.

As described in the Sampling and Study Plan (refer to Appendix D), the Phase II
testing was conducted after each DTC device had processed six to seven drums'
worth of lamps.

Table 4.7 summarizes the number of lamps processed to fill one drum. The number
of lamps is specific to the unique operation of each device.
      Table 4.7: Total Lamps Processed in Each Device, Performance Validation Study II
'TT_"t 'Device'''"' "••
Manufacturer A
Manufacturer B
Manufacturer C
.' ' .'. NumHer'pf JLarnps-JE^rMessed'-'' ,.-:,'.
667
617
801
During Phase II of the PVS, some of the lamps processed were not Phillips Alto®
lamps because .there were not enough of them available. The inclusion of
conventional lamps in the second phase of the PVS may have affected the measured
mercury concentrations because most conventional fluorescent lamps contain more
mercury than Alto® lamps.
-------
4.4.2.1 Analytical Air Sample Results               ,  -

For Phase II, a majority of the results for the analytical air samples were below the
OSHA PEL value, but not the ACGIH TLV value, as shown below in Figure 4.2.
        Figure 4.2: Analytical Air Sampling Results, Performance Validation Study IIa

0.10000 -



O.OBOOO



"_
§

c 0.06000-

5
J
g.
o
o
S" 0.04000
I


0.02000

0.00000


















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1

es
' U'
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fl









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ii
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I
>;
ri
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i
r
i
?
!,
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i
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il








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f
i

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:3f
f

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at

























mpEL
Tftl mg/m' - •
























Operator's Operator's Exhaust Exhaust Feed tube Feed tube Filter Drum Ceiling #1 Ceiling #2
Shoulder Shoulder Change Change

CZlMfg A
E3Mfg.B



— PEL(D.1)

	 TLV<0.025) '


- — HydrarBkgd.
(0.0166)
*•"• Jerome Bkgd.
(0.014)



TLV
0.025 mg/m'


The devices from
Mfg A and B do not
require a separate
filter change, so
there are only filter
change samples
for the devices.
from Mfg C and D.

  * The TLV is included on the graph as a point of reference. The analytical air samples shown on this graph do not represent
   eight-hour TWAs (refer to Appendix A, Tabk 1 for sample durations).

The Ceiling #1 sample for the Manufacturer C device met, but did not exceed, the
PEL value. 2I The two samples that exceeded the PEL were two of the three Ceiling
#2 samples (Manufacturer B and Manufacturer C devices). Throughout Phase II of
the PVS, air sample concentrations for the Manufacturer A device were consistently
lower relative to the other two devices, usually below the TLV. To review the results
for each analytical air sample, refer to Appendix A, Table 1. For a separate graphical
depiction of  the air sample results collected for each DTC device, refer to Appendix
A, Figures 6  through 9. The Data Chem reports are available in Appendix C.

4.4.2.2 Jerome Mercury Vapor Analyzer Results

The field team experienced software performance problems while attempting to
record the mercury concentration on both data loggers attached to  the vapor
analyzers during Phase II. The only available logged readings were those from
21 It is important to note that the drum-change and ceiling samples are not time-weighted averages (TWA) and should not
   be compared to tlie TLV, which is a TWA. The PEL for mercury was promulgated as a ceiling value in 1971 (36 FR
   10505, May 29,1971).  A memorandum to OSHA compliance personnel was issued on September 3,1996, that directs
   compliance officers to issue citations only when an overexposure exceeds 0.1 mg/m3 as an 8-iiour TWA.
-------
operation of the Manufacturer A and Manufacturer B devices inside the containment
structure.  Mercury vapor analyzer measurements for the Manufacturer C device
were manually recorded, as time allowed. (Prior to beginning the Phase II test for
the Manufacturer C device, the Jerome analyzer recorded 0.008 mg/m3 outside the
containment structure and readings between 0.009 mg/m3 and 0.012 mg/m3 inside
the containment structure.) Refer to Table 4.8 for the Jerome analyzer readings
taken inside the containment structure during PVS - Phase II.

Table 4.8: Jerome Analyzer Measurements - Inside Containment, Performance Validation Study II
                         '»DuringOpeBtionJ
           Manufacturer A
           Manufacturer B
           Manufacturer C
0.007-0.013
<0.003 - 0.030
 0.02- 0.04 «
No data8
No data"
No datac
No data »
No data b
No datac
           *The Manufacturer A and Manufacturer 8 devices do not have a separate filter change.
           b Drum was changed the following day.
           c Values were manually recorded, as time permitted, because data logger was not functioning.
           4 Data logger was communicating with Jerome analyzer to collect samples but did not record data.

For a graphical depiction of the logged Jerome analyzer data, refer to Figure 4.3 and
Appendix A, Figures 10 through 12.
      Figure 4.3: Jerome Results - Inside Containment, Performance Validation Study II*
0.325-

0.3 •


0.275 •

0.25 •
0.225
•v
f 02 •
! 0.175 •
0.15-
J 0.125-

0.075 •

0.0$
,






















Mfd-C - No Jaroma data ia
available forth, devicea
fromKflcrorPVSII
bacauae tha Jaroma data
MB0or WM not funco'oranfi.












(

^^s. >^^.^ • * ••*







^




• -»-MfgA |

-^MfgB

->-Mfg C 1

	 PEL (0.1) ]
	 TLV (0.025) |
	 HydrarBkgd |
(0.0166) |
' Jorofno BkQd i
(0.014)


PEL
0,1 rng/m*

1
TLV !
0.025 mg/m1 |

*»»«.„.%,;*•.' 	 « — ^.*....».,.Jijt., — ,»..,..J|j^;:j,.«^.^..^.»^..».^.....,...^.^
0:00
0:10 { 0:20 0:30 0:40 0:50 1:00 1:10 1:20 1:30 1:40
Started crushing bulb* @ 1« mln. Elapnd Tlma (hour.minuU)
  • The .TLV is included on the graph as a point of reference. The mercury concentrations shown on this graph represent
   instantaneous measurements and do not represent eight-hour TWAs.
-------
4.4-3   Comparison of Performance Validation Study Phases I and II
              '                                                '                              . ^
Overall, analytical air sample results for all three DTC devices during the PVS were  ,
higher during Phase II than Phase I (refer.to Figure 4. 4 and Figures 13,. 14, and 15 in   ,
Appendix A).  The ceiling samples collected during Phase II are not included in the
graphs below because no ceiling samples were collected during Phase I.               ,
   Figure 4.4: Analytical Air Sampling Results, Performance Validation Study - Phases I & IIa
                                        Manufacturer A Device
           0.075


           0.063


           0.050


           0.038


           0.02S


           0.013


           0.000
   TLV
0.025 mg*ms
                                                I Riase I

                                                ] Phase II

                                                - Hydrar Bkgd I
                                                 (0.0043)
                                                • Hydrar Bkgd 1
                                                 (0.0166)
                                                -Jerome Bkgd I
                                                 (0.014)'
                                                -TW (0.025)
                Operator's Operator's  Bchaust  Exhaust Feed tube Feed tube  Filler    Drum
                 Shoulder  Shoulder                               Change  Change
                                        Manufacturer B Device
            0.075

            0.063

            0.050

            0.038

            0.025

            0.013

            0.000
TLV
                                                ••••Riase I

                                                '••'••••••••••I Phase II
                                                	Hydrar Btod I
                                                     (0.0043)
                                                - - - • Hydrar Bkgd II
                                                     (0.0166)
                                                	Jerome Bkgd II
                                                     (0.014)
                                                     UV (0.025)
                 Operator's Operator's Exhaust  Exhaust Feed tube Feed tube  Fffler    Drum
                 Shoulder  Shoulder                               Change  Change
                                        Manufacturer C Device
                                                     ) Riase I

                                                     I Phase II
                                                                                 Hydrar Bkgd I
                                                                                 (0.0043)
                                                                                 Hydrar Bkgd II
                                                                                 (0.0166)
                                                                                 Jerome Bkgd I
                                                                                 (0.014)
                                                                                 UV (0.025)
           0.000
                Operator's Operator's Exhaust  Bchaust  Feed tube Feed tube  Filter     Drum
                 Shoulder  Shoulder                               Change   Change
• The TLV is included on the graph as a point of reference. The analytical air samples shown on this graph do not represent
eight-hour TWAs (refer to Appendix A, Tabk 1 far sample durations).
-------
Background mercury levels inside die AERC Ashland facility were higher during
Phase II than during Phase I. Several one-way Analyses of Variance (ANOVAs)
were calculated using the data from Phase I and Phase II. Table 4. 9 compares the
results from the Phase I and IIPVS tests to background mercury levels and to each
other.  The ceiling samples are not included in these comparisons because no ceiling
samples were taken during Phase I.
         Table 4.9: Performance Validation Study Air Sampling Data Comparison » If p-value < alpha (0.1), the data being compared are significantly different from each other (90% confidence).
 «The mean background concentration of mercury for specific Phase was subtracted from each of the
  concentrations measured for each of the devices during that Phase of the Study.
 * The comparisons for the Manufacturer A device may not be valid because the concentrations of mercury
  measured in Phase n were not significantly different from the background concentrations; however, they are
  given here for reference.

As show in Figure 4.4, the background levels measured in Phase I using the Hydrar
tubes averaged 0.0043 mg/m3, in contrast to the Phase II Hydrar tube background
levels, shown in Figure 4.5, that averaged 0.0166 mg/m3. (Jerome readings are not
comparable because no Jerome background data are available for Phase I.) During
Phase I, the concentrations of mercury detected using the personal and area air
samples were significantly different from the background concentrations for all three
devices. During Phase II, the background concentrations were significantly different
from the analytical air sample results from the Manufacturer B and Manufacturer C
devices, but not significantly different from the analytical air sample results for the
Manufacturer A device.

These statistical comparisons are empirically illustrated by the fact that in the second
phase of the PVS, during the operation of the Manufacturer B and Manufacturer C
devices, most samples exceeded the ACGIH TLV value. However, during the;
operation of the Manufacturer A device, all samples other than the drum change and
ceiling samples were below the TLV value.  The Manufacturer A device features a
larger particulate filter and a larger carbon absorption bed than the other two *
devices. The more substantial pollution control equipment could, at least partially,
explain why the PEL value was never exceeded by the Manufacturer A device
during the PVS, and the TLV value was only exceeded by three samples.

A number of additional factors, external to actual device performance, may have
contributed to the differences between the results for the two phases. During the
-------
Phase II tests (performed in June 2003), the outdoor temperature was 250F-50°F
higher than during Phase I (performed in February 2003), which could have elevated
the indoor temperature during air volume changes (e.g., doors opening). An
increase in temperature, over a range of 40 to 85 degrees Fahrenheit, has been shown
to cause an increase in volatilization of mercury, resulting in greater detected
concentrations.22 Moreover, the lamps processed in Phase II consisted of a mixture
of the Alto® Phillips Lighting lamps (which have lower nominal quantities of
mercury per lamp) and ordinary fluorescent lamps, with higher nominal mercury
content, whereas the Phase I test used Alto® lamps exclusively. Additionally, the
DTC devices were not decontaminated before performing the PVS - Phase II testing,
so the results from Phase II may be biased high due to residual mercury that may
have been in the device before the testing began. These factors may have
contributed to the higher mercury vapor concentrations measured in Phase II.
However, these factors may not have significantly affected the outcome of the
Performance Validation Study because the results in Phase II for the device from
Manufacturer A were not significantly different from  the results in Phase I.

Overall, these data suggest possible deterioration in DTC device performance for the
devices from Manufacturer B and Manufacturer C from Phase I to Phase II, as
measured by the ambient mercury vapor concentration during device operation. For
the Manufacturer C device, airborne concentrations increased by factors of between
two and five, with the most notable decrease in performance indicated in the device
exhaust samples and the drum change samples. For the Manufacturer B device,
airborne concentrations increased by factors  of between two and four, with the most
notable decrease in performance indicated in the device feed tube samples and the
drum change samples.

  4.5    Extended Field Test Study

4.5.1  Extended Field Test #1

The first Extended Field Test (EFT #1) was conducted at the EPSI facility in Phoenix,
Arizona (EPSI Phoenix), during the week of March 23,2003. Temperature and
humidity in Phoenix, AZ for each day of testing were obtained from an on-line
weather service archive.  The average outdoor temperatures during this testing
interval ranged between 63.5 and 73.0 degrees Fahrenheit. The average outdoor
relative humidity ranged between 12.1 and 31.5 percent.     ,

As described in Chapter 3, area and personal air samples were collected using
sampling pumps, and real-time vapor measurements  were recorded on Jerome    . :
analyzers. Originally, all four devices were going to be tested during EFT #1.
However, the Manufacturer D device testing was terminated when mercury
concentrations well above the OSHA PEL value were detected in the device
operator's breathing zone after processing 16 lamps.  The mercury release was likely
 2-Refer to Raposo, Claudia; Windomoller, Claudia Carualhinho; and Junior, Walter Ahxs Durao. 2003. Mercury speciation
   in fluorescent lamps bv thermal release analysis. Waste Management. 23 879-886. and Aucott, et al, 2003. Release of
   Mercury from Broken Fluorescent Bulbs. ]. Air & Waste Manage. Assoc. 53:143-151.
-------
due to the fact that the Manufacturer D device arrived at EPSI Phoenix with a large
crack in the vacuum assembly (refer to Section 3.5.3 for further discussion).

The following table summarizes the number of lamps processed to fill each drum for
the Manufacturer A, Manufacturer B, and Manufacturer C devices, by device.  The
Sampling and Study Plan (refer to Appendix D) specified that enough lamps would be
crushed to fill two 55-gallon drums for each DTC device during each EFT.
          Table 4.10: Total Lamps Processed in Each Device, Extended Field Test #1
•;:'rj;,;'1 Device. j/Vjj,
Manufacturer A
Manufacturer B
Manufacturer C a
Manufacturer D. b
Number of Lamps "- l**'Drum !
684
534
750
16
.JNuinbef of Lamps - ;H Drum -
700
580 .
336
.
     » Refer to Section 3.5.2 for an explanation of the differences between the 1s' and 2nd drums.
     b Refer to Section 3.5.3 for an explanation as to why the Manufacturer D device processed very few lamps.

4.5.1.1 Analytical Air Sample Results

As shown on Figure 4.5, most of the results for analytical air samples collected
during operation of the Manufacturer A, Manufacturer B, and Manufacturer C
devices exceeded the ACGIH TLV value, including all samples collected in the
breathing zone of the operator. A few results from these three devices also exceeded
the OSHA PEL value:

•  The Manufacturer A device exceeded the PEL value on a feed tube sample.23

•  The Manufacturer B and Manufacturer C devices exceeded the PEL value in the
   breathing zone of the operator during the second drum change.

Consistent with the observations made during PVS - Phase I, the Manufacturer D
device was unable to control its air emissions in that both samples collected in the
operator's breathing zone during operation of this device exceeded the PEL value.

For a graphical depiction of the air sample results collected for each DTC device,
refer to Appendix A, Figures 16 through 20. To review the actual results for each
analytical air sample, refer to Appendix A, Table 1. The Data Chem reports are
available in Appendix C.

One possible issue with actual mercury emissions from the DTC devices was the
large number of broken lamps visually identified in the shipping boxes as they
arrived at the facility. The study team suspected that boxes containing broken lamps
were contaminated with mercury vapor existing in air spaces inside the corrugated
matrix of the cardboard, as well as mercury particles absorbed into the cardboard.
Although the broken lamps were recognized as a possible confounding factor  during
23 A visible leak was observed at the feed tube flange of Manufacturer A for the first drum. The cause of the leak was
   determined to be due to a missing flange gasket that was not installed during assembly. After (lie first drum was filled,
   the missing gasket was installed at the feed tube flange for the second drum, and the leak problem was corrected.
-------
EFT #1, no testing to quantify the mercury contribution of the broken lamps and
assess this possibility was done until EFT #2 (the box test discussed in Section 4.6).  .

4.5.1.2 Jerome Mercury Vapor Analyzer Results

Review of the Jerome analyzer readings taken inside the containment structure at
one-minute intervals indicated a similar pattern of measured mercury concentrations
similar to the air sample analytical results (refer to Appendix A, Figure 26). Table 4.11
presents ranges of mercury concentrations measured by both Jerome analyzers,
while testing each DTC device.

            Table 4.11: Jerome Analyzer Measurements, Extended Field Test #1
" I ''«•<.,'- ....-' ^
'•3":- '!'.?;;• " £-^*] *;
Manufacturer A
Manufacturer B
Manufacturer C
Manufacturer D
1ACGIH---
:."/TtV>:::
.^(mgfofl^
0.025
0.025
0.025
0.025
!- osHAx
::;*&>
-(mg/W)
0.1
0.1
0.1
0.1
:; Jerome Mercury Vapor Analyzer Results (mg/m3)
;J fatt'-t
Samples
212
121
140
11
~' ""'<.:.: JCT°nfe #!...••••, ,".
'f-Bangf^';
0.017-0.041
0.021 ^ 0.102
0.036 - 0.211
0.011 - 0.406b
i Mean •
0.027
0.049
. 0.074
0.175
' Jerome #2^
-.,= Range" j.
0.029-0.060
0.026 - 0.131
0.0-0.102
0.0 - 0.580=
 • Jerome #2 was used to measure the concentrations at the device exhaust, at the seal around the drum, adjacent
   to the feed tube, and in the operator's breathing zone.
 b When the unit was started, the readings immediately increased to concentrations above the PEL, and testing
  • was concluded after processing only 16 fluorescent lamps:
 c Jerome #2 was stationed inside the containment structure and recorded similar readings above the PEL.

Mercury concentrations in the ambient air in the headspace of a representative drum
of crushed lamps were also measured using the Jerome analyzer. This activity was
not in the Sampling and Study Plan, but was added in the field. Mot unexpectedly, a
headspace reading of 0.909 rng/m3 was registered above a full drum immediately
after the DTC device was removed from on top of the drum. A reading taken next to
the drum after removing the DTC device from the top of the drum and affixing the
drum lid was considerably lower, as expected (0.03 mg/m3).

While operating the Manufacturer C device, some operational difficulties delayed
the start of testing and may have had an effect on the concentrations measured on
the Jerome analyzers (refer to Section 3.5.2 for further discussion regarding the operational
problems). The Jerome results were above the TLV value and below the PEL value at
the beginning, but increased to exceed the PEL value toward the end of testing.
During the first drum change, the Jerome readings inside the containment structure
slightly exceeded the PEL value; once the drum was changed, readings reverted to
levels between the TLV and PEL values. During the second drum change, readings
were already elevated above the PEL value, and the test was therefore terminated.

For a graphical depiction of each measurement, refer to Figure 4. 6 and Appendix A,
Figures 21 through 25. The graphs also include significant milestones encountered
during the device operation to better understand and interpret the measurements.
                                      47
-------
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      2    2

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-------
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-------
4.5.2  Extended Field Test #2
                                %
The second Extended Field Test (EFT #2) was conducted at the AERC facility in
Melbourne, Florida (AERC Melbourne) during the week of April 28,2003. The
temperature and relative humidity was measured using a Velocicalc instrument.
The average outdoor temperatures during this testing interval ranged between 73.6
and 77.4 degrees Fahrenheit. The average outdoor relative humidity ranged
between 73.9 and 84.4 percent. Indoor temperatures and relative humidity were also
measured and recorded during this test and were as follows:

•  Temperatures: ranged between 80.1 and 89.4 degrees Fahrenheit, with an
   average of 84.9 degrees Fahrenheit.

•  Relative humidity: ranged between 68 and 85.5 percent, with an average of 75.2
   percent

As described in Chapter 3, analytical air samples were collected with sample pumps
and Jerome analyzers. DTC devices from Manufacturer A, Manufacturer B, and
Manufacturer C were tested during the EFTS at AERC Melbourne. Table 4.12
summarizes the number of lamps processed to fill each drum, by device.  The
number of lamps is specific to the unique operation of each device.

         Table 4.12: Total Lamps Processing in Each Device, Extended Field test #2
i Device VK^:':". '";H:
Manufacturer A
Manufacturer B #1 «
Manufacturer B #2 «
Manufacturer C
"Niitaber.bfXamps 
-------
and area air samples were collected during Manufacturer B test #1, and five were
collected during Manufacturer B test #2.  For the first test, four of these samples were
above the PEL value, while only one sample was above the PEL value during the
second Manufacturer B test (refer to Section 3.5.1 /or a description of the two tests).

The samples that exceeded the PEL value during the first test of the Manufacturer B
device included both operator shoulder samples collected during filling of first
drum, the exhaust area sample during filling of two drums, and the feed tube area
sample during filling of two drums. The only sample that exceeded the PEL value
during the second test of the Manufacturer B device was the drum change sample.

For the Manufacturer C device, the only sample that did not exceed the TLV value
was the one collected on the operator's right shoulder, while filling the first drum.
The first drum change sample and both ceiling samples exceeded the PEL value.

For a graphical depiction of the air sample results collected for each DTC device,
refer to Appendix A, Figures 27 through 30. To review the actual results for each
analytical air sample, refer to Appendix A, Table 1. The Data Chem reports are
available in Appendix C.

4.5.2.2 Jerome Mercury Vapor Analyzer Results

Review of the Jerome analyzer readings taken at one-minute intervals indicated a
pattern of concentrations similar to the air sample analytical results (refer to Appendix
A, Figure 35).

The Jerome analyzer was also used to take direct readings of ambient air in the
headspace of a representative drum of crushed lamps. This activity was not in the
Sampling and Study Plan but was added in the field. A headspace reading of 0.619
mg/m3 was registered above a full drum on the morning after lamp crushing, and a
reading of off-scale (>0.999 mg/m3) was registered above a full drum immediately
after filling the drum.  (These data do not directly relate to operator health and safety
because they were not measurements of the air in or near the operator breathing
zone.) Table 4.13 presents the range of mercury concentrations detected by both
Jerome analyzers for each device during EFT #2.

            Table 4.13: Jerome Analyzer Measurements, Extended Field Test #2
                          frOSHA*
                 Jet6me Mercuj^Vapdi Analyzer Results (mgi'm3)
                                  ISarapw-
                                                                   Jerbrtie':#2:
                                                 Rangel;..1:
  Manufacturer A
0.025
0.1
347
0.003-0.046
0.013
0.006-0.06"
  Manufacturer B #1
0.025
0.1
296
0.00 - 0.328
0.078
0.004 - 0.045*
  Manufacturer B #2
0.025
0.1
74
0.021 - 0.177
0.066
0.004 -
  Manufacturer C
0.025
0.1
430
0.008 - 0.128
0.034
0.008 - 0.154'
 1Jerome #2 was used to measure concentrations outside the containment structure, the operator's breathing .
   zone, the device exhaust, and at the feed tube connection to the device.
 b Jerome #2 was used to measure concentrations outside the containment structure.
 c Jerome #2 was used to measure concentrations outside the containment structure, in the operator's breathing
   zone, at the device exhaust, and on top of the device.
-------
Most of the Jerome readings taken inside the containment structure for the
Manufacturer A unit were below the TLV value, with no readings inside the
containment structure above the PEL value. The highest reading (0.046 mg/m3) was
measured during the first drum change. The average concentration was 0.013
mg/m3. Most readings for the Jerome analyzer located outside the containment
structure were below the TLV value, and none exceeded the PEL value.

For the Manufacturer B #1 test, the readings from the Jerome analyzer located inside
the containment structure were consistently above the TLV and PEL values. In
contrast, most'of the readings taken with the Jerome analyzer inside the containment
structure during the Manufacturer B #2 test were above the TLV value, but below
the PEL value. When the drum was changed during the Manufacturer B #2 test,
levels inside the containment structure began to exceed the PEL value.

While bulbs were being crushed in the Manufacturer C device, the readings inside
the containment, structure were consistently above the TLV value but remained
below the PEL value, with the exception of the reading taken during the third filter
change. The highest reading (0.154 mg/m3) was obtained after the third filter
change and adjacent to a full drum of crushed lamps. The average Jerome analyzer
reading inside the containment structure was 0.034 mg/m3. Measurements recorded
by the Jerome analyzer outside the containment structure were below both the TLV
and the PEL values and generally did not exceed 0.010 mg/m3.

For a graphical depiction of each measurement refer to Figure 4.8 and Appendix A,
Figures 31 through 34.  The graphs also include significant milestones encountered
during the operation of the devices to better understand and interpret the
measurements.
                                    52
-------
11111!
 l
Erf
a.
                              u>
                              s
                                                                              CO
                                                                              in
(UI/BUJ
-------
-------
4.5.3  Extended Field Test #3

EFT #3 was conducted at AERC Ashland during the week of June 9,2003.  The
average outdoor temperatures during this testing interval ranged between 70.0 and
79.0 degrees Fahrenheit. The average outdoor relative humidity ranged between
73.0 and 80.6 percent. The indoor temperature and relative humidity were
measured using a Velocicalc instrument.

*  Temperatures:  ranged between 73.0 and 86.2 degrees Fahrenheit, with a weekly
   'average of 81.2 degrees Fahrenheit.

•  Relative humidity: ranged between 54.5 and 74.4 percent, with an average of 63.1
   percent.

As described in Chapter 3, ambient mercury concentrations were measured using
sample pumps and Jerome analyzers, and wipe samples were collected inside the
containment structure on nine surfaces for the Mass Balance Study (refer to Appendix
Ffor wipe sample results). DTC devices from the following manufacturers were tested
during EFT #3: Manufacturer A, Manufacturer B, and Manufacturer C. Table 4.14
summarizes the number of lamps processed to fill each drum, by device. The
number of lamps is specific to the unique operation of each device.

      Table 4.14: Total Lamps Processed in Each Device During Extended Field Test #3
;••-. '/Device1' •,.'
Manufacturer A
Manufacturer B
Manufacturer C
Number of Lamps - lsl Drum.
767 .
594
794
Number of Lamps'- 2™! Drum
719
539
689
4.5.3.1 Air Sample Results

The air sampling results from the Manufacturer B and Manufacturer C devices were
consistently greater than the ACGIH TLV value (refer to Figure 4. 9). Air sampling
results also indicated that the Manufacturer C device and, to a lesser extent, the
Manufacturer B device were prone to excursions above the OSHA PEL value during
EFT #3. This occurred most frequently during drum changes and in ceiling samples.
With the exception of one sample for the Manufacturer B device, the air samples
within the operator's breathing zone (shoulder samples) were the TLV and PEL
values during the Manufacturer B and Manufacturer C tests.  In contrast, during'the
Manufacturer A test, breathing zone concentrations remained below the TLV value.
25 No samples taken during the Manufacturer A test exceeded the  PEL value.

For a graphical depiction of the air samples collected for each DTC device, refer to
Appendix A, Figures 36 through 39. To review the actual results for each analytical
^ It is important to note that the drum-change and ceiling samples are not time-weighted averages (TWA) and should not
   be compared to the TLV, which is a TWA. The PEL far mercury was promulgated as a ceiling value in 1971 (36 FR
   10505, May 29,1971).  A memorandum to OSHA compliance personnel was issued on September 3,1996, that directs
   compliance officers to issue citations only when an aoerexposure exceeds 0.1 rng/m3 as an 8-hour TWA.
                                      55
-------
air sample, refer to Appendix A, Table 1. The Data Chem reports are available in
Appendix C.

4.5.3.2 Jerome Mercury Analyzer Results

The field team experienced software performance problems while attempting to
record the mercury concentration on both data loggers attached to the vapor
analyzers during EFT #3. During testing of the first device (from Manufacturer A),
the Jerome analyzer appeared to be communicating properly with the data logger
(i.e., it was automatically collecting samples at one minute intervals); however, upon
downloading the data from the data logger, it was discovered that the data logger
had not recorded any measurements. Therefore, there are no logged readings or
manual readings for the Jerome analyzer for the Manufacturer A device for EFT #3.
Also, due to time constraints, the study team was not able to take readings of the
mercury concentration in the head space of a full drum as was done previously.

Review of the Jerome analyzer readings indicate a similar pattern of measured
mercury concentrations, compared with the analytical air sample results (refer to
Appendix A, Figure 43). Table 4.15 presents a range of results from both Jerome
analyzers for the devices from Manufacturer B and Manufacturer C.

           Table 4.15: Jerome Analyzer Measurements, Extended Field Test #3
4 ?fs^3pv.^
«.-- > V ih «r
* s Device *^ -g
- rX*c^:
Manufacturer B
Manufacturer C
IAGCIH.
SiiV,.11
Wm»)F
0.025
0.025
', ? . -l •* *%
OSHAPEIi
Vjtawj^*, .'
0.1
0.1
y>\ Mercury,Vapbr'AnalyzerResult8 (mgfoi^l
!" #af'j',
Samples!
234
218
s,u/V Jerome #lt^ C
j^ Range? ".
0.009 - 0.258
0.008-0.121
Mean
0.051
0.040
-' Jerome f 2W*
' Range i,
<0.003- 0.017
0.008-0.02
  • Jerome #2 unit was kept outside of the containment structure during EFT #3.

For the Manufacturer B device, most measurements (except right after startup) were
above the TLV value. There were two sets of excursions above the PEL value. After
approximately one hour of operation, readings increased to a maximum of 0.26
mg/m3 and remained above the PEL value until the first drum change (10 readings
within nine minutes). After the drum change, a total of four exceedances were
recorded before levels dropped to between the PEL and TLV values and then
stabilized. Just before the second drum change, a reading of 0.13 mg/m3 was
registered. After the second drum change, all levels remained below the PEL value
and stabilized in a range just above the TLV value, until the conclusion of the test.
During operation of the Manufacturer C device, nearly all of the readings (except
right after startup, including startup after the first drum change) were above the TLV
value. There was also a brief excursion above the PEL value, three readings within
an eight-minute period, right before the first drum change. The highest reading
registered during this period was 0.12 mg/m3.

For a graphical depiction of each measurement, refer to Figure 4.10 and Appendix
A, Figures 40 through 42. The graphs also include significant milestones
encountered during the operation of the devices to better understand and interpret
the measurements.
                                     56
-------

 o      o      o       o
eui/Bui UOIJBJJUSOUOO Ainojsw
-------
ui/6uj uogejquaouoo Ajnoiew
-------
   Figure 4.13: Analytical Air Sampling Results, Extended Field Test Study - Manufacturer C *


0250

0225

0200
„
•a °'175
E
% 0.150
C 0.125
g 0.100 •
z
0.075 •


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—PEL (0.1)

	 TLV (0.025)




PEL







' TLV
. 0.025 mt)/m]



2 ... 2 • 1st 1st 2nd 2nd . Exhaust . Feed Filter Drum Filter .Drum 1st . 2nd
Drums Drums Drum Drum Drum Drum Tube Change Change Change Change Ceiling Ceiling
RS LS RS LS RS . . LS
  • Hie TLV is included on the graph as a point of reference. The analytical air samples shown on this graph do not represent
   eight-hour TWAs (refer to Appendix A, Table 1 for sample durations).

In comparing performance over time (i.e., EFT #1, EFT #2, and EFT #3), not all of the
air samples could be included.  This'was because no ceiling samples were taken for
EFT #1. The ceiling samples were designed to assess maximum operator exposure.
Therefore, inclusion of the samples would skew any statistical comparisons.
Comparisons were based on the personal samples during operation and during filter
changes and drum changes, the area samples within the containment structure, and
the overnight samples within the containment structure (refer to Section 4.7).

The Manufacturer A device had significantly poorer performance during EFT #1
than during EFT #2 and EFT #3 (95 percent confidence). This was most likely due to
a problem with assembly of the device in that test (refer to footnote 23 in Section
4.5.1.1). There was no significant difference in the performance of the Manufacturer
B device or the Manufacturer C device during the EFTS.

  4.6    Box Tests

During the first two portions of the Study (PVSI and EFT #1), the study team
recognized that lamps that were broken in their shipping boxes could contribute
mercury to the air in the containment structure during operation of the DTC devices
and confound the air sample results. In order to evaluate and quantify the
contribution of mercury to ambient mercury concentrations inside the containment
structure by broken lamps, air samples were collected at AERC Melbourne and
AERC Ashland, during EFT #2 and EFT #3, respectively.
-------
4.6.1   AERC Melbourne Box Test

As described in Section 3.5.1, the Manufacturer B device was tested twice during
EFT #2. The first test was performed with boxes of broken lamps inside the
containment structure, while the second test was performed without the boxes of
broken lamps inside the containment structure. During both tests, personal air
samples were collected during drum filling and drum changes, and area samples
were collected near the device exhaust and near the device feed tube.

Four out of six sample results collected during the Manufacturer B #1 test exceeded
the PEL value, and one out of the five sample results collected during the
Manufacturer B #2 test exceeded the PEL value. The fact that 66.7 percent of the
samples in test #1, when there were boxes with broken bulbs inside the containment
structure, exceeded the PEL value, while only 20 percent of the samples in test #2,
when there were not boxes inside the containment structure, exceeded the PEL value
suggests a relationship between storing boxes of broken lamps inside the
containment structure and elevated mercury concentrations.

The Jerome analyzer was used to measure mercury concentrations when the
crushing activity had ceased and when boxes of broken bulbs were present inside
the containment structure (refer to Figure 4.14).
        Figure 4.14: Jerome Results - Inside Containment, AERC Melbourne Box Test *
    0.5-
    0,4-
                                                                 -•-T Jerome Data .
                                                                 • •»-• Regression Data
                                                                 	Linear Regression
                                                                 	PEL {0.1)
                                                                 	TLV (0,025)
The regression line and correlation coefficient only
include data points after the spike at 6 minutes (i.e.,
only data points represented as "regression data"
were included in these calculations).
       0    0.003125  0.00625  0.009375  0.0125  0.015826  0.01375  0.021675   0.025  0.028125  0.03125
                                    Time (mlnute:seeond)
  • The TLV is included on the graph as a point of reference. The mercury concentrations shown on this graph represent
   instantaneous measurements and do not represent eight-hour TWAs.

After an initial spike in mercury concentration to 0.6 mg/m3, measurements
dropped below the PEL and then steadily increased over time. After 30 minutes, all
readings were above the PEL. There was a positive correlation (R2 = 0.7728) between
-------
 mercury concentrations and time. These results show that it is highly likely that the
 boxes containing broken lamps did contribute to increases in mercury concentrations
 within the containment structure.           .    .

 4.6.2 AERC Ashland Box Test

 For each device, after conducting EFT #3, two new air sampling pumps were set up
 in the containment structure. Boxes containing broken bulbs were placed in the
 containment structure, but no crushing activities were performed. One analytical air
 sample was collected on the east side of the containment structure, next to the boxes,
 and one was collected on the west side of the containment structure, away from the
 boxes. Samples were collected for 36-64 minutes (refer to Appendix A, Table I for
 sample durations).  Table 4.17 contains the air sampling results for the box test
 conducted at AERC Ashland.
                    Table 4.17: Results for AERC Ashland Box Test
"-, V* ~x ^ • * • •'-*•* .
»=it-i peyke ''~\?
. ,*,st-**^^fc i*~ ,r,,. 3° •*
Manufacturer A
Manufacturer B
Manufacturer C
: East Side of Containment .i
-;:' • * -ijNexf^BbJces) ?»:,.:•*.;
0.018 mg/m3
0.12 mg/m3
0.050 mg/m3
" /West Side of Containment '
•i.!J.^;'.:( Away •from. Boxes) ., ,, .,
0.10 mg/m3
0.12 mg/m3
0.014 mg/m3
'"•'•/:. Sample;; ;
j Duration (min)
64
36
45
 While three of the six samples met or exceeded the OSHA PEL, there was no
 correlation between sample location (proximity to boxes with broken lamps) and
 mercury concentration. The Jerome analyzer was used at the same time as the
.analytical air samples, but the readings are not available due to data logger failure.
 No manual Jerome readings were taken because there was not anyone in the
 containment structure during the box tests.

 The results from the AERC Ashland box test do not suggest that the broken bulbs in
 the boxes contribute to elevated mercury concentrations because there was no
 relationship between the concentration of mercury in the air and the proximity of the
 air sampling pump to the boxes of broken lamps. However, direct-reading data are
 not available, so it is not possible to determine whether or not the trend of increasing
 mercury concentrations in the containment structure over time that was observed in
 the AERC Melbourne box test is truly representative of what would happen in such
 a scenario (i.e., boxes containing broken bulbs being stored in a confined space).
 Therefore, this is an area where future research may be appropriate.

  4.7    Overnight Samples
»-
 In order to ascertain whether measurable amounts of mercury escaped from the DTC
 devices during non-operational periods when the devices were assembled on the top
 of a drum full of crushed lamps, analytical air samples were collected overnight after
 the operation of each DTC device. The Manufacturer A device blower was kept
 running (per the manufacturer's instructions) during the overnight test In
 accordance with the manufacturers' instructions, the power to the Manufacturer B
-------
and Manufacturer C devices were shut down when the devices were not in use. The
results of the overnight tests are presented in Figure 4.15.
                     Figure 4.15: Overnight Test Sample Results
                                                                     PEL
                                                                   0.1 mgftn*
   0.0875
   0.075 •
   0.0525
    0.05-
   0.037S •
   0.025
   0.0125
  • Exhaust
ES3 Feed Tube
EZ] Outside
  "PEL (0.1)
  -TLV (0.025)
                                                                      TLV
                                                                    0.025 mgfin*
Because overnight samples were collected to assess general release during non-
operational periods, values should not be compared to the OSHA PEL or the ACGIH
TLV, which is a standard for worker exposure during a regular work day. The lines
for the PEL and the TLV are included on the graph as points of reference.  The
overnight sampling was inconclusive as to whether idle DTC devices attached to
partially filled drums of lamps leaked mercury vapors. The concentrations
measured overnight were variable.  In EFT #1, the overnight sample collected for the
Manufacturer A device near the exhaust was much higher than any of the other
samples. This may somehow relate to the fact that the Manufacturer A device was
the only device that was left on overnight, per instructions in the operations manual.

In EFT #2 and EFT #3, air samples were collected outside the containment structure,
as well as inside the containment structure. The overnight samples collected in the
containment structure after operating the Manufacturer A device were below the
values measured outside the containment structure. Three of the four  overnight
samples collected inside the containment structure after crushing lamps for the
Manufacturer B device measured above the levels measured outside the containment
structure. All four of the overnight samples collected inside the containment
structure during EFT #2 and EFT.#3 for the Manufacturer C device were higher than
the outside samples.  ;
-------
  4.8    U-TubeTest

The Manufacturer B and Manufacturer C devices have attachments that enable them
to process "U" tube lamps (U-tubes). As discussed in Section 3.1.4.2, at the end of
EFT #3 at AERC Ashland, a test was conducted to evaluate the airborne mercury
levels from the two devices while processing U-tubes. The intent was for both the
Manufacturer B and Manufacturer C devices to process enough U-tubes to fill a 55-
gallon drum. However, the facility was only able to collect a limited number of U-
tubes for the U-tube study, so the available U-tubes were divided between the two
devices. The Manufacturer B device processed a total of 85 U-tubes, and the
Manufacturer C device processed a total of 89 U-tubes.  The sampling duration was
12 minutes for the Manufacturer B device and 14 minutes for the Manufacturer C
device. The U-tube air sampling results  are presented in Appendix A, Table 1 and
shown in Figure 4.16.
                       Figure 4.16: U-tube Test Sample Results3
   0.1000
   0.0875 •
   • 0.0750 •
   0.0625
   0.0500
   0.0375
   0.0250
   0.0125 f
   0.0000
                                                                      PEL
                                                                    0.1 mg/m3
 •••Mfg. B

 SI Mfg. C

 —TLV (0.025)

. 	HydrarBkgd
I   (0.0166)
  ~ Jerome Bkgd
   (0.014)
  —PEL (0.1)
Note: Manufacturer A
device cannot
process U-Tubes.
   TLV
0.02S mg/m3
         Left Shoulder of Operator Right Shoulder of Operator
                                           Exhaust •
                                                          Feed tube
  * The TLV is included on the graph as a point of reference. The analytical air samples shown on this graph do not represent
   eight-hour TWAs (refer to Appendix A, Table 1 for sample durations).  '

All samples, except for the Manufacturer B sample on the operator's right shoulder,
were above the TLV value. Furthermore, two of the operator breathing zone
samples (one for the Manufacturer B device and one for the Manufacturer C device)
equaled or slightly exceeded the PEL value. These levels are generally higher than- «
the results from processing the straight lamps, especially in light of the fact that so
few U-tubes were processed by each device. A possible explanation for the high
mercury levels is the fact that the opening for the U-tube attachment was much
larger than the opening for the feed tube for the straight lamps.
-------
5.    MASS BALANCE STUDY

The goal of the Mass Balance Study was to estimate for each DTC device its
effectiveness in capturing and retaining mercury in the device, expressed as a
percent of the total mass of mercury fed into the DTC device.  A successful Mass
Balance Study would also allow assessment of the total mercury released to the
environment due to DTC use, and also to support assessment of potential secondary
exposures to mercury from lamp crushing.  For each DTC device, the total mercury
contained in enough lamps to fill one drum was estimated, and this quantity was
then compared with the total mercury detected in samples collected during PVS -
Phase I, including: crushed lamps from the drum, DTC pollution control media
(particulate, HEP A, and carbon filters), and analytical air samples. See Section 5.1
for the mathematical mass balance equation.

The following sections describe the methodology for, and present the results of, the
Mass Balance Study. Note that these results represent the best achievable efforts
based on the techniques, methods, equipment, and conditions tested. In some cases
(e.g., estimating the quantities of mercury in the unprocessed lamps), there are no
agency-approved test methods; therefore, it was necessary to rely on either the
manufacturer's internal testing results (i.e., QC testing) or on the results from the
methods improvised by the project laboratory, which were intended to simulate the
manufacturer's test apparatus. The objectives of this project were strictly research
and investigation, and the data generated may or may not be suitable for other
purposes, such as human health risk assessment.

  5.1    Mass Balance Equation

The mass balance mathematical equation is:

      Hgr=Hgc + HgR               '                       Equation 5.1
      where: Hgr is the estimated total mercury content of unprocessed lamps
             Hgc is mercury captured in the DTC device (specifically within the
                 air filter media or "filters" and crushed lamps)
            - HgR is mercury released to the ambient air from the DTC device -
Hgj is determined by the average quantity of mercury in a typical fluorescent lamp,
multiplied by the number of lamps processed in the DTC device (refer to Section 5.2),
Hgc is determined by the quantity of mercury measured in the crushed lamps and in
the various filters (refer to Section 5.3). HgR is determined by the quantity of mercury
measured in the ambient air within the containment structure, as determined by area
and personnel air samples (refer to Section 5.4).

  5.2    Estimating Total Mercury Content of Unprocessed Lamps (Hgr)

As mentioned above, the first important step in the Mass Balance Study was to
estimate the input mercury, or the quantity of mercury contained in a typical set (i.e.,
one drum's worth) of unprocessed lamps. In theory, this amount should be 100
percent of the total mercury available for potential release to the crushed lamps, the
-------
air filtration system, and as fugitive emissions to the surrounding indoor air.  Any
difference between this amount and the total of the component terms on the right-
hand side of Equation 5.1 thus is a measurement of the potential error in this study.

Philips Lighting (Philips) "Alto®" fluorescent lamps (also referred to as "green tip"
lamps) were used during this part of the DTC Study.  According to e-mail
correspondence from Mr. Steve McGuire of Philips to Mr. Tad Radzinski of EPA,
these lamps are manufactured to achieve a specific mass content of mercury,
depending on the type of lamp (Table 5.1)/ and the tolerance on the mercury content
is +/- 0.1 mg of mercury. The mercury content is determined using a test procedure
and testing apparatus that Philips has developed specifically for this purpose.
Energized (lighted) mercury lamps are attached to the testing apparatus and then
chilled using dry ice or other super-cooled vapor.  The cooling process condenses the
mercury vapor, eventually causing the light to be extinguished. After cooling, a hole
is drilled in the metal end cap of the lamp, and an acid extraction method is used via
the hole in the metal end cap to recover the mercury for quantitative analysis (refer to
Appendix E).               '                 ,.
          Table 5.1: Mass of Mercury in Philips Lighting Alto® Fluorescent Lamps

                                                   i;;;;cse:™'-;!'"Wixi^^r"a;;ii;'^r.y^i;ss^r!.'i; f ••
                  T-8
3.5
+/-0.1
              T-12 (34 Watt)
4.4
+/-0.1
              T-12 (39 Watt)
3.5
+/- 0.1
              T-12 (40 Watt)
4.4
+/-0.1
In order to approximate real-world operating conditions for the DTC Device Study,
spent lamps were processed.  To obtain data regarding the mercury content of the
spent lamps, a sample of unbroken, Alto® lamps were removed from the stockpile
and submitted to Data Chem for analysis of total mercury. These results are
contained in Table 5.2. The data are generally lower than the results provided by
Philips for new lamps. This difference is possibly due to small leaks of mercury that
occurred during the operating lives of the lamps. Other factors, such as reaction of
mercury vapor with lamp components leading to conversion of elemental mercury
into salts, dissolution of the mercury into the lamp glass, or binding of mercury to
other lamp components, might contribute to this disparity but were not a subject of
this study. (The reaction of mercury vapor with lamp components was studied by
Hildenbrand, et al.26 and Jang, et al. 27)                           :
26 Refer to Hildenbrand, V. D.; Denissen, C. J. M.; Geerdinck, L. M.; van der Morel, C; Snijders,}. H. M.; and Tamminga,
   Y. 2000. Interactions of thin oxide films with low-pressure mercury discharge. T7rin Solid Films. 371:295-302.
** Refer to Jang, Min; Hong, Seung Mo; and Park, Joe K. 2005. Characterization of recovery of mercury from spent .
  'fluorescent lamps. Waste Management. 25:5-14.
-------
        Table 5.2: Total Mercury in Spent Philips Lighting Alto® Fluorescent Lamps *
                                                           Standard Deviation
           T-8
                                 3.0
                          2.9
                                 3.1
     3.0
<10-15mg/kg)
0.082
       T-12 (34 Watt)
                                 4.2
                          4.4
                                 4.1
     4.2
(14-21mg/kg)
0.12
       T-12 (40 Watt)
                                 4.3
                                 2.8
                                           3.6
                                      (12-18mg/kg)
                     0.75
1 No samples of T-12 39 Watt lamps were available for this analysis.
The total mass of mercury in the lamps processed in each DTC device was estimated
using the total number of each type of lamp processed and the mean mercury
content of each lamp, as shown in Equation 5.2.
Hgt
                Hgt
                 Equation 5.2
      where:  Hgr is the estimated total mercury content of unprocessed lamps
              Nt is the total number of lamps processed
              Hgt is the mean mercury content of a single lamp

Means for mercury content for each lamp type were determined from either the
unbroken lamp samples collected during the study or the information provided by
Philips Lighting. In general, use of the study sampling results was preferred, except
in the case of the T-12 39 Watt lamp type, where no data were available (see footnote
to Table 5.2). The rationale for using the study data over the manufacturer's
averages was that the unbroken lamps were obtained from the broader collection of
actual used lamps arriving at die respective facilities and thus were believed to be
more representative for this study.

After the conclusion of the DTC Study, research was published regarding the
efficacy of acid extraction of mercury from fluorescent bulbs (refer to footnote 27 is
Section 5.2).  This issue is discussed further in Sections 5.6 and 5.7.

Table 5.3 provides an inventory of the types of lamps processed by each device and
the estimated total mass of mercury processed"through each device during the Mass
Balance Study  (Hgr).
-------
                Table 5.3: Mass of Mercury Processed for Each DTC (Hgx)
L-.,\': ...'Device'.".*- '„,-'
i'V- J:f''V--
Manufacturer A
Total - HgT
Manufacturer B
Total -Hgr
Manufacturer C
Total - Hgr
.i'/.Latajp.'tjrpe!. '
• ,j
1-12 (34 Watt)
; Number of •;;
' Lamps',.,. "
.•./"•' •'"'
637
Amount ot . :
Mercury per Lamp -
(mg/lamp) .
4.2
' Total ''Quantity V
of Mercury (mg)
2,675
2,675 mg
7-12(34 Watt)
T-8
113
611
4.2
3.0
475
1,833
2,308 mg
T-12 (34 Watt)
T-12(39Watt)
T-12 (40 Watt)
621
49
36
4.2
3.5
3.6
2,608
172
130g
2,910 mg
  5.3    Estimating Mercury Mass Captured in the DTC Devices (Hgc)

Mercury was captured inside the DTC devices in either one of two ways:

•  Contained within the crushed lamps collected inside the 55-gallon drum beneath
   the device; or

•  Retained as particulate or vapor air emissions retained within the air filtration
   system that was supplied with the particular device (listed in Table 5. 4).

Section 3.3 provides details regarding the collection of bulk samples, including
crushed lamps and pollution control media, for each device. Table 5.4 summarizes.
the number and type of bulk samples.

                            v
                 Table 5.4: Samples Collected for the Mass Balance Study
Manufacturer A Device : ',..
- . » : .- 	 •...•.•:•._. .* --•.:...•:•.- 	 • 	 •. .. • ...,:- .
Crushed lamps - 3 samples
Top carbon canister - 3 samples
Middle carbon canister - 3 samples
HEPA filter - 3 samples
Manufacturer B Device ; -,;
Crushed lamps - 3 samples
Pre-filter - 1 sample
Carbon canister - 3 samples
Manufacturer C Device '
Crushed lamps - 3 samples
Pre-filter - 3 samples
Carbon canister - 3 samples
HEPA filter - 1 samples
The analytical results for the samples collected for Manufacturer A, Manufacturer B,
and Manufacturer C devices are provided in Table 5.5.  Samples from the
Manufacturer D device are not presented below because the Manufacturer D device
was removed from the Study (refer to Section 3.5.1).28
2° During the Mass Balance Study, when only "low mercury" lamps were used and outdoor temperatures were
   low, operation of the Manufacturer D device resulted in ambient mercury concentrations nearly 9 times the
   OSHA PEL, highlighting the problems inherent in the use of a poorly designed DTC device.
-------
                         Table 5.5:  Mass Balance Study Sample Results
i" * Die Device :
>' * *.„ •; >••"•:
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturers
Manufacturer B
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C .
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
-">•".•;' <•»•"• (,-.. >•:• ... *•;•> *.,,<
! /.i'VSainpIe-.Materials: '.' '.•
: ;:>~vt: ;' /:. ''".." ;* "'• •''. :•* „
Crushed Lamps
Crushed Lamps
Crushed Lamps
Carbon Canister (top)
Carbon Canister (top)
Carbon Canister (top)
Carbon Canister (middle)
Carbon Canister (middle)
Carbon Canister (middle)
HEPA Filter
HEPA Filter
HEPA Filter
Crushed Lamps
Crushed Lamps
Crushed Lamps
Pre-Filter c
Carbon Canister
Carbon Canister
Carbon Canister
Crushed Lamps
Crushed Lamps
Crushed Lamps
Pre-Filter c
Pre-Filter c
Pre-Filter'
Carbon Canister
Carbon Canister
Carbon Canister
HEPA Filter
Result;(w/w)"
* ", ^- •'; " ..**.;
5.84 ug/g
2.70 ug/g
2.57 ug/g
84 ug/g
34 ug/g
68 ug/g
39 ug/g
5.0 ug/g
1.7 ug/g
NA
NA
NA
5.17 ug/g
4.59 ug/g
5-56 ug/g
490 ug/g
11 Hg/g
19 ug/g
35 ug/g
6.07 ug/g
5.58 ug/g
2.43 ug/g
180 ug/g
180 ug/g
180 ug/g
2-7 ug/g
6.0 ug/g
8.8 ug/g
NA
/Result (Wa)T
'• ' i "' *' '
NA'
NA
NA
NA
NA
NA
NA
NA
NA ,
4.2ug/100 .
cmj
6.7 ug/100cm2
5.6ug/100cm2
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2.3 ug/100
cm2
Mean Result .
3.70 ug/g
62 ug/g
15 Hg/g
5.5 ug/100cm2
5.11 ug/g
490 ug/g
22 ug/g
4.69 ug/g
180 ug/g
5.8 ug/g
2.3 fig/100 cm2
St
-------
      The device, manufacturers were instructed to submit clean filter media to Data Chem
      for quality control (QQ samples. These clean materials were used for laboratory
      blanks and matrix spikes. The blank sample values are shown in Table 5,6. The
      spike values and recoveries are listed in Table 5.11 and discussed in Section 5.6.2.
      Table 5.6 also presents the weight or area information for the samples, as applicable. '
      Results are reported as either a mass of mercury per weight or a mass of mercury per
      area. The methods used to measure the weight of the samples are described in
      Section 3.3. The manufacturers provided the nominal areas of each type of filter
      used in the various devices. Prior to performing the mass balance calculations, all
      values were converted from standard units (i.e., pounds [Ib] or square inches [in2]) to
      metric units (i.e., grams [g] or square centimeters [cm2]). Table 5.7 presents the
      measured mass of mercury captured in each of the different media (i.e., [mean"
      concentration]*[applicable weight or area]), in milligrams (mg).

         Table 5.6: Total Weights, Areas, and Blank Mercury Concentrations of Bulk Sample Media
 -.g/g
150,139 g
25.4 g
337 g
767
12
7.4
786
Crushed Lamps •
Pre-Filter ,
HEPA Filter
Carbon Canister
4.69 ug/g
180 ug/g
2.3ug/100cm2
5.8 ug/g
197,766 g
263 g
1,250 cm2
9,979 g
928
47.3
0.029
.58
1,033
-------
  5.4    Estimated Mercury Released To The Ambient Air
The total mass of mercury released to the ambient air from each DTC device (HgR)
was estimated using the air sampling data collected during PVS - Phase I. The
method for calculating HgR is shown in Equation 5.3.
                                                            Equation 5.3
      where: HgR is mercury released to the ambient air from the DTC device
             NAE is the estimated number of air exchanges
             [Hg] mean air concentration in containment structure during PVS I
             V is the volume of the containment structure

The mean of the four area air sample results (two samples at the feed tube and two
samples at the device exhaust) was calculated for each DTC device. The
containment structure measured 12 feet by 12 feet by 10 feet, for a volume of 1,440
cubic feet (ft3), which converts to 40.78 cubic meters (m3).

During the operation of all devices, movement in and out of the containment
structure was limited to supplying boxes of lamps to the operator and the industrial
hygienist collecting the air samples, thus limiting (to the extent practicable) the
exchange of air between the containment volume and the outside. In addition, as
described previously in Section 22, the construction of the containment space itself
(e.g., taped and overlapping plastic sheeting) aided in isolating the space and
limiting air movement. While the number of air exchanges was not specifically
measured, it was estimated using Equation 5.4.
                                                            Equation 5.4
      where: NAE is the estimated number of air exchanges
             Q is the volumetric flow rate of air coming out of the device exhaust
             t is the duration of the area air sampling
             V is the volume.of the containment structure

Table 5.8 presents the mean mercury concentrations in the air samples and the
estimated mass of mercury released (HgR) for each device:
                 Table 5.8: Mercury Released from DTC Devices (HgR)
;,- - DeykeT"1/. ^P:;
'-,; •; _,••• •' '; ,.-.i '•••-:
Manufacturer A
Manufacturer B
Manufacturer C
;_-^,. ...... ,,
..:«**rlOWi-i,J
--Rate'^'
^tymin),
25»
34 *
42 b
pTftmfe-'.
(min);
112
86
100
'^Numfcfer^
i / of Aiirl V?
Exchanges
1.9 '
2.0
2.9
iMeah.Metcury . :
-•' :-.*.• '.I!" •'•- . .:•",•'., ,
\. .Concentration^
"(mg/m>)
0.0094
0.010
0.0095
Volume .
'•''•? •(*$•*-•
40.78
40.78
40.78
:Sfercury"
Released

0.75 mg
0.82 mg
1.3 mg
   • Estimate from owner's manual.
   b Measured during operation.
-------
While the reported values for the number of air exchanges are estimates, they do not
significantly affect the mass balance because HgR « Hgc (refer to Table 5.9).

Originally, it was also intended to include the wipe sampling results from the
interior surfaces of the polyethylene containment structure, to attempt to quantify
the contribution of mercury vapor condensation to the overall mass balance.
However, this process was impacted by the unexpectedly high ambient
concentrations of mercury inside the facilities.  Due to these high ambient
concentrations, it would not have been possible to effectively differentiate mercury
vapors released by the device and condensing on the polyethylene sheeting from
vapors already existing in the air arid condensing on the sheeting. Furthermore,
some of the mercury mass might have been double-counted under such a scenario.
Therefore, wipe sampling results were excluded from the Mass Balance Study.  Refer
to Appendix F for a discussion of the wipe sample results.

  5.5    Mass Balance Results                                         ,

Sections 5.2,5.3, and 5.4 described the methods used to derive the mass of mercury
that was used in the mass balance calculations. Table 5. 9 is a summary of the total
mass of mercury contributed by each source.

              Table 5.9: Summary of Mercury Mass Contributions, By Source
•'' ' '' Device. lV<^--
.'.»'••-. ' *•'•''•'• 1
; ". .. ' < • '".. ^.- ' ' **
Manufacturer A
Manufacturer B
Manufacturer C
• -'":: '"„.*' ~. r '.'.-;""".,.'•;>'«#-' . '• ": "/•:' '••."-. '.."•' V.--
',. '" •. 'Crushed »'"
• . ;;':tarhpsv; :
782 mg
767 mg
928 mg
iPte-Hlter •
.... i ...:. 	 *.,,, i
NA
12 mg
47.3 mg
••:.- HEPA
, Filter
2.7 mg
NA
0.029 mg
' ; Carbon
Canister{s)
1,013 mga
7.4 mg
58 mg
•/" Total •.;
1797.7 mg
786.4 mg
1033.329 mg
'. i-'Hgil-: •:
0.75 mg
0.82 mg
1.3 mg
 * Combined recovery by the top and middle carbon canisters on the Manufacturer A device.

 Table 5.10 contains the results of the mercury mass balance calculation for each
 device, as well as the percentage of mercury accounted for compared to the
 estimated mass of mercury processed (i.e., the mercury content of the unprocessed
 whole lamps). •
                     Table 5.10: Mass Balance Calculation Results
•j. • ••-••Device ',
Manufacturer A
Manufacturer B
Manufacturer C
; Hg Processed ,
:•-'•:., $pK';V:
2,675 mg
2,308 mg
2,910 mg .
Hg Recovered :
•..'^^^'Y1
1,798 mg
787 mg
1,035 mg
% Recovery
rt: •% "; ' ' -; •'• ' '~
67.3 %
34.1 %
35.6%
-------
  5.6    Mass Balance Discussion

Based on the mass balance results obtained from this study and presented in Table 5.
10, the total mercury mass accounted for (Hgc + Hgn) was about one third to two
thirds less than the estimated input of mercury (Hgr).  Several variables may have
contributed to the inability to account for a fairly large percentage of the mercury.
Three of the most likely variables that would affect tine mass balance are: 1)
inaccuracies in the determination of mercury in the crushed lamps; 2) inaccuracies in
the determination of mercury in the filter media due to poor recovery during the
laboratory analysis; and 3) absorption of mercury on polyethylene (the containment •
structure) and inside the DTC device. In addition, there is no approved laboratory
procedure to estimate the mercury content of whole fluorescent lamps, making this
factor another possible cause of the imbalances noted during this study. '

5.6.1  Mercury Mass in Crushed Lamps

As indicated by the results summarized in Table 5.9, a substantial fraction of the
mercury produced during the crushing of lamps in the DTC devices accumulates  in
the crushed lamps. Therefore, this variable has a substantial influence on the mass
balance results. It was closely studied to attempt to understand the reason for the
disparity between the total mercury mass in the lamps before processing and the
mercury mass accounted for after processing.

The proportion of the total mercury mass detected (Hgc + Hgn) in the crushed lamps
was 43 percent for the Manufacturer A device/97 percent for the Manufacturer B
device, and 90 percent for the Manufacturer C device.  The lower percentage
observed for the Manufacturer A device can be attributed to the relatively larger
capture of mercury mass in the more extensive air filtration equipment (HEPA filter
and carbon filters) associated with this device. As can be noted from Table 5.9, the
actual mercury mass in the crushed lamps from each of the three devices are similar
(having the same orders of magnitude).

The sample results for the crushed lamps for all devices in general may have been
biased low, for three reasons.

•  The method of collecting the samples of crushed lamps involved digging as deep
   into the drum as possible to collect the samples. However, due to the high
   density of the crushed lamps (caused by the unaided compaction of the crushed
   glass and other debris), the samples could only be collected at a depth of
   approximately eight inches.  The operation of each DTC device causes the drum
   to vibrate, and this vibration may have caused the phosphor powder fraction of
   the crushed lamps to stratify vertically within the drum.  An analysis of the
   crushed lamps components indicates that the majority of the mercury will be
   condensed onto this fine phosphor powder (refer to Appendix G), thus causing an
   unequal distribution of mercury mass with lower concentrations on top.  Jang, et
-------
   al. (2005)29 and Raposo, et al. (2003)30 provide further information on the
   distribution of mercury in spent fluorescent lamps.  Because of this likely
   distribution of phosphor powder in the drum, samples collected at a depth of
   eight inches would likely not be representative of the contents of the drum.

•  Some mercury likely volatized and-was released during the collection of the
   crushed lamps samples from die drum, compositing the samples, and transfer of
   the material to the sample containers.

•  Additional.handlirig and sorting of the composite samples at the laboratory may
   have resulted in further volatilization of mercury.

Due to a miscommunication between Booz Allen Hamilton and Data Chem, the   .
laboratory initially analyzed only the phosphor powder and glass fines portion of
the crushed lamps bulk samples. The results for the mercury concentration in
crushed lamps that were obtained in this first analysis were greater than the mercury
concentrations in unbroken lamps by an order of magnitude.
                     i                                           "*
When this error was identified, the laboratory was instructed to analyze the
remaining crushed lamp sample material (i.e., the broken glass and lamp end caps).
The combined results from both analyses were used to estimate mass of mercury in
the crushed lamps for the mass balance. Appendix G presents a discussion of the
two sets of results.

5.6.2  Mercury Mass in Air Filtration System Elements

An important variable in the mass balance equation is the analytical results for
mercury in the various air filtration media associated with the DTC devices. As
discussed below, the laboratory-reported concentrations of mercury from the carbon
media and the HEPA filters contained significant errors. Because the pre-filters were
easily accessible  and the amount of material collected in the pre-filters was limited,
the pre-filter sampling data are likely to be accurate, and thus, the efforts to identify
probable sources of error focused on the HEPA filters and the activated carbon.

Laboratory spike samples were prepared and analyzed, to assess potential matrix
interferences-from the filter or carbon media, as applicable. Manufacturer A,
Manufacturer B, and Manufacturer C were contacted and instructed to submit clean
filter media samples to Data Chem. Manufacturer A and Manufacturer C each
submitted a HEPA filter and carbon canister, and Manufacturer B submitted its
composite filtration cartridge, which consists of a particulate/pre-filter and a carbon
canister. The quantity of mercury with which to spike each media was based on the
results obtained  during prior DTC device tests in this study. Data Chem prepared
and analyzed four spike samples and two blank samples per media.
29 Refer to Jang, Min; Hong, Seung Mo; and Park, Joe K. 2005. Characterization of recovery of mercury from spent
   fluorescent lamps. Waste Management. 25:5-14:
3® Refer to Raposo, Claudia; Windomdiler, Claudia Carvalhinho; and Junior, Walter Alves Durao. 2003. Mercury
   spedation in fluorescent lamps by thermal release analysis. Waste Management. 23:879-886.
-------
The results for these QA/QC samples are given in Table 5.11.
         Table S. 11: Spike and Blank Analytical Results for Pollution Control Media
: ** -f' .Device' ; _. ^
. _•- • i. . "'" ; :
.. * ..." ."-- ' «, .•
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A •
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
„ , - • ' •' ''"Media •*.; , ;••• .. '.> • ;
Carbon (Cl)
Carbon (C2)
Carbon (C3)
Carbon (C4) ,
Carbon Blank (CB1)
Carbon Blank (CB2)
HEPA Filter (Fl)
HEPA Filter (F2)
HEPA Filter (F3)
HEPA Filter (F4)
HEPA Filter Blank (FBI)
HEPA Filter Blank (FB2)
Carbon (Cl)
Carbon (C2)
Carbon (C3)
Carbon (C4)
Carbon Blank (CB1)
Carbon Blank (CB2)
Carbon (Cl)
Carbon (C2) •
Carbon (C3)
Carbon (C4)
Carbon Blank (CB1)
Carbon Blank (CB2)
HEPA Filter (Fl)
HEPA Filter (F2)
HEPA Filter (F3)
HEPA Filter (F4)
HEPA Filter Blank (FBI)
HEPA Filter Blank (FB2)
^•"^SpU^^vs
' ECori<:enrration;j ;
60 ug/g
60 ug/g
60 ug/g
60 ug/g
0 ug/g
Oug/g
2 ug/sample
2 ug/sample
2 ug/sample
2 ug/sample
Oug/g
0 ug/g
20 ug/g
20 ug/g ,
20 ug/g .
20(ig/g
Oug/g
OMg/g
6 ug/g
6 ug/g
6 Hg/g
6 ug/g
Oug/g
0 ug/g
1 fig/sample
1 ug/sample
1 ug/sample
1 ug/ sample
Oug/g
Oug/g
../ . -Recovered . ' •;.
Concentration
67 ug/g
56"g/g
60jig/g
100 ug/g
7.4 ug/g
20 ug/g
2.2 ug/sample
2.1 ug/sample
2.2 ug/sample
2.2 ug/sample
ND
ND
4.5 ug/g
4.4 ug/g
4.3 ug/g
4.3 ug/g
ND
ND
3:4Mg/g
3-6 "g/g
3.6 ug/g
'3.6 ug/g
ND
ND
0.67 ug/sample
0.84 ug/sample
0.72 ug/ sample
0.76 ug/sample
ND
•ND
] Peicerit
Recovery,,
•112%
93%
100%
167%
NA
NA
.110%
. 105%
110%
110%
NA
NA
23%
22%
22%
22%
NA
NA
57%
60%'
60%
60%
NA
NA
67%
84%
72%
76%
NA
NA
ND - Not detected above the analytical limit of detection.
NA - Not applicable
Differences between the spiked concentration and detected concentration generally
reflect potential interferences caused by the pollution control media, as well as
-------
 analytical error.  As indicated above, the Manufacturer B carbon media, ,.
 Manufacturer C carbon media, and Manufacturer C HEPA filter produced results
 with very low recoveries. Thus, portions of the mercury that are not accounted for
. in the mass balance could have been retained in the pollution control media for these
 two devices but may not have been detected in the laboratory analysis. The
 Manufacturer A carbon media spikes generally produced results above 100 percent,
 which is consistent with the mercury detected in the manufacturer-supplied blanks.
 The HEPA filter spikes were also slightly above 100 percent in all cases, but are
 within +10 percent of the actual spiked value. No mercury was detected in the
 HEPA filter blanks..

 5.6.3 • Mercury Mass Adhering to Surfaces

 Difficulties with contamination prevented the use of the wipe samples collected for
 the mass balance. Bulk samples of the polyethylene used for each containment
 structure were not collected. Because mercury permeates through and adheres to
 polyethylene, a significant portion of the mercury not accounted for in the mass
 balance may have been associated with the containment structure. It is also possible
 that some amount of mercury adhered to the insides of the DTC devices.

 5.6.4  Mercury Mass in Ambient Air

 The mass of mercury released during DTC device operation (HgR) was calculated
 based on Equation 5.3, which included the number of air exchanges, the
 concentration of mercury in the air inside the containment structure, and the volume
 of the containment structure. The number of air exchanges was not measured
 during the Study; numbers of air exchanges were calculated for each device based on
 the speeds of the exhaust fans. However, the errors associated with these numbers..
 are not known, and these errors would affect the result of the HgR calculation.
 Additionally, it is possible that some portion of the mercury released from the DTC
 devices permeated through the containment structure and, therefore, was not  .
 accounted for in the mass balance equation.

  5.7   Mass Balance Study Observations
                                V
 A Mass Balance Study was conducted in order to determine whether the mercury
 from lamps crushed in the various DTC devices could be accounted for in
 recognizable mass flows associated with operation of the devices (i.e., crushed
 lamps, air filtration equipment, and fugitive emissions to the air). The study was
 unable to establish a concrete relationship between mass input and output, based on
 the media and waste streams that could be readily sampled during these tests. For
 all three devices, the estimated input mercury quantities on a mass basis were
 substantially larger than the measured output quantities. The following factors
 should be considered in designing any future Mass Balance Study.

 •  Appropriate sampling procedures for the crushed lamp samples need to be
   developed. The drum used for sampling the crushed lamps could be retrofitted
   to allow multiple samples to be collected at various depths within  the drum.
-------
   Any steps taken to avoid releases to the air when creating a composite sample
   and expediting transfer of the sample to the container will likely reduce mercury
   losses.                 j
•  A validated and approved test method for quantifying the mercury in whole
   unbroken lamps is needed, including an understanding of the relative accuracy
   and error inherent to such a test.

•  An approved test method for quantifying the mercury in the pollution control
   media (HEPA, carbon, and particle filters) is needed, including an understanding
   of the relative accuracy and error inherent to such a test.

•  The material used to construct the containment structure could have a significant
   affect on the containment and measurement of mercury.  A material better suited
   to mercury sampling, such as vinyl, should be considered if a containment
   structure is used.

•  Wipe sampling procedures need to be improved and pre and post samples of the
   material used to construct the containment structure may be necessary.

No scientific methodology was applied to attempt to understand the relative impact
of each of the above factors on the results presented here because it was beyond the
scope of this Mass Balance Study.
-------
6.     LIMITATIONS

After reviewing the data collected during the Study, a number of factors were
identified that may have affected the study results:

•  Mercury background levels inside the facilities where the tests were performed
•  Differences in environmental conditions (i.e., temperature and relative humidity)
   at each test site resulting in greater or lesser volatilization of mercury
•  Cross-contamination from lamps broken during shipment to the processing site
•  Contamination from lamps broken during operation.

This section provides a summary of how these factors may have influenced the
study results.

 6.1    Background Levels of Mercury                •,                .

The DTC Device Study was conducted at operational lamp recycling facilities that
crush large quantities of spent fluorescent lamps. At AERC Ashland and AERC
Melbourne, the DTC devices were operated in a separate bay from the primary lamp
processing areas. At EPSI Phoenix, due to the configuration of the .plant, the tests
could not be isolated from the normal plant operations as effectively as at the other
sites. The Study was conducted at fluorescent lamp recycling facilities for several
reasons:                                                . -

•  These facilities possessed the appropriate permits to process mercury-containing
   fluorescent lamps.

•  These facilities had ample supplies of fluorescent lamps that were provided at no
   cost to the study team.

•  The facilities had the capacity to process and dispose of the drums of crushed
   lamps, with no shipping, manifesting, or disposal arrangement required of the
   study team.

The study team made every effort to isolate the study area from normal lamp
processing operations. At all three locations, a containment structure of plastic
sheeting was constructed around the study area; however, as discussed below, this
was only partially effective as a barrier to ambient, background mercury
contamination.

At the beginning of testing at each location, two analytical air samples were collected
in the immediate vicinity of the study area, to attempt to measure background
mercury concentrations inside the lamp recycling facility. The results indicated that
each facility had elevated concentrations of mercury in the ambient air.  (Refer to
Table 4.  1 and Table 4. 2 for the background concentration measurements for each facility.)

The background mercury concentration affected, to some extent, the analytical
sample results. Elevated background concentrations would have the potential to
-------
bias any study results and may affect the validity of conclusions drawn from the
Study by:

•  Elevating the ambient air sampling analytical results and real-time (i.e., Jerome)
   readings above what they would have been if background conditions were not
   characterized by elevated levels of mercury; and

•  Causing deposition of mercury on the containment area surfaces, which later
   could have re-volatilized during the tests and created "false positives" or led to
   exceedances of OSHA or ACGIH standards.

The high background mercury made it more difficult to definitively attribute the
mercury measurements to the DTC devices.  In retrospect, background sampling was
likely inadequate to fully characterize this confounding factor. If future research is
conducted in an industrial lamp recycling facility, it will be important that rigorous
background sampling be performed, which could include collecting analytical air
samples and direct-reading air measurements before, during, and after testing.

  6.2   Experimental Conditions

As mentioned in Section 4.4.3, the outside temperatures were  25°F-50°F higher
during Phase II of the PVS (performed in June 2003) than during Phase I (performed
in February 2003), which could have elevated the indoor temperature during air
volume changes (e.g., doors opening). An increase in ambient temperature has been
shown to cause an increase in volatilization of mercury, resulting in greater detected
concentrations {see footnote 22 in Section 4.4.3). The Study was not designed to
account for the change in ambient temperature when comparing the results from
PVS - Phase I to the results from PVS - Phase II. As a result, it is difficult to
determine the extent to which any differences in measured mercury concentrations
were directly caused by a decline in device performance. To make such a
determination possible, in conducting future research, the environmental conditions
of the test should be maintained at constant levels.

  6.3   Contamination from Lamps Broken During Shipment

Another source of potential contamination of mercury during the Study was the
shipping boxes containing the fluorescent lamps that were received at the lamp
recycling facilities.  On average, approximately 10 percent of the lamps in each box
were observed to be broken during shipment to, and/or pre-handling in, the lamp
recycling facility. In order to investigate this hypothesis, box tests were conducted.
The box test results were discussed in Section 4.6.

At AERC Melbourne, measurable ambient concentrations of mercury were recorded
in the containment structure, while boxes of broken lamps were present and open,
and no lamps were  being crushed (refer to Figure 4.14). Many of these concentrations
exceeded the PEL and/or TLV values. Measurable concentrations, the majority of
which were also above the PEL and/or TLV values, were also noted from ambient air
sampling during a follow-up box test conducted at AERC Ashland. The study results
-------
suggest that, to minimize operator exposures, boxes of lamps (especially those with
significant breakage) should be staged in a separate area from the DTC device and
preferably one where: 1) worker contact is minimal (e.g., a locked storage closet); and
2) workers accessing the area have the necessary PPE, respiratory protection.  This
information is important for all persons working with or around spent lamps, not just
DTC device operators.           .

  6.4   Contamination from Lamps Broken During DTC Device Operation

As will be discussed in Chapter 7, lamps occasionally broke while they were being
fed into the DTC devices. The mercury released from these lamps directly relates to
operator exposure during DTC device operation. The occurrences of lamp breakage
were not consistent throughout the Study, so it is difficult to determine the average
impact that lamp breakage during device operation had on the results of the Study.
-------
7.
DISCUSSION
Purposely breaking large numbers of mercury-containing fluorescent lamps can
release substantial amounts of mercury to the air. Containing the released mercury
is the central goal in the design and operation of drum top lamp crushing devices.
The basic purpose of this Study was to examine how well the tested DTC devices met
the design goal of containing mercury (as measured by operator exposure) when in
routine use. The Study examined the performance of four devices over a five month
period. Over the course of the Study, approximately 5,500 lamps were crushed by
each of the three devices used throughout the Study, inside a constructed enclosure
over a range of environmental and operational conditions. A considerable amount of
data was generated that provides insight into the performance of DTC devices during
field applications.

Testing in this Study was performed under low ventilation conditions, within a
constructed containment structure.  This was done both to measure ambient mercury
concentrations during device operation in a controlled environment (i.e., segregated
from the ambient background mercury at the lamp recycling facilities) and to
evaluate performance under plausible, worst-case operating conditions (such as in an
unventilated truck trailer).31 Operator exposures would be expected to be lower than
found in this Study if a DTC device is operated in a room with higher ventilation
rates or if far fewer lamps are crushed over a longer period of time (i.e:, 40-80 lamps
crushed per day as apposed to 400-800 lamps crushed per hour).  The containment
structure was only partially effective in isolating the Study operations from the
background mercury produced by the lamp recycling activities at the facilities used
as testing locations in the Study because mercury is able to permeate through and
sorb onto polyethylene, which was the material used to construct the containment
(refer to Chapter 6 for further discussion).  Measurements made before testing and
during non-operational periods indicated that elevated background levels, which
varied by facility, were present throughout the entire Study.

The following discussion is based on the evaluation of results from the air •
monitoring and sample data collected during the course of the Study. Observations
and experience gained during the operation of these devices provide further
important information about the use of DTC devices.

  7.1    Summary of Results

Over the course of the Study, a total of 185 analytical air samples were collected
during device operation (not including overnight and background air samples).
Sixty-five samples (35.1 percent) were below both the ACGIH TLV and the OSHA
PEL values. Eighty-four samples (45.4 percent) were equal to or above the TLV but
  The facilities used to conduct the Study had background mercury levels that were higher than would be expected at a
   location that was not routinely handling mercury, as discussed in detail in Sections 4.2 and 6.1.  Correction of data by
   subtracting the background levels from the sample results may be an appropriate way to view the data, although doing
   sowould not reduce all the exceedances of the PEL or TLV to below those levels.
-------
below the PEL value, and thirty-six samples (19.5 percent) were greater than or equal
to the PEL value.32

7.1.1  Exposures during Routine Crushing Operations

Overall, seven operator shoulder samples (i.e., average mercury concentration in the
operator breathing zone air) exceeded the PEL value. Three of these samples were
collected while testing the Manufacturer B device, one was collected while testing the
Manufacturer C device, and three were collected while testing the Manufacturer D
device, which was removed from the Study. It is important to note that the shoulder
samples were average measurements, taken over the time period required to crush
one or two drums of lamps (typically one to three hours). The Jerome analyzer
readings, taken inside the containment structure, show the fact that there were a
number of excursions above the PEL during routine crushing operations, even when
the analytical air samples were not above the PEL.  Refer to Figure 4.3, Figure 4.6,
Figure 4.8, Figure 4.10, and Appendix A for graphs of the Jerome analyzer readings.

All three devices that completed the Study, especially the Manufacturer B and
Manufacturer C devices, experienced problems in maintaining operator exposures
below the ACGIH recommended TLV of 0.025mg/m3 within the containment
structure during routine lamp processing. The TLV value is a time-weighted average
(TWA) calculated over a normal eight hour work day that is considered protective of
worker  health and safety.33  Analytical air samples collected in the operator's
breaming zone and Jerome analyzer results show that the concentration of mercury
inside the containment structure was above the TLV value the majority of the time.

The Manufacturer A device maintained operator shoulder sample concentrations
below the mercury TLV value during four of the five rounds of testing; the
Manufacturer A device exceeded the TLV during EFT #1, when the feeding tube was
not properly connected to the drum-top assembly (refer to footnote 23 in Section
4.5.1.1). The Manufacturer B and Manufacturer C devices exceeded the TLV value in
at least  one operator shoulder sample during four of the five testing occurrences,
even when corrected for background mercury levels.  The only test in which all
operator shoulder samples for all three devices were below the TLV value was PVS -
Phase I  at AERC Ashland in February 2003; this may have been, in part, due to the
fact that the devices were new, the outside temperature was lower, and only low
mercury, Alto® lamps (manufactured by Phillips Lighting) were processed.

Exhaust or feed tube air samples (sometimes both)  for all three devices also exceeded
the TLV value during portions of the Study. The Manufacturer A device had feed
tube and exhaust samples that exceeded the TLV value only during EFT #1, most
32 This discussion of the number of data that exceeded the TLV and tiie PEL does not correct for background. There were
   not enough background data to reasonably estimate the contribution that background mercury could have made to the
   measured mercury concentrations.
33 The results obtained in the Study were not normalized to an eight hour workday because DTC device use patterns may
   vary significantly. In some cases only a dozen lamps may be crushed in a single day. In other cases a device may be
   used to process thousands of lamps from different sources, so the operator may be using the device forty hours a week or
   more. Therefore, sample results that are greater than the TLV should not necessarily be interpreted to indicate that use
   of one of the DTC devices included in the Study would result intime-weighted, operator exposure above the TLV.
-------
likely, because of a missing gasket on the feed tube (refer to footnote 23 in Section
4.5.2.1). All exhaust and feed tube samples for the Manufacturer B device were above
the TLV value, except those taken during PVS - Phase I. Six of the 10 exhaust and
feed tube samples collected for the Manufacturer C device were above the TLV value.
The degrees to which temperature and changes in device performance affected these
data are topics for future research.

As discussed in Section 3.5.3, the Manufacturer D device performed poorly, allowing
the mercury concentrations inside the containment structure to exceed the OSHA PEL
value by nearly 9 fold. This device was removed from the test after two rounds of
testing due to its poor performance (refer to Appendix I).

7.1.2  Exposures during Routine Drum and Filter Changes

When the drum beneath a DTC device is filled with crushed lamps, the DTC'device
must be secured to a new drum. This operation involves unsealing the DTC device
from the drum, lifting it off the drum, and placing it on a new, empty drum. During
this operation, the full drum of crushed lamps is open to the air for some period of
time during which mercury vapor is released uncontrolled to the air (in this Study,
drum changes lasted approximately two to 10 minutes). Because of mercury's
volatility under typical indoor conditions, the drum change operation poses the
potential for significant mercury release, particularly while the full drum is open to
the air (as illustrated by the results below). Minimizing the time during which the
full drum is open to the air will help reduce operator exposure to mercury and
mercury releases to the environment.

Two types of samples were collected for all three devices during drum changes:
drum change samples and ceiling samples.34  All of the DTC devices tested exceeded
the PEL value at least once during drum changes. PEL value exceedances during
drum changes were frequent for the Manufacturer B and Manufacturer C devices.
The drum change samples for the Manufacturer A device exceeded the PEL value in
only one of the five tests (EFT #2). The Manufacturer A device features a larger
particulate filter and a larger amount of activated carbon than the other two devices.
The more substantial pollution control equipment could, at least partially, explain the
differences between the results for the Manufacturer A device and the results for the
other devices.

7.1.3  Exposures Resulting From DTC Device Malfunction

There were two major types of malfunctions that occurred and caused increased
mercury release and operator exposure - improper device assembly and feed tube
jamming. The Manufacturer A device was not assembled correctly during EFT #1
(refer to footnote 23 in Section 4.5.1.1), which caused average ambient mercury
concentrations to exceed the PEL in the sample collected near the feed tube, and to
reach 0.074 ug/m3 in one operator shoulder sample. The samples collected for EFT
#1 were collected over the course of filling two drums, meaning that the mercury
3* Drum change samples and ceiling samples are described in Section 3.1.
-------
concentrations as measured by analytical air samples were averages of the
concentrations in the air throughout the filling of both drums..

The missing seal was replaced for the second drum, so during the second drum, the
mercury concentrations inside the containment were most likely lower because the  ,
device was assembled correctly. With average mercury concentrations at 74 percent
of the PEL value, it is very likely that the mercury concentrations in the operator's
breathing zone exceeded the PEL at some point during the filling of the first drum.
(There are no Jerome data available for this tune  period to verify this because the
Jerome was in regeneration mode.) These levels  were nearly four times the average
concentrations measured for this device in the other portions of the Study, showing a
higher rate of mercury release as a result of seal failure/improper assembly.

A common malfunction experienced with all the devices was jamming of the feed
tube. The Study was not designed to quantify increased ambient mercury
concentrations or increased operator exposure caused by this malfunction.  When the
lamps jammed in the feed tube, debris from inside the DTC device and the drum
occasionally blew back towards the operator, indicating that a fraction of the mercury
in the lamp that jammed was not being captured by the DTC device.

The high operator exposures experienced during the use of the Manufacturer D
device were likely due to poor design and malfunction. As noted in Section 3.5.3 and
Appendix  I, Manufacturer D sent two different DTC devices of different design for
the first two rounds of testing, and the device for the second round of testing was ,
dearly damaged, with a visible crack in the vacuum pump motor housing.
However, during Phase I of the PVS, when the device had no visible damage, only
"low mercury," Alto® lamps were crushed, and  outdoor temperatures were between
28 and 43 degrees Fahrenheit, operation of the Manufacturer D device resulted in
ambient mercury concentration nearly 9 times the OSHA PEL value. This highlights
the importance of design and optimal operation.

7.1.4  Changes in DTC Performance over Time

The performance validation study was designed to examine the change in
performance over time. The Study included five rounds of testing over a 5-month
period, and approximately 5,500 lamps were crushed by each device. The data
generated by the Study indicate that one device (from Manufacturer A) maintained
its ability to contain the mercury released when lamps were  crushed over the
duration of the Study, while the other two devices that completed the Study
declined in performance over this time frame and use.  The  Study was not designed
to determine the reason for'the decline in performance by the Manufacturer B and C
devices. However, there are several possibilities, including possible saturation of the
carbon filter material and wear and tear on DTC device seals. The changes in
performance over time documented in the Study may be evidence of potential
difficulties in maintaining optimal performance by DTC devices. Careful attention
to inspection and maintenance of the devices may make it possible for operators to
detect and repair any worn components before their deterioration could result in
mercury exposures.
-------
7.1.5  Overnight Tests

Air samples were also collected within the containment structure, near the devices,
during non-operational periods, with the DTC devices attached to drums that were
full or partially full of crushed lamps. These tests were conducted overnight at all
three locations during the EFTS. Per manufacturer instructions, the Manufacturer A
device was left running on ventilation mode throughout the course of the tests (that
is, the fan/vacuum pump was running, with air being exhausted through the carbon
filter, whenever a drum was attached to the device), and the Manufacturer B and
Manufacturer C devices were turned off.  The results from the overnight samples
were inconclusive as to whether or not mercury was released from DTC devices that
were attached to drums containing crushed lamps.

7.1.6  U-TubeTest

The Manufacturer B and Manufacturer C devices have attachments that enable mem
to process U-tubes. A test was conducted to evaluate airborne mercury levels from
the two devices while processing U-tubes. The facility was only able to collect a
limited number of U-tubes for this test, so each device processed fewer than 90 U-
tubes. Seven of the eight U-tube samples were above the TLV value, and two of the
operator breathing zone samples (one for each device) equaled or slightly exceeded
the PEL value. These levels are generally higher than the levels measured when
crushing straight lamps, especially in light of the fact that so few U-tubes were
processed by each device. A possible explanation for the high mercury levels is the
fact that the U-tube attachments have larger openings than the feed tubes for the
straight lamps, which could have allowed some air to flow from inside the device
out into the containment  structure.

7.1.7  Exposures Resulting from Lamp Breakage

Another source of mercury release associated with use of DTC devices was breakage
of lamps either before they were fed into the device, or as they were being fed in.
Studies of lamp breakage inside the containment structure via the Box Test indicated
that lamps broken during handling may have had an affect on the sample results.
Lamps also sometimes broke and shattered while being fed into the DTC. No testing
of the resulting mercury release was attempted, because this breakage occurred
sporadically and was a random event. However, during the first test of the
Manufacturer B device at the EPSI Phoenix facility (EFT #2), the Jerome analyzer
readings demonstrate that the ambient mercury concentration increased inside the
containment structure when a bulb was broken.

As shown in Figure 4.8 and Appendix A, Figure 32, the mercury concentration was
0.033 mg/m3 before a lamp was broken and increased to 0.169 mg/m3 four minutes
after a lamp was broken.  This was an increase of 400 percent in ambient mercury
concentrations. These data are further supported by research performed by Aucott,
et al., in which it was shown that "between 17 and 40 percent of the mercury in
broken low-mercury fluorescent bulbs is released to the air during a two-week period
-------
immediately following breakage, with higher temperatures contributing to higher
release rates."35 The potential for lamp breakage outside the DTC device is inherent
to device use. Possible release of and exposure to mercury vapor, as a result of
broken lamps, is an important consideration as part of .any operations managing
fluorescent bulbs.                  ,

Because of the multiple potential sources of mercury being released during normal
DTC device operations — during drum changes, through the degradation of seals
over time (leading to leaks), possible leakage due to improper assembly or
malfunction, and the breakage of lamps outside the DTC device, either during
handling or feeding lamps into the device — a respirator was always available to the
operator during the Study. Either use of a respirator, or continuous air monitoring
for mercury with a mercury vapor monitor, such as a Jerome or Lumex, were the only
ways to ensure that operator mercury exposures remained below the OSHA PEL and
AGCIH TLV throughout the Study.36                            ,    .     :

  7.2    Safety Concerns when Operating DTC Devices

Throughout the DTC Device Study, field observations were made and documented
by the study team. These observations provide insight into potential safety issues
and mitigation measures that were undertaken during the Study (and could be used
by other device operators) to,enhance the safety of operating DTC devices.

7.2.1  Operator Safety

"As noted above, when lamps were being fed into the DTC devices, they would
occasionally break and/or jam in the feed tubes. This was an issue common to all
devices. Lamps sometimes broke before they could be fully fed into the devices,
causing, in some instances, visible release of phosphor powder, as well as flying
shards of glass.  The configuration of the feed tubes on several devices exacerbated
this problem, where, for example, the operator either had to lower the lamps to waist
level or raise them up to shoulder level in order to insert them into the feed tube.
                                                                        i

Various articles of personal protective equipment (PPE) were used by the,study team
during operation of DTC devices to ensure operator safety (refer to Photograph 7,1).
These included safety glasses, full-face shields, puncture-resistant (Kevlar®) gloves,
hearing protection, and air-purifying, negative pressure respirators (when air
monitoring readings were above pre-determined safe levels).  Disposable Tyvek®
coveralls were also worn by the DTC device operator and assistant, to reduce both
skin exposure to the airborne mercury and the possibility of tracking mercury
residues out of the testing facility.
35 Aucott, Michael;-McLinden, Michael; and Winka, Michael. 2003. Release of Mercury from Broken Fluorescent Bulbs.
   Journal of Air 61 Waste Management Association. 53:143-151. Tlie lamps used in tins investigation were Phillips
   four-foot Econ-o-watt F40 CW/RS/EW, 0 8E bulbs, which are reported to contain 4.4 mg or 4.7 mg of mercury.
3*> The traditional hierarchy of occupational chemical exposure control specifies that engineering controls (i.e., adequate
   monitoring and ventilation) be used before relying on PPE.
-------
          Photograph 7.1: Clearing Jammed Feed Tube of Manufacturer A Device

Due to the possibility of mercury release from lamp breakage outside the DTC
device or leaks from the DTC device, respiratory protection was always available to
the operator and assistants throughout the Study and was used most of the time.

7.2.2  Number of Operators

During the Study, two people operated the DTC devices at each location. One
person fed the lamps into the device, and the other person supplied the operator
with full boxes of lamps, removed the empty lamp boxes, and handed lamps to the
machine operator, allowing for efficiency in feeding lamps. While one person could
probably operate the DTC device, the study team found it much easier and more
efficient to use the two-person team. This was particularly important when it came
to changing drums. Having a two person team available allowed drum changes to
be performed much more securely and quickly (the Manufacturer B device required
a two-person team to change drums, but the other devices did not).  The advantages
of a two-person team included both help in lifting the DTC off the full drum and
positioning it correctly on the empty drum, as well as allowing the full drum to be
more quickly covered and sealed.

7.2.3  Location and Ventilation for Lamp Crushing Activities

As discussed in Section 4.2, the background  mercury concentrations in the industrial
lamp crushing facilities were several orders of magnitude higher than background
mercury concentrations that would be expected outside or in a building that is not
associated with mercury processing activities, such as a home or an office building.
One of the reasons that this Study was conducted at lamp recycling facilities was
that these facilities already have safeguards in place to prevent exposure to visitors
to the facility and to residents in the surrounding neighborhood.

These safeguards include a separate ventilation system for the offices, which does
not cycle the air from the crushing area into the offices, and fume hoods on the
industrial lamp crushers that vent fumes through carbon filters. The separate
ventilation system protects the office workers from exposure to mercury. The
production workers at the facility (i.e., those operating recycling equipment) are
-------
aware of the potential of mercury exposure and have been trained in practices that
will prevent mercury release and exposure. Production workers at lamp recycling
facilities are required to have.OSHA Safety Training. Additionally, material safety
data sheets (M5DS) for mercury must be made available to these workers.

  7.3    Potential DTC Design Modifications

Drum top lamp crusher design is an evolving field, and many aspects of device
design can affect its ability to contain mercury (e.g., see Section 3.5.1). The devices
tested in this Study are only the second generation of drum-top lamp crushers and,
while they represent a significant improvement over the first generation of such
devices, further improvements in design and operation procedures would be
beneficial.37 Based on operator observations, the following areas for potential
improvements in DTC device design were noted by the study team:

•  Development of Leak Detection Systems: As discussed above, DTC devices may
   develop undetected leaks and release significant amounts of mercury as a result.
   While a portable mercury vapor monitor can easily detect rising airborne
   mercury concentrations, these devices are expensive to purchase and operate,
   ranging from $15,000- $22,000. Development of an effective leak detection
   system, such as a continuously operating pressure monitor, may reduce the need
   for continuous monitoring of DTC devices in operation to ensure operator safety
   and compliance with regulatory standards.
          *                                                            »

•  Improvement in Mercury Capture during Drum Change: Drum changes were
   identified in the Study as the routine activity with the highest potential for
   operator exposure to mercury concentrations above the PEL. None of the devices
   tested were capable of maintaining mercury concentrations below the PEL
   during drum changes, so improvements in device designs to reduce mercury
   releases during this operation would be very beneficial.

•  Chemical Treatment of Released Mercury Vapor:  Most of the mercury released
   from lamps in DTC devices is elemental mercury vapor, which is volatile at room
   temperatures.  Elemental mercury reacts with sulfiding agents very readily and
   quickly under environmental conditions to form mercuric sulfide. Because
   mercuric sulfide is a solid (powder) at room temperature, its release to the air
   should be much easier to control than mercury vapor.  Airborne mercury sulfide
   powder inside a drum would most likely settle into the crushed lamps in the
   drum or be captured by the pollution control media of DTC devices.
   Incorporating sulfiding-agent injectors into a device design could potentially
   reduce mercury release during all activities associated with DTC device use
   (except lamp breakage outside the device). The study team did not explore this
   possibility, so we are unable provide any specific design recommendations.
  Based on a 1994 EPA study, some of the first DTC device designs (not necessarily designs from the manufacturers that
   participated in this Study) may have used no mercury emissions controls.
-------
*  Increase in the Amount of Pollution Control Used in the Device: The
   Manufacturer A device showed the best performance overall. This device used
   approximately 87 pounds of activated carbon, which most likely contributed to
  • its good performance.  The other devices included much less activated carbon in
   their air filtration systems (refer to Table 5. 6 for the specifications of the pollution
   control media for each device).

This Study was designed to assess the potential for operator exposure to mercury,
while operating the four- DTC devices tested; The-areas of improvement noted above
resulted from observations made'by the study team-in the course of testing the
devices and preparing this report. This list is not meant to be exhaustive.

  7.4    Future Areas for Study

There are several areas in which additional study would be beneficial:

•  Environmental Impacts of DTC Device Use: DTG devices have the potential to be
   used in a wide variety of places. It is possible that the use of these devices will
   decrease the overall release of mercury to the environment by decreasing the
   uncontrolled disposal of mercury fluorescent lamps (i.e., disposal in a dumpster).
   Future research to assess the potential impacts of DTC device use could include:

   -  How much the use of DTC devices can impact the total amount of mercury
      being released into the environment;
   -  How much mercury is emitted from DTG devices for each lamp crushed or
      each drum full of lamps crushed;
   -  Who (in addition to the operator) may be exposed to mercury releases related
      to operation of a DTC device;
   -  How the emissions from DTC devices compare to the emissions from other
     • mercury emissions sources, including industrial lamp recycling facilities; and
   -  Whether significant amounts of mercury collect in areas where DTC devices
      are stored and operated.

•  Mercury Release from DTC Devices during Non-operational Periods: The
   overnight tests conducted in this Study were inconclusive (refer to Section 4.7).
   Because it is probable that in many cases drums partially filled with lamps will
   be stored for extended periods of time, more information about the release of
   mercury from DTC devices which are attached to partially filled drums is needed
   in order to fully characterize the mercury exposure  that could be realized as a
   result of the use of a DTC device.      '             !

•  Mass Balance Study: A concrete relationship between mercury input and
   mercury retention and release was not established for any of the devices in the
   Mass Balance Study. The following factors should be considered if a future Mass
  - Balance Study is undertaken:

   -  Appropriate procedures for representative sampling of the crushed lamps in
      the drum need to be developed;
-------
   -  A validated and approved test method for quantifying the mercury in whole
      unbroken lamps is needed, including the relative accuracy and error inherent
      in such a test;
   -  An approved test method for quantifying the mercury in the pollution control
      media (HEPA, carbon, and particle filters) is needed, including the relative
      accuracy and error inherent in such a test;                     ••
   -  A study design specific to measuring all system inputs and outputs, including
      the use of a clean-room and the measurement of emissions; and
   -  Wipe sampling procedures need to be improved, including pre and post
      sampling of the material used to construct the containment structure.

•  Development of a Standard Test Method(s) for PTC Device Performance: A
   standard DTC device evaluation protocol that can be used by DTC device
   manufacturers would ensure that manufacturer performance data are generated
   in a consistent manner, under known conditions. A true evaluation of crusher  •
   performance can be developed only if the volume of the crushing room, the air  ',
   exchange rate, the lamp crushing rate, the duration of crushing, and all sampling
   and analyticaL methods are known and validated. Absentthis information, a
   poorly performing DTC device could be "tested" and shown to perform well with
 ,  regard, to operator exposure because the test was performed using unrealistic
   ventilation rates or room size or was performed outdoors.  Evaluating DTC
   performance under consistent, known conditions would also allow meaningful
   comparison of the performance of different lamp crushers.- A standardized test
   method would help ensure the repeatability and accuracy of any tests results.

•  Investigation of Mercury Release through Different Lamp Management Methods:
   This Study only examines mercury release from fluorescent lamps as a result of
   the use of DTC devices (as measured by operator exposure). When lamps are
   handled and recycled as whole lamps, there is the potential for breakage and,
   therefore, the potential for mercury release, during the storage and shipping of the
   lamps. Information about the frequency of breakage and the amount of mercury
   released when whole lamps are stored and then shipped to a recycler is needed in
   order to compare these different lamp recycling methods. Additionally, more
   information on releases of mercury resulting from disposal of lamps would
   provide a useful baseline with which to compare releases due to recycling.

•  Aerosolization of Mercury. Additional study may be.appropriate to determine
   whether aerosol mercury was not detected using the MCE filters because no
   aerosolization occurred or because any aerosol mercury collected on the filter was
   vaporized by the sampling vacuum pump.

  7.5   Conclusions

The potential use of DTC devices involves a number of trade-offs. Spent mercury
lamps contain elemental mercury, some of which is released to the air when lamps
are broken. If thrown into a dumpster for disposal at a municipal solid waste
landfill, breakage will occur either in .the dumpster or at the landfill. In either case, a
portion of the mercury contained in the lamps is immediately released to the
-------
environment by volatilization, and the remaining mercury is available for release to
the environment, over time, by leaching or in landfill gas.

Recycling of spent lamps represents one of the best ways to control the release of
mercury to the environment from landfilling of fluorescent lamps, by keeping
mercury out of landfills in the first place.  Recycling can be done either on an
individual lamp basis (i.e., sending whole, boxed lamps to a recycler), or by using a
DTC device at the point where lamps are removed from service. Use of DTC devices
has obvious appeal in that the devices reduce lamp volume, allowing several
hundred crushed lamps to occupy the space that 40 or 50 whole lamps would
occupy, thereby reducing storage and snipping costs. This leads to a reduction in
recycling costs on a per-lamp basis.  Crushing lamps before shipment also has the
advantage of allowing shipping to the recycler in a well-sealed, durable container
that is unlikely to release substantial amounts of mercury during shipment, while
whole lamps may be broken during shipment and release mercury.

The DTC devices evaluated as part of this Study all released some mercury when
used and so have the concern of creating new mercury exposures. The mercury
released during DTC device use will inevitably create certain new mercury exposure
situations. The DTC device operator and any assistants handling lamps or working
directly with the DTC device are the most obvious new exposures. Less direct
mercury exposures that could be created by DTC device use include anyone working
in or visiting buildings in which DTC devices are used. The only way to eliminate
these unnecessary indirect mercury exposures would be to keep the ventilation of
the lamp crushing room completely separate from the general building ventilation
system as is done at industrial lamp recycling facilities.

The data collected in the course of this Study indicate that none of the DTC devices
evaluated completely controlled mercury emissions during lamp processing
operations, even with optimal operation.  The Study further indicates that
maintaining  optimal performance consistently over years of DTC device use for the
current generation of devices will be challenging. Even generally well designed
devices released mercury in routine use, particularly during drum changes. Device
malfunctions increased mercury release by a small amount (i.e., when lamps jammed
in the feed tube) or by a significant amount (i.e., when the flange gasket was not
included in assembly). Use of a poorly designed device could result in mercury
exposures nearly an order of magnitude above the OSHA PEL. Fundamental design
changes to reduce the reliance on fallible components (such as seals) would be
needed to improve the ruggedness of drum-top crushing devices.
-------
    •   Office of Solid Waste and Emergency Response
              1200 Pennsylvania Avenue, NW
                  Washington, DC 20460
                    EPA530-R-06-002
                      August 24,2006
www.epa.gov/epaoswer/hazwaste/id/univwast/drumtop/drum-top.htm
-------
       Appendix A




Air and Wipe Sample Results
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Table 2: Wipe Sample Results
Ql^fe^PWl^
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Blank
Blank
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Blank
Blank
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturers
Blank
Blank
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer D
Manufacturer D
.,»' . . *• • • "«*»* "^
&*&'&&
...±.. ., ?- ~ .% -..^.ii!!...
2/27/2003
2/27/2003
2/27/2003
2/27/2003
2/27/2003
2/27/2003
2/27/2003
2/27/2003
2/27/2003
2/27/2003
2/27/2003
2/28/2003
2/28/2003
2/28/2003
2/28/2003
2/28/2003
2/28/2003
2/28/2003
2/28/2003
2/28/2003
2/28/2003
2/28/2003
2/26/2003
2/26/2003
2/26/2003
2/26/2003
2/26/2003
2/26/2003
2/26/2003
2/26/2003
2/26/2003
2/26/2003
2/26/2003
2/27/2003
2/27/2003
«6Ji- !' *-.-" • Sf'r-.f !,- -ijM ** <°
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;:..;: -c-.S"i4iiyr:«":.>:,::.:.:.'i:'=^.-';.* 	 fislkfi
Blank
Blank
Floor-2 ft from device
Floor-5 ft from device
Ceiling
East wall of containment
West wall of containment
Exterior drum surface-side
DTC device
DTC device feed tube exterior
Floor at device exhaust
Blank
Blank
Floor-2 ft from device
Floor-5 ft from device
Ceiling
East wall of containment
West wall of containment
Exterior drum surface-side
DTC device
DTC device feed tube exterior
Floor at device exhaust
Blank
Blank .
Floor-2 ft from device
Floor-5 ft from device
Ceiling
East wall of containment
West wall of containment
Exterior drum surface-side
DTC device
DTC device feed tube exterior
Floor at device exhaust
Floor-2 ft from device "
Floor-5 ft from device
••uVRre^".^
jWipeMj
<0.01
<0.01
0.36
0.21
0.49
0.026
0.11
0.059
0.4
0.48
0.14 '
<0.01
<0.01
0.065 ,
0.14
0.053
0.017
0.044
0.17
0.017
<0.01
0.049
<0.01
<0.01
0.13
0.11
0.71
<0.01
<0.01
0.067
0.041
0.02
0.12
0.088
0.053
•I" Rostov
-WipietfH
<0.01
<0.01
0.14
0.11
0.071
0.033
0.032
0.12
0.2
0.053
0.14
<0.01
<0.01
0.054
0.074
0.2-
0.02
0.015
0.073
0.18-
0.33
0.27
<0.01
<0.01
3.1
0.62
0.27
0.12
0.034
0.027
0.27
0.052
0.45
0.06
0.063
•. J-IBre- :„/
Wniei2:;
<0.01
<0.01
0.16
0.18
0.16
0.014
0.071
0.017
0.32
0.055
0.048
<0.01
<0.01
0.064
0.12
0.045
' 0.029
0.015
0.038
0.019
<0.01
0.048
<0.01
<0.01
0.43
0.11
0.2
0.02
<0.01
0.051
0.037
0.017
0.072
0.076
0.088
f^PpsK/
^Wipefe
<0.01
<0.01
0.19
0.15
0.049
0.024
0.013
0.046
0.17
0.062
0.11
<0.01
<0.01
0.13
0.067
0.097
<0.01
0.015
0.053
1.2
0.64
0.12
<0.01
<0.01
0.33
0.15
0.15
0.024
0.021
0.044
0.93
0.047
0.48
0.041
0.072
            18
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Manufacturer D
Manufacturer D
Manufacturer D
Manufacturer D
Manufacturer D.
Manufacturer D
•iatexll/
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2/27/2003
2/27/2003
2/27/2003
2/27/2003
2/27/2003
'2/27/2003
2/27/2003
Hi; • js^y: (,••>. tf-j :; ;•••:"- «. 4,;";;- -"; v ?":
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Background
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Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
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.Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
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Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
:pafe;^:Hj
3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/24/2003
3/24/2003'
3/24/2003
3/25/2003
3/25/2003
3/25/2003
3/25/2003
3/25/2003
3/25/2003
3/25/2003
3/25/2003
3/25/2003
3/25/2003
3/25/2003
3/27/2003
3/27/2003
.3/27/2003
3/27/2003
3/27/2003
3/27/2003
3/27/2003
3/27/2003
3/27/2003
3/27/2003
3/27/2003
t^^i^lMtiory':"'}^]^ B^ :';•*
Ground in front of containment
Ground.in front of containment
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Floor-2 ft from device
Floor-5 ft from device
Ceiling
East wall of containment
West wall of containment
Exterior drum surface-side
DTC device
DTC device feed tube exterior--
Floor at device exhaust
Blank
Blank
Floor-2 ft from device
Floor-5 ft from device
Ceiling
East wall of containment
West wall of containment
Exterior drum surface-side
DTC device
DTC device feed tube exterior
Floor at device exhaust
Blank
Blank
Floor-2 ft from device
Floor-5 ft from device
Ceiling
East wall of containment
West wall of containment
Exterior drum surface-side •
DTC device
DTC device feed tube exterior
Floor at device exhaust -
"fcr^pe;
1.4
0.69
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- <0.01
0.22
0.034
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- 0.011
0.053
0.037 '
0.94
0.16-
0.26
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" 0.73
0.43 •
0.18
0.21
0.088
0.14
0.8
0.091
0;17
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<0.01
0.17
0.042
0.071
0.019 '
0.032
0.065 5
0.067
0.11
0.083
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0.41
1.3
0.81
0.11
0.058
0.22
0.53
0.17
5


0.44
1.6
0.51
0.8
0.11
0.05
0.61
0.48
0.45


1.3
0.17
0.14
2.7
1
0.36
0.85
' 0.23
2.6
20
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;.»-. v* ^Extended Flelfl Test #1 ^Phoenix, Arizona -* March 24-28, 2003 ,,.*** £, ?*., ', .,,; -«• tt<«*ii,,c) .." % '•' ,;rJ. . - '» 	 s"*:;.; .." ,'"- -c;r r, , • - ::•;•: - r, ., =.-, '.- :"-4< -..-;; , -rf *" - r''* ": ^. . f m *" ,.. ***?•"*>
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Manufacturer D
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Manufacturer D
Manufacturer D
Manufacturer D
Manufacturer D
Manufacturer D
Manufacturer D
•I^K>l->- ;
~ 'W '5- - -S «'
3/26/2003
3/26/2003
3/26/2003
3/26/2003
3/26/2003
3/26/2003
3/26/2003
3/26/2003
3/26/2003
3/26/2003
3/26/2003
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Floor-2 ft from device
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DIG device feed tube exterior
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'%^&
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. 0.018
V0.28
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0.96
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0.23
0.038
4.5
0.4
0.88
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0.56
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Manufacturer A
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Manufacturer A
Manufacturer A r
Manufacturer A
Manufacturer A
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Manufacturer A
Manufacturer A
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Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
•'•iC'.'.^i :-' •••'*• *':*8'
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5/1/2003
> 5/1/2003
5/1/2003
• 5/1/2003
5/1/2003
-5/1/2003
^5/1/2003
5/1/2003
5/1/2003
5/1/2003
". 5/1/2003
5/2/2003
5/2/2003
4/29/2003
4/29/2003
4/29/2003
4/29/2003
4/29/2003
4/29/2003
4/29/2003
4/29/2003
4/29/2003
.|&MpJ|ioc^^
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Floor-2 ft from device
Floor-5 ft from device
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West wall of containment
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,DTC device feed tube exterior
Floor at device exhaust
Next day: Floor-2 ft from device
Next day: E. wall of containment
Blank
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Floor-2 ft from device
Floor-5 ft from device
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East wall of containment
West wall of containment
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DTC device
•;Pre)App
-------
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Manufacturer B
Manufacturer B
Manufacturers
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Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
jP^i'51
4/29/2003
.4/29/2003
4/29/2003
4/30/2003
4/30/2003
4/30/2003
4/30/2003
4/30/2003
4/30/2003
4/30/2003
4/30/2003
4/30/2003'
4/30/2003
4/30/2003
4/30/2003
4/30/2003
5/1/2003
5/1/2003
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Floor at device exhaust
Inside drum before crushing
Next day: Floor-2 ft from device
Next day: E. wall of containment
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Floor-2 ft from device
Floor-5 ft from device
Ceiling
East wall of containment
West wall of containment
Exterior drum surface-side
DTC device
DTC device feed tube exterior
Floor at device exhaust
Next day: Floor-2 ft from device
Next day: E. wall of containment
'ifcre^Wipe-;
0.63
0.1
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0.086
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0.650
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Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Manufacturer A
Operator
Operator
c5S.'H>7 • i ">;<* •• ••-'•:
:;9«fer^i
6/10/2003
6/10/2003
6/10/2003
6/10/2003
6/10/2003
6/10/2003
6/10/2003
6/10/2003
6/10/2003
6/10/2003
6/10/2003
6/11/2003
6/1 1/2003 >
6/10/2003
6/10/2003'
;;st|pio^^ig?wi|2:f
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Floor-2 ft from device v
Floor-5 ft from device
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West wall of containment
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DTC device feed tube exterior
Floor at device exhaust
Next day: Floor-2 ft from device
Next day: E. wall of containment
Tad's Hands
Steve's Hands
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1.6
1.4
0.19
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0.11
0.13
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1.7
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0.022


22
-------
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Operator
Operator
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Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B
Manufacturer B -
Manufacturer B
Blank
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Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
Manufacturer C
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?Mfe£;|'t.
6/10/2003
6/10/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/11/2003
6/12/2003
6/12/2003
6/12/2003
6/12/2003
6/12/2003
6/12/2003
6/12/2003
6/12/2003
6/12/2003
6/12/2003
6/12/2003
6/12/2003
6/12/2003
6/13/2003.
6/13/2003
6/13/2003
6/13/2003
1 Sample Location ?;p' •':'?'. '' '!>Xi7
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Floor-2 ft from device
Roor-5 ft from device
Ceiling
East wall of containment
West wall of containment
Exterior drum surface-side
DTC device
DTC device feed tube exterior
Floor at device exhaust
Next day: Floor-2 ft from device
Next day: E. wall of containment
Blank
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Floor-2 ft from device
Floor-5 ft from device
Ceiling
East wall of containment
West wall of containment
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Next day: Floor-2 ft from device
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Blank
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^PMvipe •
0.055
0.53
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0.048
0.031
0.035
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0.14
0.23
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0.059
0.061
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0.2
1.7
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1.1
0.79
0.099
0.072
0.055
0.058
3.8
0.8
1.5
0.230
0.065


1.1
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0.44
0.097
0.092
0.12
1.8
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      Appendix B




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           Appendix B

    Air Sampling Data Forms
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                                                  :Date
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                      FX> 30&694:?367-
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                                                   Date;
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                                                                                      MB
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                             MMSAHPEINS
                                           Date
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                       » Colprado;801
                                 AIR
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eeritrbls
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                                                   •bate:
                                 Job
calibraticsi;
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ferfe:
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                                    safe i
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       Greenwood Vtllagt, Colorado 80111
                                                 Date
Ctontrols
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                                                         Media
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                                                                 Sltour
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-------
                lya§Si|lte;»ia

Grecmvood VHIa   GioraxJo 80111

"
                            MR

                                     _
                                  'Tiine:
                                            .Gpnpeitbcatfipn.
     L' Hygienisfe^:                                Revleweai By:
-------
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                      '
                               MR SAMEOMG DOTA FORM
                                                     Jcb Title
              •U^K*!¥v-;Agtf  fsvM'rt.>K./Uax..J'   /•fry
Indus trial Hyqienisfc:
-------
                                 MR SAMPU1JG D,\TA'
Gonctrole
                                      *,L, 1
-------
     Appendix B




Air Sampling Data Forms
-------
Sample Shipping Information
Samples were placed in an oversized, sturdy box with packing material to fill voids  /
and protect the samples during shipping.  The sampling personnel then signed the
chain-of-custody forms, and placed them in the box with die samples. Samples were
shipped via Federal Express to the laboratory.
-------
                ffljiVfl\aig£) Colorado 80111

Work Location
                                      iSSNH'f
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J" "g*'
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Concentration         is
-------
SSH 8
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-------
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                        Jcfc Cefe
^Concervb^itibn
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             801
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-------
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                                 ..MR,
                                                 Date
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Worfc
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 doritrols
17&-V

                                   I  >
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          "
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                   0.150
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                                                             Hour
                                                             By:
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                                    80151 ;
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        $299 E
                   p^
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ii
       11,i.
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Calibration:
                                         ..
                                       Tiinst
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                                                 eanoentration:
           i iHygleniist:
-------
        _
       (Gr ecn^vocrtl Village;;
ifork location
                                                                        Sob Co3e
-------


-------

                 d 159) EX.
                                   AIR SAHPIJ15G EV\TA FORM
IClfeht  K
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                                                          :QfiEi
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                                                 EORH
(Date
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-------
                                  [MR
client
                                      SSH I

                                '
                                                  Goncentratlon
                 •  •«!_
                •__^_ .-;._. ••*i:-'_,~i;.-:.V_-- '..•_
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          £299 DTG Biv
-------
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                       AIR SAMPLDXJ WK POEM
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                                   MR
Controls
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                            osfift -EEL
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                                           Date
                              SSN 8
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                                                   B3PM
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                          ..
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                                                      il -
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                                  MR
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           5299 DTC Blvd., Suite 8 KtKayJtJLfc* ?*+fi»'i*f^*j^*-*-
                                                                 ;|; itouac
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(Sreenwood Village, Colorado 8ft)tl
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-------

Rsspirafors/Ii'Bi



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-------
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                                   MR EAMPKDC
;.*jcK Description'
           * •  "
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                             ^

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fork, Descfipfcibn
-------

                                          ',&£$£*



neat.-
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                                ""
location
                                            jfote 'i
                                SSN j
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Substance
                                   Ij         '
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                                                                 '8,iH6uc
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                       xm
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         .^ t.. -,         ^  r
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                               AIR SWiPLING tVvTA' FORM
:ilent
    tesod^ion
  Inchjsferial W/nienisb:
-------
           5299
                                •80111
Sltenfc  t
     :Description
                                                    Reviewed 'By,:
-------
     Appendix B




Air Sampling Data Forms
-------
Sample Shipping Information
Samples were placed in an oversized, sturdy box with packing material to fill voids
and protect the samples during shipping.  The sampling personnel then signed the
chain-of-custody forms, and placed them in the box with the samples. Samples were
shipped via Federal Express to the laboratory.
-------
          Creernvobd i^iliic

• 4
-------
                                   «XR:
                                                                         .Job Cbda
      'ea-
 fcark
                                                                Media
                                                                            Vdluae
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                                                                By::-
-------
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                                  AIR S.SWPLING LftTA POPM
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Data*
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Subs
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Prs
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                               840
                                                   Date
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                                                                          1
-------
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18
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                      ...
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        ,5299 OTC Blvd., Suite 840*
     Cf-cenwood Village, Colorado 80111
       301,694.4159 FX; 303.694.7367
Kent
otic Description
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                              840}
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brk toeation
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 O
-------
Greenwood ViHage Colorado 801:1 li
                                        ,    ifeviewe| By:;
-------
R2-/iewed By:
-------
      Greenwood Village, Colorado 801*
                                 AIR SAMPLED TOW? FORM
orfc
                                                                 -•-"'••
 industrial ¥>
-------

                            AIR SAKPLBJG DKEK
                                          Date
                                                            	 ^e$®ti$&\k**\
lixJustrial Hygienist:
-------
;A|RfSAH
-------
                               ''
fork Locatico
                                 sat-
Sufetance
  ;	jfc
^VblMSeR ffatfify


ttotn:
-------

      Greenwood V

-torrtrols
                                   SSH
-------
JBQOZ-ALLEN & HAMILTON
     5299 DTC Blvd., Suite 840
 Greenwood Village, Colorado SOU!
   303.694.4159 FX. 303.694.7367
                         AIR SAMPLING &\TA';FOPM
-------
ViHage, Cjaloriado 80111
                         "
                    IMR SAMPLING Bfffift'lFOTM
  ,D T""'7*'     £>:  ,  I-,--    -if .•,•.,.-!.-•-!   •"-.•• "-.      r'k-"- •••• -"  7
-------
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                      '
                               MR SAMEONG QYCV FOFM
                             PEL
iidustrial ff/gienist-r
-------
GreenwootTVUiag^GolorajIb 80111
&s$  -
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                                                              CkNTA' FORM
                                                 SSH'f
                                                   TT','^^,'?!!	ill1!1111 ..i111;;	:i!Tl'?'!:''\?"'T'"'.'.'"'.	
subsCance
                                                              ] (:
-------
-------
                         ;736?
      I
                                11/77
               Post
SufastarcQ]
                             y
-------
-------
     Appendix B




Air Sampling Data Forms
-------
Sample Shipping Information
Samples were placed in an oversized, sturdy box with packing material to fill voids
and protect the samples during shipping.  The sampling personnel then signed the
chain-of-custody forms, and placed them in the box with the samples. Samples were
shipped via Federal Express to the laboratory.
-------
                                                      Title
t
*-£&
    fcsferial! l^ienist:
-------
Greenwood Vilage, Colorado 801 tl
^libration:

.»ca
Post
                               Tlm:
                                                               Volunfe
                                                               -- ..... .....
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-------
      Cre«mvoo(l
    Description
                                                    m minim
                                    •SSN'i
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Bast
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                                        .....
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                                                       Date
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'•"•*  -' '*"*'-
" ineiistirial! %gienist:
-------
BDOZ-ALLEN .& HAMllTON
    J!2W DTC Blvd.,rSttftejMO;
 C r% enwaodf Village, Colorado 80111
            TX, 303.690367
S3£
                 OSJJA EEL:
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                                 MR BAMPUEHG
                                                 Date
                                  Job
-SSIH
 """
                                                        Job! Title.,  '
                                       L. -Fl:P
•Jorii'trol^
Jubstanca
 Irdusfcrial Hygienist:

-------
           5299DTC Blvd., Suite 840
      Greenwood Village,'Colorado 80HI
                         303.694;7367
fcarJc location
Jcritiole
                                                           l
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                              MR
                                                          Jcab Code
                                                                       M.
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                                                ***M »ffi j
                                   SSNif
Title
Jontirols
       .-
CO-WEHTS:
      trial- Hgi
-------
             ; FORM
tpn*  S&fe
            Date
rSSH JJ
-------
                                 ?AiR
ferft
tespirsstors/PFB
                                                              Media
                                       Sf
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Goncentratlon
Hoiar''
                                    vt
-------
                                            ESta
- .
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-------
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|03;6?$7367 ''
         AIR
                                             ' FDR-J

                       ;Ctnoant»a"t:iOT;
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-------
1529?
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                                           ' KSBR ;
-------

                               .SSH
Ttifi
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                                                                 ;• 8 :Hour
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-------
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                       AIR SAMPtoiG tVffA' FDM
                        «:   mi1
                            'Media.!
    •XSanv
& w^iw
&i(M->      T^®-
  m^^ ^ j£M
                                    Reviewa3 By:
-------
Greenwood Village, Colorado
                                     .
                                  to

-------
          519

                               Km
ft^jpraori^lcnji
                                    yV-giS-fyh.


-------
       ^
-
                  "
                             ' FOB*
                            Date;
                 SSN:
-------

MR
                                         IVtfA' FORM :
tleht   
-------
          &
S299rDTe Bfo^s
         _
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-------
Colorado
^te^ fcf (:]/# 3
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                                                 CexSe
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-------
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                                ftER
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-------
                        303,694.7367
iient
                                    ;ssw;l-
Mta
[:      Jcfc'Tltle
-------
-------
      Appendix B




Air Sampling Data Forms
-------
Sample Shipping Information
Samples were placed in an oversized, sturdy box with packing material to fill voids
and protect the samples during shipping.  The sampling personnel then signed the
chain-of-custody forms, and placed them in the box with the samples. Samples were
shipped via Federal Express to the laboratory.
-------
JQ^           J
-------
       Grefert-ivoocJ Village, Colorado 80111
                                   367i

                                    .MR
                                        sstfM
•Iracfc
 substance
                                    .._.....
-------
      Greenwood-Viilage, ColoradQ
                                     SAMPLING DKE&
ilient
-------
'529$       iy
-------
                     ^
          5299 W(KBivdl,^lfeWd
      XJreenwood yill|ge,^Dlorado SOU 1
                                AIR SAMPUHG DM3V PCfW
tespixa tors/P?E
                                                           slfedia:
•tfbnjK if®
 'Gn~""i*
                                                      die
Substance
                               B -Heuri

  LncJustrial Hygienist:
              Reviewed By:;
-------
        3031694
;iSfinfe
SSM | J
                                                        ;Job
                                                              Hsdia
                                                                         ;Vplunie
                                                                           "''
-------
                 m(la|B,i§oIoriaao:80l|l£l




                               war
limit   '
                                  SSI f
                                e -&c
                        OSHA EEL
Qmoentratian
8
-------
G teenwbjjd Village, GoJbrado 80111
            ii4imi|pn|jB . 'l.i ,.il iMjp
-------
                                     ^
                 Villagef Colorado 80111
                                  ATR SAHPIIDJG tyvTA'PDFH
prfc Description
                                                                           Volume;
  rxJustrial Hygienist;
-------
Greenwood Villag^ Colorado 80111
                               SftMPtlHG DKT& PSRK
ssti ff
                                                  Jobj-Tltf e.-
-------
          5199
            6^
                                 	
                                  SAMPLING
                                              Date
                                                    iJbb
tespicators/PEE
                    TJ*
                        OSHA PEL
Cbreentraticai
CDHMEOTS:
-------
                              w
            Stt» p  C BI«, Strife 840
       dreea wood, village, Colorado 1(1 II I
         '303.6944 1 59 FX.
                                          SSN I
Title
                                                        -^    g
	      .„	 !%9i&           ,.,, .'. • £"i**Q ;/fcx    W-^M/tVL.'     i"/^£fef"*'
C&ifiniticfir     >0'M£0$^- .-••  '   Tiw^^'   '^ -      %£/K
fr®: ra^,,,./;,,. ,4  iw 4wv>»/Laia:  Crit "Mfl*A .^'.-oflf'wfW           V^une  ••£*&&&
     y*tyW&Jif^>>**< """•*•-'-'-.i»!ii.—'^'yjrlJfegS  ""*""•"'iEliiiSSLs::  '-•• 	'" •p^^•---—~ '-  f"	  -.rUr^***:.-!^
     ^ .i*.7r7f-  •*'•:?•.—.       t:<.,-ta.™..-'»,.-rrS?T»~Sl;:?5      - •:.: v:^. .r=J.;;->ri.-J.:-r;      -Ji—. ,,,r^.c;--.!s.,.-.-     ••      -5^-••;.^.-*^fe~;
                              osifc
       l,
-------
                      <&
        a03.69S.4t5f
Substance
     jr^-



GOHHEWIS:
-------
  '"'
DevU  ^
;OSHA-lPEli«
                                     SftHoufe
-------
                  i II age,  olorado 80111

                                    '
             on
     locatfon
Pee
Off-
'
:'VdlOTB
 """ ...... ""
Substance
-------
               oa''' VI|lSgc^<{ol<»rfatltii80 11 J.
                                        ~
                                                       K3FM
IGUeait
                                                     Baba;
                                                         "
Job
           <- jjriju j[
                                       SSH; I?
                                                                  Media
qaOlfcratfen:'
Pre
SubsSiance
                                                    condsntrajbion
-------
                                   ,V	-.'if 'J • T-

                                         ^r-^*sg	j*&*>'
'•    ;,.:  :"_  .-:      -:. ? ":J?*-"5"11£S3::
                                        *Jrw' ^W T*'*™'* * *
-------
                                                          .Title
 ®$ Description
Worfc' tc^feim
Calibration:
                                                           Hedist
-------
               oiQia !%il.l£ge; jCftl^^SMl-
                                     MR SAMPLE*;
                                                                               .;Jafe»: Cede
                                                                Jet?
Substance
                   y«.'..-9.>v>«.  rj;i*;li
                   (ifjt'l^Q^t ;itA.r-L.
OSHftiPEL
                                                               Off
                                                     Vbluiae
;Craicehtrat:ion:
-------
       irf"
       «:- -:;»..
                  i*s; ."l?^*,'-
iir-ito*
«brfc OtffiCiiptilT,
te£--^il^   rig


                                  s rTTf •"-—•-'in™'"""™  k•,.•;;;
           KM,

-------

CQMHBilS:
r	*"•	
                         CSHA PEL
-------
          5299
Hienfe ,,
                                               Date;
iOoriSJcilB;
 Su&larice,
-------
^iwpiia,^,^
       AIH
        '
                               jfetoa^
-------
2^> Tiffi* 8h'
        H5'
-------
                                     ' '
                                  AB*
lient   tCp.'|
      e *-   I
orlc Dascrigtion   Ih      ijg    fcfe
                    J it XJJCrri^'- Ajfl^;     ^:?
ferk -
Substance
OSHA EEL



     •  jg- 4>.
                                                 CSofJoenferatiohi

 Industrial;' ;Hygiaiisfc:i
-------

  Si ft
* '"   *
                                               "JSySi  Kil-v'.f,
                                               •:«;-;""~ •-'• -JJl-rfrffi

                                            l



-------
                                  ADR
DNBV'Ft*?*
                                                             ^itle
;bffc ^
                                                               'Media..
                                                                          Voluroa
Sutefcanoa
-------
                        ,, Suit #
                                 AIR S.t>lPIiDJG DATA
                                                 •^j£?M^.d?>?**^
Subs'tance
-------
                                AIR
lienfc   '
Date
Jcfe C3cda
Sontrols
PCS
                                                            fedla
                      •yoltraai-
                                                                    :8 Hcwr
                                                    Reviewed By:
-------
Green%v6o
-------
        303:69*4159
feck X£ca€lbn
itantrols
-------
    iOOZ-ALLEH & MAMIITON
         5299 DTC Blvd., Saltc ?40
     •Greenwood Village, Colorado 80111,
       303.694.415d FX. 303.69^7367~
O'-'tOi
                                             A****
Substanoa
-------
        Appendix C




Data Chem Laboratory Reports
-------
Sample Shipping Information
Samples were placed in an oversized, sturdy box with packing material to fill voids
and protect the samples during shipping.  The sampHng personnel then signed the
chain-of-custpdy forms, and placed them in the box with the samples. Samples were
shipped via Federal Express to the laboratory.
-------
                                ANALYTICAL  REPORT
                          Foiin ARF-AL

                          Page   1 '  of   3
                          Part   1   of   1
                          03060316572135RX
    A Soronson Company
Booz Allen  Hamilton
Attention:  Steve  Coffee
5299 DTC  Bled.
Suite 040
Greenwood Village,  CO 80111
Sampling Collection and Shipment
           Sampling Site 	
                                                           MAR 0 7 2003
       Date	
       Laboratory Group Name 031-0545-04
       Account No.  07003
FAX
                                    694-7367
                                               E-mail
                                                            Telephone (3P3) 231-7559
        Date of Collection February 75, 9003
           Date Samples Received at Laboratory March 03, 9.003
Analysis
           Method of Analysis NHAOQQi.
           Date(s) of Analysis Marp.h Ofi,

Analytical Results
Field
Sample
Nunber



B6-2/25-02
Be- 3/3 6-0 4
VA- 2/26-0 6
A/A-2/26-08
VA, 2/2S 10
VA-2/26-12
A/A-2/26-14
VA-2/26-16
A/A-2/26-18
H/A-2/26-20
BLAHRZ/2S/OS
BLANK2/26-03
R/A-2/27-2a
Laboratory
Hunbec




03106658
03XO««SP
03106660
03106661 .
03IOGSS2
03106663
03106664
O3IO6CC5
03106666
03106667
03IO«tf«»
03X06669.
03106670
Sample
*|typ9




TUBE
TUBE
TUBE
TUBE
TUBS
TUBE
TUBE
TUBB
SUBS
TUBE
TUBE
TUBE
TUBE

ft
>>Ot
w S
32
**\
e 01
8 4.
0.23
0. 37
0.19
0.23
o.oss
0.15
0.12
0.20
0.059
0.088
0.040
0.041
0.21


>•
u
9"
OB
"N
2?
0.0039
0.0047
0.012
0.01S
O.OOSS
0.010
0.0095
0,013
0.019
0.019

**
0.012

J
•£
""•
M
<>3
58.94
58.24
15.30
15.05
13.09
15.00
12.56
IS. 00
3.07
4.58
0.00
0.00
17.19









1





































-


































































t 3w Gonm«n^ en last bag*. ** &•• comment on Ivvfc pftq« .
RD Parameter not detected above t-OD. ( ) Parameter batuean LCD and LOQ.
KR pataoeter not requested. x^ rf , *-. „ ^^
                                       Keview
                                                Neil A. Edwards
                 960 West  LeVoy Drive
                 Phone <801)  266-7700
                 PAX (801) 268-9992
Salt Lake City, Utah 84123-2547
     Veb Page; wwy.datachem.com
     E-mail: lah@datachem.com
                                    0307121227 001 .max
-------
                              ANALYTICAL REPORT
    CHEM
    L A B OR A T ON I E5
    A  Sorenson Company
Analytical Results
                          Form ARF-BL

                          Page   -2   of   3

                          Part   1   of   1
                          03060316572135BX
                                            Date
                                                      MAR 0 7 2003
                                            Laboratory Group Name 03l-0545-(U
Field
SaBBla
Number
R/A- 2/27-2 4
R/A- 2/27-2 6
R/A-2/27-2S
ft/A-2/27-30
B/A-2/27-32
R/A-2/27-34
BX.ANK2/27/03
BI.ANK2/27/03
I/A-2/27-36
i/A-2/27-38
H/A-2/27-40
H/A-2/27-42
K/A-2/27-44
H/A-2/27-46
H/A-2-27-4B
D/A-2/2B-UO
D/A- 2/28-52
D/A- 2/28-54
D/A-2/28-56
D/A-2/2S-58
D/A-2/28-60
D/A-2/28-62
BLAHS2/28/03
BLXBK2/28/03
Laboratory
Number
03106671
03X06672
03106673
03106674
03X06675
03106676
03106677
03106678
03106679
03X06680
03X06681
03106682
03X06683
03X06684
03X06685
03TOSSBS
03106687
03X06688
03X06689
03X06690
03106691
03X06692
03X06693
03106694
Staple
Typo
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE .
TUBE
TUBE
TUDB
Reporting Limit











•



Kercury
pg/saapl*
0.19
0.22
0.19
0.048
0.19
0.061
0.041
0.038
0.34
1.1
4.9
5.3
2.7 '
S.I
0.17
0.15
0.17
0.049
0.16
0.16
0.16
0.082
0.042
0.040
0.01





S
to
S"
U B
"S
« b<
Z B
0.011
0.013
0.011
0.0028
0.011
0.020
*«
A *
0.040
0.13
0.58
0.64
0.33
0.36
0.19
0 .011
0.013
0.0039
0.012
0.012
0.012
0.025
**
* *






a
H
O
>
to
H
-------
                                                                 Torn ARF-C
                                ANALYTICAL  REPORT             Page    3   of   3'
                                                                 03060316572135RX
     IABORATOI
    A Sorenson Coapany                           _        MARJL1 2003
                                               Laboratory Group Name
           /
General Set Comments

Hethod Reference: NIOSH-Manual of Analytical Methods(NMAM), 4th ed., 08/15/94.
Results are not blank-corrected.
Results obtained for media blanks prepared from SKC Carulite tubes are typically
found to have concentrations approximately 0.035-0.045 ug/sample above the
reporting limit of 0.01 pg/sample.                ,
Results cannot be reported in mg/m3 or ppm for samples vith no air volume.


General Lab Comments

The results provided in this report relate only to the items tested.
This page is the concluding page of the report.
                 960 West LeVoy Drive / Salt Lake City,  Utah 84123-2547
                 Phone (801) 266-7700        Web Page:  wwv.datachem.com
                 FAX (801) 268-9992          E-mail:  lab@datachem.com
                                     0307121227 001 .max
-------
                  DATA
                  CHEM
                  LABORATORIES, INC.
                          ANALYTICAL REQUEST FORM
                          1. S REGULAR Status
                            O RUSH Statue Requested - AnntTUINAL CHARGE
                               RESULTS REQUIRED BY	
                                                       DATE
                               CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
2. Date 2- \ 2.5/0 3   Purchase Order No
3. Company Name  6 pg"2, A 1 1 f t\  Hn
  Address
                                                       _4. Quota No
PTC
                                      5u.-f«.
                                 (V
  Person to contact
  Telephone (30$
  Fax Telephone (30$ t3&l~Ll-!». 1
  E-mail Address i o.f P>C -.
DCL Project Manager
Sample Collection
Sampling Site 	
Industrial Process _
Data of Collection 2.
Time Collected 	
  Billing Address (if different)  .alft
                                        Date of Shipment  2-l7~ftf 6 3
                                        Chain of Custody No.  QJ	
6. REQUEST FOR ANALYSES
   Laboratory Use Oriy
  Client Samph Number
                                      Matrix*
                           Sample Volume
                                                         ANALYSES REQUESTED - Use method number if (mown
                                                                                          Unlls"
                                                                                           •I,
                               02.
                 //VOfl/1/2.
                                              re, it L
                               03
                            5B.J.H  L
' Specify: Solid sorbent tube, e.g. Charcoal; Filter type: Impinger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
** 1 mgfsample  2. mgfm3  3 ppm 4%  5	(other)  Please indicate one or more units in the column entitled Unils"
Comments

Possible Contamination andtor Chemical Hazards
7. Chain of Custody (Optional)
Relinquished by J$^f) '•
Received by ' /?« 	 SA.
Relinquished by £.* 	 -£ f
Received by
.*»
f ^ jf
'**?-
#=~l*
'^=^


Date/Time 2. liS fob I ^tkj
Oaiemma j /i
Datemme y/3/4.?
DdtB/TllllB

    960 West LeVoy Drive / Salt Lake City, UT 84123          BOO-356-9135 or 801-266-7700 / FAX: 801-268-9992
                                  DATACHEM LABORATORIES, INC
                                        _0307121227_001.max
-------
                   DATA
                   CHEM
                   LABORATORIES, INC.
                                             ANALYTICAL REQUEST FORM
                                             O RUSH Status Requested - ADDITIONAL CHARGE
                                                RESULTS REQUIRED BY	
                                                                        DATE
                                                CONTACT DATACHEM UBS PRIOR TO SENDING SAMPLES
2. Dale "Z-/T. P / 0 3   Purchase Outer No

3. Company Name   fiat*. & I If^
                                                      4. QuoleNo
  Address
                Ore.
     knfenwcorl y.'||^f i (Q   E>Q1I>
Person to Contact   $R*/t   C o££?t.	
             1.X i - ~1$S*\	


E-maUAddress  Cof&f:^ <\e.aLe.<\$ ion U .
                                DCL Project Manager

                             _S. Sample Collection

                                Sampling Site .	
                                                          Industrial Process

                                                          Date of Collection

                                                          Time Collected _
                                              •4ii/j
                                             tCv-,
                                Dale of Shipment
Billing Address (if different)
4^
                                                          Chain of Custody No.
6. REQUEST FOR ANALYSES
   Uboratoy Use Only     Cltem Sampte Number     Matrix*    Sample Volume  ANALYSES REQUESTED- U«o method numter If toown  Unlls'
                                   HYfi&Ak
                               JA
                                                                                          2-
                                              J5.00 L
                              -tit
           1*
                                            3,0-FL-
                                                                  (afltft
           in
• Specify: Solid sorbenl tube, e g. Charcoal; Filler type; Impinger solution; Bulk sample; Blood; Urine; Tissue; Sail; Water; Other
** \ mo/sample  2 mg/m1  3 ppm  4 %  6 __ (other) Please Indicate one or more units in the column entitled Units"
Comnients	^	
Possible Contamination and/or Chemical Hazards
7. Chain of Custody IQptlonal)
Relinauished by T^T^ ^^- ^J1
Received by .'C^ — ^I'V^W
X^ • Date/Time 2,(2Sjif6'=> /^Tcd
^ Datemrae */3 '
Relinauished by /** — -»<" /''*-
-------
                   DATA
                   CHEM
                   LABORATORIES, INC.
                                             ANALYTICAL REQUEST FORM
                                               EH RUSH Status Requested - ADDITIONAL CHARGE
                                                  RESULTS REQUIRED BY	___^
                                                                           DATE
                                                   CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
2. Oate^fig/f)^   Purchase Order No

3. Company Name Obj) Z,  /V 1 k>\

  Address
                                                         4. Quota No
                   PTC  gK/J . , Sif .VC
                      v. i
                                                           DCLProjeciManager  jCfl.i'Vl   / I TrC*'"
                                                        _5. Sample Collection

                                                           Sampling Site 	
  Person to Conlacl

  Telephone (3&3>
                                                           indusmai process

                                                           Dele of Collection

                                                           Time Collected _
  E-mail Address   C 0-f^C f ^ 5^0 kfc/v fi /V. /I .  / J^ ^
  Billing Address (if different)
                            i 1 1>
                                                           Date of Shipment
Chain of Custody Mo
                                                                            I "7
6. REQUEST FOR ANALYSES
   Laboratory Usa Only
                    ClianlSampla Number
                                      Matrix*
                                              Sampte Volume
                                                          ANALYSES REQUESTED - Use method number K known
                                                                                            Units"'
                                                                      tool
           7i
           73
                                                            KA m
           74
                            -30
                                                                A- m  t,
                                 SL
                                                               A
                                                                            01
                                                             rs/ A-I-TI  t oon
           77
                                                               f>r
                                                                           (501
                                                            fv
* Specify: Solid sorbent tube, e g. Charcoal; Filler type; Impinger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
" 1 mg/sample  2 mg/m*  3 ppm  4%  5	(other)  Please Indicate one or more units In the column entitled Units"
Comments   	   	  	     	  	                	
Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optlgnal)	
Relinquished fay

Received by

Relinquished by

Received by
                                                         Date/Time

                                                         Date/Time
                /?
                                                         Date/Time
    960 West LeVoy Drive / Salt Lake City, LIT 84123           800-356-9135 or 801 -266-7700 / FAX: 801-268-9992
                                  DATACHEM LABORATORIES. INC
                                        _0307121227_001.max
-------
                   DATA
                   CHEM
                   LABORATORIES, INC.
2- Date 3 J33 /i&3    Purchase Order No  	
3. Company Name mot A Jl*t\ TO.fYl i /
                                              ANALYTICAL REQUEST FORM
                                              t. OCULAR Status    O?*£ ~€>L
                                                   RUSH Status Requested - ADDITIONAL CHARGE
                                                   RESULTS REQUIRED BY	
                                                                            DATE •
                                                   CONTACT DATACHEM UBS PRIOR TO SENDING SAMPLES
                                                          4. QuoleNo
  Address   C2.
                     PT C
  Person to Contact  S^Cvf
  Telephone ($$)  ^t H <-
                                   ft)
                                                          DCL Project Manager _fl\fliAl!\
                                                       _5. Sample Collection
                                                          Sampling Sile
E-mail Address
Billing Address (if dlfferenl)
                          Tk,o U g.^, ^ b«>. h ..
                            n /6
                                                            Industrial Piucwss
                                                            Date of Collection
                                                            Time Collected _
                                                            Data of Shipment
                                                            Chain of Custody No   )...j)
6. REQUEST FOR ANALYSES
   Laboraloiy Use Only
                   Client Sample Number
                                       Mfllrlx1
                                               Sample Volume
                                                           ANALYSES REQUESTED - Use method number if known
                                                                                             UnHs"
                                3i
                                                8,11. *-
                                                             N//
                                                                       UOO*v
                                                                A-  fY^
                                      H
                                                              Ar
                                                                         t, A
                                      14
                                                             ' N A  IY\
                                                                             rt
*  Specify: Solid sorbent tube, e.g Charcoal; Filler type; Impinger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
"Imgteample  Z.mgfrn' 3. ppm 4.%  5	(other) Please indicate one or more units In the column entitled Units**
Comments

Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)
Relinquished by (A w^y^l/^y' llW^y0'^\^f
Received bv $ ^f- 	 ^ /-^tt- '
Rellnoutehed by ••'?' 	 -»<1 /-,s^S"<2r — •
Received by
Date/Time '?• lo^S/v 3 f & Q &
Uatenims -t / ?
DateTTIrrte ."J/J
Dale/nmu

    960 West LeVoy Drive I Salt Lake City, UT B4123           800-356-9135 or 801-266-77001 FAX: 801-268-9992
                                   DATACHEM LABORATORIES, INC.
                                         _0307121227_001.max
-------
                   DATA
                  CHEM
                  LABORATORIES, INC.
2- Date "i/ 2. S7 03  Purchase Order No  	
3. Company Name  &J67-. A (lf,(\  WV
  Address
                                            ANALYTICAL REQUEST FORM
                                                i RUSH Status Requested - ADDITIONAL CHARGE
                                                 RESULTS REQUIRED BY 	
                                                                         DATE
                                                 CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
                                                        4. Quote No
                    PTC
           k »f< evx »,.,rt.A  I/. I/tijf; ft> y I
            DCL Project Manager
         .5. Sampla Collection
            Sampling Site 	
  Person to Contact  SiCtff C a FA»(?
  Telephone $)^)
  E-mail Address   f toff"??
  Bitting Address (if different)

                                                          industrial Process
                                                          Date of Collection _
                                                          Time Collected 	
                                                          Date of Shipment J;
                                                          Chain of Custody No
6. REQUEST FOR ANALYSES
   Laboraloiy Usa Only
                    Qlsnl Sample Number
                                     Matrix'
Sampla Volulme
                                                        ANALYSES REQUESTED - Use method number If known
                                                                                          UnHs"
                                                                     t. no "
                                                            IV
                                                                     /..ACT
                                                               A- m  L, f\ 6
                                                              ft-
                                                                      £.0
                                                           NJv rv\
                                                                           e e(
          JH.
* Specify: Solid sorbent tube, e g Charcoal; Filter type; Impinger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
** 1 mg/sample  2 mg/m  3 ppm 4 %  5
Comments
                                   _ (other)  Please Indicate one or more units in (he column entitled Unlls"

Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)
Relinquished by QrflVJ\£l*~ i ' U^T^i^ 	
Received bv U / \ * 	 *£ /" e^^~-^
Relinquished by ^' '« 	 uC /*>*dz. —
Received by
i"
Date/Time •P-/-*^" */v3 1 £ 6 fo
Oalemme 3/9
Dale/Time ?/^ /c5 J
Date/Time

    960 West LeVoy Drive / Salt Lake City, UT 84123           800-356-9135 or 601-266-7700 / FAX: 601-268-9992
                                 DATACHEM LABORATORIES, INC.
                                       _0307121227_001.max
-------
        Appendix C




Data Chem Laboratory Reports
-------
Sample Shipping Information
Samples were placed in an oversized, sturdy box with packing material to fill voids
and protect the samples during shipping.  The sampling personnel then signed the
chain-of-custody forms, and placed them in the box with the samples. Samples were
shipped via Federal Express to the laboratory.
-------
                                ANALYTICAL REPORT
                             Form ARF-AL

                             Page   1   of   3

                             Part   1   of   1
                             04070311H0402RX
                                                          APR 0 7 2003
                                                Date _
                                                Laboratory Group Name 031-0821^01
                                                Account No.  Q70Q3	
Booz  Allen & Hamilton
Attention: Jordan Murphy
5299  DTC Blvd.
Suite 040
Greenwood Village, CO 80111
Sampling Collection and Shipment
           Sampling Site 	
                             FAX
                                       684-7367
                                                             Telephone (303) 221-6446
                                                E-mail  murphy j ordanflhah . com _
          Date  of  Collection Harph ?4t 2003
           Date Samples Received at Laboratory  March 31,  2003
Analysis
           Method of Analysis MMAM
           Date(s) of Analysis April 03f 2003

Analytical Results
Field
Sample
Number
3705B324~01
3705B024-03
3705RA324-05
3705RA324-07
3705RA324-09
3705RA324-11
3705RA324-13
170SRAJ24-1S
3705RA324-17
BLANK 3/24
BLANK 3/24
3705DA325-19
3705DA325-21
Laboratory
Number
03109961
03109962
03109963
03109964
03109965
03109966
03109967 .
03109968
03109969
03109970
03109971
03109972
03109973
Sample
Type
HYDRAR
HXDRAR
HXDRAR
HXDRAR
HYDRAR
HYDRAH
HTDRAR
HYDRAR
HYDHAH
HTDRAR
HXDRAR
HXDRAR
HYDRAR
Mercury
pg/sample
0.43
0.16
2.0
1.1
1.1
3.1
0.43
5. 8
1.4
0.078
O.OB6
2.4
0.27
Mercury
ng/m'
0.014
0.0059
0.074
0.043
0.045
0.11
0.075
0.086
0.021 '
**
* ft
0.084
0.016
e
n
•H
0
u
31.78
27.98
26.49
24.38
25.27
28.59
5.65
68.13
66.36
0.00
0.00
28.75
16.94


















•. .




1




























































  t  See  comment  on last page.
 KD Parameter not detected above LOD.
 HR Parameter not requested.
 HA Parameter not applicable.
 •* see comment on last page.
(  > Parameter between LOD-and  LOQ.
                                             7TC.
                                              : Tanya Cheklin
                                        Revi<
                                                Jason D. Kim
                 960 West LeVoy Drive / Salt Lake City, Utah 84123-2547
                 Phone (801) 266-7700        Veb Page: vw.datachem.com
                 FAX (801) 268-9992          E-mail: lab@datachem.com
                                    0407155628 001 .max
-------
DATA
ANALYTICAL REPORT
Form ARP-BL

Page   2   of   3

Fart   1   of   I
04070311110402BX
   .  LABORATORIES
    A Sorenson Company
Analytical Results
                          APR
                                              Laboratory Group Name (m-Qft21-m.
Field
sanpla
Number
3705DA32S-23
3705DA325-25
3705DA325-27
3705DA325-29
3705DA325-31
3705DA325-33
BLAHR 3/25
BI.A.HK 3/25
3705AA327-43
3705AA327-45
3705AA327-47
3705AA327-49
3705AA327-51
3705AA327-53
3705AA327-55
3705AA327-57
3705AA327-58
BLANK 3/27
BLANK 3/27
3705HA326-35
3705HA3Z6-37
3705HA326-39
3705HA326-41
BLAHK 3/26
BLANK 3/26
LAB BLX 3/2 4
LAB BLR 3/24
LAS BLK 3/24
Laboratory
dunba r
03109974
03109975
03109976
03109977
03109978
03109979
03109980
03100991
03109962
03109983
03109984
03X09965
03I099S6
03109987
03I099B8
03109989
03109990
03109991
03109992
03109993
03109994
03109995
03109996
03110003
03110004
03110666
03110669
03110670
Sample
Type
HYDRAR
HYDRAS
HYDRAS
KYDRAR
RYDRAR
HYDRAR
HYDRAR
HYORAB
HYDRAR
HYDRAR
HYDSAR
HYDRAS
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDKAR
HYDRAR
HYDRAR
KYDKAR
HYDRAR
HYDRAR
HYDRAS
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HXDRAR
Reoortinq Limit



Mercury
jig/sanple
0.60
1.8
0.32
1.7
1.8
0.23
'0.075
0. 071
0.89
2.4
0.40
1.9
0.41
0.53
0.73
1.1
0.065
0.073
0.071
0.50
0.33
1.9
0.66
0.28
0.21
0.056
0.060
0.065
0.01

Hercury
ag/m'
0.035
0.070
0.13
0.027
0.026
0.078
**
* *
0.030
0.074
0.014
0.071
0.0084
0.16
0.009S
0.014
0.021
«*
**
0.13
0.11
0.065
0.022
»*
**
* *
* *
* *


\ii Volume
L
17.00
24.94
2.54
62.85
69.40
2.96
0.00
n.on
29.69
31.75
29.20
27.34
48.12
3.40
77.60
78.53
3.05
0.00
0.00
3.97
3.12
28.92
29.85
0.00
0.00
0.00
0.00
0.00
















































-




























..














•






















































•

^






































  t  See comment on last page
  ND Parameter not detected above LOD
  HR P*r«mat»r nnt r«qu«ct.Mri .
  HA Parameter not applicable.
      ** See comment on last page.
     ( ) Parameter between LOD and LOQ.
                960 Vest LeVoy Drive /  Salt Lake City, Utah 84123-2547
                Phone (801) 266-7700       Web Page: wvw.datachem.com
                PAX (801) 268-9992         E-mail: lab@datachem.com
                                  0407155628 001 .max
-------
                                ANALYTICAL  REPORT
                          Form ARF-C
                          Page   3   of   3
                          04070311110402RX
     IABORATORIES
    A Sorsnson Company
General Set Comments
                   APP  0 7 2003
                                               Laboratory Group Name (W-nB?1~r>1
Method Reference: NIOSH Manual of Analytical Methods(NMAM), 4th ed., 08/15/94.
Results are not blank-corrected.
Results obtained for media blanks prepared from SKC Carulite tubes are typically
found to have concentrations approximately the 0.035-0.045 Kg/sample above the
reporting limit.
Recoveries of the Laboratory Control Samples (LCS) and the Laboratory Control
Sample Duplicates (LCSD) are not within the historical quality control limits.
Nonconformance/Corrective Action Report (NC/CAR) # 624 is initiated.
Results cannot be reported in mg/m3 or ppm for samples with no air volume.


General Lab Comments

The results provided in this report relate only to the items tested.
This page is the concluding page of the report.
                 960  West  LeVoy Drive
                 Phone (801)  266-7700
                 FAX  (801) 268-9992
Salt Lake City, Utah 84123-2547
     Web Page:  wwv.datachem.com
     E-mail: lab@datacheo.com
                                  _0407155628_001.max
-------
                    DATA
                    CHEM
                    LABORATORIES, INC.
                 Purchase Order No.  	
                 x  ft tie* /4m,
                                              ANALYTICAL REQUEST FORM
                                              1. ffl^KULAR Status       Q^£" ^^ ~ 0 I   •
                                                   RUSH Status Requested - ADDITIONAL CHARGE
                                                   RESULTS REQUIRED BY 	
                                                                             DATE
                                                   CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
                                                            4. Quote No.
3. Company Name
  Address  £"2 ^ C1   D TC  6 j v-. . . $L.'/K:  8
Person to Contact   5 'iff I/HC
Telephone $)})
                                             o t it
                                                            DCL Project Manager
                                                                  <
                                                         _5. Sample Collection
                                                            Sampling Site 	'
                                               'r
Fax Telephone (>J)  t {j tj -")
E-mail Address
                                 Industrial Procaes
                                 Date of Collection
                                 Time Collected
                                                                                    / /!i 3
•./•ViAd ft (P Qftk,
Billing Address (if different)
                                                            Date of Shipment '!j J
                                                                                     ^ -5
                                /"
                                                            Chain of Custody No.
6. REQUEST FOR ANALYSES
 Laboratory Use Only     Client Sample Number
                                        Matrix*
                                                 Sample Volume
                                                             ANALYSES REQUESTED - Use method number If known
                                                                                                 Units"
                                                                K!  (,-
                           •A   _H
                                                                   .«. V
                                                                   I'
                                                         c,
                                                    o
                                                    6
     .
                                     i.
*  Specify: Solid sorbanl tube, e.g. Charcoal; Filter type; Impinger solution; Bulk sample. Blood; Urine; Tissue; Soil; Water; Other
** 1. mg/sample \^2. mg/m^S. ppm 4.%   5.	/_ (other)  Please indicate one or more units in the column entitled Units"
Comments    	      RTF    f).>  . *if
•
Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)
Relinquished bv Ot^Uu fe\0Uvx'
1 •" *~-~< h&
Relinquished by ,^^^-^.f f-'t-'tC- — •
Received by
Date/Time '?/><
-------
                     DATA
                    CHEM
                    LABORATORIES, INC.
                                                 ANALYTICAL REQUEST FORM
                                                 LJ RUSH status Requested - ADDITIONAL CMAROE
                                                    RESULTS REQUIRED BY     '	
                                                                               DATE
                                                    CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
2, Date
                    Purchase Order No.
                                                              4. Quote No.
3. Company Name &QDZ, &\\t*\
  Address  ^ 2. <=f 1   p T (. ft I ^ fj^l i tt
                    V . I
                                   &  *% 6 i /
                                 DCL Project Manager  fcflfyjj
                              _5. Sample Collection
                                 Sampling Site
                        JCV-
Person to Contact ,
Telephone^) 7^1 [
fax Telephono (&§   (y Cj Uj » -""?.?L ~)
                                 industrial Process
                                 Date of Collection
                                 Time Collected
E-mail Address >v\ tA/"iC
Billing Address (if different)
                        "*
                                                                Data of Shipment
^a^W^C-f
                                                                Chain of Custody No.
6. REQUEST FOR ANALYSES
 Laboratory Use Only      Cllenl Sample Numbar
                                          Matrix'
                                                   Sample Volume
                                                               ANALYSES REQUESTED - USB mathod number If known
                                                                                                    Units"
                                                                  KJ
                           u -
                                                                      \\
                                           It
                                                                      x\
                                                   2  -
                                                                                                     -7.
                                          u
                                                                   \\
                                                      0
*  Specify: Solid sorbent tube, e.g. Charcoal; Filter type; Implnger solution, Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
** 1. mg/sampfe  C^rng/mJ~"S,l ppm  4. %   5.	(other) Please indicate one or more units in the column entitled Units"*
Comments   LV'^tvvte',   lV.                                       '
 Possible Contamination and/or Chemical Hazards
 7. Chain of Custody (Optional)
     960 West LeVoy Drive / Salt Lake City, UT 84123           800-356-9135 or 801 -266-7700 / FAX: 801 -268-9992
                                     DATACHEM LABORATORIES, INC.
                                          _0407155628_001.max
-------
                    DATA
                   CHEM
                   LABORATORIES, INC.
                                             ANALYTICAL REQUEST FORM
                                                                                     /~ 0 ?
                                               LI RUSH Status Requested - ADDITIONAL CHARGE
                                                  RESULTS REQUIRED BY 	
                                                                            DATE
                                                  CONTACT DATACHEMLABS PRIOR TO SENDING SAMPLES
2. Date 3J/2-V  C\j &/£  0>Ltfu£.

Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)
Relinquished by[ yTs/Oift^L \^W?\ffv^ —
Received bv V s? *. 	 r/<-^—
Relinquished by /'^£* — H:' /•t^uZ. — .
Received by

Date/Time
DalBfTime
Date/Time
Dale/Time

")/ ^ f/a^ / }•« 3. j —
3 ft 1
3/3 1 /* 3


     960 West LeVoy Drive / Salt Lake City, UT 84123            800-356-9135 or 801-266-7700 / FAX: 801-268-9992
                                    DATACHEM LABORATORIES. INC.
                                         _0407155628_001.max
-------
                    DATA
                    CHEM
                    LABORATORIES, INC.
                                                ANA^friCAL REQUEST  FORM
                                                1. QREGULAR status
                                                  EH RUSH status Requested • ADDITIONAL CHARGE
                                                     RESULTS REQUIRED BY	  	
                                                                               DATE
                                                     CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
2. Date
3. Company Name
  Address
                   Purchase Order No.
                     r, /Hfr\ *W
                                                           .4. Quote No.
                                     Sjilc
                                                              DCL Project Manager
                                                           _5. Sample Collection
                                                              Sampling Site
  Person to Contact
  Telephone^)
  Pox Telephone (
  E-mail Address
                        
Time Collected 	
                                                               Date of Shipment
                                                               Chain of Custody No.
6. REQUEST FOR ANALYSES
   Latxxatory Use Only
                      Client Sample Number
                                        Matrix*
                                                 Sample Volume
                                                             ANALYSES REQUESTED - Usa method number if known
                                                                                                 Unto"
                                                                K/
                                                                        oo«\
                          vv.  .
                                                                    v\
                                       /V\c.E,F
                                                                      3_MiX
                                                   ,  f Z-
       iooo /
                          tc  '3/7 (.
                                                                 (  I
      10003
                                                               M
                          1C
                                                    L>
* Specify: Solid
** 1 . mg/sample
Comments
                    e, eg Charcoal; Filler type; Impinger solution; Bulk sample; Blood; Urine; Tissue; Soil, Water, Other
                   J> 3. ppm 4. %   5 _ (other)  Please Indicate one or more units in the column entitled Units**
                               |Vv .S     D** \s\ i.-? _
                           fr-j-
Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)	
Relinquished by|
Received by
Relinquished by
Received by
                                                             Date/Time i	 	
                                                             Daierrime    ,-• /y-r
                                                             Date/Time   jT/3 f /
                                                             Dale/Time	
     960 West LoVoy Drive / Salt Lake City, UT 84123           800-356-9135 or B01 -266-7700 / FAX: 801 -268-9992
                                    DATACHEM LABORATORIES. INC.
                                         _0407155628_001.max
-------
-------
        Appendix C




Data Chem Laboratory Reports

-------
Sample Shipping Information
Samples were placed in an oversized, sturdy box with packing material to fill voids
and protect the samples during shipping.  The sampling personnel then signed the
chain-of-custody forms, and placed them in the box with the samples. Samples were
shipped via Federal Express to the laboratory.
-------
DATA1
    CHEM
    lABORATOftlES
    A Sorenaon Company
                    ANALYTICAL REPORT
Form ARF-AL
Page   1   of   3
Part   1   of   1
05140322400528RX
                                             MAY 1 5 ZDB3
                                            Date	
                                            Laboratory Group Name 031-1146-Qfi
                                            Account No. Q70Q3	

 Booz Allen Hamilton
 Attention: Steve Coffee
 5299 DTC Bled,
 Suite 840
 Greenwood Village,  CO 80111
Sampling Collection and Shipment
          Sampling Site AERC Melbourne
                                                    FAX (303^ 604-7367
                                              Telephone f303) 221-755Q
                                  E-mail  nnffeia gfccphonflhah  r>nm	
                              	 Date of Collection April 20,  2003

Date Samples Received at Laboratory May  OS, 2003	
Analysis
          Method of Analysis MMAM 600QMQD
          Date(s) of AnalysisMa3t_12U_2QQ3_

Analytical Results
Field
Sample
Number





3705B429-01
3705B429-03
3705DA429-OS
3705DA429-07
3705DA4 29-09
3705DA429-11
3705DA4Z9-13
3705DA429-1S
3705DA429-17
370SDA429-19
3705DA429-21
3705DA429-23
3705DA429-25
Laboratory
Number





03116295
03116296
03116297
03116298
03116299
03116300
03116301
03116302
03116303
03116304
03I1630S
03116306
03116307
Sample
Type





HYDRAR
HYDRAR
RYDRAR
HXDRAE
HVDHAR
HYDRAH
HYDRAR
HYDRAS
HYDRAR
MYDRAR
HYDRAR
HZDRAR
HVDHAR

»iBi
M a
3M .
u «
MX

£ si
1.0
0.77
3.7
3.0
3.3
6.7
0.044
0.21
3.7 v
3.0
2.3
0.23
0.65

N
M
^*<
US
«%.

X B
0.016
0.012
0.14
0.12
0.13
0.27
0.015
0.041
0.035
0.036
0.021
0.23
0.64
?
3
H
O
f

H

-------
                                 ANALYTICAL REPORT
                             Form ARF-BL

                             Page    2    of   3
                             Part    I    of   1
                             05140322400528RX
     LAB ORATOR) ES
    A Sorenson Company
Analytical Results
                                                 Date     MAY  1  5 ?nP3
                                                 Laboratory Group Name 031-1146-06
Field
Sample
Number
PLD SLK 4/29
»LD BLK 4/29
3705AA4 30-27
370SAA430-29
3705AA430-31
3705AA430-33
3705AA430-35
3705AA430-37
3705AA430-39
3705AA430-41
3705AA430-43
3705AA430-45
370SAA4 30-47
3705AA430-49
370SAA430-51
370SAA430-53
3705AA430-55
370SAA430-57
370SAA431-S9
FLD ELK 4/30
FLD BLK 4/30
Laboratory
Number
03116306
03116309
03116310
03116311
03116312
03H6313
03116314
03116315
03116316
03116317
03116316
03116319
03116320
03116321
03116322
03116323
03116324
031163ZS
03116326
03X16327
03116326
Sample
Type
HYDRAR
HYDRAS
HTDSAR
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAS
HTDBAR
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAS
HYDRAR
HXDRAR
HYDRAR
HYDRAR
HYDRAS
HYDRAR
Reporting Limit














.









Mercury
ng/sample
0.046
0.044
1.4
0.059
0.87
1.1
1.1
0.19
0.4S
0.1«
0.24
0.12
0.26
2.9
3.1
2.S
0.35
0.93
0.11
0.045
0.046
0.01








Mercury
ng/m>
**
+ *
0.063
0.0047
0.070
0.046
0.048
0.064
0.11
0.060
0.061
0.12
0.26
0.019
0.021
0.016
0.034
O.OSZ
0.036
**
**









Air Volume
L
0.0
0.0
22.3
12. S
12.4
22. a
22.6
2.96
4.22
1. 98
2.96
0.99
0.99
ISO. 6
149.1
154.1
10.4
10.1
3.07
0.0
0.0





























'















































'








••






































































































-



  t  See comment on last page.
 HD Parameter not detected above  LOD.
 NR Parameter not requested.
 HA Parameter not applicable.
 ** See comment on last page.
( ) Parameter between LOD and LOQ.
                 960 West  LeVoy Drive / Salt Lake City, Utah  84123-2547
                 Phone  (801)  266-7700        Web Page: Nvm.datachem.com
                 FAX {801} 268-9992          E-mail: lab@datachem.eom
-------
DATA
ANALYTICAL REPORT
Form ARP-C
Page   3   of   ;
0514Q32240Q528RX
     (. ABORATOftf
    A Sorancon Company
General Set Comments
                                             Date
                                             Laboratory W«up
Method Reference: NIOSH Manual of Analytical Methods(NMAM), 4th ed., 08/15/94.
Results are not blank-corrected.
Results cannot be reported in mg/n1  or ppm for samples with no air volume.
                                                          f

General Lab Conments

The results provided in this report  relate only to the items tested.
This page is  the concluding page  of  the report.
                960 West LeVoy Drive / Salt Lake City,  Utah 84123-2547
                Phone (801) 266-7700       Web Page: www.datachem.com
                FAX (801) 268-9992         E-mail: lab@datachem.com
-------
    A Soranson Company
 Booz Allen Hamilton
 Attention: Steve Coffee
 5299 DTC Bled.
 Suite 840
 Greenwood Village, CO 80111
Sampling Collection and Shipment
           Sampling  Site AERC Melbourne
                                ANALYTICAL REPORT
                                                Date
                                                        Form ARF-AL
                                                        Page   1   of   3
                                                        Part   1   of   1
                                                        05140323403496RX
                                                 MAY 1 5 2003
                                                Laboratory Group Name 031-1146-07
                                                Account No.  07003	
PAX
                                                                  6Q4-7367
                                                             Telephone (go?)  221-755Q
                                                E-mail   coffee
                                	 Date of  Collection -May .01, 9003

Date Samples Received at Laboratory May 05, 2003	
Analysis
           Method of Analysis HMAM_nQQ3MQIL
           Date(a) of  Analysis May 12, 2003

Analytical Results
Field
Sample
Dumber
3705RA501-S1
3705RA501-63
370SRA5Q1-65
370SRAS01-67
3705RAS01-69
370SRAS01-71
3705RAS01-73
370SBAS01-7S
3705SASOI-77
3705RAS01-79
370SRA501-B1
370SRA501-83
3705RA501-85
Laboratory
number
03116320
03116330
03116331
03116332
03116333
03116334
03I1S33S
03116336
03116337
03X16338
03116339
03116340
03116341
Sample
Type
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAB
HYDRAR
Mercury
lig/sanple
o.ao
0.28
0.31
0.3»
0.14
0.23
TBA
0.17
0.11
0.1C
0.15
1.7
1.7
Mercury
ng/iu'
0.01.B
0.024
0.026
0.019
0.0063
0.075
TBA
0.17
0.11
0.017
0.016
0.013
0.013
1
H
0
tl
rta
21.9
11.8
12.0
22.2
22.1
3.07
TBA
1.01
1.01
9.32
9.45
134.6
13*. E






































•.




.








































 t  See comment on last page
 ND Parameter not detected above
 NH Parameter not requested.
 BA Parameter not applicable.
                              See comment on last page.
                   LOO.     (  ) Parameter between LOO and LOQ.
                           TBA Parameter to be analazed,
                 960 West LeVoy Drive
                 Phone (801) 266-7700
                 FAX (801) 268-9992 '
                             Salt Lake City, Utah 84123-2547
                                  Web Page: wvm.datachem.com
                                  E-mail:  lab@datachem.com
-------
DATAi
ANALYTICAL REPORT
Form ARF-BL

Page    2   of  3
Part    1   of  1
05140323403496RX
    A Soranion Company
Analytical Results
                                          Date
                      MAY t 5 2003
                                          Laboratory Group Hame 031-1146-07
Fieia
Sample
Humba r
370SRA501-87
VI.O SIX 5/1
FID BtX 5/1
3705DA502-89
37050A502-91
3705DA5Q2-93
3705DAS02-9S
3705DA502-97
LAB BLANK "
LAB BLAHK
LAB BLAHK
FLD BM 5/2
FLD BIK 5/2
Laboratory
number
03116342
03116343
03116344
03116345
03116346
03116347
03116348
03116349
03116350
03116351
03X16352
03116353
03116889
Sample
Type
HYDRAR
KTDRAR
HYDRAR
HYDRAR
HYDRAR
HYDRAS
HYDRAH
HXDHAB
HYDRAH
HID RAH
HYDRAS
HYDRAR
HYDRAR
Reporting Limit
















































Mercury
tig/sample
2.3
0.046
0.049
0.81
0.76
0.66
0.78
0.60
0.046
0.046
0.045
0.049
0.049
0.01
















M
3^
0.017
»*
**
0.094
0.088
0.076
0.090
0.20
**
**
**
**
**

















Air Volume
L
137. £
0.0
0.0
8.60
8.60
8.69
8.66
3.07
0.0
0.0
0.0
0.0
0.0




































































'










































<

















































'







































t See comment on last page. ** See comment on last page.
ND Parameter not detected above LOD. ( ) Parameter between LOD and iOQ.
NR Parameter not requested. TEA Parameter to be analyzed.
NA Parameter not applicable.
               960 West LeVoy Drive / Salt Lake City, Utah 84123-2547
               Phone (801). 266-7700       Web Page: www.dataehem.com
               FAX•(801) 268-9992         E-mail: lab@datachem.com
-------
DATA1

    CHEM
    I ABQRATORI E S
    A Soranaon Compftny


General Set Comments
ANALYTICAL REPORT
Form ARF-C
Page   3   of   3
05140323403496RX
                       MAY f 5 2003
              Date	
              Laboratory Group Name Q3I-1146-07
Method Reference: NIOSH Manual of Analytical Methods(NMAM), 4th ed., 08/15/94.
Results are not blank-corrected.
Results cannot be reported in mg/m1  or ppm for samples with no air volume.
Field sample 03116335 was not submitted by the client.
                     ;                         -                      i

General Lab Comments

The results provided in this report  relate only to the items tested.
This page is the concluding page of  the report.
               960 Hesit LeVoy Drive./ Salt Lake City, Utah 84123-2547
               Phone (801) 266-7700       Web Page: www.datachem.com
               FAX (801) 268-9992    .     E-mail: lab@datachem.com
-------
                                                                                                                   1
                   DATA
                   CHEM
                   LABORATORIES, INC.
ANALYTICAL REQUEST  FORM
1. D REGULAR Status        03T -
     RUSH Status Requested - ADDITIONAL CHARGE
     RESULTS REQUIRED BY	
                              DATE
     CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
2. Oats
                   Purchase Order No.
                                                        .4. Quote No.
3. Company Name  ($60?  AU.f*J  j-Mll\l CT6/O
  Address      DTfl.  flCj/0-.
           .  DCL Project Manager
           _5. Sample Collection
              Sampling Site
Person to Contact _
Telephone (j*}) _
FaxTelupliuiie(3«3
E-mail Address  £,
                 -2.it -
  Billing Address (if different)   (1.&&.Q—  TR
Industrial Process - tVig.
DateofCoilecllon  .
Time Collected 	
Date of Shipment
Chain of Custody No.  	f_
                               -24fa
6. REQUEST FOR ANALYSES
   Laboratocy Use Only
                     Client Sample Number
 Sample Volume  ANALYSES REQUESTED - Use malhod number if known  Units"
                                                  - 1J
                                                    ! S?
                             - II >
                             -Zf
     . Z 1.
                             -7/5
*  Specify: Solid soibent tube, eg. Charcoal; Filter type; Implnger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
"* 1. mg/samplB  2. mg/m* 3.ppm  4.%  S.	(other)  Please indicate one or more units In (he column entitled Units"
Comments

Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional) _
<=r-i__ /-) / y fe#
Relinquished bv W j 7Z~ *J (_-4rH«
-" T '• V/^
Received bv ^Ta-i-' •*< / *-<*-*£-&-
Relinquished bv jfa*- — ft /^c^«-"—
Received bv


~3— Oatemme ^5fl_(Cft . fZjfi
Date/Time f/^^
Date/Time */W*3 ff)
O
Date/Time
, „ , 	
    960 West LaVoy Drive / Salt Lake City, UT B4123           BOO-356-S135 or 801-266.7700 / FAX: 801-268-9992
                                  DATACHEM LABORATORIES, INC.
-------
                   DATA
                   CHEM
                   LABORATORIES, INC.
                                            ANALYTICAL REQUEST FORM
                                            1. D REGULAR Status    	0*lf'lflJ'V
                                              ED RUSH Status Requested - ADDITIONAL CHARGE •
                                                 RESULTS REQUIRED BY 	
                                                                          DATE
                                                 CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
2. Dale
3. Company Name
  Address
                   Purchase Order No.
                      AU£jd
                                                          4. Quote No.
                                                          DCL Project Manager
                                                       .5. Sample Collection
                                                          Sampling Site
                                                                                 Mgx.aflje.fi/ Pi
Person to Contact _
Telephone (3*5) _
Fax Telephone (y$
E-mail Address
                                                            Industrial Process
                                                            Date of Collection
                                                            Time Collected _
  Billing Address (if different)
                                                            Date of Shipment    *T/'2/0 3
                                                          Chain of Custody No.-v
6. REQUEST FOR ANALYSES
   Laboratory Us« Only
         n
         a
          it
          w
         JLJ,^
                   CnenlSumpteNumbat
                    ZA-Atfv2r,NYQlUlt-
                                H\
                                               Sample Volume
                                              2Z.--5
                                            vz.s'Q.
                                                          ANALYSES REQUESTED - U t* method number if known
                                                                                             Units"
*  Specify: Solid fefbent tube, e.g. Charcoal; Filter type; Implrvger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
"1. mg/sample  2. mg/m3 S.ppm 4.%  S.	(other) Please indicate one or more units in the column entitled Units"
Comments    _._J?-
M ' /A*
Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)
Relinquished by ^J/3'y -^ JT\\?^~~ """
Received bv " ' /f *-~—^ ^M^—
Relinquished by /€t— ^< /1?CC——
Received by

Date/Time Jz/Z'fGl) /3/&
Uats/Time *'7«"
Date/Tima 57>"
DalB/Tliue

    960 West UVoy Drive / Salt Lake City, UT 84123..          800-356-9135 or 801-266-7700 / FAX: 801-268-9992
                                   DATACHEM LABORATORIES. INC.  '
-------
        Appendix C




Data Chem Laboratory Reports
-------
Sample Shipping Information
Samples were placed in an oversized, sturdy box with packing material to fill voids
and protect the samples during shipping.  The sampling personnel men signed the
chain-of-custody forms, and placed them in the box with lite samples. Samples were
shipped via Federal Express to the laboratory.
-------
DATA3

     L A B O R A T OR I ES
    A Soranson Company
                    ANALYTICAL REPORT
Form ARF-AL
Page   1   of   3
Part   1   of   1
06230312005398RX
                                              Laboratory Group Name 031-1506-01
                                              Account No.  07003	
 Booz Allen Hamilton
 Attention: Steve Coffee
 5299 DTC Bled.
 Suite 840
 Greenwood Village, CO 80111
Sampling Collection and Shipment
           Sampling Site AlfrRC1. Aahland TripftA
                                              E-mail
                                                     FAX (3O3) 69A-7367
                                               Telephone  30^ 7?.1-7S."iQ
                                   Date of Collection

Date Samples Received at Laboratory .lung  16, 2003
Analysis
           Method of Analysis flMAM  6009
           Date(s)  of Analysis.Tung 19, 2003

Analytical Results
Field
Sample
Nunba r
3705BA6/9-01
3Y05BA6/9-03
LAB BLASK
LAB BLAHS
LAB BLAHK
PB 6/10
PB 6/10
PB 6/11
PB 6/11
PB 6/12
PB 6/12
FB 8/13
PB 6/13
Laboratory
number
03119545
03119548
03119547
03X19S4B
03119349
03X19550
03119551
03119352
03119553
03119554
03119555
03119556
03119557
Sample
Type
TUBS
TUBB
TUBE
TUBS
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
Mercury
ug/Sample
0.77
0.46
0.040
0.047
0.040
0.039
0.041
0.041
0.038
0.040
0.038
0.036
0.043
Mercury
ng/a'
0.013
0.0086
»*
* *
A *
»*
" *
* *
**
ft*
A »
**
ft*
Air Voluae
L
58.3
54.1
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
































,



















































ND Parameter not detected above LOD. ( ) Parameter between tOD and LOQ.
MR paraneter not requested.
HA Parameter not applicable. . ~ .
                                      Analyst :/0Mj» ^ Roefaka
                                            f P\  n   P
                                      	f^^->  He vC
                                      Reviewer:f Nail  A. Edwards
                960 West LeVoy Drive
                Phone (801) 266-7700
                FAX (801) 268-9992
                            Salt  Lake City, Utah 84123-2547
                                 Web Page: vww.datacheni.com
                                 E-mail: lab@datachem.com
-------
DATA^P
ANALYTICAL REPORT
Form ARF-BL

Page   2   of   3
Part   1   of   1
06230312005398RX.
     LABORATORI E S
    A Sorenson Company
Analytical Results
                         JUN 2 4 2003
                                             Date _
                                             Laboratory Group Name 031-1506-01
Plaid
Sample
Number
3705HA6/1005
3705RA6/1007
370SSAS/1009
3705RAfi/1011
370SRAG/1013
370SHA6/101S
3705RA6/1017
3705HA6/1019
FB FACILITY

Dumber
03119558
03I19S59
03I19S60
03119561
03I195S3
03119563
03119564
03119565
03X19885

Type
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
Reporting Limit











'








'







































Hercury
tig/Sample
0.23
0.083
0.14
0.29
0.31
0.042
0.077
0.050
0.031
0.01




















Mercury
i»g/n'
0.0093
0.0062
0.011
0.010
0.011
0.013
0.025
0.050
* *





















a
•
3
H
o
>
h
•w4
-------
DATAip
ANALYTICAL REPORT
Form ARF-C
Page   3   of   3
06230312005398RX
     LA BORA TORI E
    A Socenson company
General Set Comments
                                             Date _4UN_2_4_28Q3_
                                             Laboratory Group Name Q3T-1506-Q1
Method Reference: NIOSH Manual of Analytical Methods(NMAM), 4th ed., 08/15/94.
Results are not blank-corrected.
Results obtained for media blanks prepared from SKC Carulite tubes are typically
found to have concentrations approximately 0.035-0.045 ug/Sample above the
reporting limit.
Results cannot be reported in mg/m3  or ppm for samples with no air volume.


General Lab Comments

The results provided in this report  relate only to the items tested.
This page is the concluding page of  the  report.
                960 West LeVoy Drive
                Phone (801) 266-7700
                FAX (801) 268-9992
        Salt Lake City, Utah 84123-2547
             Web Page: www.datacheDi.com
             E-mail: lab@datachem.com
-------
                     DATA
                    CHEM
                    LABORATORIES, INC.
                                                 ANALYTICAL REQUEST  FORM
                                                      I REGULAR Status
                                                    C~l RUSH Status Requested • ADDITIONAL CHARGE
                                                       RESULTS REQUIRED BY	'
                                                                                   DATE
                                                       CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
                    Purchase Order No.
2. Date 	
3. Company Name Booz Allen Hamilton
  Address    5299 PTC Blvd., Suite 640
             Greenwood Village, CO 60111
  Person to Contact Steve Coffee
  Telephone (303) 221-7559
  Fax Telephone (303 > 694-7367
  E-mail Address ootfee_stephen@bah.com
  '. Billing Address (if different from above) refer to contract
                                                              4. Quote No.
  DCL Project Manager Rand Potter
5. Sample Collection
  Sampling Site AERC Ashland Trip #4
  Industrial Process DTC Device
  Date of Collection
  Time Collected
                                                                                  *\ <"  1/I6 -I <,({ ( *• (, (it
                                                                 Date of Shipment
                                                                 Chain of Custody No. 1
6. REQUEST FOR ANALYSES
    Laboratory Use Ortly
                      Client Sample Number
                                          Matrix*
                                                   Sample Volume
                                                               ANALYSES REQUESTED • Use method number H known
                                                                                                     Unte"
                                                                  N
           5M6
                                 .63-
                                                   n*.
                    fre.U
                                  */«
          5 S3
                                                                           j-
   Specify. Solid sorbent tube. e.g. Charcoal; Filter type; Impinger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water, Other
**1.mg/sample  2.mg/m3  3. ppm  4.%   S..
Comments
                                        . (other) Please indicate one or more units in the column entitled Units**

Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional) ^ ,
Relinquished by ^fes^L >J. ( ffrr —
RKBivadbv /?J ' -fttffli .
Relinquished by /g»— rf-f.^f •
Received by
Rellnqulslieci by
Received by
Date/Time ( /&. £-S
Date/Time ^ jv^f>
Date/Time £//C/Oj
Date/Time
Date/Time
Date/Time

     960 West LeVoy Drive / Salt Lake City, UT 84123           800-356-9135 or 801-266-7700 / FAX: 601-268-9992
                                     DATACHEM LABORATORIES, INC.
-------
                     DATA
                     CHEM
                     LABORATORIES, INC.
                                                 ANALYTICAL REQUEST FORM
                                  REGULAR Status
                                  RUSH Status Requested - ADDITIONAL ctlAP.ee
                                  RESULTS REQUIRED BY	
                                                                                  DATE
                                                       CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
2. Date
Purchase Order No.
3. Company Name Bore Allen Hamilton
  Address     5299 PTC Blvd.. Suite 640
             Greenwood Village. CO 60111
  Person to Contact  Steve Coffee
  Telephone (303) 221-7559
  Fax Telephone (303) 694-7387
  E-mail Address coKee_stepheriefaah.conn
  Billing Address (if different from above) refer to contract
                                                             4. Quote No.
                                            DCL Project Manager Rand Potter
                                        _5. Sample Collection
Sampling Site AERC Ashland Trip «4	
Industrial Process PTC Device     ft. T I.
Date of Collection
Time Collected
                                                                \   U. t>
                                            Date of Shipment
                                            Chain of Custody No.
6. REQUEST FOR ANALYSES
    Laboratory Uee Only
                      Client Sample Number
                                          Matrix*
                                                  Sample Volume
                                                              ANALYSES REQUESTED • Use method number H known
                                                                                                   Units"
                                                                  N/
                                                  1 5.1*1.
                                  -oi
                              13.4*-
         'SCO
                              (3.
                                -n.
                                -,.3-
                              Z1J
                                                    . 1.  i.
                                -If
                               3.1
                                                   l.o  U
 '  Specify: Solid sorbent tube, e.g. Charcoal; Filter.type; Impinger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
 " 1. mg/aomple  2. mo/m3  3. ppm  4.%  5. .    (othert  ; please indicate one or rnore units In the column entitled Units
 Comments        '-ftcll
/ .
Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)
Relinquished by ySj^ I/- UJHyA'
Received by /£ JL_ **^V*^^-
Relinaulshed by f& 'm _ ^f /^f^~ '-—
Received by
Relinquished by
Received by '
Date/Time fv//3/jO'5 tO-aJ
Date/Time &/'4L
Date/tlma {.^{t/
Date/Time
Date/Time
Date/Time

     960 West LeVoy Drive / Salt Lake City, UT 84123           800-356-9135 or 801 -266-7700 / PAX: 801-268-9992
                                     DATACHEM LABORATORIES, INC.
-------
    CHEM
     LABORftTORI E S
    A So ran son company
                               ANALYTICAL REPORT
                                               Date
                                                   •   Futa ARF-AL   .

                                                      Page    1    of  3

                                                      Part    1    of  1

                                               JUN 2 J,°gM9312244758B*
                                               Laboratory Group Name Q3T-1506-Q2

                                               Account  No.  07003	
Booz Allen Hamilton
Attention: Steve Coffee
5299 DTC Bled.
Suite 840
Greenwood Village', CO 80111
Sampling Collection and Shipment

           Sampling Site ARRf! Ashland
                                    E— nail  Pf^
                                                       FAX (303) 694-7367
                                                 Telephone r*m\ 991-7SSO.
                                                              steplipnflhflh. r.nm
                                  _ Date of Collection June  10,  2003

Date Samples Received at Laboratory Jnna 16,  3QO3	:	;	
Analysis
           Method of Analysis MMAM fiOOQ
           Date(s) of Analysis Jimp 19, 2003

Analytical Results
Field
Sanpla
Nunbar
3705RAS/1021
3705HA6/1023
3705RA6/1025
3705RA6/1027
3705RAS/1023
3705RA6/1031
3705RA.6/1033
3705KA6/103S
3705RAS/1037
3705RA6/1039
37U5JKA6/1041
37D5HAS/104J
370SRAS/1045
Laboratory
number
03119566
03I1PS67
03119568
03I195S9
03X10570
03119571
03119572
03Z19573
03119574
03119575
03X19970
03119577
03119578
sample
Typa
TUBE
IOBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBS
TUBE
a
u e
9 a
I!
0.047
0.19
0.19
0.37
O.S6
0.95
0.15
0.1C
0.17
o.ie
0.17
0.14
0.056
Mercury
ng/n'
0.047
n.ms
0.015
0.0066
0.011
0.017
0.012
0.0X3
0.015
0.014
0.013
0.013
O.D31
i
»4
O
•rl
•< J
1.0
12.3
12.3
55.8
54.7
56.2
12.5
12 S
11.4
11.5
11. C .
10. A'
3.1














•













I













J













_ • ,•

'

























  t  S»» comment on last page.
 HO Paranator not datectid abov* LOD.
 NR Pscameter not requistad.
 NA Pdramater not applicable.
   s«« contno
(  ) Paranetac
                                     nt on laet paga.
                                      batvaen LOD and LOQ.
                                       Beviewar: /Hail A. Edwards
                 960 West LeVoy Drive / Salt Lake City, Utah 84123-2547
                 Phone  (801)  266-7700        Veb Paget wvw.datachQffl.com
                 FAX (801)  268-9992          E-mail: lab@datachen.com
-------
DATA^P
ANALYTICAL REPORT
Form ARF-BL

Page    2   of  3

Part    1   of  1
0624031224475BRX
    IABORATORI
    A Socanson Company
Analytical Results
                                          Date     JUN 2 k 2003	
                                          Laboratory Group Name 031^1506^02
ri.lt)
Sample
Number
370SHA6/1047
3705BAS/104S
3705RA6/1051
370SRAS/1053
T-Ahoratory
Hunber -
03119579
0)119580
01I195B1
03119582
Sample
Type
TUBE
TUBE
TUBS
TUBE
Reporting Linit















•














'












































Mercury
ug/Sarapli
0.23
1.3
0.067
D.D4Z
0.01

























Mercury
»g/»'
o.oia
o.io ,
0.067
0.042


























»
r4
o
>
M
t4
-------
BATA^P
     LABORATDRIE5
    A Sorenson Company,
General Set Comments
             ANALYTICAL REPORT
                                             Date
Form ARF-C
Page   3   of   :
06Z40312244758RX
                                                          JUN 2 4 2003
                                             Laboratory Group Name UlL-l506-02
Method Reference: NIOSH Manual of Analytical Methods(NHAM),  4th ed., 08/15/94.
Results are not  blank-corrected.
Results obtained for media blanks prepared  from SKC Carulite tubes  are  typically
found to have concentrations approximately  0.035-0.045 ug/Sample above  the
reporting limit.

The result foi sample 03119580 exceeded the calibration range of the instrument.
Due to an overs!te,  the sample was not diluted and reanalyzed.  The  reported
result for this  sample is therefore estimated.
 Sample Comments

 Laboratory
 Number

 03119580
Comment

See set comments.
General Lab Comments

The results provided in  this raport relate only  to  the items tested.
Th'is* page is the concluding page of the report.
                 960 flest LeVoy Drive
                 Phone (801) 266-7700
                 FAX (801) 268-9992
                     Salt Lake City, Utah 84123-2547
                          Veb Page: vww.datachem.com
                          E-maili lab@datachem.com
-------
                                          ANALYTICAL REQUEST FORM
• ' • MJjT\ 1 JT\
CHEM
•^*~-**~' LABORATORIES, INC.
2. Date Purchase Order No.
1. ED REGULAR Status Oj^L " \^Q6~Ol
CH RUSH Statue Requested - ADDITIONAL CHARGE
RESULTS REQUIRED BY
DATE
CONTACT OATACHEM LABS PRIOR TO SENDING SAMPLES
4. Quote No.
3. Company Name Booz Allen Hamilton
Address 5299 DTC Blvd., Suite 840
firwwiwood Villaos. CO 801 11
Person to Contact Steve Coffee
Telephone ( 303 ) 221-7559
Fax Telephone (303 ) 694-7367
E-mail Address coffee.stephen® bah.com
BlUliiy AUJiosi (If dlHerent from obovo) refer to contract

6. REQUEST FOR ANALYSES
Laboratory Use Only
_03D^S'£6
5"C~? -
IffctJ
. 5C°(
5->O
571
575.
5"73-
r?*/
fTS
&C.
Client Sample Number
S7fl5-R-A-V*p-2.l'
-23.
-Z5,
" -a"7*
IV ~2q-
" -3 |»
'v -3j'
4> -3.S .
11 -3T<
" -3?.
,, -Ml .
Matrix'
rfyi^/--









\"-
Sample Volume
\,0 L
VLA U
JZ..3L.
j^ 1^ ^> 1
3 ^ * ^P ^^
f/.l i-
5"fc,7. (_
12..SL-
iZ.5"U
j/.^ £-
f/. Sl-
;/. «»'L.
DCL Project Manogar Rand Pottar
6. Sample Collection
Sampling Site AERC Ashland Trip *4
Industrial Process DTC Device £.T*X
Date of Collection <*Jjt)/o3
Time Collected
Dale of Shipment fe U 3 / » 3
Chain of Custody No 3 •

t
ANALYSES REQUESTED - Use method number II known
NMOSf/t feOOl





-



V











Units"
2.









Jx
  Specify: Solid sorbent tube, e.g. Charcoal; Filter type; Implnger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
" 1. mg/sample 2 mg/m3 3. ppm 4, %  5.	. (other)  Please Indicate one or more units In Ins column entitled Units"
Comments

Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)
Relinquished by ' .J^fva^/i I rvy~
Received by jj& ' ^ ^. ^,^6^
7 V-
n^llr,T.!n.hr,rlhy ^ ;. j3 T£~ ,
Received by
Rsllnnulshad by
Received by
Date/Time LJW
-------
                                           ANALYTICAL REQUEST FORM
= = LJS\IS\
•2JJ"™""SS ^ggmfj^ggmmjg
aL 	 S CM cm
	 • . "^ LABORATORIES, INC
2. Dale Purchase Order No.'
1. H REGULAR Status ^jL~" }1>0» "OA
ED RUSH Status Requested - ADDITIONAL CHARGE
RESULTS REQUIRED BY
DATE
CONTACT DATACHEM UBS PRIOR TO SENDINQ SAMPLES
4. Quote No
3. Company Name Booz Allen Hamilton DCL Project Manager Rand Potter
Address 5299 DTC Blvd., Suite 840
Greenwood Village, CO 801 11
5. Sample Collection
Sampling Site AERC Ashland Trip #4
Person to Contact Steve Coffee Industrial Process DTC Device RT I
^Telephone ( 303 ) 221-7559 Date of Collection £>/ )o ( o j
Fax Telephone (303 ) 694-73S7 Time Collected
E-mail Address caHae_stephen 9 bah.com Date oi Shipment .*"/' 3/^.7
Billing Address (If dltferent from above) refer to coniract

6. REQUEST FOR ANALYSES
Laboratory Use Only
05£ \°( <57~7
* * Cfc
ST^
5So
C8f
58'J»
^Tt--




Client Sample Number
37oy-j?-*-fc/»-*Y3«
^ -4J-
vv ,47..
»' - 4 1 •
^-5"\-
v ~5'3«





Matrix*
HvA/»^




v/





Sample Volume
JO. 8^
3. I «~
12. 7-i-
)3.0 L.
t O f
/.O L.



*

Chain of Custody No. f

ANALYSES REQUESTED • USB method number It known
N)&5 f"/ (» O° °J
1
'
- /

^
*- • ,




Unite"
X




V





  Specify: Solid sorbent tube, e.g. Charcoal; Filter type; Impinger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
" 1. mg/sample  2, mg/m3  3.. ppm  4. %  5.	(other)  Please Indicate one or more units In the column entitled Units"
Cofnrnente

Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)
Relinquished by ^5(^Q^ £sr (~jVy~^ Datemme ( f//Y&3 • fd'*- *'^
Received by >^«fa . > ^ X«fCC^__
Relinquished by ^ « 	 f /^^Ct^ ^
Received by
Relinquished by
Received by
. Date/Time t ft*
Date/Time $/f£/oy •
Date/Time
Date/Time
Date/Time

    960 West LeVoy Drive / Bolt Lake City, UT 84123          800-356-9135 or 801-266-7700 / FAX: 801-268-9992
                                DATACHEM LABORATORIES, INC.
-------
DATAif
                              ANALYTICAL REPORT
                                                     Form ARF-AL
                                                     Page   1  .of   3
                                                     Part   1   of   1
                                                     06230316244303RX
     LABORATORI E S
    A Sorenson Company
 Booz  Allen Hamilton
 Attention: Steve Coffee
 5299  DTC Bled,
 Suite 840
 Greenwood Village, CO 80111
Sampling Collection and  Shipment
           Sampling Site Ai3R.CA.sMand.
                                            natp      JUN  2 it 2DD3	

                                            Laboratory Group Name 031-1506-06
                                            Account No.  07003	
                                                      FAX
                                                                         69A-7367
                                             E— nail
                                                          Telephone (Vtt) 221-7559
                                                             atephenflhah.pom _
                                 _ Date of Collection

Date Samples Received  at Laboratory June 16,  2003	
                                                                     11, 2003
Analysis
           Method of Analysis NMAM 6009
           Date(s)  Of Analysis June 20, 2003

Analytical Results
.' field
Sample
tfumber
3705DA61155
370SDA61157
3705DA61159
3705DA61161
3703DA61163
3705DA61165
3705DA61167
3705DAG1149
3705DA61171
37050A61173
3VUbDAG1175
3705AA612117
3705AA612119
Laboratory
number
03119603
03119004
03119605
03119606
03119607
03I1960B
03119609
03119610
03119611.
03119612
03119613
03119615
03119616
Sample
Type
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
e
X H
a 4
II M
I?
1.2
0.68
0.90 •
1.5
0.98
1.0
0.20
0.10
0.19
0.62
0.99
0.77
0.77
3»
U B
0.064
0.058
0.076
0.074
0.047
0.20
0.065
0.10
0.19
o.oai
0.11
0.029
0.049
3
1-1
o
rtJ
19.20
11.7
11.8
20.1
20.8
5.2
3.1
1.0
1.0 -
- 7.7
3.3
26.5
15.8

















.































-


































t  see connunt ou last
HD Parameter not detected above
Hit Paraaeter not requested.
HA Parameter not applicable.
                             LOD.
                                           comment on laat page.
                                    ( )  Parameter between LOD and LOQ.
                                                eil A.  Edwards
                960 West LeVoy Drive / Salt  Lake City, Utah 84123-2547
                Phone (801) 266-7700        Web Page: wvw.datachera.com
                FAX (801) 268-9992          E-mail: lab@datachem.com
-------
                               ANALYTICAL REPORT
                                              Date
                         Form ARF-BL
                         Page   2   of   3
                         Part   1   of   1
                         0623Q316244303RX
                  JUN 2 4 2003
                                              Laboratory Group Name H1T-1506-04
Analytical Results
Field
Sample
number .
3705AA612121
3705AA612123
3705AA612125
3705AA612127
3705AA612129
J705AAS12131
3705AA612133
3705AA61213S
Laboratory
dumber
03119617
03119618
03X19619
03119620
03119621
03119622
03119623
03119624
Sample
Type
TUBE
TUBE
TUBE
TUBE
TUBE
TUBS
TUBE
TUBE
Reporting Limit































































Mercury
eg/Sample
0.89
1.1
0.02
0.17
0.41
0.19
0.22
0.40
0.01





















Rercury
»g/»'
0.053
0.041
.00075
0.055
0.15
0.19
0.22
0.030





















1-4
0
>
u
•rt
•«! J
16.7
26.4
26.5
3.1
3.1
1.0
1.0
10.3













































































































































.




t See comment on last page. ** See comment on last page.
HD Parameter not detected above LOD. ( ) Parameter between LOD and LOQ.
HR Parameter not requested.
HA Parameter not applicable.
































'


























t




                 960 West  LeVoy Drive
                 Phone  (801) 266-7700
                 FAX (801)  268-9992
Salt Lake City,  Utah 84123-2547
     Web Page: vww.datacheD.com
     E-mail:  lab@datachem.com •
-------
DATA^P
     LABORATORI E 5
    A Soranson Conpany
General Set Comments
ANALYTICAL REPORT
                                             Data
Form ARF-C
Page   3   of   3
06230316244303RX
                     JUN 2 
-------
                    DATA,
                    CHEM
                    LABORATORIES, INC.
                                                ANALYTICAL REQUEST  FORM
   REGULAR Status
O RUSK Status Requested - ADDITIONAL CHARGE
    RESULTS REQUIRED BY	
                                                                                DATE
                                                      CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
                    Purchase Order No.
2. Date
3. Company Name Booz Allen Han illiun
  Address     5299 DTC Blvd., Suite 840
             Greenwood Village, CO 00111
   Person to Contact Steve Coffee
  Telephone (303) 221-7559
   Fax Telephone (303 > 694-7367
   E-mail Address coffee.,stephen (8 bah.com
   Billing Address (if different from above) refer to contract
          4. Quote No. ^_______i___
             DCL Project Manager Rand Potter
         _5. Sample Collection
             Sampling Site AERC Ashland Trip #4
             Industrial Process PTC Device   DflfM K.
             Date tit Collection  i>(h 11 3
             Time Collected 	
             Date of Shipment if / I
             Chain of Custody No.  *\
6. REQUEST FOR ANALYSES
Laboratory Use Only
trtLKtoi
COM
t>5
CO*
ten
Coz
£<*
C\o
cu
til
Cn
Client Sample Number
??os- &-*-£/«- S5»
v .5*-
* - 51 .
>• - tl >
*v -13-
^ - U5 •
\v - 









/
*  Specify: Solid sorbent tube, e.g. Charcoal; Filter type; tmpinger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
" 1. mg/sample  2. mg/m*  3. ppm  4. %   S.	(other)  Please Indicate one or more units in the column entitled Units"
Comments

Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)
«cv__ __ /n /^c^i
Ralinauished bv ^tf\ff\-jf ** ' -rV\f
Received by ^^~ i/-f*f~ft- ' -
D^ltn^nichori Ky (|^/r| ^f /9^ ff ^ ,-.
Received by
Relinquished by
Received by
DatefTlme (jf/'t)l&2 /6 "• O«J
Daten"lme f/iff-
Date/Time £//£
Date/Time
Date/Time
Date/Time

     960 West LeVoy Drive / Salt Lake City, UT 64123           600-356-9135 or 801-266-7700 / FAX: 801-268-9992
                                    DATACHEM LABORATORIES, INC.
-------
                    DATA
                    CHEM
                    LABORATORIES, INC.
                                                ANALYTICAL REQUEST FORM
             REGULAR Status
                                                                          03E
                                                    I RUSH Status Requested - ADDITIONAL CHARGE
                                                     RESULTS REQUIRED BY	L	
                                                                                DATE
                                                     CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
2- Date
                   Purchase Order No.
3. Company Name Bom Allen Hamilton
            5299 PTC Blvd.. Suite B40
             Greenwood Village, CO B0111
  Person to Contact Steve Coffea
  Telephone (303} 221-7559
  Fax Telephone (303 > 694-7367
  E-mail Address cotfee_8t9phen@bah.com
  Billing Address (If different fmm above) refer to contract
                                                            4. Quote No.
                                                              DCL PrnjBrt Manager Rand Potter
                                                            S. Sample Collection
                                                              Sampling Site AERC Ashland Trip #4
                                                              Industrial Process PTC Device
                                                              'Date of Collection   Le ff2. /0
                                                              Time Collected
                                                              Date of Shipment
                                                              Chain of Custody No.
S. REQUEST FOR ANALYSES
    Laboratory Use Only
                     Client Sample Number .
Matrix*
         Sample Volume
                                                             ANALYSES REQUESTED - Use method number II known
 63EHfelH-
                               •leJL
                              (,Q0
         CIS
         uc,
                                                   <-.
         en
                             12.1
                               ZV-
         en
         £310
                                                 •?,.
                                                   .a  J?
         £33
   Specify: Solid sorbent tube, e.g. Charcoal; Filter type; Impinger solution; Bulk sample; Blood; Urlf
                                                                       Tissue; Soil; Water, Other
"1.mg/sampl9  2. mg/m1 3. ppm  4.%  5.
Comments
                                        (other)  Please indicate one or more units In the column entitled Units"
•
Possible Contamination and/or Chemical Hazards •
7. Chain of Custody (Optional)
Relinquished bv ^fVyi-] V^ /jST/l^'
Received by ^^^ — f^*J*-
Retlnoutsfied bv ^ l2f rf <*!**- 	 •
Received by
Relinquished by
Received by
Date/Time (ffi^/4~^ /OtS^
Date/Time <£ ffV-/
Date/Time / //& fa 3
Date/Time
Date/Time
Date/Time

    960 West LeVoy Drive / Salt Lake City, UT 64123           800-356-9135 or 801-266-7700 / FAX: 801-268-9992
                                    DATACHEM LABORATORIES. INC.
-------
DATAip
                    ANALYTICAL REPORT
                                              Date
     LABORATORIES
    A Sorenson Company
 Booz Allen Hamilton
 Attention: Steve Coffee
 5299 DTC Bled.
 Suite 840
 Greenwood Village, CO 80111
Sampling Collection and Shipment
           Sampling Site AERC Ashland TripftA
      Form ARF-AL
      Page    1  of.   3
      Part    1  of   1
      06240312455882RX

JUN 2 4 2003
                                              Laboratory Group Nam«vOVr-150fi-Q3
                                              Account No. -07003.-	
                                                      FAX
                                                Telephone
                                              E—mai1  coffee s tpphgnQhah.com
                                    Date  of Collection Jung 11, 20Q3

Date Samples Received at Labora tory June 16r  2003	
Analysis
           Method of Analysis tjMAH 6009
           Date(s) Of Analysts June 19,

Analytical Results
Field
Sample
Number
3705DA61199
370SDA6111Q1
3705DA611103
3705DA611105
3705DA611107
3705DA611109
3705DA611111
3705DA611113
3705DA611115
3705DA61177
3705DA61179
3705DA61181
J705DA61183
Laboratory
number
03119583
03119584
03119585
03119586
03119587
03119588
03119589
03119590
03119591
03119592
03119593
03119594
03X19595
sample
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
e
§9
0.23
0.23
0.23
0.094
0.11
0.89
0.85
l.fi
1.3
0.065
£.0
0.059
0.24
Mercury
rog/m>
0.033
0.034
0.074
0.094
0.11
0.12
0.12
0.089
0.073
9.00052
0.049
9.00052
0.10
Ait Volume
L
6.9
£.8
3.1
1.0
1.0
7.2
7.2
18.0
18.0
125.9
123.5
113.1
2.4



























































-
























  t  See coioDiBnt on last pags.
  ND Paranetac not detected above LOD.
  RR Parametar not requested.
  NA Parameter not applicable.
                             Sea conment on last
                          ( ) Parameter between LOD and LOQ.
                                       Bovievert Hail A.  Edwards
                 960 West LeVoy Drive
                 Phone  (801) 266-7700
                 FAX (801) 268-9992
                            Salt Lake City,  Utah 84123-2547
                                 Web Page: vwv.datachem.com
                                 E-mail:  lab@datachem.com
-------
                               ANALYTICAL REPORT
                         Form ARF-BL
                         Page    2   of   3
                         Part    1   of   1
                         06240312455882RX
                                                        JUN 2 4 2003
                                               Date 	•_	
                                               Laboratory Group Name 03I-15f)fi-M
Analytical Results
Field
Sample
Hunbec
3705DA61185
3705DA61187
37D5DA611B9
3705DA61191
37OSUAS1193
3705DA61195
3705DAS1197
Labotarory
Number -,
03H9596
03X19597
03119598
03119599
0)119800
03119601
03119602
Sample
Type
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
TUBE
Reporting Limit


































































Mercury
ug/saaple
0.044
0.20
0.23
0.23
0.23
0.19
0.23
0.01






















Mercury
ng/m>
0.018
0.083
0.092
0.034
0.034
0.026
0.034























i
«H
0
>
It
•H
•4 Hi
2.4
2.4
2.5
6.8
6.8
7.2
6'. 7



















































































































































t See comment on last page. *' See comnant on last page.
HD Parnm«tar not detected above LOD. ( ) Varavetor between LOD and I.OQ,
HE paranatec not requested.
NA Parameter not applicable.
































































                 960 West  LeVoy Drive /
                 Phone  (801)  266-7700
                 FAX (801)  268-9992
Salt Lake City,  Utah 84123-2547
     Veb Page: wwv.datachem.com
     E-mail:  lab@datachem.com
-------
DATA^P
     LABORATORI E :
    A Sorenson Company
 General Set Comments
ANALYTICAL REPORT
                                             Date
         Form ARF-C
         Page   .3   of   '
         06240312455882RX

JUN2U003
                                             Laboratory Group Name 031-1506-03
 Method Reference: NIOSB Manual of Analytical Methods(NMAM), 4th ed.,  08/15/94.
 Results are not blank-corrected.
.Results obtained for media blanks prepared from SKC Carulite tubes are typically
 found to have concentrations approximately 0.035-0.045 ug/Sample above the
 reporting limit.                                      •   «
 Samples 03119590, 91 and 93 required a 10X dilution.


 General Lab Comments

 The results provided in this report relate only to the items tested.
 This page is the concluding page of the report.
                960 West LeVoy Drive / Salt Lake City, Utah 84123-2547
                Phone (801)  266-7700        Web Page: www.datachem.com
                FAX (801) 268-9992          E-mail: lab@datachem.com
-------
                     DATA
                     CHEM
                     LABORATORIES, INC
                                                  ANALYTICAL REQUEST FORM
   REGULAR Status
ED RUSH Status Requested - ADDITIONAL CHARGE
   RESULTS REQUIRED BY       .	'	.
                                                                                 ;. DATE
                                                       CONTACT DATACHEM UBS PRIOR TO SENDING SAMPLES
2. Date U/ <3 H>1      Purchase Order No.
3. Company Name Booz Allen Hamilton
  Address    5299 PTC Blvd., Suite 640
              Greenwood Village. CO 80111
   Person to Contact Steve Coffee
  Telephone (303) 221-7569
   Fax Telephone (303) 694-7367
   E-mail'Address coffee_stephen 9 bah.com
   Billing Address (if different from above) refer to contract
          4. Quote No.
             DCL Project Manager Rand Potter
          5. Sample Collection -
             Sampling Site AERC Ashland Trip *4

             Industrial Process PTC Device     D&*4f'<
             Date of Collection  & //i
             Time Collected
             Date of Shipment
             Chain of Custody No.
6. REQUEST FOR ANALYSES
    Laboratory Use Only      Client Simple Number      Matrix*
                                                   Sample Volums
                                                               ANALYSES REQUESTED - Use method number H known
                                                                                                    Units"
                           ^   -  [03

                                                     1.0 L.
                               -107
          528
                                                     -7.2.C
                                                                                                     V
*  Specify: Solid sorbent tube, e.g. Charcoal; Filter type; Irnpinger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water, Other
" 1. mg/samplB  2. mg/rn* 3. ppm  4.%  5.	 (other)  Please indicate one or more units in the column entitled Units**
Comments
.
Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional) •
Relinquished by O^JU** /? . f ^Q-^
Received by ''/?" -f /°^
Relinquished by y£^^__/' /**f*~~- , — -
Received by •
Relinquished by
Received by '
Date/Time •• (jt ft °3/6 "7 t a T -•£>
Date/Time ^A**"
Date/Time fof/£,&f •
Date/Time
Date/Time
Date/Time

     960 West LeVoy Drive /Salt Lake CHy, UT 84123            800-356-9135 or 801-266-7700 / FAX: 801-268-9992
                                     DATACHEM LABORATORES, INC.
-------
                     DATA
                    CHEM
                    LABORATORIES, INC
                                                  ANALYTICAL REQUEST FORM
                           1.
                                 REGULAR Status
                                 RUSH status Requested - ADDITIONAL CHARGE
                                 RESULTS REQUIRED BY	
                                                                                   DATE
                                                       CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
8. Date  C. ( / 3/1 ?    Purchase Order No.

3. Company Name Booz Allen Hamilton

  Address    5299 PTC Blvd., Suite 840  ,
                                        4, Quote No.
                                          DCL Prelect Manager Rand Potter

                                        5. Sample Collection
             Greenwood Village, co 60111
  Person to Contact Steve Coffee
  Telephone (303 ) 221-7S59
   Fax Telephone (303) 694-7367
                                          Sampling Site AERC Ashland Trip #4	

                                          Industrial Process PTC Device    p/s^tv? K-

                                          Date of Collection  £f \llOJ  	

                                          Time Collected
   E-mail Address cotfee_stephen Q bah.com.
                                          Date of Shipment \t>
  Billing Address (if different from above) refer to contract
                                          Chain of Custody No.
6. REQUEST FOR ANALYSES
    Laboratory Use Onty
Clianl Sample Number
                                          Matrix*
                                                   Sample Volume
                                                               ANALYSES REQUESTED - Use method number if known
                                                                                                     Units"
         ^5jl
                                                  \ 1 3. ) «-
          srv
          Cot
    H   -«
   Specify: Solid sorbent tube, e.g. Charcoal; Filter type; Impinger solution; Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
** 1. mg/sample  2. mgW  3. ppm  •
* Yjt3 .£. > nv
Received by *^7V — r^ rt-*-i .
Relinquished by _S* ^ S***~^
Received by
Relinquished by
Received by
Date/Time C^//"?/fl? /<5- c)j
Date/Time '£/*?>
Date/Time £/?£/* J
Date/Time
Date/Time
Date/Time

     960 West LeVoy Drive / Salt Lake City, UT 84123            800-356-9135 or 801-266-7700 / FAX: 801-268-9992
                                     DATACHEM LABORATORIES, INC.
-------
DATAV
    CHEM
    LABORATORI E S
    A  Sorenson company
                    ANALYTICAL REPORT
Form ARF-AL
Page   1   of   3
Part   1   of   1
06230316253074RX
                                             JUN 2 *  20B3
                                  Laboratory Group Name 031-1506-05
                                  Account No.  Q7QQ3	
 Booz Allen Hamilton
 Attention: Steve Coffee
 5299 DTC Bled.
 Suite 840
 Greenwood Village, CO 80111
Sampling Collection and Shipment
          Sampling Site AERC Aghland.Tripft4
                                            E-mail
                                                    FAX (303) 694-7367
                                              Telephone (303) 221-7559
                                                gfgnhanObah.com	
                                  Date of Collection .Tune 11,

Date Samples Received at  Laboratory June 16r 2Q03
Analysis
          Method Ot Analysis NMAH 6009
          Date(s) of Analysis June—2Q*_2QQ3_

Analytical Results
' , Field
Sample
' Number
3705AA612137
370SAAC12139
3705AA612141
3705AA612143
370SAA612145
370SAA612147
3705AA612149
370SAA612151
370SAA612153
3705AA6121SS
3705AA612157
370SAA612159
3705AA612161
Laboratory
Number
03119626
03119*27
03I1962B
03119629
03119630
03119631
03119632
03119633
03119634
03119635
03119637 -
03119638
03119639
Sample
Type
TUBE
TUBE
CUBE
TUBE
TtlBE
TUBE
TUBE
TVBE
TUBE
TUBE
TUBE
TUBE
TUBE
Mercury
ug/Sample
0.43
S.I
7.4
5.5
0.13
0.29
0.29
0.32
0.32
0.29
0.12
0.26
0.10
Mercury
ng/n'
0.039
0.057.
0.058
0.044
TBA
TBA
TBA
TBA
0.042
0.039
0.039
0.072
0.10
Air Volume
L
11.0
118.2
121.9
123.1
TBA
TBA
TBA
TBA
7.7
7.5
3.1
3.6
1.0




















































































t 3«e eoaaent on iaat pig* . ** See comment on lact pago.
HD Parameter not detected above LOO. ( > Parameter between LOO and LOC.
NK Parameter not requested. TBA Parameter to be analyzed.
RA Parameter not applicable. „ \ O \
                                     Analyst:
                                     Reviewer:/Neil A.  Edwards
                960 West LeVoy Drive / Salt Lake City, Utah 84123-2547
                Phone  (801) 266-7700        Web Page: www.datachem.com
                FAX (801) 268-9992         E-mail: lab@datachem.cora
-------
DATAip
    t A B 0 R A T 0 R I
    A Sorenson Conpany
Analytical Results
ANALYTICAL REPORT
                                          Date
Form ARF-BL
Page-   2   of   3
Part   1   of   I
06230316253074RX
                      JUN 2 4 2003
                                          Laboratory Group Name Q3T-15Q6-05
Field
Sample
number
3705AA612163
3705AA612165
3705AA612167
3705TA612167
3705TA612169
3705AA61214S
3705AA612147
3705AA612149
3705AA612151
Laboratory
Numbe r
03119640
03119641
03119642
03119644
03119645
03120063
03120064
03I200S5
03120066
Reporting Limit






























.-

•







Sample
Type
TUBB
TUBE
TUBE
TUBE
TUBE
TUBE
TUBS
TUBE
TUBE












-








nercury
ug/sample
0.21
D.S4
0.31
0.45
0.13
0.33
0.075
0.13
0.14
0.01




















nercury
n«/m>
0.21
0.17
0.094
0.050
0.014
TBA
TBA
TBA
TBA




















Air Volume
L
1.0
3.1
3.3
9.0
9.0
TBA
TBA
TBA
TBA








.





















.
































....


*


















\




'



















j
.










































'






*


,








t see comment on last page. ** Sec comment on last page.
HD Parameter not detected above I.OD. ( | Parameter between LOD and LOQ.
NX Parameter not requested. TBA fararaetor to be analyzed.
NA Parameter not applicable.



















-












              • 960 West LeVoy Drive
               Phone (801)  266-7700
               FAX (801) 268-9992
       Salt.Lake City, Utah 84123-2547
           Veb Page: wvw.datachem.com
           E-mail:  lab@datachem.com '
-------
    A Sor«nson Company
                                               Date
                                                                • Form ARF-C
                                ANALYTICAL  REPORT              Page    3    of   3
                                                                 06230316253074RX


                                                           JUN 2 4 2003
                                               Laboratory Group .Name 03T-1506-05

General Set Comments

Method Reference: NIOSH Manual of Analytical Methods(NMAM), 4th ed., 08/15/94.
Results are not blank-corrected.
Results obtained for media blanks prepared from SKC Carulite tubes are typically
found to have concentrations approximately 0.035-0.045 ug/Sample above the
reporting limit.
Samples 03119627, 28 and 29 required a 10X dilution.


General Lab Comments

The results provided in this report relate only to the items tested.
This page is the concluding page of the report.
                960 West LeVoy Drive / Salt Lake City, Utah 84123-2547
                Phone  (801)  266-7700        Web Page: vww.datachcra.com
                FAX (801) 268-9992          E-mail: lab@datachem.coin
-------
                     DATA
                    CHEM
                    LABORATORIES, INC.
ANALYTICAL REQUEST  FORM
                          O%£tedC~o$
                                REGULAR Status
                                RUSH Status Requested - ADDITIONAL CHARGE
                                 RESULTS REQUIRED BY 	
                                                                                  DATE
                                                       CONTACT DATACHEM LABS PRIOR TO SENDING SAMPLES
2. Date
                    Purchase Order No.
                                                              4. Quote No.
3. Company Name Booz Allen Hamilton
  Address    5299 PTC Blvd., Suite 840
                                          DCL Pmjert Manarjer Rand Potter
                                        5. Sample Collection
             Greenwood Village, CO 80111
  Person to Contact Stave Coffee
  Telephone (303.) 221-7559
  Fax Telephone (303} 694-7367
                                          Sampling She AERC Ashland Trip #4
                                          Industrial Process PTC Device     fy.\0
                                          DataofColtectlon 	
                                          Time Collected
  E-mail Address coff ee_stephen Q bflh.com
                                          Date of Shipment
  Billing Addrose (if different from above) r«f ar to contract
                                          Chain of Custody No.
6. REQUEST FOR ANALYSES
    Laboratory Use Only
Clienl Sample Number
                                         Matrix-
 Sample Volume  ANALYSES REQUESTED-Use method number if known  Units"
         CW.
                            /A 6   J?
         GST)
                             M/ .
         Cw
                               r'ST'
*  Specify. Solid sorbent tube, e.g. Charcoal; Filter type; Implnger solution: Bulk sample; Blood; Urine; Tissue; Soil; Water; Other
" 1. m^sample   2. mg/m3  3. ppm  4. %  5.	(other)  Please indicate one or more units In the column entitled Units**
Comments

Possible Contamination and/or Chemical Hazards
7. Chain of Custody (Optional)
Relinquished by ,-36579 1 J • I TT'j-2 —
Received by /f ,„ — ,t j*fj£l. ,_
Relinquished by /? ~ *('/**^--- •
Received by
Relinquished by
Received by
Datemme tf//3/f\ f /A '- 6*
Date/Time £ /tff
Date/Time C/f&
Date/Time
Date/Time
Date/Time

    960 West LeVoy Drive / Salt Lake City, UT 84123            800-356-9136 or 801-266-7700 / FAX: 801-268-9992
                                     DATACHEM LABORATORIES, INC.
-------
                                           ANALYTICAL REQUEST FORM
*F=^ DATA
'" ~ CHEIW
"^^SmHS^r LABORATORIES, INC.
2. Date ( fh'$ Purchase Order No.
1. 51 REGULAR Status 03E " 1*3°^-'°^
CD RUSH Statue Requested - ADDITIONAL CHARGE
RESULTS REQUIRED BY
DATE
CONTACT OATACHEM UBS PRIOR TO SENDING SAMPLES
4. Quote No.
3. Company Name Booz Allen Hamilton
Address 5299 DTC Blvd., Suite 840
Greenwood Village. CO 801 1 1
Person to Contact Steve Coffee
Telephone { 303 ) 221-7559
Fax Telephone (303 ) 694-7367
E-mail Address coffear.etephen8bah,c6m
Billing Address (if different from above) refer to contract

6. REQUEST FOR ANALYSES
Laboratory Use Only
tT^P^C^r **-
I1CT7
/A &38
ft&rt
R4Ho
I'UVl
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Client Sample Number
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Sample Volume

-*>., .0
"%-O S.
l-f> .S
l.n .0
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Ruoorvod hy -^ ' _£ j^T^* ". -
Relinquished by /£. 	 ^ /****=^
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Received by

Datemme /,? // ?//) ? /O- * 0
Date/Time £//¥"
Date/Time ^•ff^/o^f
Date/Time
Date/Time
DaterTfme

    960 West LeVoy Drive/Salt Lake City, UT 84123         800-356-9135 or 801-266-7700/FAX: 801-268-9992
                                DATACHEM LABORATORIES, INC.
-------
-------
       Appendix D

Drum-Top Crushing Device
 Sampling and Study Plan
-------
                    Mercury Lamps Drum-Top Crushing (DTC) Device
                                 Sampling and Study Plan

                                     February 4,2003
                                   REPA3-0305-001vl
Objective

The basis of this study is to collect reliable measurements to document the potential release of mercury
and human exposure to mercury during the processing of fluorescent tamps in a drum top crusher
(DTC) device.  Four manufacturers will provide DTC devices for evaluation and comparison. The data
collected from the measurements will be used by EPA to assist in the development of a national policy
for the use of DTC devices to process mercury containing fluorescent lamps. Part of the objectives are
to be in compliance with and by the plans REPA Quality Management Plan (QMP), REPA Region 3
Quality Assurance Project Plan, and the Region 3 Health and Safety Program. For all sampling,
analysis and handling procedures, where applicable, Booz Allen staff will follow REPA3 Standard
Operating Procedures (SOPs).

Scope

Two different studies will be completed as part of the overall DTC device study. The detail methods
for conducting each study are documented in this Sampling and Study Plan.  The first study is the
environmental validation study and is divided into two phases: Equipment comparison phase and mass
balance phase.  The second, real world study, is real world testing of the devices. A brief description
of the tests for the DTC device study include:

       Environmental Validation Study
       •   Equipment Comparison - Quantify mercury vapor emissions and measure personal mercury
           exposure during the operation of new devices provided by the manufacturer. Compare the
           emissions of mercury from the DTC devices, when new, to emissions after the DTC
           devices have filled a number of 55-gallon drums.
       •   Mass Balance - Conduct a mass balance study to quantify the mercury released during the
           processing of fluorescent lamps compared to the estimated quantity of mercury contained in
           the fluorescent lamps.
       Real World Study
       •   Real World Testing - Conduct field sampling to quantify mercury vapor emissions and
           worker exposure during the operation of four different DTC devices at three locations in the
           continental United States.
                                        Page 1 of 12
-------
Schedule

Four manufacturers will provide DTC devices for inclusion in this DTC device study. The following
devices will be included in the study:

       •   Air Cycle Bulb Eater Mode! 55 VRS
       •   Resource Technology, Inc. (RTI) Model DTP
       •   The Hazardous Materials Specialist, Inc. (HMS) Fluorescent Lamp Disposal and Mercury
           Vapor Recovery System
       •   Dextrite Model ULC-55 FDA-E

Each manufacturer will provide one new DTC device for the DTC device study. Each of the four
devices will be used for die validation testing and real world testing.

Biological monitoring will be incorporated into the study to further define potential mercury exposure.
Each DTC device operator will participate in the biological monitoring process. Before the DTC
device study begins, the operators wffl provide urine samples to a medical aKnto to establish
background mercury levels. The operators will submit urine samples at the conclusion of the study to
determine whether mere is a increase in mercury due to exposure while operating the DTC devices.
Mercury levels will be examined and tested to ensure that they are not above acceptable bodily
concentrations. All samples will be collected after operators have completed a 24 hour fasting.

Sample collection for the first stages of the equipment comparison phase and the mass balance study
will be performed concurrently. The proposed site for these studies is the AERC facility in Ashland,
Virginia. The expected time to complete the validation testing includes one day to set up and two days
to complete the studies. Once the rente of the  samples from then two phases are received and
reviewed by Booz Allen, die proposed methods for tamping during the real worid testing will be
evaluated and modified as necessary by Booz Aflen with assistance from the EPA WAM. Once the
methods for the real world testing are determined, Booz Allen and EPA (the team) will conduct tests
starting at the Earth Protection Services Inspection (EPSI) facility in Arizona Next, the team will travel
to the Fluorocycle facility in Ingleside, EL. Finally, the team will conduct real world testing back at the
AERC facility in Ashland.. The real world testing at eachjocation is expected to last the  entire week.
After completing the real world testing at the Ashland facility, the second stage of the equipment
comparison phase will be conducted at this facility.
                                         Page 2 of 12
-------
Sampling Strategy
ENVIRONMENTAL VALIDATION STUDY:  Equipment Comparison

The purpose of the equipment comparison phase is to evaluate the potential release of mercury from
new DTC devices compared to the same DTC devices after the devices have processed enough
fluorescent lamps to have completed a number of drum and filter changes. The equipment comparison
phase will be conducted in two stages. The first stage will be conducted before the real world sampling
and the second stage will occur at the conclusion of the real world sampling. This will allow each
device to have processed enough lamps to completely fill eight drums. -Booz Allen will collect wipe
samples from various surfaces and collect air samples to measure the concentration of mercury in the
air. The first stage of the equipment comparison phase will be conducted concurrently with the mass
balance study and some of the sample results will be incorporated into the mass balance equation.

All operations, for each of the devices, will be conducted as directed by the user manual and
instructions.  This includes the operation of the devices as well as scheduling filter changes and drum
changes. Each DTC device will be operated for the time it takes to completely fill one 55-gallon drum.
Filters and drums will be changed according to the manufacturer's recommendations. It is estimated
that the typical device can fill the drum in 3.5 hours.  Based on information provided by the
manufacturers, a full drum may hold from 400 to  1,200 lamps depending on the device. Once the drum
is full, die next device from another manufacturer will be tested in the same manner. During the
operation of all DTC devices only  4-foot Alto T12 lamps by Philips Lighting will be processed.  These
lamps were chosen because T12 lamps are still the predominant lamps used today compared to the T8
lamps. The Philips Lighting Alto lamps were selected because the Alto lamps are more consistent in the
quantity of mercury used in each lamp, although Alto lamps typically contain less mercury. EPA
personnel and a Booz Allen Hamilton (Booz Allen) employee will operate and feed the lamps into the
DTC  devices.              -       •     .

EPA and Booz Allen personnel, with assistance from facility personnel, will build a containment
constructed from a rigid tube frame and polyethylene (plastic) sheeting to isolate each DTC device
during testing and assist in reducing potential interferences.  The containment dimensions will be 12 feet
by 12 feet in order to accommodate for the unique sizes of the different DTC devices. Each device will
be operated in a containment with new plastic on the walls, floor, and ceiling. Therefore, once each
drum  has been filled and all samples have been collected, all the plastic sheets from the containment will
be removed and new plastic sheets will be installed on the floor, walls, and ceiling before operating the  .
next device.  The old plastic will be decontaminated by washing with a water solution containing HGX
compound. An appropriate portion of the plastic (determined by testing requirements),  will then be
tested and disposed of based on the results of the test by the team,  ffthe reruftc indicate the plastic is
contaminated TOih mercury that it above acceptable levek. the level* of mercury on the sheeting wffl be
recorded and the plastic-win be disposed of as mercury contaminated waste according to mercury
disposal standards.

Prior to the start of both the first and second stages of the equipment comparison phase, two
background air samples will be collected by Booz Allen staff in the immediate location where the DTC

                                         Page 3 of 12
-------
devices will be operated. Additionally, Booz Allen will use the Jerome Mercury Vapor Analyzer to
collect direct measurements and data log the results. The Jerome Analyzer will be operated in
accordance with Region 3 SOPs for calibration and measuring. Results of the air monitoring will identify
background mercury concentrations that may need to be accounted for in the results and analysis of the
study to be performed by Booz Allen.

During the operation of the DTC devices, air samples will be collected, by the team, in specified areas
inside the containment and on the operator. All air sampling will be performed in accordance with
acceptable industrial hygiene air monitoring procedures.  Air samples will be collected in each
containment in the following areas (see attached Table-1 for further detail). Booz Allen will perform all
air monitoring according to Booz Allen SOPs:

       •   Two samples (one on each shoulder) will be collected on the operator for the entire
           duration of the device operation, including filter changes and the drum change.
       •   Two concurrent samples will be collected at each DTC device exhaust for the duration of
           tfie device operation. The results of mis sampling during the first stage will be used in the
           mass balance study.
       •   Two concurrent samples will be collected at the DTC device feed tube for the duration of
           the device operation. The results of this sampling during the first stage will be used in the
           mass balance study.
       •   One sample will be collected on each operator during the change-out of the filters and
           drum. Particulate filter changes will occur based on manufacturer's recommendations. It is
           anticipated that the filter change and drum change will only take a few minutes to complete.
           In order to ensure a detection limit of less the 0.1 mg/m3 the sample pumps will operate
           after the filter change and drum change is complete in order to achieve sufficient air volume,
           ac was determined by EPA and Booz Allen. The cohedule for each device's filter change
           and subsequent air sample is as follows:

              •   HMS-every 300 lamps = three samples/drum
              •   Air Cycle-every drum change = one sample/drum
              •   RTI-No filter changes, system back purges the filter every 15 minutes
              •   Dextrite-every 2400 lamps = approximately every third drum.

       •   Two field blanks will be prepared for each day of sampling.
       •   One set of three laboratory blanks will be prepared for each stage  of the equipment
           comparison study.

Air samples will  be collected to measure airborne mercury concentrations in the vapor phase and
aerosol phase. Air samples to measure mercury in the aerosol phase will be collected and analyzed in
accordance with the Occupational Safety and Health Administration (OSHA) analytical method ID-
145. Air samples to measure mercury in the vapor phase will be collected and analyzed in accordance
with the National Institute for Occupational Safety and Health (NIOSH) analytical method  6009. The
samples will be collected on a 37-mm  mixed cellulose ester filter to capture aerosols connected to a

                                         Page 4 of 12
-------
Hopcalite sample media or an.equivalent sample media to capture vapors. The sample pump for every
air sample will be pre-calibrated and post-calibrated against a primary standard to adjust the air flow to
the proper flow rate.
             U.S. EPA Headquarters Library
               -,   Mail Code 3404T
            1200 Pennsylvania Avenue, NW
                Washinaton DC 20460
                     £02^-566-0556
                                       Page 5 of 12
-------
Information to document each air sample will be recorded on air monitoring forms. The information
required on each form includes:

       •  A sample number unique to that air sample
       •  Specific 'details of the sample location or name of the operator wearing the samples
       •  Pre-calibration and post-calibration results
       •'  Time on and time off of the sample pump
       •  Volume of air collected-duration of the sampling multiplied by the air flow rate (average of
          the pre-and post-calibration)
       •  Number of fluorescent lamps processed during the sampling and categorized by wattage
       •  Other notable conditions that may effect the sample results.'

Li addition to air samples, the equipment comparison phase will also include wipe samples collected
inside the containment on numerous surfaces.  A set of wipe samples will be collected prior to the start
of the DTC device operation and a set will be collected at the conclusion of the DTC device operation.
A set of pre- and post-operation wipe samples will be collected for each of the manufacturer's
devices. The wipe samples will be collected and analyzed in accordance with the NIOSH draft
analytical method N9103 for wipe samples. Under this procedure, a 100 cm2 wipe sample will be
collected using a "Wash-n-Dry" towelette and placed into a vial provided by the laboratory.  For each
location two side-by-side wipe samples will be collected.  The nine locations for the wipe samples
inside each containment include:

       *  FlooMwo   feet from the device
       »  Floor-five feet from the device
      . •  Floor-at the device exhaust
       •  Drum side
       •  DTC device
       •  Feed tube inlet exterior
       •  Ceiling
       •  Wall
       •  Wall

At the end of the each equipment comparison stage, the air samples and wipe samples will be collected,
packaged, and submitted by the team to DataChem Laboratories, Inc. (DataChem) located in Salt
Lake City, Utah, along with completed chain-of-custody forms. DataChem is an American Industrial
Hygiene Association (AIHA) accredited laboratory. Samples will be placed in an oversized sturdy box
with packing material to fill voids and protect the samples. The Booz Allen person shipping the samples
will sign the chain-of-custody forms and will place the forms in the box with the samples.  Samples will
be submitted via Federal Express to the laboratory.
                                         Page 6 of 12
-------
During the process of measuring mercury concentrations in the air using sampling pumps, two factory
calibrated mercury vapor analyzers will be employed by the team to measure real-time mercury
concentrations in the air.  At least one of the mercury vapor analyzers will be equipped with a data
logger to measure and record the mercury concentrations throughout the day. The analyzers, one
stationary and one mobile, will be used to identity fluctuations in concentrations while the DTC devices
operate and will also measure for leaks in the seals of the DTC devices.

At the conclusion of the device operations for the day, each DTC device will be placed on a drums
containing crushed debris and be allowed to set for the night.  Any operation of the devices will be
performed in accordance with manufacturer instructions.  Air samples will be collected next to the DTC
device/drum assemblies during the night in between equipment comparison studies. The air samples will
measure for any escaping mercury off-gassing that may occur when the devices are not in operation.
Air sample pumps with in-line collection media will be set next to each device and the mercury vapor
analyzer will log the concentrations throughout the  night            .

After completion of the first stage of the equipment comparison phase, the new devices will be shipped
to the EPSI facility in Arizona. To prepare the devices for shipping the team, with assistance.from
facility personnel, will be wipe down each device, wrap each device in plastic, and place each device in
the crates provided by the manufacturers. Plastic sheet roles and framing will not be shipped but will be
purchased separately at each location.  Upon receipt of the devices at each of the testing sites, the team
will perform an inspection of the devices for damages that resulted from the transport.

In order to test the efficiency of the DTC devices and their performance in use with "U" shaped tubes,
a study will take place at the completion of the validation phase. A defined number of lamps will be
determined based on amount available at the AERC facility in Ashland, Virginia and used for testing in a
final study and the required amount to gain an accurate  sample collection. The "U" shaped lamps will
be crushed using the devices provided by Air Cycle, Dextrite, and HMS. The RTI device is not
equipped with an attachment for feeding "U" shaped tubes and therefore will not be included in this
portion of the study. Air samples and wipe samples as described in Table-1 will be collected during the
operation of the devices until tubes have been crushed.

ENVIRONMENTAL VALIDATION STUDY;  Mass Balance Study

The mass balance study is intended to determine the capture efficiency of mercury vapors during the
operation of the DTC devices. Only Alto T12 lamps will be used in the mass balance study. The study
will take into account the different wattages of the T12 lamps (wattage 34/40 and 39/60). This study
will incorporate the results of the air samples and wipe samples collected during the first stage of the
equipment comparison phase. In addition, the team will collect bulk material samples and have them
analyzed for mercury by DataChem. The bulk samples will be collected from the DTC devices after
the devices have completely filled one drum during the equipment comparison phase prior to removing
the device from the containment. The bulk samples will be collected and analyzed in accordance with
EPA method SW-846 method 7471A and sampling directions provided by the analytical laboratory
(DataChem).

                                         Page 7 of 12
-------
The bulk samples to be collected from the each of the four DTC devices include:

       •   Three samples from the paniculate pre-filters from the HMS device, Air Cycle device and
           Dextrite device.  The RTI device is not equipped with a paniculate pre-filter.
       •   Three samples from the HEPA filters from all four devices.  ,
       •   Three samples from the carbon filters from all four devices.
       •   Three samples from the crushed material in the drums. This sample will include
           representative amounts of broken glass, metal end caps, and phosphor powder.

Before the DTC devices are operated, the filters and empty drums will.be tared, to measure the weight
of the fitters and drum before crushing the lamps. After crushing enough lamps to fill a drum, the filters
will be accessed with support from the device manufacturer's representatives and the bulk samples will
be collected by cutting out portions of the particulate filters or removing the loose carbon from the top
of the carbon filter container. The bulk material will be placed into collection vessels provided by the
laboratory.  Next, the devices will be removed from the drum, and bulk samples will be collected from
the crushed debris below the top surface of debris. The debris samples will be placed in collection
vessels provided by the laboratory. '

In addition, five Alto T12 lamps (wattage 34/40 and 39/60) will be submitted to the analytical
laboratory to confirm the quantity of mercury contained in the lamps. DataChem will crush the lamps in
a similar manner as occurs in the devices to ensure that the measurement for mercury is accurate.
These results will be used to confirm the amount of mercury reported by the manufacturer.  These
results will be used to calculate the quantity of mercury based on the number of lamps processed. The
bulk samples and intact lamps will be submitted to DataChem for analysis along with completed chain-
of-custody forms.

Booz Allen will select, based on accuracy determinations, wipe samples and air samples collected
during the equipment comparison" phase on the DTC devices will be incorporated into the mass balance
study.  These select samples include:

       •   Wipe samples from the exterior drum surface
       •   Wipe samples from the DTC device
       •   Air samples collected at the DTC device exhaust
       •   Air samples collected at the DTC device feed tube.
Upon return of the laboratory results for mercury, the data will be plugged into the mass balance
equation by Booz Allen to determine the mercury capture efficiency of the DTC devices. The mass
balance equation is:

       Total Hg = Hg retained in the DTC device + Hg released from the DTC device
                                         Page 8 of 12
-------
 Total Hg is the quantity of mercury calculated by the quantity of mercury contained in a fluorescent
 lamp multiplied by the number of lamps processed.  Hg retained is determined by the results of the bulk
 samples collected from the crushed debris in the drum and the bulk filter samples. Hg released is
 determined by the results of the air samples and wipe samples. Using the equation, the percent
 recovery of mercury can be calculated. The mass balance study is contained in Attachment 1.

 REAL WORLD STUDY: Real World Testing

 The real world testing phase will determine the release of mercury vapors and human exposure to
 mercury vapors during the normal operation of the DTC devices.  The same DTC devices used in the
 equipment comparison phase will be evaluated in a real world industrial setting. The DTC devices will
 process a variety of four foot T12 lamps for an entire work shift. For this study, a work shift will
 include the time needed to completely fill two 55-gallon drums. The real world testing will be repeated
 at three separate locations. The DTC devices will be operated inside a containment equivalent to the
 containment used in the equipment comparison phase. Each device will be operated in a containment
 with new plastic on the walls, floor, and ceiling. Therefore, once the work shift has been completed
 and all samples have been collected, all the plastic sheets from the containment will be removed and
 new plastic sheets will be installed on the floor, walls, and ceiling before operating the next device.  The
 old plastic will be decontaminated by washing with a water solution containing HGX compound. An  „
 appropriate portion of the plastic (determined by testing requirements), will then be tested and
 disposed of based on the results of the test by the team,  ffthe rendtc indicate the plartac ic
 oofrianmated'with meroury that ic above acceptable levek. the levek of mercury on the fheetm&wffi be
 recorded and tteplacfoTOffl be dkpoced of acmertnirya                                     .
 dicpocal ctandarde.

 Air samples will be collected over the entire work shift (two drum changes).  The operation of the DTC
 device over the work shift will be performed by EPA and Booz Allen staff. The first person will
 operate the DTC device until the first drum is filled, including the filter changes and drum change.  The
 second person will operate the DTC device until the second drum is filled, including me filter changes
 and changing the drum at the end of the day.

 During the operation of the DTC devices, air samples will be collected in specified areas inside the
. containment and on the operator by the team. All air sampling will be performed in accordance with
 acceptable industrial hygiene air monitoring procedures as well as the Region 3 SOPs.  Air samples will
 be collected in each containment in the following areas (see Attached Table-1 for more detail):

        •  Two samples (one on each shoulder) will be collected by the operator while they operate
           the device and completely fill the drum, including filter changes and the drum change.
        •  Two samples will be collected inside the containment at locations that will be determined
           based on the results from the equipment comparison phase.
                                          Page 9 of 12
-------
       •   One sample will be collected oh each operator during the change-out of the filters and
           drum. 'Particulate filter changes will occur based on manufacturer's recommendations. It is
           anticipated that the filter change and drum change will only take a few minutes to complete.
           In order to ensure a detection limit of less the 0.1 mg/m3 the sample pumps will operate
           after the filter change and drum change is complete in order to achieve sufficient air volume.
           Hie schedule for each device's filter change and subsequent air sample is as follows:

              •   HMS - every 300 lamps = eight samples
              •   Air Cycle - every drum change = two samples
              •   RTI - no filter changes, system back-purges the filter every 15 minutes
              •   Dextrite - every 2400 samples = one sample

       •   Two field blanks will be prepared for each day of sampling.
       •   One set of three laboratory blanks will be prepared for each location.

Air samples will be collected to measure airborne mercury concentrations in the vapor phase and
aerosol phase. Air samples to measure mercury in the aerosol phase will be collected and analyzed in
accordance with the OSHA analytical method ID-145.  Air samples to measure mercury in the vapor
phase will be collected and analyzed in accordance with the NIOSH analytical method 6009.; The
samples will be collected on a 37-mm mixed cellulose ester filter to capture aerosols connected to a
Hopcalite sample media or an equivalent sample media to capture vapors.  The sample pump for every
air sample will be pre-calibrated and post-calibrated against a primary standard to adjust the air flow to
the proper flow rate.

Information to document each air sample will be recorded on air monitoring forms by Booz Allen. The
information required on each form includes:

       •   A sample number unique to that air sample
       •   Specific details of the sample location or name of the operator wearing the samples
       •   Pre-calibration and post-calibration results
       •  Time on and time off of the sample pump
       •  Volume of air collected-duration of the sampling multiplied by the air flow rate (average of
          the pre- and post-calibration)
       •  Number of fluorescent lamps processed during the sampling and categorized by type of
           lamp and wattage
       •  Other notable conditions that may effect the sample results.

In addition to air samples, the equipment comparison phase will also include wipe samples, collected by
Booz Allen, inside the containment on numerous surfaces. A set of wipe samples will be collected prior
to the start of the DTC device operation and a set will be collected at the conclusion of the DTC device
operation.  A set of pre- and post-operation wipe samples will be collected for each of the
manufacturer's devices. The wipe samples will be collected by Booz Allen and analyzed by DataChem
in accordance with the NIOSH draft analytical method N9103 for wipe samples. Under this

                                        Page 10 of  12
-------
procedure, a 100 cm2 wipe sample will be collected using a "Wash-n-Dry" towelette and placed into a
vial provided by the laboratory. For each location two side-by-side wipe samples will be collected.
The nine locations for die wipe samples inside each containment include:

       •   Floor-two feet from the device
       •   Floor-five feet from the device
       *   Floor-at the device exhaust
       •   Drum side                  .  .
       •   DTC device
       •   Feed tube inlet exterior  .                                           .
       •   Ceiling
       •   Wall
       •   Wall

At the end of the each real world testing location, the air samples and wipe samples will be collected,
packaged, and submitted by the team to DataChem located in Salt Lake City, Utah, along with
completed chain-of-custody forms. DataChem is an AIHA accredited laboratory. Samples will be
placed in an oversized sturdy box with packing material to fill voids and protect the samples. The
chain-pf-custody forms will be signed by the Booz Allen person shipping the samples and the form  ,
placed in the box with die samples. Samples will be submitted via Federal Express to the laboratory.

During the process of measuring mercury concentrations in me air using sampling pumps, two factory,
calibrated mercury vapor analyzer will be employed to measure real-time mercury concentrations in the
air. At least one of the mercury vapor analyzers will be equipped with a data logger to measure and
record the mercury concentrations throughout the day. The analyzers, one stationary and one mobile, .
will be used to identify fluctuations in concentrations while the DTC devices operate and will also
measure for leaks in the seals of the DTC devices.

After completion of real world testing at each location, the DTC devices will be shipped to the next
location by the team with assistance from facility personnel.  The device surfaces will be wiped clean
using a water solution containing the HGX compound.  The cleaned devices will be capped or plugged
at the feed tube  intake and at the exhaust wrapped in plastic.  The devices will then be placed in the
crates or packaging provided by the manufacturers and prepared for transportation.
                                         Page 11 of 12
-------
ATTACHMENT 1

Lamp Crusher Hg Mass Release/Mass Balance Study

Total Hg = Hg retained in crusher unit + Hg released from unit

       Where:

       HgT ¥ Total Hg
       Hgu = Hg retained in crusher unit
       HgR = Hg released from unit


1.     HgT= Total Hg

           = Total # lamps crushed X Hg/lamp

              Hg/lamp based on:     1) manufacturer's claims/estimates; and/or
                                   2) testing of 5 lamps for total Hg

2.     Hgu = Hg retained in crusher unit

           = Hg in crushed lamps + Hg retained in HEPA filter + Hg retained in carbon filter + Hg
              residual on interior surface of crusher


3.     HgR = Hg released from unit

          HgR = Hg released at exhaust port + Hg fugitive release

                   ) = Hg exhaust cone X air flow rate X air flow duration
              Hg(F) = (Hg cone, at fugitive release sites X est. air leakage rate) +
                 (drum change air cone X est. air release at drum change)
       And/Or,
          Hg(R) = (chamber ambient air Hg cone X chamber volume) +
                  (wipe sample Hg cone (in mass/SA) X surface area of chamber)
                                        Page 12 of 12
-------
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            Appendix E




Laboratory Methods and Modifications
-------
NIOSH Draft Method 9103 - Modified: Analysis of MCE Filter

1.  Transferred each filter sample to pre-cleaned individual 250-mL HDPE bottles.
                                                                    i
2.  Added 10 mL of concentrated nitric acid to each sample and gently swirled until the
   filter was completely saturated.

3.  Placed caps loosely on the bottles and men set samples in a water bath maintained at
   90 to 92 °C. After 2 minutes in the water bath, removed samples and cooled bottles
   to room temperature.

4.  Added 50 mL of ASTM Type II water to each sample and gently swirled to mix
   thoroughly.

5.  Added 25 mL of 5% potassium permanganate to each sample and gently swirled to
   mix thoroughly.

6.  Added 8 mL of 5% potassium persulfate to each sample and gently swirled to mix
   thoroughly.

7.  Placed caps loosely on the bottles and then set samples in a water bath maintained at
   90 to 92 °C. After 30 minutes in the water bath, removed samples and cooled bottles
   to room temperature.

8.  Immediately prior to analysis, added 7 mL of 20% hydroxylamine hydrochloride to
   each sample, replaced and tightened caps, and shook the bottles to mix samples
   thoroughly. Allowed bottles to cool to room temperature and proceeded to analysis.

•  All standards were prepared the same manner as the sample except no filter media
   was present.

•  One set of QC samples (QB, LCS, and LCSD) were prepared using MOE filter at the
   rate of 1 set per 20 field samples. (LCS & LCSD samples were prepared using 0.5
   mL of 1.0 ng/mL Hg standard, yielding a spike target at 0.5  ^g/sample.)
-------
NIOSH Method 6009 - Modified:  Analysis of Carulite (Hvdrar) Tube

1.  Carefully broke the edge of the sampling tube adjacent to sorbent material, and
   carefully transferred only the sorbent material of each sample to pre-cleaned
   individual 50-mL volumetric flasks.

2.  Added 2.5 mL of concentrated nitric acid to each sample and gently swirled until the
   sample was completely saturated.

3.  Added 2.5 mL of concentrated hydrochloric acid to each sample and gently swirled
   until the sample became dark.  Placed the sample in a hood at least for 1 hour and
   swirled occasionally.

4.  Diluted each sample to 50 mL volume with ASTM Type II water and shook the
   flasks to mix thoroughly.

5.  Allowed samples to settle and  proceeded to analysis.

•  All standards were prepared the same manner as the sample except no sorbent
   media was present and no 1 hour waiting time was needed.

•  One set of QC samples (QB, LCS, and LCSD) was prepared using SKC Carulite
   (Hydrar) tubes at the rate of one set per 20 field samples.  (LCS and LCSD samples
   were spiked using 0.5 mL of 1.0 ng/mL Hg standard, yielding spike targets at 0.5
   Hg/ sample.)
-------
NIOSH Draft Method 9103: Analysis of Wash'n Dri Wipe

1.  Transferred each wipe sample to pre-cleaned individual 250-mL HDPE bottles.
                                 s
2.  Added 5 mL of concentrated nitric acid to each sample and gently swirled until the
   wipe was completely saturated.

3.  Added 5 mL of concentrated sulfuric acid to each sample and gently swirled until
   the wipe was dissolved. Placed samples in a hood until all acid fumes were evolved
   and no further reaction was observed.

4.  Added 50 mL of ASTM Type II water to each sample and gently swirled to mix
   thoroughly.

5.  Added 10 mL of 10% potassium permanganate to each sample and gently swirled
   until purple color disappeared. Added another 10 mL of 10% potassium
   permanganate to each sample, gently swirling until the reaction subsided. Added  ,
   an additional 30 mL of 10% potassium permanganate to each sample and gently
   swirled to mix thoroughly.

6.  Added 8 mL of 5% potassium persulfate to each sample and gently swirled to mix
   thoroughly.

7.  Placed caps loosely on the bottles and then set samples in a water bath maintained at
   90 to 92 °C. After 30 minutes in the water bath, removed samples and cooled bottles
   to room temperature.

8.  Immediately prior to analysis, added 7 mL of 20% hydroxylamine hydrochloride to
   each sample, replaced and tightened caps, and shook the bottles to mix samples
   thoroughly. Allowed bottles to cool to room temperature and proceeded to analysis.

•  All standards were prepared the same manner as the sample except no wipe media
   was presented.

•  One set of QC samples (QB = quality control blank = media blank, spiked LCS =
   laboratory control sample, and LCSD = duplicate spiked laboratory control sample)
   was prepared using Wash'n Dri wipes at the rate of one set per 20 field samples.
   (LCS and LCSD samples were spiked using 0.5 mL of 1.0 ng/mL Hg standard,
   yielding a spike target at 0.5 ng/ sample.)
-------
EPA Method 7470 -Modified/Phillips Lab Procedure - Modified: Analysis of
Unbroken, Spent Lamp              .       '                  »

1.  Each entire lamp was cooled with dry ice for 1 hour and one end of the lamp was
   carefully broken.

2.  Inner contents of the lamp was washed out with 200 mL of concentrated nitric acid
   and mixed well.

3.  1 mL of the acid leached sample was transferred to pre-cleaned 250-mL HDPE
   bottles.

4.  Added 99 mL of ASTM Type II water, 5 mL of concentrated sulfuric acid, 2.5 mL of
   nitric acid, 15 mL of 5% potassium permanganate, and 8 mL of potassium persulfate,
   then mixed well.

6.  Placed caps loosely on the bottles and then set samples in a water bath maintained at
   90.to 92 °C. After 2 hours in the water bath, removed samples and cooled bottles to
   room temperature.

7.  Immediately prior to analysis, added 5 mL of 20% hydroxylamine hydrochloride to
   each sample, replaced and tightened caps, and shook the bottles to mix samples
   thoroughly. Allowed bottles to cool to room temperature and proceeded to analysis.

•  All standards were prepared the same manner as the sample except no acid leaching
   was involved.                                         ,

•  One set of QC samples were prepared using ASTM Type II water at the rate of one
   set per 20 field samples. (LCS and LCSD samples were spiked using 0.5 mL of 1.0
   ug/mL Hg standard, yielding spike targets at 5.0 ug/L.)
-------
EPA Method 7470 - Modified/Phillips Lab Procedure - Modified: Analysis of Lamp
Debris (including glass, metal endcaps, and fines)

1. The lamp debris samples were preserved in a cooler and each sample was weighed
(total weight — bottle weight = sample weight).

2. Each sample was leached with 200 mL of concentrated nitric acid for 1.5 hours.

3.2 mL of homogeneous representative aqueous sample was transferred into pre-
cleaned 250-mL HDPE bottles.             .                •-..•,

4. Added 98 mL of ASTM Type I water, 5 mL of concentrated sulfuric acid, 2.5 mL of
nitric acid, 15 mL of 5% potassium permanganate, and 8 mL of potassium persulfate,
then mixed well.,  .

5. Placed caps loosely on the bottles and then set samples in a water bath maintained at
90 to 92 °C. After 2 hours in the water bath, removed samples and cooled bottles to
room temperature.

6. Immediately prior to analysis, added 5 mL of 20% hydroxylamine hydrochloride to
each sample, replaced and tightened caps, and shook the bottles to mix samples  .
thoroughly. Allowed bottles to cool to room temperature and proceeded to analysis.

• All standards were prepared the same manner as the sample except no acid leaching
was involved.

* One set of QC samples (LCS, and LCSD) were prepared using EPA reference soil at
the rate of one set per 20 field samples. LCS and LCSD samples were obtained by
leaching 0.5 g of EPA reference soil (target concentration of 12.3 ug/g) in 20 mL of
concentrated nitric acid  2 mL of the leachate solution was used to prepare the QCs.
-------
NIOSH Draft Method 9103 - Modified:  Analysis of HEPA Filter

1.  Each HEPA filter container was opened and a representative portion of the main
   filter membrane was cut by 5 cm x 5 cm (= 25 cm2).

2.  Transferred each filter sample to pre-cleaned individual 250-mL HDPE bottles.

3.  Added 5 mL of ASTM Type II water to each sample and gently swirled until the
   filter was saturated.

4.  Added 5 mL of aqua regia to each sample and gently swirled until the filter was
   saturated.

5.  Added 50 mL of ASTM Type II water to each sample and gently swirled to mix
   thoroughly.

6.  Added 30 mL of 5% potassium permanganate to each sample and gently swirled to
   mix thoroughly.

7.  Added 8 mL of 5% potassium persulfate to each sample and gently swirled to mix
   thoroughly.

8.  Placed caps loosely on the bottles and then set samples in a water bath maintained at
   90 to 92 °C.  After 30 minutes in the water bath, removed samples and cooled bottles
   to room temperature.

9.  Immediately prior to analysis, added 7 mL of 20% hydroxylafnine hydrochloride to
   each sample, replaced and tightened caps, and shook the bottles to mix samples
   thoroughly. Allowed bottles to cool to room temperature and proceeded to analysis.

•  All standards were prepared the same manner as the sample except no filter media
   was present.

•  One set of QC samples (QB, LCS, and LCSD) were prepared using Whatman filters '
   at the rate of 1 set per 20 field samples. (LCS and LCSD samples were spiked using
   0.5 mL of 1.0 ng/mL Hg standard, yielding a target at 0.5 |ug/sample.)
-------
EPA Method 7470 - Modified: Analysis of Carbon Pellets, Fines from Lamp Debris
Samples, and Pre-filter Samples

1.  Weighed 0.5 g of each representative sample and transferred the sample to pre-
   cleaned individual 250-mL HOPE bottles.

2.  Added 5 mL of ASTM Type II water to each sample and gently swirled until the
   sample was wetted.'

3.  Added 5 mL of aqua regia to each sample and gently swirled until the sample was
   fully wetted.

4.  Placed caps loosely on the bottles and then set samples in a water bath maintained at
   90 to 92 °C. After 2 minutes in the water bath, removed samples and cooled bottles
   to room  temperature.

5.  Added 50 mL of ASTM Type II water to each sample and gently swirled to mix
   thoroughly.

6.  Added 15 mL of 5% potassium permanganate to each sample and gently swirled to
   mix thoroughly.

7.  Placed caps loosely on the bottles and then set samples in a water bath maintained at
   90 to 92 °C. After 30'minutes in the water bath, removed samples and cooled bottles
   to room  temperature.

8.  Immediately prior to analysis, added 50 mL of ASTM Type II water and 5 mL of 20%
   hydroxylamine hydrochloride to each sample, replaced and tightened caps, and '
   shook the bottles to mix samples thoroughly. Allowed bottles to cool to room
   temperature and proceeded to analysis.

«  All standards were prepared the same manner as the sample except no bulk or soil
   media was present.                     ,                         -

•  One set of QC samples (LCS and LCSD) were prepared using EPA reference soil at
   the rate of 1 set per 20 field samples. (LCS and LCSD samples were prepared using
   0.5 g of EPA reference soil, which has a targeted mercury concentration at 12.3
   Hg/g.) Also, one matrix spike sample (MS) and one matrix spike duplicate sample
   (MSD) was prepared at the rate of one per 20 field samples by spiking 0.1 mL of 1.0
   ug/mL Hg onto the field samples, yielding spike targets at 1.0 ug/L,
-------
          Appendix F




Wipe Sample Data and Discussion
-------
Wipe Sampling Results

Wipe samples were collected from various surfaces to evaluate the deposition of
mercury condensate and mercury-contaminated particulates on surfaces inside
the containment. A set of wipe samples from nine different locations was
collected prior to testing each DTC device (pre-test wipes), and another set was
collected near the same nine locations at the conclusion of the test for each device
(post-test wipes).  Refer to Section 3.3 for wipe sample locations. These analyses
were conducted as part of the Mass Balance Study to help quantify the mass of
mercury released (i.e., not captured by the DTC device).

The results of the pre-test wipes and the post-test wipes were compared to each
other. Pre-test and post-test wipes were collected from approximately the same
general locations within the containment, to account for any spatial variation in
ambient conditions (e.g., sampling location relative to the crusher, difference in
local ventilation patterns).

To review the individual wipe sample results, refer to Appendix A, Table 2.

Wipe Sample Results - FVS Phase I

The wipe sample analytical results from Phase I of the Performance Validation
Study (PVS) indicated that baseline mercury concentrations were present inside
the AERC Ashland facility prior to initiation of this study. The ranges of results
for each device are listed in Table 1 below.
          Table 1: Phase I Performance Validation Study Wipe Sample Results
           ip §lki!isS|i;K3K'Sppi
           ^s^ss^sBflpsBif^l
            Manufacturer A
            Manufacturer 6
            Manufacturer C
            Manufacturer D
                                0.016 - 0.49
                                ND-0.17
                                ND - 0.71
                                0.028 - 0.40
0.013-0.19
 ND - 0.64
0.021 - 3.1
 ND-0.1
Detectable concentrations of mercury were noted on pre-test wipes when testing
all four devices.  Approximately 44 percent of the total post-test wipes exhibited
higher levels of mercury than the pre-test wipes.

Wipe Sample Results - EFT#1

The wipe sample analytical result indicated that baseline mercury concentrations
were present during Extended Field Test (EFT) #1 in the EPSI facility. The
ranges of results for each device are presented in Table 2.
-------
               Table 2: Extended Field Test #1 Wipe Sampling Results
Detectable concentrations of mercury were noted on pre-test wipes when testing
all four devices. Approximately 75 percent of the total post-test wipe results
exhibited higher levels of mercury than the pre-test wipes.

Wipe Sample Results - EFT #2

Upon review of the wipe sample results collected during PVS Phase I and EFT
#1, it was apparent that the baseline level of mercury contamination already
present at the recycling facilities had the potential to confound the study results.
One possible source of this contamination was the practice of measuring and
cutting the polyethylene sheeting on the (contaminated) work area floor.

The team worked to reduce the interference from this contamination at the AERC
Melbourne facility by measuring and cutting the polyethylene outdoors, in the
parking lot behind the facility.  A clean sheet of polyethylene was first laid on the
ground to create an uncontaminated work surface. The polyethylene sheeting
for the containment structure was cut and stored outside the facility on the clean,
polyethylene work surface.

To further evaluate baseline the high levels of mercury found in pre-test wipes, it
was  also decided to collect two additional wipe samples inside the containment
area the morning after the DTC devices were left idle in the containment  .
overnight. One of the additional wipe samples was taken from the floor
approximately two feet away from the device, and the other additional wipe
sample was taken from the east wall of the containment. Field personnel
attempted to collect these samples from approximately the same location as the
earlier wipe samples.

Levels of mercury were still detected on the pre-test wipes collected for all three
devices during EFT #2. The ranges of results for each device are presented in
Table 3 below.
-------
               Table 3: Extended Field Test #2 Wipe Sampling Results
. * ** ' M", ,V '„ * "," r .'; 1 . :
jDevj.cs.'/i-'sritr
•>"U iia «•-,>'/:
Manufacturer A
Manufacturer B
Manufacturer C
K J;"Jf :i'-:>Vipe.Sainple Results (ugflLOO cm*) -i ' /' ;-;
;1:^;::;..sp*r«tr--.is;«;,,::
0.015-0.860
0.035-0.63
0.08 - 0.25
;-;-,;• '.llostfest :. ' ;, -'
0.052-3.6
0.050-1.60
0.02-0.49
Approximately 70 percent of the total post-test wipes exhibited higher detected
levels of mercury than the pre-test wipes, which was similar to the EPSI facility,

Wipe Sample Results - EFT #3  .

As in EFT #2, to reduce the level of mercury contamination on the polyethylene
used to construct the containment, the procedure of measuring and cutting the
polyethylene sheeting was performed outdoors in the parking lot behind the
Ashland AERC Facility. In addition, a separate piece of polyethylene was
measured, cut, and placed on the facility floor beneath each prepared
containment structure.  This task was performed to attempt to further reduce the
effects of the ambient level of mercury contamination on test results.

The wipe sample results indicate that there was a level of background
contamination present in the AERC Ashland facility during EFT #3. The ranges
of results for each device are presented in Table 4 below.

               Table 4; Extended Field Test #3 Wipe Sampling Results
!;l§evice7i f ?.,"; - i '-'>. "*£
Manufacturer C
Manufacturer B
Manufacturer A
5 y1!:;vWip¥Sampie Results (ug/iOOctn*) ; :
i^^Test;;,;;:^
0.020 - 017
0.024 - 0.23
ND - 0.73
;':,l:^posfcTest;-;,i>-;;
0.092-2.8
0.055-3.8
0.11 - 1.7
All three DTC device studies resulted in the detection of mercury on pre-test
wipes. Approximately 89 percent of the total post-test wipes exhibited higher
detected levels of mercury than the pre-test wipes.

Wipe Sample Results - PVS Phase II

The ranges of wipe sampling results for each device are presented in Table 5.
-------
         Table 5; Phase II Performance Validation Study Wipe Sample Results
                  .
            Manufacturer A
            Manufacturer B
            Manufacturer C
0.011 - 1.7
0.039-0.98
0.016-0.98
0.024-11
0.043-0.45
0.019-0.43
As during the Phase I test, the wipe sampling results from PVS Phase II indicated
a baseline level of airborne mercury present in the AERC Ashland facility, most
likely caused by the routine lamp crushing operations. All three DTC device
tests resulted in the detection of mercury on pre-test wipes. Only 48 percent of
all post-test wipes exhibited higher concentrations of mercury than the pre-test
wipes.

Conclusions

Mercury was detected in the pre-test wipes, regardless of testing location. The
higher mercury concentrations on pre-test wipes were not anticipated when the
sampling and study plan was finalized.  These elevated results indicated
contamination prior to the operation of the DTC devices. Thorough review of
the sampling and study plan by an individual with experience measuring
mercury in field conditions would likely have helped the study team avoid or
minimize these complications.

The mercury contamination on the polyethylene containment surfaces may have
had several different sources. The ambient mercury vapor in the facilities may
have deposited/sorbed onto on the polyethylene  before the pre-test wipes were
collected. Cross-contamination of the polyethylene sheeting may have occurred
when it was sized and cut on the warehouse floor of the facility.

As described above, at the AERC Melbourne facility and the AERC Ashland
facility (EFT #2, EFT #3, and PVS Phase II), the polyethylene sheeting was
measured and cut outside the facility. Even after  this methodology was adopted,
many of the pre-test wipes were higher than the post-test wipes (during EFT #2,
30 percent were higher; during EFT #3,11 percent were higher, and  during PVS
II, 52 percent were higher). This indicates that cutting the  polyethylene sheets
outdoors, away from the warehouse and on top of another polyethylene sheet,
did not significantly decrease mercury contamination during construction of the
containment.

hi general, the two additional post-test wipes taken the day after testing at the
AERC Melbourne facility and the AERC Ashland facility were higher than the
corresponding post-test wipes taken the same day that the DTC device was
-------
operated. This indicates that the ambient mercury most likely contributed to the
high mercury levels detected for most of the pre-test wipes.

The wipe samples provided inconclusive data due to contamination. The study
team determined that the wipe sample results would not be used as part of the
Mass Balance Study.
-------
           Appendix G

Sampling Error and Correction Efforts
      For Mass Balance Study
-------
                            Mass Balance Sampling Error
       The initial sample results from the drum debris samples reported by the laboratory were
much higher than the results used in the mass balance equation in Chapter 5. These higher
concentrations were scrutinized by the team and upon further discussion with the laboratory, an
error in the analytical method for the drum debris bulk samples was discovered. Table 1 presents
the results from the initial analysis that was used in the original mass balance equation.

                 Table 1: Initial Drum Debris Bulk Sample Analytical Results
"'-. '"••-' Device
:*?•';.•;,.•; Y/ :. ,-f .=
MFGA
MFGA
MFGA
MFGB
MFGB
MFGB
MFGC
MFGC
MFGC
; , Sample*
R/B-2/27-16
R/B-2/27-17
R/B-2/27-18
D/B-2/28-35
D/B-2/28-36
D/B-2/28-37
A/B-2/26-07
A/B-2/26-08
A/B-2/26-09
: Result
160 |lg/g
100 Ug/g
110 Ug/g
140 Ug/g
130 U£/g
270 Jlg/g
150 Ug/g
200 Ug/g
86 Ug/g
:. Average ,
Concentration :
123.3ug/g
180.0 Jlg/g
145.3 Ug/g
       The quantity of mercury in the drum debris was calculated by multiplying the average of
the drum debris results by the weight of the debris in the drum. The weight of the drum debris
for the Mfg C device was 436 pounds that converts to 197766.3 grams.  The weight of the drum
debris for the Mfg A device was 466 pounds that converts to 211374 grams. The weight of the
drum debris of the Mfg B device was 331 pounds that converts to 150139.1 grams.  Based on
the drum debris analytical results and debris weight the quantity of mercury in the debris for each
device is:

   •   MfgC    28,735.4 mg
   *   Mfg A    26,062.4 mg
   •   MfgB    27,025.0 mg

       When these quantities are added into the table presenting all the mass balance quantities,
a large difference between the quantity of mercury processed Hgi and the quantity of mercury in
the drum debris is notable. Table 2 presents the results of the mass balance equation using the
values presented for Hgf, Hgu, and HgR.  Refer to Chapter 5 of the report for a description of
how the other quantities were derived.

                               Table 2: Mass Balance Results
Device j
MFGA
MFGB
MFGC
*. '• ';HgW
* • :' •*
2675.4 mg
2307.6 mg
2934.5 mg
:....;, -:Y \.:£ >-^Y-\IL J**^':-- ..;.'' 	 :: Y--...V: .' 	 .
Drum Debris
26,062.4 mg
27,025.0mg
28,735. 4 mg
pPre-filter
NA
12.45 mg
47.35 mg
HEPAfilter ,
2.659 mg
NA
0.029 mg
Carbon filter
1015.5 mg
7.3 mg
57.9 mg
Hgi
0.38 mg
0.41 mg
0.39 mg
       Upon reviewing results in Table 3 below, the amount of mercury recovered is
significantly greater than the calculated quantity of mercury processed in the study.
-------
                           Table 3: Percentage of Mercury Recovery
.Device ",.,„::>•
MFC A
MFGB
MFGC
' Hg Processed tHgl); 3 •"
2675.4 mg
2307.6 mg
2934.5 mg
Hg Recovered (HgU+HgR)
27080.8 mg
27045.0 mg
28841.0 mg
54 Recovery
1012.2 %
1172.0%
982.8 %
       Due to significant error in the results of the Mass Balance Analysis, the study team re-
evaluated the entire original mass balance study including the laboratory results to identify
discrepancies in the study to account for the errors when balancing the equation. Upon further
discussion with the laboratory it was discovered that the when preparing the drum debris sample
for analysis, only the "fines" were removed from the bulk sample for analysis. The "fines"
consisted of the fine phosphor powder and possibly the very small pieces of glass.  However, the
content of the drum debris samples also consisted of larger glass pieces and metal end caps,
which could also contain some of the unaccounted mercury and contributed mass to the
calculation of the total mercury concentration. In an effort to  obtain more accurate bulk sample
results and  account for mercury post crushing, the remainder of the original drum debris bulk
samples were analyzed and the results were combined with the results from the first analysis.

       The second analysis of the drum debris involved weighing the entire remaining content of
the samples and digesting the entire sample. The results from the original analysis and the
second analysis were combined mathematically and presented as ng/sample.  The weights in
grams from the original analysis and the second analysis were added together to get the total
weight of the drum debris bulk samples. The final reported results shown below in  Table 4, in
ug/g, are a  combination of the analytical results and the weights from the original and second
analyses. The following table presents the drum debris bulk sample  results from the second
analysis and shows a comparison to the original analysis.

                   Table 4: Drum Debris Bulk Sample Results (2nd Analysis)
Sample •*:--.-
A/B-2/26-07
A/B-2/26-08
A/B-2/26-09
R/B-2/27-16
R/B-2/27-17
R/B-2/27-18
D/B-2/28-35
D/B-2/28-36
D/B-2/28-37
^f'J^':J
MFGC
MFGC
MFGC
MFC A
MFGA
MFC A
MFGB
MFGB
MFGB
PCpmbined.Wt,^
74.8 g
56.6 g
95.2 g
72.9 g
79.2 g
86.4 g
67.7 g
85 .2 g
79.0 g
i'Cbfnscted^'it''- !
6.07 ug/g
5.58 ug/g
2.43 ug/g
5.84 ug/g
2.70 jig/g
2.57 ug/g
5.17ug/g
4.59 ug/g
5.56 ug/g
Original •/;.,. •••
Result •. •:"',, "'
150 ug/g
200 ug/g
86ugfe
160 ug/g
100 ug/g
110 ug/g
140 ug/g
! 130 ug/g
270 ug/g
% Difference
- 95.9 %
- 97.2-%
-97.2%
-96.4%
- 97.3 %
- 97.7 %
- 96.3 %
-96.5%
- 97.9 %
1. The combined weight presented in the table was reported in the final analytical report as measured by the
laboratory.

       Analyzing the results between the original analysis and the corrected analysis has
identified an approximate 96 % difference in the concentration of mercury in the drum debris
bulk samples. This significant change in values is due to the significant increase in sample
weight when the larger pieces of debris are included in the analysis. When the analysis included
only the "fines", where mercury is expected to be concentrated, it resulted in biased results and
increased the concentration.
-------
       Table 5 presents the recalculated quantity of mercury in the drums compared to the
original quantity:
                           Table 5: Re-calculated Mercury Amounts
, Device ; *
:. '' ' .- •• ' *>"- -
MFGC
MFC A
MFGB
'Total Weight Crushed Material
aii'
197,765 g
21 1,373 g
150,138 g
Total Mass of Hg
•••,, Corrected v
927.5 mg
782.1 mg
-767.2 mg
Total Mass of Hg
Orifiinal
28,735.3 mg
26,062.3 mg
27,024.8 mg
       The new drum debris results above are inputted into the mass balance table to replace the
original results. Refer to Chapter 5 of the report presents the mass balance study using the
correct drum debris bulk sample results.
-------
           Appendix H

Procedures for Collection of Samples
   From Pollution Control Media
-------
Samples were collected from the pollution control media for each device using
the following procedures:

Manufacturer A

•    The HEPA filter, located inside the filter canister, was accessed after the
     system had performed a filter purge where the device reverses the airflow
     to blow the collected particulates (purge) off the filter and back into the
     drum. Three bulk samples were collected from the filter by cutting
     approximately 100 cm2 portions per sample out of the filter using a razor
     knife. The samples were folded in half, with any bulk material on the
     inside, and placed into separate sample containers.

•    The top of the carbon filter canister was opened to access the carbon. The
     carbon filter consisted of three bags of carbon stacked on top of each other
     inside the canister. The top two bags were removed and opened. The
     carbon from each of the two bags was transferred to a separate generic
     plastic trash bag of sufficient size to accommodate its volume and each
     plastic bag of carbon was composited.  Three bulk samples of carbon
     (approximately three ounces per sample) were collected from the top
     carbon bag, and three bulk samples of carbon (approximately 3 ounces per
     sample) were collected from the middle carbon bag using a clean plastic
     spoon. The samples were placed in separate sample containers.

Manufacturer B

•    The pre-filter and carbon filter were all contained in a single cartridge. One
     bulk sample was collected from particulate contained in the pre-filter and
     placed in a sample container (there was only sufficient amount of
     particulate for one sample). Three carbon bulk samples (approximately two
     ounces per sample) were taken directly from the carbon container within
     the cartridge and placed into separate sample containers.

Maniuf acturer C

•    Three samples of bulk particulate were collected inside the filter bag using
     a clean plastic spoon and placed in separate sample containers.

•    The HEPA filter was removed, placed into a plastic Ziploc bag, and sealed.

*    The top of the carbon filter canister was removed to access the loose carbon.
     The carbon was transferred to a generic plastic trash bag of sufficient size to
     accommodate its volume. The carbon was composited inside the bag, and
-------
     three bulk samples (approximately three ounces per sample) were collected
     using a clean plastic spoon and placed in separate sample containers.

Manufacturer D

•    Three samples of bulk particulate were collected inside the filter bag using
     a clean plastic spoon and placed in separate sample containers.

•    The HEPA filter was removed, placed into a plastic Ziploc bag, and sealed.

•    The carbon filter bag was removed and cut open, and the carbon was
     transferred to a generic plastic trash bag of sufficient size to accommodate
     its volume. The carbon was composited in the bag, and three bulk samples
     (approximately three ounces per sample) were collected  Using a clean
     plastic spoon and placed in separate sample containers.
-------
-------
           Appendix I

   Letter from EPA Documenting
Problems with Manufacturer D Device
-------
UNITED 3STATI&fKN,VWOftMKjM i rAii?
                         REGION III
                       1650 Arch Street
             Philadelphia; Pennsylvania 19103-2029
                                                                         /s$j!SC!!*,i.
                                             May 8,2003
 Mr. Edward J. Domanico
 ThejHazardous Materials; Specialist, Inc
 3200'S. Andrews
 flauderdale, FL    ir •>

 Dear Mr. Domanico:

       The puipose of this letter is to document EPA'SLObseryatipns and provide Hazardous
 Material Specialist; Inc. (HMS) with-a copy of the sampling data collected during testing of the
 Hazardous Material Specialist Fluorescent Lamp Disposal and Mercury Vapor Recovery System
 in Ashland, Virginia on February 27|2003 and Phoenix, Arizori&6n March 26, 2003. The
 Equipment Validation Phase I andlReal World Testing tasks in the Mercury Lamps Drum Top
 Crushers (DTC) Study are designedlto evaluate how.efficiently ]&TC devices capture mercury
 vapors emitted while crushing fluorescent lamps. Airborne mercury samples were collected and
 measured per the Sampling and Study Plan and following the NIOSH analytical methods.
 Furthermore, two Jerome mercury vapor &alyzers; were employed to collect and measure real-
 time airborne concentrations. Once the data has been collected; the results of the two studies are
 reviewed and compared against published mercury exposure4units. The results from the DTC
 device study are compared against the Occupational Safety and Health Administration (OSHA)
 regulated Permissible Exposure L^^E^j^rimercuiy of 0.10 mg/m3, and the American
 Conerence for Governmental IndustraliHy                           Threshold Limit
                                         "
ValUs'(TLV) for mercury of 0.025 mg/m-/ ' '
       EPA detected elevated levels of mercury vapor during testing of the HMS machineloin
February 27,2003 during the Equipment Validation Phase I testing in Ashland, VA. Jerome
readings collected during the operation of the HMS device measured a continuous increase in
concentration that exceeded norninalilimits.  The operation of the HMS device was suspended
whence readings measured 0.44 mg/m3 (after crushing approximately 25- 30 bulbs) to allow for
the operator to put on respiratory protection/ Operation of the HMS device continued for
approximately 45 minutes, where readings increased to measurements of 0.89 mg/m3.  At this
time the study was concluded.  The HMS device exceeded the OSHA PEL within a short period
of time from the start of the operation. Note that when comparing the Jerome reading to the
analytical air sample measurements, the Jerome is providing real-time data at the specific point in
time. The analytical air sample measurements are collected over a period of time at specified
-------
 locations, and represent a timed average exposure concentration. This accounts for differences in
 the results between the Jerome and analytical air samples.

        Analysis of the analytical air sample results-indicate that the HMS device was not
 efficient in capturing and retainingimercury vapor£and?exceeded OSHA PEL and ACGffl TLV
 exposure limits.  Out of eight samples collected dunhgjthe operation of this device, one sample
 did not exceed the OSHA PEL, while the remaining seven samples did exceed the OSHA PEL
 (reference the "Ashland, VA AERC Facility Analyticii^ir Results February 2003" graph.)
       At the conclusion of the HMS machine test in Ashland, HMS requested that EPA ship the
 unit back to the HMS facility in Fort Lauderdale, Florida so an evaluation into the cause of the
 elevated mercury readings could be determined. The;iim't was returned to HMS during the week
 of March 10,2003.  EPA requested a written report detailing the cause of the elevated mercury
 emissions and confirmation of the adequacy of the repairs by conducting an analysis for mercury
 vapors by a qualified industrial hygienist. See attached e-mail from Mr. Tad Radzinski to Mr. Ed
'D6h|ahico outlintng'tm'i request dated March 7,2003* EPA had requested that HMS complete
Meslvaiuation and issue a report by March 17,2003. Howsver, due to shipping delays and
 problems reported by HMS in regard; to obtaining a^,erome mercury analyzer, EPA received a fax
 summary of "Findings on the Malfunctioning Bulb' Machine" bn; March 19,2003, followed by a
 written report (dated December 17, 2002) on the HMS;findings via fax on March 24,2003, and a
 fax of Jerome Mercury Analyzer results on March 22;<20to. The Jerome data provided by HMS
 indicated several readings on hose connections that exceeded the OSHA PEL after processing
 only 30 Samps as well as elevated mercury levels frbmlthe charcoal discharge.

         The HMS device that jmyed!tp|the Earth Protection Services Inc. facility: in Phoenix,
 Arizona on March 25, 2003 was damaged. The vacuum assembly had a large crack, which
 appeared to be either shipping damage, or damage that.pcbvured when the unit was packed by
 HMS for shipping.  The unit received in Phoenix; appeared^ be a redesigned model from the
 unitforiginally tested in Ashland, Virginia. The dmf-|este
-------
 i lie nazaruuuii ivuucuats
 exceeded the OSHA PEL after processing only 16 lamps (see attached "Phoenix, AZ EPSI
 F^HJty Jerome Hg Vapor Analyzer Direct Reading j\iryResults March 2003" graph and
 f Wioenix, AZ EPSI Facility Analytical Air Results March 2003" graph.)

  ,:  i   EPA recommends that HMS conduct an independent test of a machine that is identical to
 models that are in use in the field. This test should include processing of enough lamps to fill a
 drum in order to determine if the machine is operating in a manner to effectively control mercury
 emissions.  If elevated mercury levels are detected, then HMS will need to take appropriate
 action to correct the problem and notify al!'facilities that are utilizing this equipment as outlined
 in Item (4) of the HMS fax from Mr. Edward Domanicpto EPA (Subject: Findings on
 Malfunctioning Bulb Machine Tested in 1st EPA Validity Test") dated March 19,2003.
        Please contact me at 215-814i23S4jf ybu/haye any questions.
                                       Sincerely,
                                       Tad Radzmski, P.E.
                                       DTC-Device Study Project Manager
Attachments
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          Tad Radzinski •

          03/07/2003 10:01 AM
    To: hazmatspex@aol.coTi
    cc:
Subject: Return of Your Equipment and Next Steps
Ed,

As we discussed today I have made arrangements for AERC to ship your DTC unit back to you COO via
their freight company. When you receive the machine please evaluate to determine the cause of the
elevated mercury emissions from your machine during the testing in Ashland. VA on February 27, 2003. I
will need you to submit a written report to me with the results of your assessment.  Once the machine is
repaired you will need to test the machine including art analysis for mercury vapors using a Jerome or
other mercury monitoring device by a qualified industrial hygienist Please include the results of this test
with your written report. We are plann ng to conduct the next round of testing in Phoenix, AZ during the
week of March 24, 2003. I will need your report and testing rest Its as soon as possible but no later than
March 17 in order to confirm your cont nued particpation irt this study.

The contact for the Earth Protection Services Facility in Phoenix. AZ is Mr  John Chilcott and the shipping
address and phone are listed below:
10S.48th Ave., Suite#4
Phoenix, AZ 85063-3820
Phone: 800-414-0443 - Fax: 602-353-9285
http://www.earthpro.com/
Please let me know if you have any questions. For shipping questions please contact Mr. Tom Downing
of AERC at 804-798-9295.

Thank You,

Tad Radzinski
EPA Region III
Waste Minimization Team Leader
215-814-2394
-------
           THE  HAZARDOUS  MATERIALS SPECIALIST, INC.
                          ENVIRONWFNTAL IftAiHiHG, CONSULTING AND  COMPLIANCE
                                             * CRUISE  * MARINE
   December 17,2002
          Radzinski
   Waste Minimization TeaiJiCeader
   U.S. EPA Region 3
            Street
         phia, PA 19101-2029
  REF: Equipment Comparison Ph^se I- Sauiipl^ JRef^tts ofiTHMSl Bulb Crushing Unit

  Dear Tad,

  Pursuant to our conversations, J  apolpgiM-ifor'-ihft delay in providing you with this
  report,'However, there have been several obstacles we  have had to overcome.  First,
  our unit did not arrive back here until March 13* late in the day: This was 2 full weeks
  from the test date in Virginia; of February.; 27?, \OMe'-w tewaved the unit the problem
  was quickly  identified. However^ liningup the ;test^oved^ be another challenge
  because of the unavailability ;6fiM%6i^                         with trucking
  companies not guaranteeing ;arrival: timesthas :nT^;it:;aJtou.ghVweek. As you might
  recall, our unit  did inotiarrive :,n Virginia  until;;V hojir l*fore the test was to be
  performed. We landed at the airport when I phoned you  and )ybu said the unit had not
  even  arrived  yet and then it came in while  were on the phone.  Regardless of these
  obstacles, I am providing ^e following report for yoy and your colleagues to review,

  1)     At the Virginifete«ti5ifc,iiffcr ihitiaiiziiiglbitt unit;it ;was clear to Mike and I that
  something was wronj;;^^                        into the machine they were not
 ^iflgiwin  smoothly and Mike' determined mat ifie feeder tube was slightly bent.
 Apparently, this happened during shipping or unpacking.  Mike bent it back a little and
 the feeder tube performed more normally. It wasn't perfect but it was better. This kind
 of a crate for us was new and both feeder tubes will be secured in a stronger manner so
 ?this$oesn't happen again.

'ffl  ^Unnecessarily High Readings of Mercury. As you might recall, just prior to
 starting the test on bur unit you and your associates switched out the drum that came

-------
 Mtji.our unit. As explained by you, this was tpause we-had used our unit prior to
 shipping it and you needed a "clean" drum fbrittie teat. Id placing the unit on top of
 li|:hew!:driffiv we;arfcnat clear as to Aether or not the side bolts were tightened down
 sufficiently. We do not believe they were and I will-explain why.

        a)     When your initial readings were coming up high we could not understand
        why, especially based on other tests that we did independently. At the time of
        the first HEPA Filter change it became pbyious to us that something was wrong
        because the HEPA filter was almost "clean"  with no powder.  The bag was
        almost clean and light/Again, normally the bag would be  filled up, especially-
        after 150 bulbs and it would be fully expanded; \vtiicb it was not.             ;  :
       As you continued with the" 'test and- inercury levels rose, we were almost
       there was a vacuum or seallei&^uSe^              At that point,
       and as you might imagine, feeling; yery perplexed: Tad, I'm sure you realiie we
       spent a lot of time and money to participate in this  study and feel  it is  very
        *          .•'»'• .V  "!"ji; •' '"-'  -' •       *    ;»,..-. ; !'.; tf "i -,•-«          "r                  -f
       useful  and necessary. I  consider myself one of the  pioneers regarding this
                  .;••.•:••_; ..•,•'-••:., :KL; ,* '<.."           • •"-'.:•."" ..'.I I -'***, -•',- ' " /i ' , * "t ..... -,~*          *^     "^
       technology ii^makuigiit a "real world product" and in no way want you or  your
       management to think that think this malfunction represents our standards.

3)     Review of Unit Upon its Refarn .lO'Bbridajfori'Evatuation.. When the returned
cirate was opened we immediatejy; observed ^
       a)     The'side set jiolts were miwa^i.aiwl:-^6'^1-?^!^ on *e druirthad a
       good % " play in it. When the unit vvas tilted on its side,: it is our Fmding that it
       slipped off the upper seal that sits on .the rolled metal edge of the drum, This
       would cause aWacuum leak allowbgihc-iiniti to draw clean air allow mercury to
      Corrective Action; Replace and evenly; tighten Tunitfui lop of drum. Increase seal
      size width .a^toertojpjc^unlt that sitS:Orisdrim;;Eyea'if:Ui£^crew> were not put
      in it could not shifter (enough to split off the seat.

      In addition .-to- this, ^  we? .;.ft»L-thAty^:;.-(^iarcpal filter my  have somehow  tost
      connectionfto;l^;exhaust: c^                account for  the high readings at
                       ''   "   "'     ' "   '
      In addition to these •corrective. iUms^we.-ch'eckedi^ttr'^BM flow on the vacuum
      with and wiihout jttie HEPA filter. With the1 HEPA Filter removed, it is 55 cfm.
      With the HEPA Filter, in':place  it drops to: 3Q. cfta, This is considered normal.
      Also,  the  charcoal  filter  medium  is  the; EPA  recommended product  in
      accordance with EPA metn'odJ245^^eciaily; treated charcoal #580-13.
   Recieved  Time Mar-2*.-  10:03AH
-------
 We will provide you, by fax, late this afternoon, the field test results from our unit.
 "Also, it wiU be arrivingjin Phoenix on Monday act^ding to Delta Freight.

 If you-require any additional details please advise me accordingly,

                          - and best regards.
Edward J, Domanico
Senior Certified Hazardous Materials Maaager

cc: Mike Briiton
   Rscieved  Tine Mar.24.
                                                                               TOTAL P.05
-------
Hazardous Materials Specialist, Inc.
3200 S. Andrews Avenue
port Lauderdale, Florida
Mercury Testing
Test Location- Spray Booth
Test Run Quantity:          30 Bulbs
Sample Location           He fme/m3)
 Booth Background-
 GJbsircp»i Discharge-
 How (Connections:
     Charcoal Supply-
     Vacuum Ejthaust-
     Vacuum Suction-
.000
.20?
.062
Seals-
     Vacuum HostlrDrum- .070
                                                    EHE;Pro;ect # 03-023
                                                    Date:  March 22.2003
                                             Process
H
                                           'After 30 Bulbs Procsse
with 'Unit1 running
.000
.059
Testing Device:      Jertftiie^ Jl-X;M«rcury Analyzer
      ceiling level for MMCuTy!:isjp;Img/rn3.
-------
                   Appendix J

Peer Review of Mercury Lamp Drum-Top Crusher Study:
              Response to Comments
-------
Background

The universal waste regulations, set forth in 40 CFR 273, were formulated in order to ease the
regulatory burden associated with the collection of universal waste and to thereby facilitate the
entry of these hazardous wastes into the RCRA hazardous waste management system. The
original federal list of universal wastes included certain hazardous waste batteries, pesticides,
and mercury-containing thermostats. Hazardous waste fluorescent lamps were added to the
federal list of universal wastes on January 6,2000 (64 FR 36465). One of the issues raised
during the notice and comment period of this rulemaking was the use of Drum Top Crusher
(DTC) devices for lamp management. A DTC device fits over the top of a standard 55-gallon
drum and crushes the spent lamps into the drum. The DTC device is used to simplify handling
of the spent lamps by reducing their volume.
      *
At the time that hazardous waste lamps were added to the universal waste list, some states
already allowed the use of DTC devices. EPA provided some general guidance to states with
regard to the appropriate use of DTCs for lamp management (64 FR 36477) and determined that
further, more detailed information or guidance regarding the use of DTC devices needed to be
informed by an assessment of DTC device performance. Therefore, in 2003, EPA performed a
study assessing the performance of DTC devices.

EPA prepared a draft report for the DTC Device Study (the Study), Mercury Lamps Drum-Top
Crusher Study Report.  RTI International (RTI), under contract to EPA, arranged for an
independent review of the draft report, dated September 20,2004, by recognized technical
experts. This review was conducted by letter format in a manner consistent with EPA's Office
of Research and Development and Science Policy Council Peer Review Handbook (December,
2000). The peer review was sought so that EPA may benefit from additional viewpoints and
perspectives. Each reviewer certified that they had no actual or potential conflicts of interest;
therefore, these reviews provided impartial evaluations of the scientific information and study
findings. The following experts served as reviewers of the report:

       •  Carl Herbrandson, Ph.D., Minnesota Department of Health
       *  Steven Lindberg, PhD., Corporate Fellow Emeritus (retired)
          Environmental Sciences Division, Oak Ridge National Laboratory
       •  Michael McLinden, M.S., C.I.H., New Jersey Department of Environmental
          Protection

This report presents a compilation of the reviewers' verbatim comments on the draft report and
the Agency's responses to these comments. Many substantive comments were made by the
reviewers. As a result of these comments, EPA extensively revised the study report.  Many
sections of the report were rewritten, expanded upon, or moved in order to address the concerns
of the commenters and provide a clear, thorough discussion of the DTC Device Study. Because
of this extensive revision, several of the specific statements that the reviewers quoted and
commented on are not in the revised report. Agency responses to these comments explain why
the text was changed and addresses the substantive portions of the comments. The comments
and responses are grouped by subject and generally follow the order of the report.
-------
Comments Answering Questions Posed to the Reviewers by EPA

EPA posed the following specific questions to the reviewers:
1. General Design/Execution of the Study: Is the design and execution of the Study appropriate
  for evaluating the likely Hg releases from DTCs in use?
2. Laboratory Methods/QA/QC: Are the laboratory analytical methods and QA/QC procedures
  appropriate and adequate to generate reliable data?
3. General Results/Conclusions: Do the data generated by the Study support the conclusions
  presented in the report? If not, in what regard? Are other conclusions supported'by the data
  generated?
4. Effects of Temperature and Humidity: DTC operations were performed at three locations
  under temperature and humidity conditions'that varied at the different sites.  The report does
  not attempt to quantify the effects of temperature and humidity on mercury releases from DTC
  devices in operation. Are the data generated by the Study adequate to assess the impacts of
  temperature and humidity on Hg release from DTCs in operation?
5. Background Hg: The DTC Study was conducted at operating commercial lamp recycling
  facilities. As a result, background mercury levels in the areas of the Study were much higher
  than would be expected to occur in buildings that do not use Hg in routine operations.  How
  should the background levels of mercury be considered in assessing DTC releases of Hg?
6. Mass Balance Study: One portion of the Study consisted of a Mass Balance Study of mercury
  being put into the DTC devices, and the mercury released from the devices (Chapter 5).
  Estimated recoveries ranged from 34% to 67%. A number of possible reasons for the low
  recovery rates are discussed in the report. Do the sources of error described in the report
  adequately address the low recoveries? Are other sources of error plausible (and should be
  considered in any subsequent Mass Balance Study)?
7. Operator Observations: Are the operator observations presented in chapters 6 and 7
  appropriate?
8. Study Limitations: Does the discussion of study limitations (Chapter 8)  identify all important
  weaknesses in the Study not elsewhere identified in the report?
The reviewers' answers and the corresponding responses are presented below.

/. General Design/Execution of the Study: Is the design and execution of the Study appropriate
  for evaluating the likely Hg releases from DTCs in use?

   Carl Herbrandson's Comment: Mercury emissions from DTCs, as mass of mercury released
   or as a fraction of mercury released from each fluorescent bulb, were not characterized in this
   study. The study was not designed appropriately for evaluating likely mercury releases
   during DTC use. The study measured containment area air concentrations, which was also
   an objective of the study. "The objective of the project was to evaluate the performance of
   the DTC devices in terms of mercury emissions and potential for worker exposure to adverse
   levels of mercury releases due to the operation of these devices." The potential for worker
   exposure to adverse levels of mercury releases due to operation of DTCs was effectively
   evaluated.
-------
Response: EPA agrees that mercury emissions from DTCs in use were not measured in this
Study. The discussion presented in this report has been modified to more clearly state that
the Study was designed to evaluate DTC device performance in terms of worker exposure.

Steven Lindberg's Comment: No. The study was flawed, resulting in serious contamination
which makes it difficult to quantify actual Hg releases.

Response: Mercury releases from DTC devices were not quantified in the Study. The Study
was.designed to evaluate mercury exposures that could result from the use of DTC devices
and changes in mercury exposure over time. The data collected during the Study provide
information about which activities involved in DTC device operation are associated with the
highest mercury exposure and about how devices perform over time, in terms of their ability
to prevent mercury exposure.  Contamination, due to mercury present in the testing
environment, was an issue. The limitations due to background mercury are discussed in
Chapter 6 of the revised report, and background air sampling data (Jerome analyzer readings
and analytical air samples) are presented in Chapter 4 of the  revised report.

Steven Lindberg's Comment: Statements made in Section 7 suggest that the design was
compromised to decrease costs of the study.

Response: The reviewer did not specify what statements in Section 7 suggest that cost
concerns caused the study team to compromise the study design.  However, one of the major
concerns expressed was that the testing was conducted at lamp recycling facilities and thus,
high background concentrations of mercury were present.  (See next comment and response
for specific response to this concern.)  In addition, the study  team made many ad hoc
decisions in response to data that was collected during the early phases of the Study. A .
thorough review of the original study design by researchers more experienced in mercury
sampling would most likely have  lead to an improved study design.  As with any large-scale
study, cost and time considerations were important because inattention to these constraints
(i.e., planning more sampling than could be completed in the amount of time allotted for a
given test) would have made it difficult or impossible to complete the Study.  However, the
primary concern in designing the DTC Device Study was to  assess the performance of the
four DTC devices tested, and concerns about the cost of the testing were secondary to
completing the objectives of the Study.

Steven Lindberg's Comment: The notion that these devices  might be used at major existing
recycling facilities seems poor justification for the chosen sampling locations. My
experience in seeing these devices in the field is that they are used primarily at small to
moderate-sized generators of used bulbs, such as small industries and hospitals.

Response: There were several reasons why lamp recycling facilities  were used as the sites for
the Study. Not all of these reasons were clearly explained in the draft study report. The .
revised report includes the following, more detailed explanation as to.why the Study was
conducted at lamp recycling facilities:
       •  These facilities possessed the appropriate permits to process mercury-containing
          fluorescent lamps.
-------
       •  These facilities had ample supplies of lamps that were provided at no cost to the study
          team.
       •  The facilities had the capacity to process and dispose of the drums of lamp debris, with
          no shipping, manifesting, or disposal arrangement required of the study team.
       The study team made every effort to isolate the study area from normal lamp processing
       operations.                                                       (pg. 78)

The study team considered other locations for the Study. However, some states require
permits for the operation of a DTC device, and it was not feasible to obtain state permits
within the timeframe of the Study.

The containment structure used for testing the DTC devices was constructed in order to
simulate field conditions for DTC use by creating a small, confined space, similar to a boiler
room or janitor's closet. The containment structure was also intended to isolate the test area
from the rest of the lamp recycling facility, as best as possible.  .

Steven Lindberg's Comment: Perhaps the only questions these data could answer are "Do
the tested DTC's have serious operating problems [yes], and do they capture all of the Hg
from the feed lamps [no]?"

Response: EPA agrees that the data collected for this report should primarily be used to
answer qualitative questions. The purpose of this Study was to provide information
regarding possible worker exposures due to DTC device use. The agency believes that there
are many insights that can be gained from the data collected in the Study. Chapter 7 of the
revised report discusses the study results.

Laboratory Methods/OA/OC: Are the laboratory analytical methods and QA/QC procedures
appropriate and adequate to generate reliable data?

Carl Herbmndson's Comment: Generally, yes. The use of a realtime monitor (Jerome) also
provided supporting confirmation of the analytical results.  The effectiveness of the MCE
filters, as the first stage of the sample collection train, to capture and retain aerosol Hg could
be suspect and was not demonstrated.

Response: The effectiveness of the mixed cellulose ester (MCE) filters is discussed at the
beginning of Chapter 4 of the revised report. It is possible that the MCE filters were not
effective for capturing aerosol mercury; however, the total amount of mercury in the air
sampled was effectively measured because any aerosol that was not captured in the MCE
filter was captured by the Hydrar tubes (the second stage in the sample collection train).

CarlHerbrandson's Comment: Jang et al., 2005 shows an HC1 / nitric acid solution
removes a maximum of 36% of the Hg from bulb waste. Therefore, the effectiveness of the
methods employed in this study to measure the amount of Hg in spent bulbs should be
confirmed.

Response: In the revised report, a reference to Jang et al., 2005 is included in the section
describing the extraction (in Chapter 5). Additionally, the need for a valid laboratory method
-------
for quantifying the amount of mercury in spent lamps, with appropriate QA/QC procedures,
is suggested in Section .7.4 as an area where further work is needed.

Steven Lindberg's Comment:  In 3 decades of working with Hg I have never heard of
Hydrar solid sorbent tubes. This does not mean they are unacceptable, but in the absence of
strenuous QA tests, I was unable to verify the validity of data generated by this approach.
My group has sampled Hg at levels in air and solids from background (pg of Hg) to highly
enriched (mg of Hg), and or approaches have involved various sorbent traps (activated
iodated C, gold), automated instruments (Jerome, Tekran, Lumex) and chemical extraction
methods (such as for methylmercury).  I found no QA testing of these tubes that provided
any evidence of their ability to quantitatively collect Hg under conditions encountered.  I
would describe the methods as less than adequate (Appendix D titled Data Chem Methods
was blank in my copy).

Response:  According to OSHA's Occupation Safety and Health Guideline for Mercury
Vapor, which can be found at
hto://www.osha.gov/SLTC/healthguidelines/niercuryvapor/recognition.html. "Determination
of a worker's exposure to airborne mercury vapor is made using a Hydrar or Hopcalite tube
(200 mg section), SKC brand with a prefilter/cassette." (The prefilter used in the Study was
a mixed cellulose ester filter.)  In addition to the OSHA guideline, Hydrar tubes are an
acceptable medium for sampling mercury vapor in an industrial setting according to the
National Institute for Occupational Safety and Health (NIOSH [1994]. NIOSH manual of
analytical methods, 4th ed. Cincinnati, OH: U.S. Department of Health and Human Services,
Public Health Service, Centers for Disease Control  and Prevention, National Institute for
Occupational Safety and Health, DHHS (NIOSH) Publication No. 94-113.).

Steven Lindberg's Comment:  I was surprised that  readily available, widely used and
accepted methods were not employed.  Although the Lumex data could have been very
valuable, the users seemed to have encountered several problems deploying this instrument,
which many others have used successfully.                                     "•

Response:  EPA agrees that the Lumex data would  have been very valuable. The study team
attempted to record data with the Lumex but was unable to do so because the instrument was
not functioning properly.

Steven Lindberg's Comment:  The Jerome is a valuable instrument when properly used.
However, there seemed to be no serious attempt to perform a sampling or analytical
intercomparison between these two methods (see comment on Section 4 below). This would
have proved useful in evaluating the Hydrar method.  Also, the most interesting Jerome data
were relegated to the Appendices and the trends not discussed (see below).

Response:  The study team found that the Jerome data were valuable, and EPA agrees with
the reviewer that the importance of the Jerome data was understated in the draft report.
Unfortunately, because of problems with the data loggers, there were not enough Jerome data
for each device at each location to perform any rigorous statistical analyses.  The revised
report highlights the Jerome data. Also, averages of the Jerome data and the analytical air
-------
sample (Hydrar tube) data were graphed together to better facilitate comparison of the results
from the two air sampling methods; these graphs are in .Appendix A, Figures 26,35 and 43,
of the revised report.                                              '

Steven Lindberg's Comment: The supplied raw analytical data tables suggested that up to
half of the samples were below detection. This seemed odd given the enriched background
under which the study was performed.
Also, I noted that the detection limits seem to have varied by over an order of magnitude
(<0.1 to <1.1 ug) which is worrisome.

Response:  Aside from the blank Hydrar tube samples, the samples that were below the
detection limit were the MCE filter samples. The report was revised to highlight the fact that
the majority of the MCE filter results were below the detection limit. (See earlier comment
and response under "Laboratory Methods/QA/QC" for specific response to this concern.)
The actual detection limits were based on the actual sampling media (0.1 ng per Hydrar tube
or MCE filter). The "less than" values in the raw data tables vary because the total volume
of air sample varied for each MCE filter/Hydrar tube. The units used for the final reporting
value reported were mg/m3, so the volume of air affected the "less than" value for each
individual sample.

General Results/Conclusion^: Do the data generated by the Study support the conclusions
presented in the report?  If not, in what regard? Are other conclusions supported by the data
generated?

CarlHerbrandson's Comment: Generally, the data supported the results and the
conclusions of the report. With the following exceptions:
•   There is no analysis of data' showing that Manufacturer A's device performed better than
    the other devices in the PVS. While data from Phase 2 suggests this to be true, data from
    Phase 1 are equivocal.
•   Data available are not sufficient to allow a mass balance calculation. Therefore,
    mentioning "a large fraction unaccounted for" may be misleading.

Response:  An analysis was performed to support the assertion that there was a decrease in
the performance of the devices from Manufacturer B and C but not the device from
Manufacturer A. This is discussed in Chapter 4 of the revised report.

EPA agrees with the commenter regarding the Mass Balance Conclusions so the report was
revised to eliminate the Conclusions section. The Mass Balance Study discussion was
revised so that no definitive statements based on the data were made. Instead, the problems  s
with the Mass Balance Study were presented along with the data so that this information
could be used by future researchers.

Steven Lindberg's Comment: It would be difficult to draw any quantitative conclusions
from the data presented in the report.
-------
Response: EPA agrees, and thus, the conclusions presented in the report are primarily
qualitative.
               i
Effects of Temperature and Humidity: DTC operations were performed at three locations
under temperature and humidity conditions that varied at the different sites.  The report does
not attempt to quantify the effects of temperature and humidity on mercury releases from
DTC devices in operation. Are the data generated by the Study adequate to assess the
impacts of temperature and humidity on Hg release from DTCs in operation?

CarlHerbrandson's Comment: NO. There are too many variables. Differences between
sites include: building configurations, proximity to industrial crushers, air currents within the
buildings, potential changes in DTCs as a result of shipping, as well as seal leakage, and
potential maintenance issues could also omfound a relationship. Differences between PVS
phases 1 and 2 in Virginia may show a temperature/humidity effect, and some site related
variables may be controlled, but showing a.relationship between temperature/humidity and
emissions would require showing that differences are outside any expected variability (i.e.,
multiple tests would be needed, at different times, and with cold temperature tests both
before and after warm temperature tests).

Steven Lindberg's Comment: No, the data are not adequate.  This question required a
systematic approach under controlled conditions.

Michael McLinden's Comment: I expect temperature would directly influence the amount
of mercury released from  crushed/broken lamps as well as the amount escaping from the
DTC devices, higher temperatures would volatilize more mercury. As for relative humidity,
my guess is that since mercury is thirteen times as dense as water, it would not have a
significant affect on mercury volatilization. As for your question "Are the data generated by
the study adequate to assess the impacts of temperature and humidity on Hg release from
DTCs in operation?" It may be helpful to graph results of a particular sampling location
(e.g., all area air sample taken at feed tube) for all three Extended Field Tests.  You could
then compare the graph with ambient air temperatures to see if temperature affected the
results.             •

Response: The Study was not designed to evaluate the effects of temperature on the
measured mercury concentrations. After the Study began, the study team recognized that
ambient temperature could significantly impact the amount of mercury that volatilized when
the lamps were crushed, so temperature data was collected. The peer reviewers were
specifically asked to comment on the adequacy of the temperature and humidity data for the
purposes of assessing any possible effects that environmental conditions may have had oh the
results of the Study. Based on the comments made by the reviewers, no attempt was made to
assess the impacts of temperature and humidity on DTC performance  in the revised report.

Background Hg: The DTC Study^ was conducted at operating commercial lamp recycling
facilities. As a result,  background mercury levels in the areas of the Study were much higher
than would be expected to occur in buildings that do not use Hg in routine operations. How
should the background levels of mercury be considered in assessing DTC releases ofHg?
-------
 CarlHerbrandson's Comment: High background mercury in the testing areas was handled
 properly in the report: background Hg was recorded and reported. Certainly if longterm
 testing had occurred in a pristine setting, wipe samples could have provided some useful data
 about the potential for DTCs to contaminate work areas. However, it is not clear how the
 background concentrations may have impacted the mercury vapor data acquired during the
 reported experiments. Background mercury vapor concentrations could be subtracted from
 the test data, but this would have required substantial data supporting the use of specific
 background concentrations.

 Response: In the revised report, more complete background data are presented in the results
 section (Section 4.2). The background air sample data was compared to the air samples
 taken during testing to show that the mercury concentrations measured during testing were
 significantly higher than the background levels at each facility.

 Carl Herbrandson's Comment: Data from Jerome #2 is not shown in the figures. As noted
 in the report, air leaks and exchanges occurred whenever the bay doors at the testing facilities
 were open. The readings from Jerome #2 could provide useful information for evaluating the
 variability of background mercury vapor concentrations.

 Response: EPA agrees that the data from the Jerome Mercury Vapor Analyzer that was used
 'to sample the air outside the containment structure during testing would have enhanced the
 analysis and discussion of the background data. Unfortunately, due to problems with the
 Jerome data loggers, the real-time background data is not available.

 Carl Herbrandson's Comment: The report should note that the background concentrations
 in locations at some distance from the 'industrial' crushers suggest that exposures near
 operating industrial crushers may be above levels of concern for the general public; and that
 Hg contamination on floors near the containment areas suggests that tracking of mercury
 from facilities like these may be significant.

 Response: The potential for exposure to the general public is discussed in Chapter 7 and
 several other sections of the revised report. The Study was not designed to measure possible
. migration of mercury off site from the lamp recycling facilities, so the report does not make
 any statement about the possibility of significant amounts of mercury being released due to
 tracking from the facilities.

 Steven Lindberg's Comment: The decision to perform these tests under the chosen
 conditions represents a fatal flaw in this study. The problems of such serious contamination
 cannot be overcome without a revised study design. Since the background was never
 adequately controlled, or even quantified (too  few samples, too much variability); I don't see
 how any quantitative conclusions can be drawn from the study as designed and performed.

 Response: As stated above, there were many reasons that the lamp recycling facilities were
 chosen as the sites for this Study. EPA agrees that the background mercury is a  serious
 confounding factor in the Study, and the  majority of the conclusions drawn in the report are
-------
qualitative. In response to the reviewers' concerns about the low number of background
samples, a more thorough presentation of all available background mercury samples measured
using the Hydrar tubes and using the Jerome Mercury Vapor Analyzer is included in the
results section (Chapter 4) of the revised report, and the chapter about limitations (Chapter 6)
discusses several ways in which the background samples may bias the results.

Mass Balance Study: One portion of the Study consisted of a Mass Balance Study of mercury
being put into the DTC devices, and the mercury released from the devices (Chapter 5).
Estimated recoveries ranged from 34% to 67%. A number of possible reasons for the low
recovery rates are discussed in the report.  Do the sources of error described in the report
adequately address the low recoveries? Are other sources of error plausible (and should be
considered in any subsequent Mass Balance Study)?

Carl Herbrandson's Comment: Calculations and estimates used in the "mass balance"
should not be reported. Instead, for the benefit of future investigators, the problems with
attempting to show a mass balance with the available data should be detailed. Other potential
sources of mass balance loss are described in accompanying comments.

Steven Lindberg's Comment: Considering all  of the assumptions, analytical errors, and
background problems, I would not accept that even the stated range of recoveries is accurate.
Given the analytical and sampling errors, and the flawed design, it is not surprising that
correction factors as large as 95% were applied in an attempt to close the mass balance. It is
never explained why there was no attempt to quantify the losses based on the air
concentration data.                                                  .               '

Response: EPA agrees that the uncertainty in the Mass Balance Study is too high to estimate
the different fractions of mercury.  The discussion of the Mass Balance Study was revised to
present the data collected, the calculations, and the problems encountered. The air
concentration data was used to calculate the amount of mercury released; however, there was
a significant mass of mercury unaccounted for.

Operator Observations: Are the operator observations presented in chapters 6 and 7
appropriate?

Carl Herbrandson >s Comment:, Yes. Inclusion of operator observations can provide
important subjective information and insight.                                   -

Steven Lindberg's Comment: These were possibly the most useful contribution.  The DTC's
as a whole seemed poorly designed, and the problems encountered were not surprising. The
safety suggestions offered are valuable, although several were also noted in the
manufacturer's guidelines. It is interesting to note that these manuals contained
misinformation concerning Hg.              '

Response: The operator observations are included in Chapter 7 of the revised report.   .
                                        10
-------
Study Limitations: Does the discussion of study limitations (Chapter 8) identify all important
•weaknesses in the Study not elsewhere identified in the report?        <

Carl Herbrandson's Comment: Additional study limitations are discussed in the
accompanying comments.

Steven Lindberg's Comment: In general, the major limitations were noted, but several more
could be listed, as noted both above and below.

Response: The study limitations are discussed in Chapter 6 of the revised report. EPA has
responded to all comments in this document.
                                       11
-------
Additional Comments of Peer Reviewers and Agency Responses
The additional comments provided by the reviewers follow. General comments are presented
first, and specific comments are organized to follow the order of the report.

General Comments                                                       .      :

   Carle Herbrandson's Comments: This study was a very good initial study of DTCs. The
   study showed operator exposures to mercury vapor may regularly be above the TLV (for the
   duration of operation) and often above the PEL. Adverse health effects are consistently seen
   in studies of workers exposed at the TLV (0.025 mg/iro for 8-hour day).  Therefore as a
   scientist in the field of public health, I would recommend to my state environmental agency
   that additional study should be conducted prior to allowing the use of DTCs. These studies
   should answer the following questions:
   a.  Can contamination accumulate in areas where DTCs are used? Can this contamination be
       tracked? Is there a need to establish decontamination areas and procedures for operators?
   b.  Can the circumstances of use of DTCs be controlled so that the general public is not
       exposed to potentially hazardous levels of mercury?
   c.  What fraction of the mercury in a fluorescent bulb is emitted from DTCs, in all phases of
       operation?
   d.  Are there regulations that will ensure control and proper disposal of full drums?
   e.  How do emissions from currently operated 'industrial' recycling processors and DTC
       emissions compare? Can the use of DTCs reduce the overall emissions from spent
       fluorescent bulbs to the environment?
   f.  Can we objectively evaluate the apparent tradeoff between potential decreased
       environmental emissions and the potential for significant exposures to more individuals -
       individuals exposed to emissions or contamination associated with DTCs?  .
   I would hope that, without answers to the above questions, DTC usage does not increase.

   Response:  The questions posed by the reviewer are excellent research questions. While the
   Agency is not suggesting that DTC devices not be used until these questions are answered,
   EPA agrees that regulators should carefully consider the possible effects to human health and
   the environment that would come from allowing the use of DTC devices. This then can be
   compared to continuing to have the majority of mercury containing fluorescent lamps
   disposed of in MSW landfills.

   Carle Herbrandson's Comments: The order of presentation of data on DTC devices in all
   tables and figures should be A, B, C, D.  Data are always more confusing when they are listed
   in different order in different places. If the actual sampling order was different than the
   reporting order (A,B,C,D), then the sampling order should be  noted in table/figure footnotes.

   Response:  The presentation of the data  has been changed to A, B, C, D order.

   Carle Herbrandson's Comments: Pg 92 last line-there is no section 3.6.2.1.

   MichaelMcLinden's Comment: There is no Section 3.7, perhaps it should read Section
   3.5.2.1. There is no section 3.9.1.
                                          12
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   Response; All references within the report were checked and revised to ensure that they
   were correct.

   Steven Lindberg's Comments: Although the nature of this project led to moderately difficult
   objectives, they should have been achievable by an experienced research group with
   sufficient planning.  In my opinion, this project and the report do not meet the stated
   objectives. The primary reasons relate to the apparent inexperience of the project team in
   working with Hg and an inability to anticipate potential problems.  Detailed comments
   follow the questions below.

   Response: While some objectives of the Study were not met, the data collected in this Study
   provide valuable information to regulators and users of DTC devices. EPA agrees however,
   that a more thorough review of the sampling and study plan by researchers more experienced
   with mercury monitoring would have been beneficial to the study team to avoid some of the
   problems encountered during the Study.

Executive Summary

Note to the reader: The Executive Summary that was included in the draft report given to the
reviewers was extensively revised. The Executive Summary in the revised report provides the
reader with the background of the Study and the results of the Study, in a concise form. Many of
the comments made by the reviewers are not directly relevant to the revised report; however,
responses to the concerns raised by these comments are provided below.

   CarlHerbrandson's Comment: The executive summary introduction says that the use of
   DTCs "will likely increase." This will certainly be true, in the absence of regulatory action.
   Does this report assume that there will be no regulatory action taken? Or that additional
   testing will not occur before DTC-use increases?

   Response: EPA is not proposing any changes in regulations; the purpose of this Study was
   to provide information about the use of DTC devices.  The statement that DTC use "will
   likely increase" is no longer in the Executive Summary.  The issue of the use of DTC devices
   was discussed in the final notice for the addition of hazardous waste lamps to the federal list
   of universal waste (64 FR 36477).  Authorized state programs have the authority to make
   regulatory decisions about the use of DTC devices as part of their universal waste
   management programs.

   Carle Herbrandson's Comment:  Pg 5 (TLV) of 0.25  mg/m3 - - should read 0.025 mg/m3

   Response:  The TLV listed in the Executive Summary now reads 0.025 mg/m3.

   Carl Herbrandson's Comment: The conclusions and  recommendations section of the
   Executive Summary includes the statement that "Additional recommendations for
   engineering controls, PPE, equipment isolation, and worker medical monitoring may apply in
   site-specific situations." Does this suggest a  different level of regulation than is typically seen
                                          13
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in Haz Waste regulations? Are equipment isolation, PPE, .. .controls EPA wants to,
recommend only at certain sites?

Response:  EPA is not proposing any changes in regulations; the purpose of this Study was
to provide information about the use of DTC devices. The statement quoted by the reviewer,
which is no longer in the Executive Summary, reflects the fact that EPA expects that there
will be a broad range of conditions under which DTC devices will be used.  The members of
the operator and operator's assistant wore Tyvek® coveralls, Kevlar® gloves, safety glasses,
and, at times, full-face respirators while conducting the Study.

Michael McLinden's Comment:
   Report Text:
   The Manufacturer D device was removed from the study after the second round of testing
   due to its inability to control mercury emissions below Occupational Health and Safety
   Administration (OSHA) and the American Council of Governmental and Industrial
   Hygienists (ACGIH) standards.
   Comment (Suggested Text Changes Highlighted): The Manufacturer D device was
   removed from the study after the second Around of testing due to its inability to control
   mercury emissions below ^||y5^^ilPJrf^;^il^iSffl Administration (OSHA) and
   the American filling                          Hygienists (ACGIH) standards.
Response: The correction suggested in the above comment was made in the revised report.

Steven Lindberg's Comment: The accuracy and precision of the data are never mentioned.
There seems to be a lack of any serious attempt to reproduce these results, and no replicates
are discussed.

Response: There is no longer a discussion of the data in the Executive Summary. The study
design did not call for replicate testing because one of the basic assumptions of the Study was
that there would be changes in device performance over time. Multiple air samples were
collected during each test. The variability between air samples collected for each device
during a specific testing event were used to determine the variance associated with the
measured mercury concentrations.                                   •

Steven Lindberg's Comment: Phrases suggesting that emissions were measured are
inaccurate. There were no measurements of emissions performed in this Study, only
estimates made, based on concentration data.

Response: The report has been revised to make it clear that emissions were not measured.
The concentrations near the feed tube and exhaust port were measured.

Michael McLinden's Comment: Although this is a good recommendation [medical
monitoring program for device operators}, OSHA does not require specific biological
monitoring in order to use respiratory protection, only a questionaire and/or physical exam. I
agree that respiratory protection should be used, however based on established industrial
hygiene hierarchy to control workplace contaminants respiratory protection would be
                                       14
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    recommended only after engineering and administrative controls were explored. Engineering
    controls should be instituted first in order to reduce employee exposure below the PEL. If
    engineering controls are not feasible (and I believe they would be feasible in this case) then
    administrative controls would be explored. Repiratory protection is used as a last resort or
    while instituting engineering controls.

    Response: These recommendations are not in the Executive Summary, but some of the
    issues are discussed in Chapter 7 of the revised report. The revised report mentions the
    established.industrial hygiene hierarchy (Chapter 7).

    MichaelMcLinden's Comment: In order for an air purifying respirator to work (and be
    certified by NIOSH) it must have adequate warning properties to indicate when the
    filter/cartridge has reached break-through. Mercury cartridges do not have adequate warning
    properties; however, some manufacturers (e.g., MSA mersorb cartridge) have received
    approval for cartridges equipped with an end of service life indicator (ESLI) so employee can
    check for break through.  Special SOPs (e.g., wearing a belt-mounted cartridge so employee
    can see the ESLI, or providing mirrors so a worker could see ESLI on his full-face APR)
    would have to be developed for using APR with Hg.

    Response: This fact was not addressed in the revised report; however, EPA will consider
    this point in drafting additional guidance.

Scope of Study

    Carl Herbrandson 's Comment: The study objective was to evaluate the performance of
    DTCs with respect to potential mercury emissions and potential exposures to workers
    operating DTGs. The study does provide useful data and information on the potential
    exposures to DTC operators. However, mercury emissions from DTCs, as mass of mercury
    released or as a fraction of mercury released from each fluorescent bulb, were riot
    characterized in this study.

    Response: EPA agrees that the Study was designed to assess worker exposure due to
    operation of DTC devices and not to measure mercury emissions. The revised report reflects
    this point - that is, the fact that mercury emissions from DTC devices were not characterized
    in this Study.

    Steven Lindberghs Comment: Several design decisions mentioned in this section are hard to
    reconcile with an assumed experience of working with environmental or occupational levels
    of Hg. The decision to  locate the study at recycling facilities is surprising and suggests a lack
    of understanding of (or experience with) the behavior of elemental Hg vapor. It's surprising
    that someone didn't realize the impact of this decision sooner.

    Response: There were several reasons why lamp recycling facilities were used as the sites for
    the Study.  Not all of these reasons were clearly explained in the draft study report.  The
    revised  report includes the following, more detailed explanation as to why the Study was
    conducted at lamp recycling facilities:
                                           15
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          •  These facilities possessed the appropriate permits to process mercury-containing
             fluorescent lamps.
          •  These facilities had ample supplies of lamps that were provided at no cost to the study
             team.
          •  The facilities had the capacity to process and dispose of the drums of lamp debris, with
             no shipping, manifesting, or disposal arrangement required of the study team.
             The study team made every effort to isolate the study area from normal lamp processing
             operations.      •                          •     ,        .             (pg. 78)

   The study team considered other locations for the Study; however, it was not feasible to
   obtain permits for each site within the timeframe of the Study. The most important reason
   for using the lamp recycler facilities for the Study was the fact that they had permits for lamp
   crushing.

   The containment structure used for testing the DTC devices was constructed in order to
   simulate field conditions for DTC use by creating a small, confined space, similar to a boiler
   room or janitor's closet, and also to isolate the test area from the rest of the lamp recycling
   facility.                              .    .      .

   EPA also agrees that future studies conducted in a testing environment with very low
   background mercury levels, involving the measurement of emissions, would be helpful in
   evaluating the effectiveness of DTC devices.

Data Collection Methodology

   MichaelMcLinden's Comment: Which model, Jerome-411  or newer model?

   Response: The model for the Jerome was 431-X.  This  information is included in the revised
   report.

   Michael McLinden's Comment: Were any background samples collected at the end of the
   week to determine if background Hg levels had risen during the week due to normal facility
   processing-of lamps?  It may be possible that background levels on Monday are lower than
   Friday levels if the facility is shut down for the weekend.

   Response: Background samples were not specifically taken at any point after the first day at
   each facility. However, during EFT #2, EFT #3, and PVS-II, one overnight air sample was
   taken outside of the containment structure after each day of testing. These air-sample results
   are presented Table 4.1 and Table 4.2 in the revised report along with the other background
   sample data and the Jerome background sample data that was manually recorded throughout
   the Study. Based on this limited sampling, there was no observable trend indicating an
   increase in background concentrations throughout the week.

   CarlHerbrandson's Comment: Table 3.1 is poorly designed - not very understandable.

   Response: Table 3.1 in the draft report described the types of analytical air samples that
   were taken during each portion of the Study. This table has been replaced by four distinct
                                           16
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tables - Tables 3.1, 3.2, 3.3, and 3.4 - in the revised report, which describe the samples for
each portion of the Study (the Performance Validation Study, Extended Field Test #1,
Extended Field Test #2 and #3, and "U"-tube Test).

CarlHerbrandson's Comment: Last sentence on page 26 - not clear. 2 samples "in
sequence, for a total duration of 4 minutes per sample." Does that mean a total duration of 8
minutes?

Steven Lindberghs Comment: The intent of ceiling  samples was never clearly described, but
they seem to be interpreted as representative of maximum exposure. Why?

Response: The description of the ceiling samples that were described on page 26 of the draft
report was clarified in the final report. The original  description was:

    Short-term ceiling samples were air samples collected over a short duration in time (for this study
    the sample period was 12 minutes) in order to evaluate the airborne concentration at a specific
    time. These samples were collected to attempt to quantify airborne concentrations at the
    estimated time of maximum exposure determined to be during the drum changes. Readings
    taken on the Jerome Mercury Vapor Analyzer indicated that maximum exposure conditions most
    probably occurred during drum changes.  Thus, the ceiling samples were collected during one of
    the drum changes for each device. Two samples were collected on the operator's shoulder, in
    sequence, for a total duration of four minutes per sample.

The revised description is:

    The ceiling samples were another set of personal air samples, which were collected to attempt to
    quantify airborne mercury concentrations at the estimated time of maximum exposure. Readings
    taken on the Jerome analyzer indicated that maximum exposure conditions most probably
    occurred during drum changes. Thus, the ceiling samples were collected during one of the drum
    changes for each device during PVS-Phase II, EFT #2, and EFT #3.  Two samples were collected
    on the operator's shoulder, in sequence; each ceiling sample was collected for 4 minutes, {pg. 18)

    ***

    Short-term ceiling air samples were introduced into the Study during this round of testing. As
    described above, ceiling samples were air samples collected over a short duration in time in an
    attempt to quantify airborne concentrations at the estimated time of maximum exposure.

    Readings taken on the Jerome analyzer indicated that maximum exposure conditions most
    probably occurred during drum changes.  Drum change sample results from EFT #1 showed that
    the ambient concentration of mercury is sufficiently high during drum changes such that the
    samples did not need to be 12 minutes in order to exceed detection limits. Thus, two short-term,
    personal air samples  were collected in sequence during one of the drum changes for each device.
    The sampling time was four minutes per sample, for a total duration of eight minutes.   {pg. 21)

Steven Lindberg's Comment: The decision to cut the plastic on the floor was a fatal flaw.

Response: The study team attempted to rectify the problem with the contaminated wipes
samples. Because many of the pre-test wipe results were higher than the post-test wipe
                                         17
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results, the wipe sample data were not used in the report and were only included in the
Appendix. Later, the plastic was cut outside in the parking lot; however, the number of pre-
wipe samples exhibiting high amounts of mercury did not decrease.

Steven Lindberg's Comment: The Lumex was "written off' with a brief comment regarding
inoperability. Were any attempts made to rectify the problems?

Response: EPA agrees that the real-time data would have been an asset to the Study;
however, although the study team attempted to correct the problems with the Lumex, the
device obtained for the Study did not operate correctly.

MichaelMcLinden's Comment: Was the DTC decontaminated between EFT #3 and PVS-
Phase II? Would contaminated DTC indicate lower performance when compared to Phase I
using a clean DTC device?

Response: The DTC devices were not decontaminated between EFT #3 and PVS-II. This
may have slightly elevated the results from PVS-II. This is discussed in the revised report.

Steven Lindberg's Comment: The NIOSH methods applied are never described in detail, but
are simply defined as being unpublished. The normal set of QA tests one would expect are
missing.

Response: Due to an error in distributing the report to reviewers, Appendix D was omitted,
so the reviewers did not receive a copy of the analytical methods. The National Institute for
Occupational Safety and Health (NIOSH) method for sampling mercury vapor in air, Method
6009, and the draft NIOSH method for sampling mercury aerosol in air, Method 9103, were
used in the Study. Copies of all NIOSH methods and laboratory methods used are contained
in Appendix E of the revised report. Method 6009 is published, and Method 9103 is
unpublished. Field QA/QC samples results (i.e., trip blanks and field blanks) are in Chapter
4 of the revised report. All laboratory QA/QC procedures specified in the methods were
followed by the laboratory analyzing the samples (Data Chem Laboratories), and, as is
standard procedure for commercial analytical laboratories, the laboratory QA/QC data should
be on file at Data Chem.

Steven Lindberg's Comment: The duration of the samples is not discussed, but the number
of samples "below detection" suggests they were too short. Why was this not resolved with a
simple change in design?

Response: The duration of the sample and the volume of air sampled are listed along with
the raw data in Appendix A, Table 1. As discussed above, the majority of "below detection"
samples were the MCE filter samples. This is discussed in the report in Chapter 4, footnote
12. The purpose of the MCE filter samples was to measure the concentration of mercury
aerosols inside the containment structure during operation of the DTC device; the "below
detection" results may indicate that no aerosols were formed or that the MCE filters were not
the most appropriate media for the detection of mercury aerosols. The Study was not
designed to make evaluate the likelihood of either possibility. Further study of this question
                                       IS
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is suggested in Section 7.4 of the final report. The Hydrar tube samples were not "below
detection".                                                               •

Steven Lindberg's Comment:  Hydrar tubes are never defined. Were the air flows checked
during sampling? Were they recorded continuously?

Response: Hydrar tubes are one of the acceptable media for sampling mercury vapor in
NIOSH Method 6009. Each air pump was calibrated before and after sampling. The two
calibration values were averaged to determine the approximate velocity at which air was
being drawn through the pump. The air flows on the pumps were not checked during
sampling or continuously recorded.

Steven Lindberg's Comment:  The reliance on sorbent tubes for much of the data biased the
concentrations measured to temporal means.  Spikes in exposure were generally not detected
unless the Jerome was being used.

Response: EPA agrees that the use of sorbent tubes resulted in measurements that did not
allow for the measurement of spikes in exposure. The Jerome Mercury Vapor Analyzer was
included in the study design to identify spikes in exposure; unfortunately, problems with the
Jerome data-loggers prevented the study team from collecting Jerome data for every device
at every location. In general, the Study was designed to measure worker exposure during
device operation; this evaluation was best served by collecting samples that were a temporal
average of mercury concentrations that the operator of a DTC device would be exposed to
under test conditions.

Steven Lindberg's Comment: Swipe samples are never quantitatively defined (surface area
wiped, duration of wipe, composition of solvent, etc). Why were the pre/post swipe samples
not collected at the same locations? How can they be quantitative? The extreme variability
reflects these problems. The statement at the end of p. 29 regarding replicate sampling is
wrong.  Upon encountering high variability, one should attempt to increase the number of
replicate samples, not decrease it.

Response: The wipe samples were moved from the main report to'Appendix F in the revised
report. The method for collection and the wipes used for sampling (Clorox®'Wash N Dri)
are described in greater detail in the revised report.  The reviewer is correct in noting that the
number of replicates should have been increased instead of decreased to account for sample
variability.

Steven Lindberg's Comment:  Was any attempt made to sample the air in the drum
headspace? The elevated concentrations one would expect to find there suggest a
considerable Hg pool, unless the volume was very small.

Response: The air in the headspace of the drum was tested during EFT #1 and EFT #2 using
the Jerome Mercury Vapor Analyzer. The results are given in Chapter 4:
                                       19
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Carl Herbrandson's Comment: It would be helpful to include, in the section on wipe
samples and perhaps in the section on study limitations, some discussion of the Hg
permeability of polyethylene. Hg can permeate through polyethylene. Polyethylene cannot be
used for taking water-Hg samples because the water will take up some Hg from air, through
the container. Does a wipe sample from the polyethylene containment wall take Hg that has
permeated the material? Does it only take Hg that is oxidized, complexed or bound and
cannot pass through the material? Or is it likely that this permeability is not significant
enough to affect these data?

Steven Lindberg's Comment: The choice of polyethylene film was also a serious flaw. Most
people experienced with sampling for Hg in air are aware of the well-known ability of Hg
vapor to both penetrate through and sorb onto polyethylene, rendering any conclusions
regarding the behavior of Hg within these enclosures highly uncertain and subject to
considerable error. It is difficult to understand why these problematic approaches continued
to be applied for so long before drawing attention.

Michael McLinden's Comment: Plastic absorbs mercury vapor, might this bias your results
low due to Hg absorbtion by the plastic? It would have been helpful to collect a bulk sample
of polyethylene before arriving at the facility to set up the containment and a bulk sample of
the plastic containment wall just prior to dismantelling to see how much Hg was absorbed by
the plastic.

Response: EPA agrees that use of polyethylene most likely biased the measured mercury
concentration in the air samples and in the wipe samples due to mercury's ability to permeate
through and sorb onto polyethylene. Vinyl sheeting would have most likely been a better
choice of materials for the containment structure. This issue is discussed in Chapter 6 in the
revised report.

Michael McLinden's Comment:
   Report Text:                                     ,,
   Bulk samples were collected from the particulate filters and carbon filters for each device
   at the following frequencies:
   Comment (Suggested Text Changes Highlighted): Bulk samples were collected from the
   particulate filters and carbon filters for each device uju|f the following procedures:
Response: The wording was changed as suggested. The description of the collection of
samples from the pollution control media for each device was moved to Appendix H in the
revised report.

Michael McLinden's Comment:  Were any bulk samples collected and analyzed prior to the
start of Phase I to detect background Hg contamination of the filter media (similar to hydrar
Hg background contamination)?

Response: Blank samples of the pollution control media were taken and analyzed. The
results are presented in Chapter 5. There was some background mercury  in some of the
pollution control media, but the mercury levels were quite low.
                                       20
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   MichaelMcLinden's Comment: Please elaborate on what this "mercury absorbing powder"
   [that was used to decontaminate the sampling spoons prior to use] is.

   Response:  The "mercury absorbing powder," a product called "Hg-X," is described in the
   revised report. Hg-X reacts with elemental mercury to form HgS, a reaction that occurs
   readily under ambient indoor conditions.

   Michael McLinden's Comment: Please elaborate a bit more on the condition of
   Manufacturer D DTC and any damage or modifications made to the device by the
   manufacturer. Sections 4.2.1 and 4.3.1  both give a bit more information but it is difficult to
   visualize the condition of the device and possible reason for such poor performance.

   Response:  Information about the problems with the Manufacturer D DTC device can be
   found in Section 3.5.3 and Appendix I of the revised report. There is a more detailed
   description than that presented in the draft report

Data Presentation and Evaluation

After reading the comments from the reviewers, EPA determined that the draft report contained
insufficient data analysis.  In order to answer many of the questions posed by the reviewers, the
data collected during the DTC Device Study were reanalyzed, and the discussion of the data was
expanded. Two significant changes to Chapter 4 of the report were the addition of background
and blank data  to this chapter (initially, this information was only presented in Chapter 8:
Limitations) and the use of simple statistical comparisons, whenever possible, to evaluate study
objectives.

   Michael McLinden's Comment: I agree with your conclusion [regarding whether the OSHA
   PEL is a ceiling or TWA], however, the regulated community will most likely disagree. The
   Ceiling limit is more difficult to comply with since a short (15 minute)  excursion above the
   ceiling would indicate an over-exposure and violation where as when calculating the 8 hr
  . TWA for the PEL a short excursion would be averaged out over the eight hour shift resulting
   in no violation. Critics will discount the argument that the PEL has been exceeded arguing
   that OSHA policy and intent is to enforce the standard as an eight hour TWA. It may be wise
   to also present a calculated/estimated 8  hr TWA based on Jerome readings.  Either
   extrapolate to 8 hrs using an "average" Jerome Hg reading thought to be representative of the
   entire 480 minute workday or calculate  the concentration (CI) during the actual  duration of
   Jerome sampling (Tl) and add to background dose (C2) for the remainder of the shift (T2).

   ShrTWA  =   C1T1 + C2T2
                      480 minutes

   Response:  The OSHA exposure limit for mercury is published in the CFR as a ceiling limit,
   so the PEL  was treated as a ceiling limit for the purposes of this Study.  It would be
   inappropriate for EPA to comment on the discretion that OSHA uses or may use when
   implementing its own regulations.  Also, there is not sufficient Jerome data to perform TWA
                                          21
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calculations for each device.  EPA did not extrapolate the data to 8 hours because of the
potentially widely varying use patterns for DTC devices.                      •

MichaelMcLinden's Comment: FYI while the TLV is an 8 hour TWA over a 40 hour
week, the REL is a TWA based on a 10 hr workday in a 40 hr week to allow for extended
work shifts such as overtime). Recommended exposure level (REL) should be recommended
exposure limit.                                                      .

Response: The REL was not used for evaluation in the Study, so the description of the REL
was removed from the revised report.

Steven Lindberghs Comment: Background values are often mentioned, but rarely defined as
to location. It is never quite clear how any "background or blank" data were treated. What is
the meaning of values such as 0.0059/0.014 in Table 4.18? Are these reps? Is this a range?
WasN=2?

Response: In the revised report, there is a more complete discussion of blank and
background samples in both the data collection section (Chapter 3) and the results section
(Chapter 4). The table is not in the revised report. The results for the background air
samples can be found in Table,4.1 and Table 4.2.

Carl Herbrandson 's Comment: Discussion of the implications of the vapor phase and
aerosol data would be helpful. Does the very low level detected  in only 7 of about 177 MCEF
samples suggest that only Hg vapor is emitted from the DTCs? Or is Hg aerosol that sticks to
the MCEF volatilized by the  sampling vacuum pump? Does this study help to answer these
questions? Should future studies assume that there is no aerosolization?                 .

Response: The draft report did not discuss the low number of the MCE filter samples that
had detectable levels of mercury. The revised report contains the following discussion to
address this:
   It is important to note that, out of the 199 analytical air samples collected, only eight mercury
   aerosol (MCE filter) samples had values above the detection limit, and all blank MCE filter
   samples were below the detection limit.  Because the amount of mercury aerosol was not high '
   enough to measure, the air results discussed in this chapter only address the mercury vapor
   {Hydrar tube) samples. The results for the MCE filters can be found in Appendix A, Table 1.
   Future research-may be necessary to determine whether aerosols were not detected because no
   aerosouzation occurred or because any aerosol mercury collected on the MCE filter was
   vaporized by the sampling vacuum pump and subsequently sorbed onto the Hydrar tubes.
                                                                   {footnote 12, pg. 21)
              *
The DTC Device Study was not designed to answer the questions posed by the reviewer.
EPA agrees that these questions are important and that could be considered for future study.

Steven Lindberg's Comment: Comparisons with the Jerome are mentioned, but never
discussed in detail or presented quantitatively.  Was there a systematic approach to
performing a method intercomparison? It would have been useful to see overlain plots of the
Hydrar and Jerome data for periods both were used at the same location. The data  .
                                       22
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"comparison" is inadequate for evaluation of the validity of the airborne Hg data'(see
above). The only mention of the results of any method comparisons on p. 58 is inadequate
("analysis of Jerome... indicate a similar pattern..."), especially given the objective of the
study (to evaluate performance, to quantify emissions, mass balance determination, etc.).
The numbers of replicate samples collected was similarly inadequate.

Response: In the revised report, averages of the Jerome data and the analytical air sample
(Hydrar tube) data were graphed together to better facilitate comparison of the results from
the two air sampling methods.  The Jerome data was not complete (due to the malfunctioning
data loggers) and did not include enough sampling events to create an overlay plot or to
justify statistical comparisons between the two types of data. The language in the report has
been revised to reflect the fact that no quantitative comparisons between the Jerome data and
the Hydrar data were made. Graphical comparisons of the data are presented in Appendix A,
Figures 26, -35 and 43, of the revised report.

As noted above, the study design did not call for replicate testing because one of the basic
assumptions of the Study was that there would be changes in device performance over time.
Multiple air samples were collected for each device during each test.

MichaelMcLinden's Comment: After being in the containment for such a long time I'm
supprised the gold foil [on the Jerome] didn't get overload/over-ranged. Did you have any
"over-ranging" problems which necessitated purging the  foil??

Response: The model 431-X Jerome analyzer has an improved film regeneration circuit,
which makes the serisor last longer than earlier models. When the sensor became saturated.
while the Jerome analyzer (model 431-X) was attached to the data logger or computer, the
analyzer automatically regenerated the sensor and then resumed sampling. The Jerome
graphs in Appendix A note when the Jerome was regenerating.

Michael McLinden's Comment: Why were the results inside containment lower than TLV
while results outside containment were dccassionally above the TLV? - is it due to data
logger failing and no data gathered?  Which Jerome data-logger failed? Please clarify.

Response: The results inside the containment structure that were lower than the TLV were
collected at a different time than the results outside the containment structure that were above
the TLV.  Thus, there is no data suggesting that the mercury concentration was higher
outside the containment structure than inside the containment structure at any point in time.
These different Jerome analyzer readings do show that there was variability in the mercury
levels. This is clearer in the revised report.  Both Jerome data-loggers failed at different
points during the Study.                                              •  •

Steven Lindberg's Comment:  The statement on p. 47 "as measured by the ambient airborne
emissions" is in error. There were no measurements of emissions performed in this study,
only estimates based on concentration data.  ;

Response: The report has been revised to make it clear that emissions were not measured.
                                       23
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Michael McLinden's Comment: What size & wattage lamps were processed in Phase II, T-
8, T-12? You provide the number of lamps but not the number of each size lamp and
wattage of each lamp processed as you did in Table 4.1. In Phase II did you use all Phillips
Lighting "Alto" lamps? If you used lamps other than Phillips "Alto" you would have
processed more mercury, also if you processed larger lamps you would again process more
mercury (in Phase I Manufactruer B device processed 611 T-8 lamps). This seems more .
likely to contribute to higher phase II result than the higher Phase II background levels.

Response: There were not sufficient Phillips Lighting "Alto®" lamps for use in PVS-II.
Because the waste lamps were from different manufacturers, and therefore did not contain a
standard amount of mercury, the types of waste lamps processed were not recorded during
PVS-II. The possible effects of crushing waste lamps other than Alto® lamps could have
impacted the results during PVS-II, and the possible impacts are discussed in the revised
report.

Michael McLinden's Comment: Were these low results [in PVS-phase I] due to colder
temperature resulting in less Hg being volatalized ?.                 ,

Response: The temperature most likely had some affect on the amount of mercury that was
volatilized during the different parts of the Study; although, this could not be quantified.
This is discussed in Section 6.2 of the revised report.

Carl Herbrandson's Comment:
    o  Location of background, TLV and/or PEL lines on figures 4.2; 4.3,4.4 and 4.5 aren't
       at the correct locations, (no background line for Fig 4.1) Similarly, these lines in
       Appendix A don't always line up right.
    o  Table 5.2 - Is the "measured mercury" the "average mercury quantity"? Aren't you
       really reporting the mean of the measured values? Means and averages are confused
       in this table and others (e.g. Table 5.5).
    o  %CV is more informative than Std Dey in many of the tables, especially where the
       means have large ranges (e.g. Table 5.5). What, actually, does the "Standard
       Deviation" in Table 5.8 describe? This standard deviation may provide some (poor)
       measure of the mixing between a few locations in the containment area, but still, this
       column should be omitted. The column contains the standard deviation of
       measurements that are not realistically comparable. Each measurement describes a
       unique volume of the containment area. It isn't known if the air at these various
       locations was moving or quiescent, or if the volume that the concentration described
       was large or smaH.
    o  Appendix A, Table 2-5 label box described as "%  valid data" should be renamed
       something like "% locations with increase".

Steven Lindberg's Comment:
    o  The term NA is not defined or  explained (why not analyzed, or not attempted, or not
       applicable?).
                                       24
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    o  The % difference numbers in Table 4.6 are in error based on the definition of the
       validation (if the Phase II results are > Phase I, the differences would normally be
       expressed as + values, not -).
    o  Table 4.9 would have benefited by an inclusion of the corresponding Hydrar trap
       data.
    o  Several tables express data with a greater number of significant digits than are
       justified.                                  •
    o  Several tables show ranges in data, but means and SD would also be useful.
    o  The Figures (here and in App's) are inconsistently labeled.

Michael McLinden's Comment:
    o  TABEL ENTRY [Table 4.6\: MANUFACTURER C, On Operator during Filter
       Changes-118%/105%   Should 105% be a negative number?

Response:  There were several errors on the labels for the figures and tables throughout the
draft report. -These errors have been corrected, and the titles for the figures" and tables have
been changed to provide a more detailed description of the data being presented.
    o  The PEL and TLV lines were corrected for all figures, and lines for background
       concentrations were added.
    o  The "average mercury" actually is the calculated mean. The labels in the tables were
       corrected. Standard deviations were calculated to describe many means, but this
       statistic is only presented if it is valid for the measurements being averaged.
    o  The column describing "% valid data" was removed from the table in Appendix A.
    o  All notations in tables, such as NA or ND, are now defined in the revised report.
    o  The % differences column was deleted from Table 4.6 (Table 4.9 in the revised
       report). Other statistics were used to compare phase I and phase II of the PVS.
    o  Averages of the Jerome data and the analytical air sample (Hydrar tube) data were
       graphed together to better facilitate comparison of the results from the two air
       sampling methods.
    o  Means and standard deviations are included'wherever these descriptive statistics are
       appropriate and valid.

Michael McLinden's Comment:
    Report Text:
    As noted in the table, the Hydrar sorbent tube appeared to capture a greater amount of
    ambient mercury during the sample acquisition period (i.e., when the sample pump was
    in operation). Furthermore, two of the operator breathing zone samples (one for the
    Manufacturer C and one for the Manufacturer B) equaled or slightly exceeded the PEL.
    The remaining results for both devices were above the TLV and below the PEL. No
    U-tube tests were performed using  the Manufacturer A or Manufacturer D devices.
    Comment: In Table 4.19 the results for "Manufacturer B, Operator's right shoulder"
    indicate 0.018 mg/m3 which is lower than the 0.025 mg/m3 TLV.

Response: The text was corrected to reflect the fact that one of the operator shoulder samples
for Manufacturer B was below the TLV.  The table is not in the revised report (air sampling
results can be found  in Appendix A, Table 1):
                                       25
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CarlHerbrandson's Comment:  Wipe sample results should be reported as u.g/100 cm2, not
fag/sample.

Steven Lindberg's Comment: Was any attempt made to wipe the insides of the drums to
determine the sorbed Hg? Was wipe efficiency/extraction/analysis ever determined with
knowns? Was the parking lot "wiped" to determine if this approach was an improvement?
The other problems with the study design mentioned above would still apply however.

Response: Due to difficulties with contamination, the wipe sample data was not used in the
report to support any of the findings or observations; therefore, wipe sample data is presented
in Appendix F in the revised report, instead of Chapter 4. The wipe sample results are
reported as /^g/100cm2 in the revised report in Appendix F. The insides of the drums were
riot wiped. The wipe sample extraction method was developed by Data Chem as a NIOSH
method and has been tested by Data Chem. The parking lot was not wiped, and there is no
evidence that the change from cutting the polyethylene on the facility floor to cutting the
polyethylene outside in the parking lot decreased contamination of the plastic sheeting.

Cart Herbrandson's Comment:  Manufacturer A's device was run in ventilation mode
throughout the course of the tests - including over night. Is it possible to estimate the mass of
overnight emissions from available data? While these emissions are likely to be only a small
fraction of the overall emissions for B and C, it is unclear what fraction of A's emissions
occur in the ventilation mode.

Response: The data collected for overnight samples is shown in the revised report in Figure
4.15: Overnight Test Sample Results (pg. 63). There is not sufficient data to estimate the
mass of overnight emissions.

Steven Lindberg's Comment: The problem of atmospheric contamination ("background")
due to broken bulbs in bulb boxes should have been anticipated, or at least recognized
sooner. The "box test" is not clearly defined until after the data are presented.

Response: EPA agrees that a more thorough review of the sampling and study plan by
researchers more experienced with mercury monitoring would have been beneficial to the
study team.  The study team added the "Box Test" to the Study in order to quantify the
atmospheric contamination due to broken bulbs in bulb boxes; the revised report more clearly
defines the Box Test.

MichaelMcLinden's Comment: Can you elaborate on what happened [in Figure 4.6] during
the 6th minute and again at the 28th minute to explain these spikes? Was the spike at the 6th
minute due to handling and opening the top of the boxes? Also, can you explain why the
concentration levels off from about the 8th minutes to the 19th minute but then begins a
steady rise?  Was the DTC in operation at any point during the test (e.g., from the 8th to the
19th minute) to influence the results shown in Figure 4.6? It may be helpful to explain the
box test in more detail, this data alone may have important implications regarding Hg
concentrations in and around storage locations of spent/broken lamps in general industry as
                                       26
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   well as at lamp recycling facilities.  Were the air sampling results collected with the Jerome
   or with sampling pumps?

   Response:  There is not sufficient data to speculate about the cause of the spikes in measured
   mercury concentration in Figure 4.6 (Figure 4.14 in the revised report). There is a general
   increase in the ambient mercury concentration, which may be due to mercury release from
   the broken lamps in the boxes; however, there is not enough data to fully substantiate this
   hypothesis.  The DTC device was not operated during the box test.  The air sampling results
   for the box test in Table 4.17 (same table number in draft report and in revised report) were
   collected using the Hydrar tubes and sampling pumps.

   Steven Lindberg's Comment: The phrase "outside the containment" is used, but never
   defined specifically.  Some observations seem trivial (e.g. that the Hg sorbent is more
   efficient when the pump is running).

   Response: The phrase "outside the containment" generally referred to the area that was not
   inside the containment structure but was inside the room in the facilities in which the Study
   was being conducted. Wherever possible, the revised report specifically describes the
   locations "outside the containment" where samples were taken.

Mass Balance

One of the questions posed to the peer reviewers by EPA concerned the validity of the discussion
of the error associated with the Mass Balance Study. The reviewers generally commented that
the amount of uncertainty in the Mass Balance Study was too high to draw any conclusions from
that portion of the Study. Therefore, the revised report concentrates on presenting the data
collected during the Mass Balance Study, explaining the difficulties encountered during the
Study, and providing suggestions for future mass balance studies involving DTC devices.

   Carl Herbrandson's Comment: The tenor of the mass balance discussion should be changed
   to focus on why available data can't provide the necessary information for a mass balance.
   Estimates and calculations should not be reported. A mass balance would be useful for
   determining the fraction of fluorescent bulb mercury that escapes into the environment from
   DTCs. However, even as a range estimating tool, this mass balance is not instructive.

   Steven Lindberg's Comment: The issue of quantitative uncertainty must be addressed for all
   of these measurements. This is especially true for the mass balance.  The uncertainties and
   assumptions of the mass balance computations must be clearly stated. A serious and critical
   assessment of uncertainties involved in this particular study might indicate the impossibility
   of drawing any quantitative conclusions.
       '     i(
   Response: EPA agrees that the uncertainty in the Mass Balance Study is too high to estimate
   the different fractions of mercury. The discussion of the Mass Balance Study was revised to
   present the data collected, the calculations, and the problems encountered. While the high
   degree of uncertainty does limit the types of analyses that can be'performed to evaluate the
   study results, the data were collected in the field under conditions that were as close to a
                                           27
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probable management scenario as possible. The revised report acknowledges the limitations
of this set of data.

Michael McLinden's Comment: I agree .with your decision not to use Jerome readings for
this portion on the study [Mass Balance Study}.
       » '                               *                                    '
Michael McLinden's Comment: Hgu [the amount of mercury captured by, the device]
missing the amount of Hg adhering to the inside of the DTC device. Hg may have been
bound to interior metal and plastic parts of the DTC, this may lower your recovery. Mercury
may have been absorbed by plastic containment, lowering your Hgr [the amount of mercury
released by the device] result. It might have been wise to collect a pre and post bulk sample
of the plastic containment.                                           .        .

Response:  These factors are discussed in the revised report in Chapter 5 and Chapter 6.
(Note: Hgu was changed to Hgc in the revised report.  Hgc is the amount of mercury
captured by the device.)                                 .              '

Steven Lindberg's Comment: How much Hg was added to these lamps during
manufacturing? The amounts analyzed seem  low, depending on date of manufacture.

Response:  Table 5.1  in the report lists the amount of mercury added to each type of lamp.
The Phillips Lighting Alto® lamps are specifically manufactured to avoid adding excessive
amounts of mercury by precisely dosing each lamp.

CarlHerbrandson's Comment: The study design optimized the ability to measure potential1
exposure concentrations, not the mass emitted from the DTCs. These are two very different
goals and require different tools. Attempts to calculate the mass emitted from many different
air-Hg concentrations assumes each sample location represents a volume of air in the
containment area that is characteristically similar to the other sample locations in: virtual
volume, air flow, mixing, replacement rate (or containment area input rate) and removal rate
(or containment area exhaust rate). It is likely that each measurement location was very
different, and weighting of individual sample results would be necessary to calculate a
reasonable emission rate/mass - an impossible task given the study design.

Steven Lindberg's Comment:  Why was no attempt made to estimate the gaseous loss based
on the air concentration measurements?

Response:  EPA recognizes that the Mass Balance Study was not properly designed to
achieve the goals stated in the study plan. Mercury emissions were not measured during the
DTC Device Study.  The air concentration data was used to estimate the amount of mercury
released; however, because the study design was not optimal for precise measurement of
mercury emissions, there was a significant mass of mercury unaccounted for.

Steven Lindberg's Comment: Given the uncertainties in all the raw data, the SD's shown in
Table 5.8 seem much too low. What do they  represent?
                                       28
-------
The number of air exchanges was never measured, but can have an important effect on the
calculations. How was this evaluated?

MichaelMcLinden's Comment: Looking at Figures 27 and 28 in Appendix A it indicates
that it took over four hours to fill two drums. Two air changes seems very low for this time
period.  Making an air tight containment, even sealing plastic with duct tape, is difficult to
achieve as demonstrated in asbestos abatement containments which are similar in design and
generally tighter than your containment.  I suspect you are under estimating the air changes
and under estimating fugitive emissions through the door and walls of the containment.
As per Appendix C, [Manufacturer A] Drum Top Crusher process description - the fan
draws 25 CFM:
25 CFM = (1,440 CF) / (57.6 Minutes)
One Air Change in Minutes = (CF) / (CFM)
(1,440 CF) / (25 minutes) = 57.6 Minutes for one air change
(60 minutes) / (57.6 minutes) = 1.04 Air Changes per hour
(1.04 ACH)  X  (4 hours)  =4.16 Air Changes over the four hour it takes to fill two drums.
Please elaborate on how you estimated the number of air changes.

Response: The  averages shown in Table 5.8 of the draft report were the averages of the air
samples from the Performance Validation Study - Phase I. This portion of the Study had the
lowest amount of variability between the air samples. The standard deviation is no longer
included in this  table.
Table 5.8 how includes the data used for the calculation of the number of air exchanges, in
addition to the values for the amount of mercury released from the devices.
In the draft report, the numbers of air changes were estimated based on general knowledge.
In the revised report, the volumetric flow rate of the DTC device fan was used to estimate the
number of air exchanges, following the suggestion of one of the reviewers.
The Mass Balance Study only involved filling one drum per device, so the duration ranged
between 86 and  112 minutes. The calculations used to estimate the number of air exchanges
for each device are explained in Chapter 5 of the revised report.

The assumption that the Manufacturer A  device released a similar amount of mercury as the
Manufacturer B and Manufacturer C devices is based on the calculations described in
Chapter 5. While this assumption is most likely not correct, additional attempts were not
made to correct  the estimate for HgR because the amount of mercury estimated as being
released was very small as a percentage of the total mercury processed through each DTC
Device (HgR).

CarlHerbrandson's Comment:  Problems in estimating barrel content. These problems are
well documented in the report and appendix.

Response: As discussed in the limitations section (Chapter 6), the phosphor powder, which
tends to contain the largest fraction of the mercury in the drum, sifts to the bottom due to the
vibration of the  drum in operation.  Therefore, any sample taken from a full 55-gallon drum
of crushed lamps would likely not be representative of the contents of the drum. Based on
                                       29
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such a sample, a determination, that the waste contained in such a drum is not hazardous,
may be questionable.                           .        .          .

Steven Lindberg's Comment:  I could not find any blank data for the contents and
components of the DTCs.

MichaelMcLinden's Comment: New drum filters may be contaminated with background
Hg, did you test a filter for backgound?

Response:  The blank data for the components of the DTC devices were presented in Table
5.11 in the draft report.  These data are presented earlier in Chapter 5 (in Table 5.6) in the
revised report.

Steven Lindberg's Comment:  Detailed method descriptions for obtaining representative
samples of any substrate are lacking.

Response:  The description of the collection of samples from the pollution control media of
the DTC devices is included in the revised report in Appendix H.

CarlHerbrandson's Comment:  Problems with measuring filter/carbon content (e.g. high
%CV in carbon samples implies non-uniform capture and poor capture/mass estimate).

Carl Herbrandson's Comment:  Errors on the order of 2400,1100 and 1800 times the
estimated mercury vapor emissions; 2, 0.5 and 2 times the calculated barrel contents; or 18,
0.9 and 78 times the calculated filter/carbon mercury could account for the discrepancies in
•the quantitative mass balance. There is no apparent consistency to the possible error.

Steven Lindberg's Comment:  Given the gross differences among the activated C weights
used in each DTC, the conclusion that Mfg A device "released" about the same amount of
Hg as DTC's B & C seems in error.

Carl Herbrandson's Comment:  Jang et al. Waste Management 25 (2005) 5-14 showed a
maximum of 36% recovery with an acid extraction of Hg from fluorescent bulbs. Can
additional mercury can be released from the bulbs by heating them (part of QA/QCing the
methods?)? (This could increase the discrepancy in the attempted mass balance.)

Steven Lindberg's Comment:  Did the team attempt to test the method for measuring Hg in
lamps?  Although some Hg may condense, quantitative condensation seems unlikely.

Response:  The study team did not test the method for measuring mercury in spent lamps.
The values measured in the spent lamps were slightly lower than the amounts of mercury
reported to be added to each Phillips Lighting, Alto® lamp as discussed in Section 5.2 and
shown in Table 5.1 and Table 5.2 of the revised report. A reference to Jang et al., 2005 is
also included in Section 5.2. Additionally, at the end of Chapter 5 of the revised report, EPA
suggests that any future research quantifying the amount of mercury in spent lamps should
develop and test a laboratory method with appropriate QA/QC procedures.
                                       30
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   Steven Lindberghs Comment: The recovery data in Table 5.11 suggest serious analytical
   problems which could have influenced much of the other data. Where are similar'data for the
   other sample types and analytical methods?

   Response:  The recovery data in Table 5.11 for the matrix spikes of the pollution control
   media do suggest serious analytical problems.  These data were presented to help explain the
   problems with the mass balance. Data Chem Laboratories followed the appropriate QA/QC
   described in the analytical methods, which are included in Appendix E of the revised report.
   All QA samples met the criteria specified by the test method being used. The Data Chem
   Laboratory reports are included in Appendix B.

Operator Observations and Safety Concerns

   Steven Lindberg's Comment: Statements made here, and elsewhere, refer to data which are
  ' not clearly identified as to their source (Table or Fig. #).

   Response:  The reviewer did not list specific instances in which data were not clearly
   identified; however, in the revised report, the actual table and/or figure numbers were
   included whenever a reference was made to specific data.

   Michael McLinden's Comment:
       Report Text:
       Lamp breakage was a common issue for all devices. The fragile lamps often broke
       before they could be fed into the devices, causing, in some instances, visible release of
       mercury-containing phosphor powder. The ergonomic orientation of the feed tubes on
       several devices also exacerbated this problem, where, for example, the operator either
       had to lower the lamps to waist level or raise them up to shoulder level in order to insert
       them into the feed tube.
       Comment: I'm not sure ergonomic is the best/correct word for this situation.

   Response: "Ergonomic" was changed to "configuration".                   [pg. 86]

Lessons Learned

   Steven Lindberg's Comment: One is left with the impression that the study and sampling
   design was compromised to decrease costs.

   Response:  As discussed above, the study team made every effort to carefully collect field
   data that represented possible mercury exposures associated with DTC device operation. The
   primary concern in designing and conducting the DTC Device Study was to assess the
   performance of the four DTC devices tested with regard to operator exposure, and concerns
   about the cost of the testing were secondary to completing the objectives of the Study.
   Nevertheless, EPA recognizes that certain decisions made regarding the design of the Study
   do present problems in analyzing the data.
                                          31
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Limitations

   Steven Lindberg's Comment: A statement such as "each facility had a measurable
   concentration of mercury in ambient air" misrepresents the severity of existing and ongoing
   contamination encountered during this study, and the degree to which this problem
   compromised this study and its conclusions. Blanks defined as containing "trace amounts of
   Hg" but in actuality containing microgram amounts of Hg are also misleading.

   Response: The two statements commented on by the reviewer, as well as several other
   statements on the same topic, were changed in the revised report to better emphasize the
   degree to which background mercury levels may have impacted the study results.
   Background mercury concentrations are discussed in Chapter 6 of the revised report.

   Steven Lindberg's Comment: Many comments in this section indicate that a thorough
   design evaluation should have been conducted prior to the study. Surely, some, if not many,
   of the problems encountered in the field could have been anticipated.

   Response: EPA agrees that a review of the original study design by researchers more
   experienced in mercury sampling would likely have lead to an improved study design.

   Steven Lindberg's Comment: Given the degree of variability noted in many of the samples,
   the assumption that each milliliter of air contains approximately the same concentration of
   mercury as the adjacent milliliter seems subject to large uncertainty.

   Response: The analytical air samples collected thousands of milliliters of air under several
   different operating and non-operating conditions. These data provide information about
   possible worker exposure to mercury,  as opposed to the specific concentration of mercury in
   each milliliter of air.

   Steven Lindberg's Comment: The data in Table 8.3 should  include the appropriate statistical
   summaries.  These data do not support the conclusion drawn below the table regarding
   concurrence between lab and field blanks (e.g. data from 3/26).

   Response: Table 4.4 contains the field blank data.  This data was moved to Chapter 4 so that
   the blank data and the air sampling data could be discussed together. The averages and
   standard deviations are now presented with these data.

   MichaelMcLinden's Comment: I agree with your conclusion, sample volume is the critical
   value for calculating concentration, flow rates need to be within the range specified by the
   analytical method.

   Response: The discussion as to whether variations in air sampling pump flow rates may have
   affected the study results was removed from the revised report.
                                           32
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Conclusions and Recommendations

   CarlHerbrandson's Comment: Data from this study shows: high mercury vapor
   concentrations in existing facilities; high levels of removable (trackable) mercury on floors of
   existing bulb recycling facilities; and, high mercury vapor concentrations near bulb-transport
   boxes containing broken bulbs. These data suggest that bulb transport containers and
   currently operating recycling facilities should be studied for ways to improve their mercury
   retention and control.

   Response: This is an area where further study would be helpful. Some of these topics where
   included in Section 7.4 (Future Areas for Study).

   Steven Lindberg's Comment: As discussed above, the application of any, much less several,
   correction factors adds significant uncertainty in any conclusions drawn from these data.
   This results in an inability to draw firm conclusions in my opinion. The study should have
   encouraged support for the design of improved DTC's, as those tested left much to be
   desired. The misinformation on Hg included in the manufacturer's manuals should also have
   been noted.

   Response: The correction factors applied to the mass balance data are no longer included in
   the main body of the revised report. This information is included in Appendix G. The
   uncertainty associated with the data does limit the information and knowledge that can be
   drawn from this study; however, a significant amount of relevant information was gained in
   performing this study. The discussion presented in the revised report was written to provide
   information about DTC device performance. The report is not a guidance document;
   however, it provides observations noted in conducting the Study.

   Michael McLinden's Comment: Venting outdoors would defeat the purpose of using the
   DTC device to control emission, suggest venting  to a pollution control device rather than
   simply to outside air.

   Response: The revised report does not suggest venting outdoors. The Study was not
   designed to make specific recommendations or determinations about the most appropriate
   ventilation for a room in which a DTC device is operated.

Appendices

   Steven Lindberg's Comment:  As mentioned above, these tables and figures relate poorly to
   the text, carrying in many cases different and undefined labels compared to comparable items
   in the main text.  There were also no captions. Several experiments are illustrated here
   which are never described elsewhere (e.g. real world tests).

   Response: The tables and figures in the appendices were extensively revised in the final
   report, including adding captions, to make them clearer and more consistent. The use of
   terminology such as "real world tests" was removed. The names used for the study
                                          33
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components in the original sample and study plan (now contained in Appendix D) were not
the names that were used in the report. These inconsistencies have been corrected.
                     '»
Steven Lindberg's Comment; The scale chosen for the Y axis (Hg concentration in mg/m3)
would have been more readable if converted to ug/m3.

Response:  The,units of mg/m3 were chosen for the y-axis of the graphs because the OSHA
PEL is reported as O.lmg/m3.                                             .

Steven Lindberg's Comment: The Jerome data were buried in the appendices, with no
discussion, despite the capture of several interesting temporal trends in airborne Hg, .Why
were these never compared directly to the Hydrar data?

Response:  In the revised report, wherever possible, the Jerome data were highlighted,
discussed, and compared to the Hydrar data. Due to problems with the data loggers, there
were, significant gaps in the Jerome data, making the uncertainty of the data too high to make
quantitative comparisons.

MichaelMcLinden's Comment: Appendix C - initial paragraph and paragraph below Table
AE both reference "the mass balance equation in section 6.0," perhaps this should be Section
5.0.       ,                           .    •       '

Response: The discussion regarding the sampling errors and corrections for the Mass   ,
Balance Study is now in Appendix G; references to the Mass Balance Study in Appendix G
were corrected in the revised report.

Steven Lindberg's Comment: Finally, Appendix D titled Data Chem Methods was blank.

Response:  There was an error in distributing the report, and Appendix D was not included in
the draft report received by the reviewers. All of the analytical methods and any
modifications are included in Appendix E of the revised report.
                                       34
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Mercury Lamp Drum-Top Crusher Study Peer Reviewers:

 •  Carl Herbrandson, Ph.D., Minnesota Department of Health
                                       r
 •  Steven Lindberg, Ph.D., Corporate Fellow Emeritus (retired)
   Environmental Sciences Division, Oak Ridge National Laboratory

 •  Michael McLinden, M.S., C.I.H., New Jersey Department of Environmental
   Protection
-------
                                   Carl Herbrandson                     .

Contact Information
       Site Assessment and Consultation Unit
       Environmental Surveillance and Assessment Section
       Environmental Health Division
       Minnesota Department of Health
       121 East Seventh Place, Suite 220
       St. Paul MN 55101
       carl.herbrandson@health.state.mn.us
       651/215-0925
       fax: 651/215-0925

Education
       1991 - 1996 University of Minnesota, Minneapolis, MN. Degree: Ph.D. in Toxicology

       1969 - 1973 Case Western Reserve University, Cleveland, OH. Degree: B.A. in English

Research and Professional Experience

       1996 - present Research Scientist 3, Minnesota Department of Health, St. Paul, MN
             • Toxicologist and Health Assessor for Site Assessment and Consultation Unit, a
             cooperative partner grantee of the Agency for Toxic Substances and Disease
             Registry, Center for Disease Control, Atlanta GA
             • Review health hazards and risks associated with exposure to chemicals in the
             environment; evaluate data and conduct health assessments; model potential
             human exposures; investigate biomarkers which may indicate exposures; and
             determine the likelihood of conducting successful exposure or health
              investigations.
              • Focus is currently on complex multimedia evaluations with an emphasis on
             environmental.chemistry. Two focus areas of work are fate, exposure and toxicity
             of heavy metals (primarily mercury and arsenic) and quantitative evaluation of the
              six potential routes of exposure to organic and inorganic compounds in sediments.
              • Recommend sampling and remediation criteria for environmental media.
              • Write technical evaluations of potential health impacts of environmental
              exposures to toxic chemicals for U.S. Agency for Toxic Substances and Disease
              Registry concurrence.
              • Write public health information sheets for affected communities  about potential
              effects of exposure to environmental chemicals and procedures for prudent
              avoidance or reduction of exposure.
              • Represent the Minnesota Department of Health in meetings with responsible
              parties, state and federal agencies,  in interviews with news media,  and in
              interactions with the public.
-------
       1996 Research Associate, University of Minnesota, St. Paul, MN

             * Design and perform experiments to identify a sex pheromone from Eurasian
             Ruffe (Gymnocephalus cernuus).
             • Endocrine manipulation offish reproductive cycle; extraction of steroids,
             prostaglandins and bile acids excreted by fish; in vitro receptor binding studies;
             and in vivo electrophysiological studies.

       1992 -1996 Graduate Research Assistant, University of Minnesota, Minneapolis, MN

             • Develop laboratory model for investigating toxicodynamic and toxicokinetic
             interactions of a chemical and a physical stressor on a whole organism in an
             aquatic environmental system.
             • Thesis: Toxicological Effects  of Suspended Solids and Carbofuran on Daphnia
             magna, Graduate School of the University of Minnesota, February 1996
                               •f
       1984 - 1991 Engineering Research Specialist, Unisys, Eagan, MN

             • Invented and developed a system for passively monitoring the growth rate of
             YIG crystals which are used as the active element in solid state magnetooptical
             switches and optical isolators.                                     '
             • Designed and developed a system for mounting lasers into connectorized fiber
             optic packages while maintaining laser coupling efficiency  into a 6 |Jm core over
             a 75° C temperature range.
             • Designed and developed a computer automated station for testing
             superconducting tunnel junctions to be used as sensors.

Invited Lecturer/Instructor

       2005  Seminar, University of Minnesota Duluth Medical School:  Toxicology/Public
       Health response to a recent mercury spill. Public health concerns coupled with an
       emergency response incident required rapid development of public health clearance
       criteria, modeling likely juvenile exposure, and development of new biomarkers of
       exposure.
       2004  Grand Rounds, Minnesota Poison Control System, Hennepin County Medical
       Center: Rosemount Woods Mercury Incident/The behavior of a chemical in the
       environment is important when evaluating exposures and undertaking a successful
       cleanup.
       2004  Grand Rounds, Regions Hospital Department of Emergency Medicine:
       Rosemount Woods Mercury Incident. Problems related to understanding chemical
       exposures during an emergency incident: biomarkers, kinetics, analytical issues, and
       people.
       2004  Grand Rounds, University of Minnesota School of Public Health: Public Health
       and a mercury spill. The responsibility of public health experts in an emergency is to
       support local officials, communities and medical practitioners.
-------
       2003  Guest Lecturer, Toxicology Program, University of Minnesota Graduate School:
       Toxicology in State Government. When and how we evaluate exposures and assess
       health.
       2003  Guest Lecturer, University of Minnesota School of Public Health: Mercury. The
       environmental chemistry of mercury: sources, exposures, fate and toxicity.
       2003,2001 Guest Lecturer, Toxicology Program, University of Minnesota Graduate
    .   School: Aquatic Toxicology. An introduction to chemicals in the aquatic environment
       and how they affect aquatic species.
       2002  Guest Lecturer, University of Minnesota School of Public Health: Mercury and
       Arsenic - two toxic heavy metals. How do they behave in the environment and why are
       we concerned about them?
       2001.  Grand Rounds, Minnesota Poison Control System, Hennepin County Medical
       Center: Mercury and Chromated Copper Arsenate. Presentation to poison control
       specialists, toxicologists and medical practitioners on the environmental chemistry,
       bioavailability, kinetics and toxicity of mercury and CCA. Included measuring mercury
       volatilization from the amalgam fillings of audience volunteers with a realtime mercury
       vapor analyzer and a discussion of the data.
       2000  Invited Presentation, Minnesota Metal Finishers Association, Minneapolis, MN:
    .   Health concerns associated with metal finishing operations. A review of current
       epidemiology and toxicology related to aerosols and vapors emitted by metal finishing
       companies.
       2000  Invited Presentation, Minnesota Environmental Health Association Annual
       Meeting, Brainerd, MN: Clandestine methamphetamine labs. A discussion of potential
       meth lab exposures and the cleanup criteria derived by the Minnesota Department of
       Health.
       1999  Invited Presentation, Bi-National Forum Meeting, Thunder Bay, Ontario,
       Canada: Issues related to improving and assuring air quality. Air monitoring, dispersion
       modeling, chemical reactions in the troposphere, health effects, risk assessment and
       current regulations were discussed.
       1996,1998 Assistant Professor /Instructor, Department of Fisheries and Wildlife,
       University of Minnesota. FW 5460: Pollution Impacts on Aquatic Systems. Course was
       offered during the winter quarter every other year on the principles and experimental
       techniques for investigating the impacts of chemical pollutants in aquatic environments.

Presentations at ATSDR Partners in Public Health Meetings

       2001  Evaluating sediments at contaminated sites. What do we know about the
       behavior of chemicals in sediments? How do groundwater and freeze-thaw cycles affect
       the integrity of large volumes of chemical wastes in sediments?
       2001  Are clandestine methamphetamine laboratories a public health concern?
       Evaluating potential exposures to hazardous chemicals in Clan labs.
       2001  Air modeling or air monitoring? While ambient air monitoring data are often
       requested by health assessors, dispersion modeling of stack testing data is typically more
       useful in evaluating potential hazards from facility emissions.  .
-------
       1999  Weight of evidence in health assessments. When quantitative health
       assessments cannot be performed it is often necessary to use a weight of evidence
       approach to qualitatively evaluate a potential public health hazard.

Peer reviewed / refereed publications

       • Baker, B., C. Herbrandson, T. Eshenaur and R. Messing (2005). Measuring Exposure to
       an Elemental Mercury Spill — Dakota County, Minnesota, 2004. Morbidity and
       Mortality Weekly Reports 54(6): 146-149.
       • Herbrandson, C., Bradbury, S.P., and Swackhammer, D.L. (2003). Influence of
       suspended solids on acute toxicity of carbofuran to Daphnia magna: I. Interactive effects.
       Aquatic Toxicology, 63(4):333-42
       • Herbrandson, C., Bradbury, S.P., and Swackhammer, D.L. (2003). Influence of
       suspended solids on acute toxicity of carbofuran to Daphnia magna: II. An evaluation of
       potential interactive mechanisms. Aquatic Toxicology, 63(4):343-55
       • Herbrandson, C., Bradbury, S.P., and Swackhammer, D.L, (1999) New Testing
       Apparatus for Assessing Interactive Effects of Suspended Solids and Chemical Stressor
       on Plankton invertebrates. Environmental Toxicology and Chemistry, 18:4 679-684.

Selected, authored ATSDR Health Assessment Reports on mercury

       2005  Rosemount Woods mercury incident. Report includes discussion of:
       decontamination; the need for exposure and medical screening during the incident;
       methods of evaluating individual exposures; the environmental .chemistry of mercury;
       quality assurance and control issues related to the use  of real-time mercury vapor
       analyzers; evacuation criteria; re-occupation criteria; vehicle clearance criteria;
       discussion on the clearance of personal property, and risk communication.
       2003  Drum-top bulb crusher demonstration at the MinneapoHs-St. Paul
       International Airport. Report reviews published information about mercury contained
       in and released from fluorescent light bulbs when they are discarded, as well as data
       acquired during a demonstration of a fluorescent bulb crusher. Regulatory restrictions on
       the use of this machine in Minnesota are discussed.
       2003  Onyx Special Services, Incorporated. Report is a review of issues related to
       human health following attempts to cleanup a mercury recycling facility.
       2002  Chemically contaminated South Minneapolis residence. Report reviews
       mercury vapor data acquired using hopkalite tubes (1998) and 2 different realtime
       monitors (2000,2001) to evaluate indoor contamination in a house where an amateur
       chemist used many processes to reclaim precious metals from disposed products.
       2001  Mercury from a gas regulator spill. Mercury in a low-pressure gas regulator
       was spilled in the basement of a residence. This report evaluates exposures that may have
       resulted from the spill and the cleanup.
       2001  Mercury in a Marine residence. Report evaluates the potential exposures that
       may occur when thermometers (4) are broken in a home.
-------
                                Steven E. Lindberg

Environmental Sciences Division                    email: lindbergse@oml.goy
Oak Ridge National Laboratory                      Phone: (865)574-7857
P.O. Box 2008, Oak Ridge, TN 37831-6038           Fax:(865)576-8646

Education  •
Duke University       B.S.  ,1969   Chemistry
Florida State University M.S.   1973   Chemical Oceanography *
Florida State University Ph.D.  1979   Geochemistry

Professional Experience
1971-1974     Graduate Fellow, Florida State University Department of Oceanography,
             - Tallahassee.   .  .
1974-1986     Research Associate and Staff Mem ber, Oak Ridge National Laboratory, Oak
              Ridge, TN.
1987          Visiting Professor, Institute of Bioclimatology, University of Go'ttingen,
              Germany.
1994          Visiting Scientist, Swedish Environmental Research Institute, GcHeborg,
              Sweden.                           "             '            "
1995          Visiting Professor, University of Stockholm and University of Lund, Sweden
1996-1997     Visiting Scientist, Institute of Hydrophysics, GKSS Fed. Laboratory, Geestacht,
              Germany
1995-present   Adjunct Professor, School of Public Health, University of Michigan, Ann
              Arbor, MI; Dept. of Ecology and Evolutionary Biology, The University of
              Tennessee, Knoxville, TN
1987-1999     Senior Research Staff Member, and Group Leader for Atmospheric and
              Biogeochemical Cycling
20QQ-present   ORNL Corporate Research Fellow, Environmental Sciences Division, Oak
              Ridge National Laboratory, Oak Ridge, TN.
2002          Visiting Scientist, Institute of Ecosystem Studies, NY

Honors and Awards
• Alexander von Humboldt Foundation Fellowship Award, 1986-1987
• Elected Fellow, American Association for the Advancement of Science, 1992
• Lab-wide Publication and Technical Achievement Awards, 1985,1986,1997, and 2001
• Nominated for Ernest Orlando Lawrence Award, 1990, and ORNL Scientist of the Year, 2001
• American Men and Woman of Science, Who's Who in Science and Technology
• Environmental Sciences Scientific Achievement Award, 1984
• Oak Ridge National Laboratory Significant Achievement Awards: 1983, 1985, 1992,1995

Professional Activities
• Associate Editor, Environmental Reviews, Science of the Total Environment, Tellus (Sweden)
• Member, Review Boards: EPA Science Advisory Board for Mercury, Swedish EPA Mercury
  Panel
• Chairman, International Conference on Mercury as A Global Pollutant, 1995-1996; 1999-2001
• Director for Atmospheric Research, Integrated Forest Study, 1986-1990
• Chairman, United States National Atmospheric Deposition Program; 1988-1989
• Conference Chairman (1986-87) and Member of Conference Honorary Committee (since
  1983) for the International Conference on Heavy Metals in the Environment
-------
Publications
       Six books edited, and over 200 publications authored in the open literature, with more
       than 110 in refereed journals in the fields of atmosphere/surface exchange, trace metal
       chemistry, and biogeochemical cycling. Invited lecturer or plenary speaker on
       atmospheric deposition, mercury, and canopy interactions at more than 100 institutes and
       conferences in North America, Europe, South America, and Asia.
Funded Proposals. Contracts, and Grants (with ORNL collaborators unless otherwise noted):

1970-1979
    •   1975-1976, "Trace Element Emissions from Coal Fired Power Plants" (with A Andren).
       US Dept. of Energy (DOE) ($50,000).
    •   1975-1976, "Geochemical Cycling of Hg in a River-Reservoir System" (with R Turner).
       NSF-RANN ($90,000).
    •   1978, "Mercury Emissions from Mine Spoils" (with D Jackson). NSF-RANN ($75,000).
    •   1977-1980, "Trace Element Deposition, Stream Chemistry, and Cycling in Forest
       Watersheds" (with R. Turner). US DOE ($ 1,000,000).

1980-1989
    •   1981 -1982, "Dry Deposition to Petri Dish and Foliar Surfaces" (with C Davidson, CMU).
       US Environmental Protection Agency (EPA) ($30,000).
    •   1981-1983, "Acid Deposition/Forest Canopy Interactions: Mechanisms of Sulfur and
       Nitrogen Deposition to Forests." Electric Power Research Institute (EPRI) ($675,000).
    •   1981-1984, "Atmosphere/Canopy Interactions: Wet Deposition and Rain Chemistry." US
       DOE ($900,000).
    •   1985-1989, "Integrated Forest Study (IPS) of the Effects of Atmospheric Deposition on
       Forest Nutrient Cycles" (with D Johnson) EPRI (total project $11,600,000).
    •   1985-1989, "Atmosphere/Canopy Interactions: Development of Surface Analysis
       Methods for Dry Deposition." US DOE ($920,000).
    •   1987, "Deposition and Atmospheric Chemistry of Nitrogen Compounds" (with G.
       Gravenhorst, U. Gottingen). West German Federal Ministry for Technology and
       Alexander von Humboldt Foundation ($45,000).
    •   1989, "Atmospheric Deposition and Red Spruce Nutrition in the Great Smoky Mountains
       National Park" (with D Johnson and H Van Miegroet). USDA Forest Service
       ($225,000).

1990-1999
    •   1990, "A Soft lonization Mass Spectrometer for the Simultaneous, Real-time Analysis of
       Biogenic Non-
    •   methane Hydrocarbons in the Forest Canopy Airspace" (with M Payne, W Chen, and P
       Hansen). ORNL Seed Money Committee ($100,000).
    •   1990, "Integrated Forest Study of the Effects of Atmospheric Deposition on Forest
       Nutrient Cycles: Synthesis of Results." (with D Johnson) EPRI ($198,000).
    ••  1990, "Atmospheric Deposition'and Red Spruce Nutrition in the Great Smoky Mountains
       National Park-Testing the Al Hypothesis" (with H Van Miegroet). USDA Forest Service
       (total project $235,000).
    •   1990-1991, "Development of Methods for Network Sampling of Air Toxics in
       Precipitation" (with S. Vermette, ISWS) USGS ($70,000).
-------
2000
       1991-1994, "Atmosphere/Canopy Interactions: Surface Analysis of Dry Deposition in.
       Complex Terrain". US DOE ($700,000).
       1992-1996, "Air/Surface Exchange of Mercury (MASE): Development of Flux Methods
       and Models". EPRI ($1,195,000).
       1993-1995, "Elevational Trends in Deposition in the Smoky Mountains" (with S. Nodvin,
       USBS).  NFS ($150,000).
       1994-1995, "Aerosols at the Sea/Land Interface", (with B Wiman, U Lund) Swedish NFR
       (NSF) (30,OOOKr).
       1996, "Emission of Mercury from Freshwater Lakes". USEPA ($18,000).
       1996-1997, "Emission of Mercury from soils in the Elbe River Floodplain". (with R.
       Ebinghaus, GKSS) German BMFT (15,OOODM).
       1996-1999, "Mercury Emissions from Wetlands in the Florida Everglades". South Florida
       Water Management District ($400,000).
       1997-1998, "Mercury Fluxes and Exposure over Contaminated Industrial Soils". ABB
       Engineering ($32,000).
       1997-2000, "Mercury Emissions from Landfills in Florida". Florida DEP ($190,000).
       1997-2000, "Natural Mercury Emission Study (NaMES): Their Role in the Global
       Cycle",  (with M. Gustin, UNR) EPRI (total project $580,000).
       1997-2000, "Air/Surface Exchange of Mercury in the Lake Superior Watershed". Lake
       Superior Trust ($250,000).
       1998-1999, "Intercomparison of Speciation Methods for Reactive Gaseous  Mercury in
       Ambient Air", (with
       W. Stratton, Earlham College) Florida DEP ($20,000).
       1998-2000, "Air Mass Trajectories of Mercury Transport in the Arctic Environment"
       (with T.  Meyers, ATDD) NOAA ($100,000).
       1998-2003, "Atmospheric Deposition in Mountainous Terrain: Scaling up to the
       Landscape", (with K  Weathers and G Lovett, IES)  USEPA and NPS (total project
       $580,000).
       1999, "Pilot Studies with Stable Isotopes to Quantifying Air/surface Exchange Rates of
       Hg, USDOE ($280,000).
       1999-2000, "Dry Deposition of Mercury in the Florida Everglades", (with G. Keeler,
       UMAQL) Florida DEP (total project $200,000).
       1999-2000, "Emission of Mercury from Chlor-alkali Plants", (with J. Kinsey, NERL)
       USEPA  (total project $200,000)..
       1999-2000, "Chlor-alkali wastes: Assessing their Role as a Mercury Source in the Great
       Lakes",  (with J. Nriagu, UM) Great Lakes Protection Fund (total project $225,000).
       1999-2000, "Evaluating a reactive gaseous mercury sampler for the Arctic". USEPA and
       Florida DEP ($65,000).
       2000-2002, "The role of plants & soils in the biogeochemical cycling of Hg on an
       ecosystem level, (with UNR/DRI), EPA EPSCOR, ($60,000).
       2000-2002, "Mercury transport and fate through a watershed: The role of Hg reduction
       reactions, (with J. Nriagu), USEPA STAR Grant, ($260,000).
       2000-2004, "Applications of Stable Isotopes to Quantifying Air/surface Exchange Rates
       of Hg in Whole-ecosystem Manipulation Studies at the ELA, Canada, USDOE
       ($1,270,000).
       2000-2004, "Fugitive Mercury Emissions from Non-combustion Sources in the Great
       Lakes Region, (with Frontier Geosciences), USEPA, GLNPO, ($200,000).
-------
    •  2001 -2002, "MethyImercury Production in Florida Landfills".  Florida DEP ($ 140,000).
    •  2001-2003, "Mercury Emissions from Natural Processes: Scaling to the Landscape".
       (with M. Gustin, UNR) EPRI ($ 170,000).
    •  2001 -2004, "Dynamic Oxidation of Mercury in the Arctic Environment" (with S. Brooks,
       ATDD) NOAA ($295,000).
    •  2002-2005, "Assessment of Natural .Source Mercury Emissions" (with UNR/DRI), EPA
       STAR, (total project $891,500).                          •

/gronte last updated in Dec; 2002]            •
Students Supervised:

Advisor to ORNL Student Interns
       S. Henry, B.S., Chemistry, Earlham College (1976)
       S. Kimbrough, B.S., Biology, College of the South (1976)
       W. Petty, B.S., Biology, Grinnell College (1986)
       A. Pendergrass, B.S., Civil Engineering, Auburn University (1993)
       T. Kuiken, B.S., Chemistry, Rochester State (1999)
       J. Ramierez, Chemistry, U. Puerto Rico (2000)
Advisor to Postdoctoral Researchers at ORNL

    •  Dr. G. Lovett (Ph.D., Ecology, University of New Hampshire), ORAU Postdoctoral
       Fellow (1982-1984) (currently Sr. Scientist, Institute of Ecosystem Studies, NY)
    •  Dr. D. Schaefer (Ph.D., Biogeochemistry, University of New Hampshire), ORAU
       Postdoctoral Fellow (1986- 1988, currently Asst. Prof., University of Puerto Rico)
    •  Dr. K.-H. Kim (Ph.D., Marine Chemistry, .University of South Florida), ORNL
       Postdoctoral Fellow (1992- 1994, currently Asst. Prof, University of Seoul, Korea)
    •  Dr. Hong Zhang (Ph.D., Soil Chemistry, University of Vermont), ORNL Postdoctoral
       Fellow (1998-2001, currently Assoc. Prof., Tennessee Tech. University, Cookeville)
    •  Dr. Weijin Dong (Ph.D., Plant Physiology, Tulane University), ORNL Postdoctoral
       Fellow (2000-2002, currently Assoc. Prof., McNeese State University)
-------
Adjunct Faculty Committee Member for Graduate Students

    •   C. Potter, Ph.D. in Ecology, Emory University (1983-1985)
    •   M. Hoyer, Ph.D. in Atmospheric Chemistry, Air Toxics Laboratory, School of Public Health,
       University of Michigan (1992-1995)
    •   A. Rea, Ph.D. in Air Quality, Air Quality Measurements Laboratory, School of Public Health,
       University of Michigan (1994-1998)
    •   J. Shubzda, M.S. in Forestry, School of Fisheries, Forestry, and Wildlife,
    •   The University of Tennessee (1995-1999)
    •   A. Carpi, Ph.D. in Environmental Toxicology, Cornel! University (1994-1996).
    •   A. Vette, Ph.D. in Air Quality, Air Quality Measurements Laboratory, School of Public Health,
       University of Michigan (1996-1999).
    •   M. Goodsite, Ph.D. in Atmospheric Chemistry, Department of Chemistry, University of
       Copenhagen, Denmark (2000-present).

Invited Faculty Opponent for Ph.D. Defense
       W. Ivens, Ph.D. in Biogeochemistry, University of Utrecht, The Netherlands
       (1989-1991)
       Z. Xiao, Ph.D. in Inorganic Chemistry, Chalmers University of Technology, Goteborg, Sweden
       (1994-1995)
       M. Coggin, Ph.D. in Atmospheric Chemistry, University of Galway, Ireland (1999-2000)
       J. Benesch, M.S. in Environmental Science, University of Nevada, Reno (2001-2002)
Expert External Reviewer for Habilitation to Professor

    •   Dr. D. Godbold, Habilitation candidate, University of Gottingen, Germany (1990)
    •   Dr. R. Ebinghaus, Habilitation candidate, University of LQiieberg, Germany (2002)

Informal PhD Advisor          ;

    •   D. Walschlager, Ph.D. in Geochemistry, University of Hamburg, Germany (1995-1996)
    •   T. Frescholtz, M.S. in Environmental Science, University of Nevada, Reno (2001-2002)
    •   K. Scott, Ph.D. in Microbiology, University of Manitoba, Winnipeg, Canada (2001-2002)

Publications-fin prep and submitted)    [updated Apr 2003, published list starts below]

Lindberg, S.E., G. Southworth, E.M. Prestbo, D. WallschlSger, M. A. Bogle, J. Price.  Gaseous
methyl-and inorganic mercury in landfill gas from landfills in Florida, Minnesota, and
California. Atmos. Envir. (in prep).

Schroeder, W.H., A. Steffen, K. Scott, T. Bender, E. Prestbo, R. Ebinghaus, J.Y. Lu and S. E.
Lindberg. First International Arctic atmospheric mercury research workshop. Atmos. Envir.
(submitted).

Amyot, M., G.  Southworth, S.E. Lindberg, H. Hintelmann,  J.D. Lalonde, C. Gilmour, J.W.M.
Rudd, C.A. Kelly, R. Harris, F.M.M. Morel, A.Poulain, Ken Sandilands.  Evolution of dissolved
-------
                                                 2UU
gaseous mercury in large lake enclosures amended with  HgCh. Can J. Fish Aq Sci (submitted).

Southworth, G. R., S. E. Lindberg, H. Zhang, J. S. Kinsey, F. Anscombe, and F. Schaedlich.
Fugitive mercury emissions from a chlor-alkali facility: sources and fluxes to the atmosphere.
Atmos. Envir. (submitted).

Kinsey, J. S., Swift, J., Bursey, J., Lindberg, SE, and Southworth, G. Characterization of
mercury emissions from the cell building at a U. S. chlor-alkali plant. Atrrios. Envir.
(submitted).

Lindberg, S., G. Southworth, M. Bogle, T. Biasing, H. Zhang, T. Kuiken, D. Wallschlaeger, J.
Price, D.  Reinhart, H. Sfeir, J. Owens, and K. Roy. Airborne emissions of mercury from
municipal solid wasteNew measurements from three landfills in Florida. JAWMA, (submitted).
                                                           j
W. Dong, S.E. Lindberg, T. Meyers, and J. Chanton. A proposed mechanism of gaseous
mercury emission mediated via aquatic plant in the Florida Everglades. Atmos. Envir. (in prep.)

Brooks, SB, K. Scott, and SE Lindberg. Surface Mercury Hg(0) Emissions during Annual
Snowmelt at Barrow, Alaska. J. Geophys. Res. (in prep. 5/02).

Brooks, SB, M. Goodsite, SE Lindberg, M Landis, and R. Stevens. Aircraft Studies of
Atmospheric Mercury Conversion in the Arctic Marine/Coastal Boundary Layer. Nature (in
prep. 6/02).                          "  '

Tate, Scherbatskoy, Donlon, Keeler, Shanley, Lindberg. Dry Deposition of Hg to a Northern
Hardwood Forest (in prep 5/02).

Brooks S., and S. E. Lindberg. Estimates of Springtime Atmospheric Mercury Deposition rates
at Barrow, Alaska from Stable Boundary Layer Inverse Method. J. Geophys. Res. (in revision).

Publications (in printl [updated Apr 2003, new submissions listed above]
Books and Whole Journal Issues:

L. Levin, D. S. E.Lindberg, and D. Porcella (Guest Eds.). 2000. Special Issue on Mercury
Biogeochemistry. Science of the Total Environment: Vols. 259-260-261, 511 pp. Elsevier Publ.,
N.Y.

Gustin, M-S., S. E.-Lindberg, and M. A. Allan (Guest Eds.). 1999. Special Issue: Nevada
SToRMS mercury flux intercomparison study: Constraining mercury emissions from naturally
enriched surfaces: Assessment of methods and controlling parameters. J. Geophys. Res: 104, No.
D17,  pp. 21829-21896. American Geophysical Union Publ., Washington.

Lindberg, S. E. (Sr. Guest Ed.). 1998. Special Issue: Atmospheric Transport, Chemistry and
Deposition of Mercury. Atmospheric Environment: 32, No. 5,134 pp. (807-940). Pergamon
Press, U.K:'
-------
Johnson, D.W., and S.E Lindberg (Eds.). 1992. Atmospheric Deposition and Forest Nutrient
Cycling, Ecological Studies Vol. 91, Springer-Verlag, New York, 707 pp.

Norton, S., S. E. Lindberg, and A. L. Page. (Eds.) 1990. Soils, Aquatic Processes, and Lake
Acidification, Advances in Environmental Sciences Series Acidic Precipitation, Vol. 4. Springer
Verlag, NY., 293 pp.

Lindberg, S. E., A. L. Page, and S. Norton. (Eds.) 1990. Sources, Deposition, and Canopy
Interactions, Advances in Environmental Sciences Series Acidic Precipitation, Vol. 3. Springer
Verlag, NY., 332 pp.

Lindberg, S. E. and T. C. Hutchinson (Eds.). 1987. Proceedings of the Sixth International
Conference on Heavy Metals in the Environment, New Orleans, LA, September 15-18, 1987,
CEP Limited Publishers, Edinburgh, UK.

Shriner, D. S., C. R. Richmond, and S. E. Lindberg (Eds.)  1980. Atmospheric Sulfur Deposition.
Ann Arbor Science Publishers, Ann Arbor, MI, 568 pp.

Journal Papers and Book Chapters:

In Press

Gustin, M-S., and S.E. Lindberg. Understanding the role of natural ecosystems in the
biogeochemical cycle of Hg. Proc. Air Quality-Ill (in press).

2000's               ..       '

Johnson, D.W., Benesch, J.A., Gustin, M.S., Schorran, D.E., Coleman, J., and Lindberg, S.E.
2003. Soil gaseous Hg and CO2 concentrationsresponse to watering, plants, and evidence
against diffusion control of Hg flux, Science of the Total Environment 304:175-184.

Gustin, M.S, M. Coolbaugh, M. Engle, B. Fitzgerald, R:Keislar, S. Lindberg, D. Nacht, J.
Quashnick, J. Rytuba, C. Sladek, H. Zhang, R. Zehner. 2003. Atmospheric Mercury Emissions
from Mine Wastes and Surrounding Geologically Enriched Terrain. Envir. Geol. 43:339-351.

J. Ericksen, M.S. Gustin, D.  Schorran, D. Johnson, S. Lindberg, and J. Coleman. 2003.
Accumulation of atmospheric mercury in forest foliage, Atmos. Envir. 37:1613-1622.

Hintelmann, H., V. StXouis, K. Scott, J.Rudd, S. E. Lindberg, D. Krabbenhoft, C. Kelly,A.
Heyes, R. Harris, and J. Hurley. Reactivity and mobility of newly deposited mercury in a Boreal
catchment, 2003. Envir. Sci. & Techno!. 36:5034-5040.     ..                          ..

Lindberg, S. E., W. Dong, and T. Meyers. 2002. Transpiration of gaseous mercury through
vegetation in a subtropical wetland in Florida. Atmos. Envir. 3j6: 5200-5219.

Zhang, H, Lindberg, S, Gustin, M, and Xu, X. Towards A Better Understanding of Mercury
Emissions from Soils. IN Cai, Y, and Braids, O. C. Eds., Biogeochemistry of Environmentally
Important Trace Elements, ACS Symposium Series 835, American Chemical Soc, Washington.
-------
Wallschleger, D., Kock, H.H., Schroeder, W.H., Lindberg, S.E., Ebinghaus, R. and Wilken, R.D.
2002. Estimating gaseous mercury emissions from contaminated floodplain soils to the
atmosphere with simplified field measurement techniques. Water, Air, Soil, Pollut. 135: 39-54.

Van Miegroet, H. IF. Creed, N.S. Nicholas, D.G. Tarboton, K.L. Webster, J. Shubzda, B.
Robinson, J. Smoot, D.W. Johnson, S.E. Lindberg, G. Lovett, S. Nodvin, S. Moore. 2001. Is
there synchronicity in N input and output fluxes at the Noland Divide Watershed, a small N-
saturated forested catchment in the Great Smoky Mountains National Park? In Optimizing
Nitrogen Management in Food and Energy Production and Environmental ProtectionProceedings
of the 2nd International Nitrogen Conference on Science and Policy: TheScientificWorld 1 (S2),
480-492.

Lindberg, S. E., Brooks, S.B., C-J. Lin, K. J. Scott, M. S. Landis, R'. K. Stevens, M. Goodsite,
and A. Richter. 2002. The Dynamic Oxidation of Gaseous Mercury in the Arctic Atmosphere at
Polar Sunrise, Envir. Sci. & Technol. 36: 1245-1256.

Zhang, H, Lindberg, SE, Barnett, MO, Vette, AF, Gustin, MS. 2002. Dynamic flux chamber
measurement of gaseous mercury emission fluxes over soils, Part 1 Simulation of gaseous
mercury emissions from soils measured with dynamic flux chambers using a two-resistance
exchange interface model. Atmospheric Environment 36: 835-846.

Lindberg, SE, Zhang, H, Vette, AF, Gustin, MS, Barnett, MO, and Kuiken, T. 2002. Dynamic
flux chamber measurement of gaseous mercury emission fluxes over soils, Part 2 Effect of
flushing flow rate and verification of a two-resistance exchange interface simulation model.
Atmospheric Environment 36: 847-859.

Zhang, H., and S.E. Lindberg.  2002. Dissolved gaseous mercury in Whitefish bay and the
Taquemenon River watershed in the Michigan Upper Peninsula: Distribution and dynamics.
Water, Air, Soil, Pollut. 133: 379-389.

Rea, A.W.; Lindberg, S.E.; Scherbatskoy, T. 2002. Mercury accumulation in foliage over time
in two northern mixed-hardwood forests. Water, Air, Soil, Pollut. 133: 49-67.

Lindberg, S. E., S. Brooks, C-J Lin, K.  Scott, T. Meyers, L. Chambers, M, Landis, and R.
Stevens. 2001. Formation of reactive gaseous mercury in the arcticevidence of oxidation of Hg°
to gas-phase Hg-II compounds after arctic sunrise Water, Air and Soil Pollution: Focus, 1:295-
302.

Lindberg, S.E., S.B. Brooks, M. Landis, and R. Stevens. 2001.  Comments on atmospheric
mercury species in the European Arctic: Measurements and modeling, Atmospheric
Environment 35:5377-5378.

Levin, L., Lindberg, S. and Gustin, M.  2001. Uncertainties in Mass Balance of U.S.
Atmospheric Mercury Emissions. IN Air-Surface Exchange of Gases and Particles Poster
Proceedings (D. Fowler,

C. E. R. Pitcairn, L. Douglas and J-W. Erisman, Eds.). Publ. By Center for Ecology and
Hydrology, Edinburgh.
-------
Lindberg S. E. and T. P. Meyers. 2001. Development of an automated micrometeorological
method for measuring the emission of mercury vapor from wetland vegetation. Wetland Ecology.
& Management, 9: 333-347.

St.Louis,.VL, JW Rudd, CA. Kelly, BD.Hall, KR. Rolfhus, KJ. Scott, SE. Lindberg, and W
Dong, 2001. The importance of the forest canopy to fluxes of methyl mercury and total mercury
to boreal ecosystems, Envir. Sci. & Technol. 35:.3089-3098. .

Munthe, J., I. Wangberg, N. Pirrone, A. Iverfeldt, R. Ferrara, P. Costa, R. Ebinghaus, X.Feng, K.
Girdfelt, G. Keeler, E. Lanzillotta, S. E. Lindberg, J. Lu, Y. Mamane, E.Nucaro, E. Prestbo, S.
Schmolke, W. H. Schroeder, J. Sommar, F. Sprovieri, R.K.Stevens, W. Stratton, G. Tiincel, A.  .
Urba. 2001. Intercomparison of methods for sampling and analysis of atmospheric mercury
species. Atmos. Env. 353007-3017.                                     .

Lindberg, S.E., D. Wallschlaeger,  E. Prestbo, N. Bloom, J. Price, and D. Reinhart. 2001.
Methylated mercury species in municipal waste landfill gas sampled in Florida. Atmospheric
Environment 35:4011-4015.
   (
Lindberg, S. E., Brooks, S., Lin, C-J., Scott, K., Richter, A., Meyers, T., Stevens, R., and
Landis, M. 2001. Studies of interactions between reactive gaseous mercury and elemental
mercury vapor during polar spring at Point Barrow, Alaska. Proc. of International Symposium on
the Measurement of Toxic and Related Air Pollutants Symposium held in Research Triangle
Park, North Carolina, September 1214, 2000.

Rea, A.W., S.E. Lindberg, and G.  Keeler. 2001. Dry deposition and foliar leaching of mercury
and selected trace elements in deciduous forest throughfall. Atmospheric Environment 35: 1352-
2310.

Zhang, H, and S.E. Lindberg. 2001. Sunlight and iron(III)-induced photochemical production of
dissolved gaseous elemental mercury in fresh water. Envir. Sci. & Technol. 35: 928-935.

Stratton,  W.  J., S. E. Lindberg, and C.J. Perry. 2001. Atmospheric Mercury Speciation: Critical.
evaluation of a mist chamber method for measuring reactive gaseous mercury, Envir. Sci. &
Technol. 35: 170-177.              .                                           .

Zhang, H., S. E. Lindberg, F. J. Marsik, and G. J. Keeler.  2001. Mercury air/surface exchange
kinetics of background soils of the Taquamenon River watershed in the Michigan Upper
Peninsula. Water, Air, Soil, Pollut. 126: 151-169.

Lindberg, S. E., S. Brooks, C-J Lin, K. Scott. 2001. Recent research on missing sources and
sinks in the global mercury cycle:  The role of the Arctic. Proc. NIMD Forum-01, publ. by the
National Institute of Minamata Disease  Press, pp. 53-58.

Gustin, M..S. and S. E. Lindberg. 2000. Assessing the contribution of natural sources to the
global mercury cycle: The importance of intercomparing dynamic flux measurements.  Invited
paper for Fresenious Journal of Analytical Chemistry, 366: 417-422.

Zhang  H., and S. E. Lindberg.  2000. Air/water exchange of mercury in the Everglades I: The
-------
 behavior of dissolved gaseous mercury (DGM). Science of the Total Environment 259:123-134.

 Lindberg, S. E., and Zhang H. 2000. Air/water exchange of mercury in the Everglades II:
 Measuring and modeling evasion of mercury from surface waters. Science of the Total
 Environment 259: 13 5144.

 Gustin, M..S. and S. E. Lindberg, K. Austin, M. Coolbaugh, A. Vette, and H. Zhang. 2000.
 Assessing the contribution of natural sources to regional atmospheric mercury budgets. Science
 of the Total Environment 259: 61 -72.

 Rea, A.W., S.E. Lindberg, and G. Keeler. 2000. Development of a washing technique for
 measuring dry deposition of mercury to foliage and surrogate surfaces, Envir. Sci. & Technol.
 34:2418-2425.

 Lindberg, S.E., S, Brooks, C-J Lin, T. Meyers, and L. Chambers. 2000. BAMS- the Barrow
 Arctic Mercury Study: a preliminary description of recent measurements of mercury depletion
 events at Point Barrow, Alaska. CD-ROM Proceedings, 25 International Conference on Heavy
 Metals in the Environment, Ann Arbor, MI (6-10 August, 2000).

 Marsik, F.J., G. Keeler, E. G. Malcolm, J. T. Dvonch, J. A. Barres, S. E. Lindberg, H. Zhang, R.
 K. Stevens and M. S. Landis. 2000. FEDDS: The Florida Everglades Dry-Deposition Study.
                        Hi
 CD-ROM Proceedings, 25 International Conference on Heavy Metals in the Environment, Ann
 Arbor, MI (6-10 August, 2000).

 Lindberg, S. E^, P. J. Hanson, W. Strattoh, T. Meyers, K. Kim, A. Carpi, H. Zhang, J. Owens, M.
 Gustin, RTurner, J. Munthe, F. Schaedlich, J Price, M. Barnett, and D. Wallschleger.  2000. The
 Role of Mercury Air/surface Exchange Processes in the Global Biogeochemical Cycle: a Brief
 Summary of Research by the ORNL Mercury Group, Proc. NIMD Forum-99, publ. by the
 National Institute of Minarnata Disease Press.

 Lindberg, SE, A. Vette, C. Miles, and F. Schaedlich. 2000. Application of an automated
 mercury analyzer to field speciation measurements: Results for dissolved gaseous mercury in
 natural waters. Biogeochemistry,  48(2), 237-259.

 Lindberg, S. E., W. J. Stratton, P. Pai, and M- Allan.  2000. Measuring and modeling
 concentrations of a water-soluble gas-phase mercury species in ambient air. Fuel Proc. Technol.
 1288: 65, 143-156.

'Wallschleger, D., Kock, H.H., Schroeder, W.H., Lindberg, S.E., Ebinghaus, R. and Wilken, R.D.
 2000. Mechanism and significance of mercury volatilization from contaminated floodplains of
 the German river Elbe. Atmos. Environ 34:3745-3755.

 1990's

 Weathers, K.C., G.M. Lovett, S.E. Lindberg, S.M. Simkin, D.N. Lewis and M.L.  Chambers.
 1999. Atmospheric deposition in mountainous terrain: Scaling up to the landscape. EOS, Trans.
 American Geophysical Union: 80, 390.
-------
Lindberg, S. E., D. Reinhart, P. McCreanor, and J. Price.  1999. Pathways of mercury release in
municipal solid waste disposal: A preliminary data report. Proceedings Sardinia 99, Seventh
International Waste Management and Landfill Symposium, 4-8 October, 1999, pp. 225-232.
CISA, Environmental Sanitary Engineering Centre, Cagliari, Italy.

Gustin, M-S., S. E. Lindberg, and M. A. Allan.  1999. Preface to the Nevada StoRMS mercury
emissions project special issue. J. Geophys. Res: 104,21829-21830.

Lindberg, S.E., Zhang, H., Gustin, M., Vette, A., Owens, J., Marsik, F., Casimir, A., Ebinghaus,
R., Edwards, G., Fitzgerald, C., Kemp, J., Kock, H.H., London, J,. Majewski, M., Poissaht, L.,
Pilote, M., Rasmussen, P., Schaedlich, F., Schneeberger, D., Sommar, J., Turner, R., Walshlager,
D., and Xiao, Z. 1999. Increases in mercury emissions from desert soils in response to rainfall
and irrigation. J. Geophys. Res: 104,21879-21888.                            .

Zhang, H. and Lindberg, S.E.  1999. Processes influencing the emission of mercury from soils: a
conceptual model, J. Geophys. Res: 104, 21889-21896.

Gustin, M-S., S. E. Lindberg, Casimir, A., Ebinghaus, R., Edwards, G., Fitzgerald, C., Kemp, J.,
Kock, H.H., London, J,. Majewski, M., Owens, J., Marsik, F., Poissant, L., Pilote, M.,
Rasmussen, P., Schaedlich, F., Schneeberger, D., Sommar, J., Turner, R., Vette, A., Walshlager,
D., Xiao, Z., and Zhang, H. 1999. The Nevada SToRMS Project: Measurement of mercury
emissions from naturally enriched surfaces. J. Geophys. Res: 104,21831-21844.

Lindberg, SE, and J Price. 1999. Measurements of the airborne emission of mercury from
municipal landfill operations: A short-term study in Florida. J. Air and Waste Man. Assoc.
49:174-185.

Ebinghaus, R., Tripathy, R., Wallschleger, D., and Lindberg, S.E. 1999. Natural and        ; *
anthropogenic mercury sources and their impact on the air-surface exchange of mercury on th^
global scale. IN Ebinghaus, R., Turner, R., LaSerda, D., Vasiliev, O., and Salomons, W. (Eds.),
Mercury contaminated sites: Characterization, risk assessment, and remediation, pp. 1-50.
Springer-Verlag Environmental-Science Series.

Lindberg, S. E., P. J. Hanson, T.P. Meyers, and K-Y Kim.  1998. Micrometeorological studies of
air/surface exchange of mercury over forest vegetation and a reassessment of continental
biogenic mercury emissions. Atmos. Envir. 32:895-908.

Carpi, A. and S.E. Lindberg.  1998. Application of a teflon dynamic flux chamber for
quantifying soil mercury fluxes: tests and results over background soils. Atmos. Envir. 32:873-
882.

Lindberg, S. E. 1998. A Listening and Liberating Science: The Ultimate Problem of Education.
IN The Art of Natural Resource Management: Poetics, Policy, Practice (Eds.: B.L.B. Wiman, I.
M. B. Wiman, S. L. Vanden Akker), pp. 348-351. Lund University Press.

Lindberg, S. E. and W. J. Stratton. 1998. Atmospheric mercury speciation: Concentrations and
behavior of reactive gaseous mercury in ambient air. Envir. Sci. & Technol. 32:49-57.
-------
Carpi, A., S. E. Lindberg, E. M. Prestbo, andN. S. Bloom. 1997. Global and regional impacts of
elemental and methyl mercury emitted by soils to the atmosphere. J. Env. Qual. 26:1650-1655.

Hanson, P. J., T. Tabberer, and S. E. Lindberg.  1997. Emissions of Mercury Vapor from Tree
Bark. Atmos. Envir, 31: 777-780.

Kim, K-H., P. J. Hanson, M. O. Barnett, and S. E. Lindberg. 1997. Biogeochemistry of mercury
in the air-soil-plant system. Met. Ions Biol. Syst, 34:185-212.

Carpi, A. and S. E. Lindberg. 1997. The sunlight mediated emission of elemental mercury from
soil amended with municipal sewage sludge. Envir. Sci. & Technol. 31:2085-2091.

Lindberg, S. E. 1996. Forests and the Global Biogeochemical Cycle of Mercury: The
Importance of Understanding Air/vegetation Exchange Processes. IN: Baeyens, W., Ebinghaus,
R., Vasiliev, O. (eds.): Global and Regional Mercury Cycles: Sources, Fluxes and Mass
Balances. NATO-ASI-Series, Vol. 21, Kluwer Academic Publishers, Dordrecht, The
Netherlands, 359-380.

Iverfeldt, A., S.E. Lindberg, S. Karamata, G. Anoshin, M. Horvat, T. Laperdina, A. Obolenskiy,
K. Osmonbetov, C. Ramel, N, Roslyakov, and V. Tausen. 1996. Working group report on
terrestrial mercury cycling. IN: Baeyens, W., Ebinghaus, R., Vasiliev, O. (eds.): Global and
Regional Mercury Cycles: Sources, Fluxes and Mass Balances. NATO-ASI-Series,  Vol. 21,
Kluwer Academic Publishers, Dordrecht, The Netherlands, 543-546.

Meyers, T.P., M.E. Hall, and S.E. Lindberg. 1996. Use of the modified Bowen ratio technique to
measure fluxes of trace gases. Atmos. Envir. 30: 3321-3329.                           »

Meyers, T.P. and S. E. Lindberg, 1996: Use of the Modified Bowen Ratio technique for
                                               id
determining fluxes of mercury. Proceedings of the 22 Conference on Agriculture and Forest
Meteorology with Symposium on Fire and Forest Meteorology, January 28 - February 2,1996,
Atlanta, GA, American Meteorology Society, Boston, MA, pp. 11-14.

D. Holland, C. Simmons, L. Smith, T. Conn, G. Baier, J. Lynch, J. Grimm, G. Oehlert, S.
Lindberg. 1995. Long-term trends in NADP/NTN precipitation chemistry data: results of
different statistical analyses. Water, Air, Soil Pollut. 85: 595-601.

Shubzda, J., S. E. Lindberg, C. T. Garten, and S. C. Nodvin.  1995.  Elevational trends in the
fluxes of sulfur and nitrogen in throughfall  in the southern Appalachian Mountains:  Some
surprising results. Water, Air, Soil, Pollut. 85:2265-2270.

Nodvin, S. C., H. VanMiegroet, S. E. Lindberg, N. S. Nicholas, and D. W. Johnson. 1995.
Acidic deposition: Ecosystem processes and nitrogen saturation in a high elevation southern
Appalachian watershed. Water, Air, Soil, Pollut. 85: 1647-1652.

Lindberg, S. E., Meyers, T. P., and J. Munthe.  1995. Evasion of mercury vapor from the surface
of a recently limed acid forest lake in Sweden. Water, Air, Soil, Pollut. 85: 725-730..

Kim, K.-H., Lindberg, S. E., and Meyers, T. P.  1995. Micrometeorological measurements of
-------
mercury fluxes over background forest soils in eastern Tennessee. Atmos. Envir. 27:267-282.
                 1                         .                                     '«.*•
Stratton, W. J. and S. E. Lindberg.  1995. Use of a refluxing mist chamber for measurement of
gas-phase water-soluble mercury (II) species in the atmosphere. Water, Air, Soil, Pollut. 80:
1269-1278.

Lindberg, S.E., K-H. Kirn, T.P. Meyers, and J.G. Owens.  1995. A micrometeorological gradient
approach for quantifying air/surface exchange of mercury vapor: Tests over contaminated soils.
Envir. Sci. Technol. 29:126-135.

Lindberg, S. E., K.-H. Kim, and J. Munthe. 1995. The precise measurement of concentration
gradients of mercury in air over soils: a review of past and recent measurements. Water, Air,
Soil, Pollut. 80: 383-392.

Vermette, S.J., M.E. Peden, T.C. WUloughby, S.E. Lindberg, and A.D. Weiss. 1995.
Methodology for the sampling of metals in precipitation: Results of the National Atmospheric
Deposition  Program (NADP) pilot network. Atmos. Envir. 29:1221-1230.

Kim, K.-H and S. E. Lindberg.  1995. Design and initial tests of a dynamic enclosure chamber
for measurements of vapor-phase mercury fluxes over soils. Water, Air, Soil, Pollut. 80: 1059-
1068.                                                                               .

Vermette, S.J., S.E. Lindberg, and N. Bloom. 1995. Field tests for a regional mercury deposition
network: Sampling design and test results. Atmos. Envir. 29:1247-1252.

Johnson, D. W. and S. E. Lindberg.  1995. Sources, sinks, and cycling of Mercury in forested
ecosystems. Water, Air, Soil, Pollut. 80:1069-1077.

Lindberg, S.E. and S.J. Vermette. 1995. Workshop on sampling mercury  in precipitation for the
National Atmospheric Deposition Program. Atmos. Envir. 29: 1219-1220.

Hanson, P.  J., S. E. Lindberg, T. A. Tabberer, J. G. Owens, and K.-H. Kim. 1995. Foliar
exchange of mercury vapor: evidence for a compensation point. Water, Air, Soil, Pollut. 80: 373-
382.                           '                           .               .    ''

Lindberg, S.E., J.G. Owens, and W. Stratton. 1994. Application of throughfall methods to
estimate dry deposition of mercury. IN J. Huckabee and C. Watras, (Eds.), Mercury as A Global
Pollutant, pp. 261 -272. Lewis Publ.

Kim, K.-H. and Lindberg, S. E. 1994. High-precision measurements of mercury vapor in air:
Design of a six-port-manifold mass flow controller system and evaluation of mass flow errors at
atmospheric pressure. J. Geophys. Res. 99:5379-5384.                                  '.'

Erisman J. W., C. Beier, G. Draijers, and S. Lindberg. 1994. Review of deposition monitoring.
Tellus 46B: 79-93.                                                             '  .

Ross, H., and S.E. Lindberg. 1994. Atmospheric chemical input to small  catchments. IN B.  ;
Moldan and J. Cerny (Eds.), pp. 55-84, Biogeochemistry of Small Catchments: A Tool for
-------
Environmental Research, United Nations SCOPE Series Vol. 51, John Wiley and Sons.

Kim, K.K., S.E. Lindberg, PJ. Hanson, T.P. Meyers, and J. G. Owens. 1993. Application of
micrometeorological methods to measurements of mercury emissions over contaminated soils. In
Proceedings of the Ninth International Conference on Heavy Metals in the Environment, Vol I.
pp. 328331. CEP Limited Publishers, Edinburgh, UK. Text also reproduced in Proceedings of the
First Workshop on Emissions and Modelling of Atmospheric Transport of Persistent Organic
Pollutants and Heavy Metals, J.M. Pacyna et. al. (Eds.), USEPA Report EMEP/CCC-Report:
7/93,1993.

Lovett, G.M. and S.E. Lindberg. 1993. Atmospheric deposition and canopy interactions of
nitrogen in forests. Can. J. For Res. 23:1603-1616.

Erisman J. W., C. Beier, G. Draijers, and S. Lindberg.  1993. Deposition Monitoring:
Background Document. Appendix 6, IN Lovblad G., J. Erisman, and D. Fowler (Eds), Models
and Methods for the Quantification of Atmospheric Input to Ecosystems, Published by The
Nordic Council of Ministers, pp 163-183.

Feier C., S. Braun, J. Brook, G. Campbell, G. Draaijers, K. Hansen, D. Kallweit, R. Lenz, S.
Lindberg,

H. Staaf, and R. Stary. 1993. Deposition Monitoring. Chapter 7, IN LOvblad G., J. Erisman, and
D. Fowler (Eds), Models and Methods for the Quantification of Atmospheric Input to
Ecosystems, Published by The Nordic Council of Ministers, pp 37-41.

Lindberg, S. E. and J. G. Owens. 1993. Deposition to Edges and Gaps in Mountain Forests:
Throughfall Studies at Two Elevations in The Smoky Mountains. Biogeochemistry  19:173-194.

Johnson, D.W., S.E. Lindberg, H. Van Miegroet, G.M. Lovett, D.W. Cole, M.J. Mitchell, and D.
Binkley. 1993. Atmospheric deposition, forest nutrient status, and forest decline: Implications of
the Integrated Forest Study. IN Huettl, R., and Mueller-Dombois (Eds.), pp. 66-81, Proc.
International Conf.  on Forest Decline in the Pacific Rim., Springer-Verlag, NY.

Wu, Y-L., C.I. Davidson, Lindberg, and A. Russell. 1992. Resuspension of particulate chemical
species at forested sites. Envir. Sci. Technol. 26:2428-2435.

Lindberg, S. E. and G. M. Lovett. 1992. Deposition and forest canopy interactions of airborne
sulfur: Results from the Integrated Forest Study. Atmos. Envir. 26A: 1477-1492.

Tjoelker, M.G., S. B. McLaughlin, R. DiCosty, S.E. Lindberg, and R.J. Norby. 1992. Seasonal
Variation of Nitrate Reductase Activity in Needles of High-elevation Red Spruce Trees. Can. J.
For Res. 22: 375-380.

Lovett, G.M., and Lindberg, S.E.  1992. Concentration and deposition of particles and vapors in
a vertical profile through a forest canopy. Atmos. Envir. 26A: 1469-1476.

Lindberg, S.E., T.P. Meyers, G.E. Taylor, R.R. Turner, and W.H. Schroeder. 1992.
Atmosphere/surface exchange of mercury in a forest: Results of modeling and gradient
-------
approaches. J. Geophys. Res. 97: 2519-2528.

Bredemeier, M. and S.E. Lindberg.  1992. Stoffeintrage in Einzelniederschlags und periodischen
Gesamt Niederschlagsproben in einem Fichtenwald: Bin methodischer Vergleich.  Staub
Reinhaltung der Luft 52:67-72.

Lindberg, S. E., Garten C. T. Jr., Cape J. N., and Ivens W. 1992. Can sulfate fluxes in forest
canopy throughfall be used to estimate atmospheric sulfur deposition?-A summary of recent
results. IN, Slinn,

W.G.N. Precipitation Scavenging and Atmosphere-Surface Exchange,.Vol. 3, Applications and
Appraisals, pp.  1379-1390. Hemisphere Publ., Washington, DC, 1808 pp.

Johnson,  D. W., S. E. Lindberg, and L. F. Pitleka.  1992. Introduction. Chapter 1 IN Johnson,
D.W., and S.E Lindberg (Eds.). Atmospheric Deposition and Forest Nutrient Cycling,
Ecological Studies Vol. 91, Springer-Verlag, New York, pp.  1-7.

Lindberg, S.E. Atmospheric deposition and canopy interactions of sulfur!  1992. IN Johnson,
D.W., and Lindberg, S.E. (Eds.). Atmospheric Deposition and Forest Nutrient Cycling,
Ecological Studies Vol. 91, Springer-Verlag, New York, pp.  72-90 in Chapter 5: Sulfur cycles.

Lindberg, S. E., D. W. Johnson and E. A.-Bondietti.  1992. Background  on research sites and
methods.

Chapter 2 IN Johnson, D.W., and S.E Lindberg (Eds.). Atmospheric Deposition and Forest
Nutrient Cycling, Ecological Studies Vol. 91, Springer-Verlag, New York, pp. 8-26.

Mitchell, M. J.,  R. B. Harrison, J. W. Fitzgerald, D. W. Johnson, S. E. Lindberg, Y. Zhang, and '
A. Autry. 1992. Sulfur distribution and cycling in forests. IN Johnson, D.W., and S.E Lindberg
(Eds.).                       '     ,

Atmospheric Deposition and Forest Nutrient Cycling, Ecological Studies Vol. 91, Springer--
Verlag, New York, pp. 90-140 in Chapter 5: Sulfur cycles.

Ragsdale, H. L., S. E. Lindberg, G. M. Lovett and D. A. Schaefer. 1992. Atmospheric
deposition and throughfall fluxes of base cations. IN Johnson, D.W., and S.E Lindberg (Eds.).
Atmospheric Deposition and Forest Nutrient Cycling, Ecological Studies Vol. 91, Springer-
Verlag, New York, pp. 235-253 in.Chapter 8: Base'cations.

Schaefer, D. A., S. E. Lindberg and G. M. Lovett. Canopy Interactions. 1992. Processing of
acidic deposition. IN Johnson, D.W., and S.E Lindberg (Eds.). Atmospheric Deposition and
Forest Nutrient  Cycling, Ecological  Studies Vol. 91, Springer-Verlag, New York, pp. 444-449 .
in Chapter 11: Processing of acidic deposition.
-------
Lindberg, S. E. 1992. Summary and synthesis of the Integrated Forest Study: Atmospheric
deposition and its interactions with the forest canopy. IN Johnson, D.W., and S.E Lindberg
(Eds.). Atmospheric Deposition and Forest Nutrient Cycling, Ecological Studies Vol. 91,
Springer-Verlag, New York, pp. 571-580 in Chapter 14: Synthesis and modeling of the results of
the Integrated Forest Study.
                                                     -j
Johnson, D. W. and S. E. Lindberg. 1992. Implications of the Integrated Forest Study for
understanding forest nutrient cycles. IN Johnson, D.W., and S.E Lindberg (Eds.). Atmospheric
Deposition and Forest Nutrient Cycling, Ecological Studies Vol. 91, Springer-Verlag, New
York, pp. 580-582 in Chapter 14: Synthesis and modeling of the results of the Integrated Forest
Study.

Vermette, S. J., Peden, M., Hamdy, S., Willoughby, T., Lindberg, S. E., Owens, J. G., and Weiss,
A. 1992. A pilot network for collection and analysis of trace metal wet deposition. IN Verry, S.
and Vermette, S. J. (Eds.) Trace Metals in Atmospheric Deposition, USDA Forest Service
Report No. NC150, North Central Forest Experiment Station, St. Paul, MN.

Vermette, S. J., Peden, M., Willoughby, T., Lindberg, S. E., and Weiss, A. 1992. Pilot network
for metals in wet deposition. Preprint # 92-69.06, Air and Waste Mgmt. Assoc. 85th Ann. Mtg.,
12pp.

Lindberg, S. E., R.R. Turner, T.P Meyers, G.E Taylor, and W.H. Schroeder. 1991.  Atmospheric
concentrations and deposition of airborne Mercury to Walker Branch Watershed. Water, Air,
Soil, Pollut. 56:577-594.

Johnson, D.W., H. Van Miegroet, S.E. Lindberg,.R. Harrison, and D. Todd. 1991.Nutrient
cycling in red spruce forests of the Great Smoky Mountains. Can. J. For. Res. 21:769-787.
                                      i •
Hanson, P.J. and S.E. Lindberg. 1991. Dry deposition of reactive nitrogen compounds: A review
of leaf, canopy, and nonfoliar measurements.  Atmos. Envir. 25A:1615-1634.

Petty, W., and S.E. Lindberg. 1990. A comprehensive 1-month investigation of trace metal
deposition, atmospheric concentrations, and throughfall at a mountain spruce forest. Water. Air.
Soil. Pollut. 53:213-226.

Lindberg, S. E., M. Bredemeier, D. A. Schaefer, and L. Qi.  1990. Atmospheric concentrations
and deposition of nitrogen compounds and major ions during the growing season in conifer
forests in the United States and West Germany. Atmos. Envir. 24A:2207-2220.

Wiman, B., M. Unsworth, S. E. Lindberg, B. Bergqvist, R. Jaenicke, and H-C. Hansson.  1990.
Perspectives on aerosol deposition to natural surfaces: Interactions between aerosol residence
times, removal processes, the biosphere, and global environmental change. J. Aerosol Science
21:313-338.

Taylor, G.E.,  P.J. Hanson, and S.E Lindberg.  1990. Deposition.and emission of trace gases in
controlled environments: A conceptual model, experimental methodologies, and application of
results to the disciplines of physiological ecology and'biogeochemistry. IN Payer, H.D. (Ed.),
Environmental Research with Plants in Closed Chambers, Air Pollution Research Report 26:
-------
Commission of the European Communities, Brussels, pp. 194-215.

1980's     .                        .    '             '  '  .

Lindberg, S. E. 1989. Application of surface analysis methods to studies of atmospheric
deposition in forests, p. 269-283, IN Ulrich, B. (Ed.), International Congress on Forest Decline
Research: State of Knowledge and Perspectives, Kernforschungszentrums Karlsruhe GmbH.

Hanson, P. J., K. Rott, G. E. Taylor, Jr., C. A. Gunderson, S. E. Lindberg, and B. M. Ross-f odd.
1989. NO2 Deposition to forest landscape surfaces. Atmos. Envir. 23:1783-1794."

Hicks, B. B., D. R. Matt, R. T. McMillen, J. D. Womack, M. L. Wesely, R. L. Hart, D. R. Cook,
S. E. Lindberg, R. G. de Pena and D. W. Thomson.  1989. A field investigation of sulfate fluxes
to a deciduous forest, J. Geophys. Res. 94:13003-13011.

Schaefer, D. A., S. E. Lindberg, and W. A. Hoffman. 1989. Fluxes of undissociated acids to
terrestrial ecosystems by atmospheric deposition. Tellus 41B: 207-218.

Lindberg, S. E., and T. Butler. 1989. On composition of particles dry deposited to an inert
surface at Ithaca, NY, and Author's response. Atmos. Envir. 23: 279-280.

Ottar, B., Lindberg, S. E., Voldner, E., Lindqvist, O., Mayer, R., Steinnes, E., and Watt, J. 1989.
Special topics concerning interactions of heavy metals with the environment. In Pacyria, J. and
Ottar, B. (eds.). Control and Fate of Atmospheric Trace Metals, NATO Advanced Science   '
Institute Series, Kluwer Academic Publishers, Dordrecht, Holland, pp. 365-372.

Lindberg, S. E. 1989. Behavior of Cd, Mn, and Pb in forest canopy throughfall, In Pacyna, J. and
Ottar, B. (eds.). Control and Fate of Atmospheric Trace Metals, NATO Advanced Science
Institute Series, Kluwer Academic Publishers, Dordrecht, Holland, pp. 233-258.

Johnson, D. W. and S. E. Lindberg.  1989. Acidic deposition on Walker Branch Watershed.  In
Adriano, D. and W. Salomons (eds.). Acidic Precipitation, Vol. I: Case Studies, Advances in
Environmental Sciences Series, Springer Verlag, NY. pp. 1-33.

Lindberg, S. E., R. C. Harriss, W. A. Hoffman, G. M. Lovett, and R. R. Turner. 1989.
Atmospheric chemistry, deposition, and canopy interactions.  IN D. W. Johnson and R. I. Van
Hook (eds.) Analysis of Biogeochemical Cycling Processes in Walker Branch Watershed.
Springer Verlag, Berlin, pp. 96163.

Lindberg, S. E., G. M. Lovett, D. A. Schaefer and M. Bredemeier. 1988. Coarse aerosol
deposition velocities and surface-tp-canopy scaling factors from forest canopy throughfall. J.
Aerosol Science 19:1187-1190.

Lindberg, S. E., D. Silsbee, D. A.  Schaefer, J. G. Owens, and W. Petty. 1988. A comparison of
atmospheric exposure conditions at high- and low-elevation forests in the southern Appalachian
Mountains. In Unsworth, M. and Fowler, D. (Eds.). Processes of Acidic Deposition in
Mountainous Terrain, Kluwer Academic Publishers, London, pp. 321 -344.
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Lindberg, S. E., and C. T. Garten, Jr. 1988. Sources of sulfur in forest canopy throughfall.
Nature 336:148-151.

Lindberg, S. E. and R. R. Turner. 1988. Factors influencing atmospheric deposition, stream
export, and landscape accumulation of trace metals in four forested watersheds. Water, Air and
Soil Pollut. 39:123-156.

Richter, D. D. and S. E. Lindberg. 1988. Incident precipitation and forest canopy throughfall:
Analyses of sampling methods. J. Envir. Qual. 17:619-622.
                     »                .                 i
Johnson, D.W., A.J. Friedland, H. Van Miegroet, R.B. Harrison, E. Miller, S.E. Lindberg, D.W.
Cole, D.A. Schaefer, and D.E. Todd. 1988. Nutrient status of some contrasting high elevation
forests in the eastern and western United States, p. 463-469 IN: Proceedings of Symposium The
Effect of Atmospheric Pollutants on Spruce Fir Forests in the Federal Republic of Germany and
the Eastern United States, Burlington, VT, Oct. 18-23,1987.

Lindberg, S. E., G. M. Lovett, and K. J. Meiwis. 1987. Deposition and canopy interactions of
airborne nitrate. In T. C. Hutchinson and K. Meema (eds.) Proceedings Advanced NATO
Workshop on Effects of Acidic Deposition on Ecosystems, Springer-Verlag, NY, pp. 117-130.

Johnson, D. W., S. E. Lindberg, E. A. Bondietti, D. W. Cole, G. M. Lovett, M. Mitchell, L. H.
Ragsdale, and L. F. Pitelka. 1987. The Integrated  Forest Study: A status'report. Proc. Air Pollut.
Control. Assoc. Annual Meeting, Paper 87-34.4, New York, June  21-26,1987.

Barrie, L. A., S. E. Lindberg, W. H. Chan, H. B. Ross, R. Arimoto, and T. M. Church. 1987. On
the concentration of trace metals in precipitation. Atmos. Environ., 21:1133-1135.

Petty, W. and S. E. Lindberg. 1987. An intensive study of Pb deposition to a high elevation
spruce forest in the Appalachian Mountains. In Procedings of the  sixth International Conference
on Heavy Metals in the Environment, New Orleans, LA, September 15-18,1987, CEP Limited
Publishers, Edinburgh, UK.              .

Coe, J. M. and S. E. Lindberg. 1987. The morphology and size distributions of atmospheric
particles deposited on foliage and inert surfaces. J. Air Pollut. Control Assoc., 37:237-243.

Lindberg, S. E., P. M. Stokes, E. Goldberg, C. Wren. 1987. Rapporteur's report on mercury. In T.
C. Hutchinson and K. Meema (Eds.), Lead, Cadmium, and Mercury in the Environment, United
Nations Scientific Committee on Problems in the Environment Series, John Wiley, NY, p. 17-34.

Lindberg, S. E. Emission and deposition of atmospheric mercury vapor. 1987. In T. C.
Hutchinson and K. Meema (Eds.), Lead, Cadmium, and Mercury  in the Environment, United
Nations Scientific Committee on Problems in the Environment Series, John Wiley, NY, p. 89-
106.

Lindberg, S. E. 1986. Collection and analysis of trace metals in continental precipitation at
forested sites in southeastern U.S. In Barrie, L. (Ed.). Measurement of Metals in Precipitation,
Atmospheric Environment Service Publishers, Toronto, Canada.
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Hicks, B. B., M. L. Wesley, S. E. Lindberg, and S. M. Bromberg (Eds.), 1986.  Proceedings of
the Dry Deposition Workshop of the National Acid Precipitation Assessment Program. March
25-27,1986. NOAA/ATDD, P. O. Box 2456, Oak Ridge, TN 37831.

Lovett, G. M. and S. E. Lindberg. 1986. Dry deposition of nitrate to a deciduous forest.
Biogeochemistry, 2:137-148.

Lindberg, S. E., and S. B. McLaughlin. 1986. Current problems and future research needs in the
acquisition, interpretation, and application of data in terrestrial vegetation - air pollutant
interaction studies. IN. A. Legge and S. V. Krupa (Eds.), Air Pollutants and Their Effects on the
Terrestrial Ecosystem, pp. 449-504. John Wiley and Sons, New York, NY.

Lindberg, S.-E. 1986. Mercury vapor in the atmosphere: Three case studies on emission,
deposition, and plant uptake, pp. 535-560, In Nriagu J. O., and C. I. Davidson (eds.) Metals in
the Air.  John Wiley and Sons, New York, 635 pp..

Lindberg, S. E., G. M. Lovett, D. R. Richter, and D. W. Johnson. 1986. Atmospheric deposition
and canopy interaction of major ions in a forest. Science 231:141-145.

Mayer, R. and S. E. Lindberg. 1985. Deposition on heavy metals to forest ecosystems — their
distribution and possible contribution to forest decline. Proceedings Fifth International
Conference on Heavy Metals in the Environment, CEP Consultants Ltd. Publishers, Edinburgh,
UK, Vol. 1,351-353.

Lindberg, S.E. 1985. The production history of the Waltham Maximus. Bull. Nat. Assoc. Watch
and Clock Coll. 27:174-188.      -

Lovett, G. M., S. E. Lindberg, D. D. Richter,  and D. D. Johnson. 1985. The effects of acidic
deposition on cation leaching from a deciduous forest canopy. Can. J. For. Res. 15:1055-1060

Turner, R. R., S. E. Lindberg, and J. M. Coe.  1985. Comparative analysis of trace metal
accumulation in forest ecosystems. Proceedings Fifth International Conference on Heavy Metals
in the Environment, CEP Consultants Ltd. Publishers, Edinburgh, UK, Vol. 1,356-358.
   •j
Lindberg, S. E. and R. C. Harriss. 1985. Mercury in rain and throughfall in a tropical rain forest.
Proceedings Fifth International Conference on Heavy Metals in the Environment, CEP
Consultants Ltd. Publishers, Edinburgh, UK, Vol. 1 „ 527-529.

Johnson, D. W., D. D. Richter, G. M. Lovett, and S. E. Lindberg. 1985. The effects of
atmospheric deposition on K, Ca, and Mg cycling in two forests. Can. J. For. Res. 15:773-782.

Davidson, C. I., S. E. Lindberg, J. Schmidt, L. Cartwright, and L. Landis.  1985. Dry deposition
of sulfate onto surrogate surfaces. Journal Geophysical Research 90:2121-2130.

Lindberg, S. E. and G. M. Lovett. 1985. Field measurements of particle dry deposition rates to
foliage and inert surfaces in a'forest canopy. Envir. Sci. Technol. 19:238-244.

Lindberg, S. E., J. M. Coe,  and W. A. Hoffman. 1984. Dissociation of weak acids during Gran
-------
plot free acidity titrations, Tellus 363:186-191.

Lindberg, S. E., G. M. Lovett, E. A. Bondietti, and C. I. Davidson.  1984. Recent field studies of
dry deposition to surfaces in plant canopies. Air Pollution Control Association Meeting
Proceedings, Vol. 6, Chapter 84-108.5, p. 1 -15, APCA, Pittsburgh, PA.

Lovett, G. M. and Lindberg, S. E.  1984. Dry deposition and canopy exchange in a mixed oak
forest determined from analysis of throughfall.  J. Appl; Ecol. 21:1013-1028.  .

Lindberg, S. E., and R. R. Turner. 1983. Trace metals in rain at forested sites in the eastern
United States. Proceedings Fourth International Conference on Heavy Metals in the
Environment, pp. 107-114, CEP Consultants Ltd. Publishers, Edinburgh, UK, 1284 pp.

Lindberg, S. E., R. R. Turner, and G. M. Lovett.  1983. Mechanisms of the flux of acidic
compounds and heavy metals onto receptors in the environment. In LSbel, J. and W. R. Thiel
(Eds.) Acid.Precipitation: Origin and Effects, p. 165-172. Lindau, FRG, June 1983. Verlag des
Vereins Deutscher Ingenieure, Dttsseldorf, FRG.

Lindberg, S. E. and G. M. Lovett.  1983. Application of surrogate surface and leaf extraction
methods to estimation of dry deposition to plant canopies. IN H. R.  Pruppacher, R. G. Semonin,
and W. G. N. Slinn (Eds.), Precipitation Scavenging, Dry Deposition and Resuspension.
Elsevier Science Publ., New York, Vol. 2, pp. 837-848.

Lindberg, S. E. and R. C. Harriss.  1983. Water and acid soluble metals in atmospheric particles.
Jour. Geophys. Res. 88:5091-5100.

Johnson, D.  W., G. S. Henderson, D. D. Huff, S. E. Lindberg, D. D. Richter, D. S. Shriner, D. E.
Todd, and J. Turner. 1982. Cycling of organic and inorganic sulfur in a chestnut oak forest.
Oecologia 54:141-148.

Lindberg, S. E., R. R. Turner, and G. M. Lovett.  1982. Processes of atmospheric deposition of
metals and acids to forests. Air Pollution Control Association Annual Meeting Proceedings,
Paper 82-55M.3, Vol. 4,  Chapter 10, pp. 1-14, APCA, Pittsburgh, PA.

Hoffrnan, W. A., Jr., Si E. Lindberg, and R. R. Turner. 1982. Characterization of covalent
constituents in coal conversion solid wastes, Envir. Pollut. 4:219-229.

Lindberg, S. E., R. C. Harriss, and R. R. Turner.  1982. Atmospheric deposition of metals to a
forest canopy. Science 215:1609-1611.

Ferguson, N. M.^ S. E. Lindberg, and J. D. Vargo. 1982. A simple reverse-phase column clean-
up for the determination  of sulfate  in aqueous leachates containing organic compounds.
International Journal of Environmental Analytical Chemistry 11:61-65.

Lindberg, S. E., D. S. Shriner, and  W. A. Hoffrnan, Jr. 1982. The interaction-of wet and dry
deposition with the forest canopy. Chapter 17. IN Acid Precipitation: Effects on Ecological
Systems, pp. 385-409. Ann Arbor Science Publishers, Ann Arbor, MI, .506 pp.
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Hosker, R. P., and S. E. Lindberg.  1982. Review Article: Atmospheric deposition and plant
assimilation of airborne gases and particles. Attnos. Environ.  16:889-910.

Lindberg, S. E. 1982. Factors influencing trace metal, sulfate, and hydrogen ion concentrations •
in rain. Atmos. Environ. 16:1701-1709.   ,

Chen, N.C.J., R. E. Saylor, and S. E. Lindberg. 1982. Plume washout around a major coal-fired
power plant: Results of a single storm event. Chapter 2. IN Energy and the Environment, pp. 11-
22. American Chemical Society.
          -'•."                        *                              ,    •      .
Lindberg, S. E., R. R. Turner, D. S. Shriner, and D. D. Huff.  1981. Atmospheric deposition of
heavy metals and their interaction with acid precipitation in a North American deciduous forest.
Proceedings Third International Conference on Heavy Metals in the Environment, pp. 306-309.
CEP Publishers, Edinburgh, U.K., 732 pp.

Lindberg, S. E. and R. C. Harriss.  1981. The role of atmospheric deposition in an eastern U.S.
deciduous forest Water, Air, Soil Pollut. 15:13-31..                           '•    .

Lindberg, S. E. 1981. The relationship between Mn and sulfate ions in precipitation. Atmos.  ~
Environ. 15:1749-1753.

Lindberg, S. E. 1981. A reply on the efficiency of in-plume mercury vapor collection by
activated charcoal. Atmos. Environ. 15:631 -634.

Lindberg, S. E. 1981. Mercury in the atmosphere - A new problem? Laboratory News, Oak
Ridge National Laboratory, February 1981.

Parker, G., S. E. Lindberg, and J. M. Kelly. 1980. Atmosphere canopy interactions in
southeastern U.S. forested watersheds. IN D.  S. Shriner, C. R. Richmond, and S. E. Lindberg
(Eds.), Atmospheric Sulfur Deposition, pp. 477-493.  Ann Arbor Science Publishers, Ann Arbor,
MI, 568 pp.                   .      .
                     \                           .
Lindberg, S. E., and R. P. Hosker.  1980. Effluent delivery and air mass/landscape interactions:
An overview. IN D. S. Shriner, C. R. Richmond, and S. E. Lindberg (Eds.), Atmospheric Sulfur
Deposition, pp 181-184. Ann Arbor Science Publishers, Ann Arbor, MI, 568 pp.

Hoffman, W. A., S. E. Lindberg, and R. R.  Turner. 1980. Some observations of organic
constituents in rain above and below a forest canopy. Environ. Sci. Techno!.  14:999-1002.

Lindberg, S. E., and R. C. Harriss.  1980. Trace metal solubility in aerosols produced by coal
combustion. IN J. Singh and A. Deepak (Eds.), Environmental and Climatic Impacts of Coal
Utilization, Academic Press, NY, 655 pp.

Lindberg, S. E. 1980. Mercury partitioning in a power plant plume and Its influence on
atmospheric removal mechanisms.  Atmos. Environ. 14:227-231.

Hoffman, W. A., S. E. Lindberg, and R. R.  Turner. 1980. Precipitation acidity: The role of the
forest canopy in acid exchange. Jour. Environ. Quality 9:95-100.
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1970's

Lyon, W. S., S. E. Lindberg, J. F. Emery, J. A. Carter, N. M. Ferguson, R. I. Van Hook, and R. J.
Raridon. 1979. Analytical determination and statistical relationships of 41 elements in coal from
three coal-fired steam plants.  IN Nuclear Activation Techniques in the Life Sciences, pp. 615-
625. IAEA-SM-227/61, International Atomic Energy Agency, Vienna, Austria.

Lindberg, S. E., D. R. Jackson, J. W. Huckabee, S. A. Janzen, M. J. Levin, and J. R. Lund. 1979.
Atmospheric emission and plant uptake of mercury from agricultural soils near the Almaden
mercury mine. J. Environ. Qual. 8:572-578.

Turner, R. R., and S. E. Lindberg. 1978. Behavior and transport of mercury in a river-reservoir
system downstream of an inactive chloralkali plant. Environ. Sci. Technol. 12:918-923.

Ausmus, B. S., S. Kimbrough, D. R. Jackson, and S. E. Lindberg.  1979. The behavior of
hexachlorobenzene in pine forest microcosms: Transport and effects on soil processes. Environ.
Pollut. 13:103-111.

Turner, R. R., S. E. Lindberg, and K. Talbot. 1977. Dynamics of trace element export from a
deciduous watershed, Walker Branch, Tennessee. IN D. L*. Correll (Ed.), Watershed Research in
Eastern North America, pp. 661-681. Smithsonian Institution Press, Washington, DC, 419 pp.

Lindberg, S. E., and R. C. Harriss.  1977. Release of dissolved mercury and organic matter from
resuspended near-shore sediments. J. Water Pollut. Control Fed.  7:2479-2487.

Lindberg, S. E., and R. R. Turner. 1977. Mercury emissions from chlorine production solid waste
deposits. Nature 268:133-136.

Lindberg, S. E., R. R. Turner, N. M. Ferguson, and D. Matt. 1977. Walker Branch Watershed
element cycling studies: Collection and analysis of wetfall for trace elements and sulfate. IN
Correll, D. L. (Ed.), Watershed Research in Eastern North American,  pp. 125-150.  Smithsonian
Institution Press, Washington, DC, 469 pp.

Andren, A. W., and S. E. Lindberg.  19771 Atmospheric input and origin of selected trace
elements in Walker Branch Watershed, Oak Ridge, TN. Water Air Soil Pollut. 8:199-215.

Bate, L. C., S. E. Lindberg, and A. W. Andren.  1976. Elemental analysis of water and air solids
by neutron activation. J. Radioanal. Chem. 32:125-135.

Lindberg, S. E., A. W. Andren, R. J. Raridon, and W. Fulkerson.  1975. Mass balance of trace
elements in Walker Branch Watershed - The relation to coal-fired power plants.  Environ. Health
Perspect. 12:9-18.

Bate, L. C., S. E. Lindberg, and A. W. Andren.  1975. Analysis of water and air by neutron
activation. Trans. Am. Nucl. Soc. 21 (Suppl. 3):20-21.    '
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Lindberg, S. E., A, W. Andren, and R. C. Harriss.  1975. Geochemistry of mercury in the
estuarine environment, pp. 64-107. IN L. Cronin (Ed.), Estuarine Research, Vol. I: Chemistry
and Biology. Academic Press, NY, 750 pp.

Lindberg, S. E., and R. C. Harriss. 1974. Mercury enrichment In estuarine plant detritus. Mar.
Pollut. Bull. 5:93-95.

Lindberg, S. E., and R. C. Harriss. 1974. Mercury - organic matter associations in estuarine
sediments and their interstitial water. Environ. Sci. Technol. 8:459-462.

Lindberg, S. E., and R. C. Harriss. 1973. Mechanisms controlling pore water salinities in a salt
marsh. Limnol. Oceanogr. 18:788-791.

Reports

Marcy, S. M. Dam, D. Dasher, R. Dietz, L. Duffy,  M. Evans, S. Juntto, S. Lindberg, L. Lockhart,
S. Naido, T. O'Hara, J. Pacyna, A. Robertson, E. Yngvadottir, and G. Asmund. 2000. Mercury
in the Arctic: An Update, In Arctic Monitoring and Assessment Program (AMAP) Report on
Issues of Concern, AMAP Report 2000: 4, Stromsveien, Norway.

Lindberg, S. E., K. Roy, and J. Owens. 1999. PaMSWaD (Pathways of Mercury in Solid Waste
Disposal): ORNL sampling operations summary and preliminary data report for PaMSWaD-I,
Brevard County Landfill. A Report to the Florida Department of Environmental Protection.

Lindberg, S.E., Zhang, H., and Meyers, T.P. 1999. Final Report: Everglades Mercury
Air/Surface Exchange Study (E-MASE). South Florida Water Management District, West Palm
Beach, FL.

Lindberg, S.E. and Meyers, T.P. 1998.  Everglades Mercury Air/Surface Exchange Study (E-.
MASE): Second Annual Report. South Florida Water Management District, West Palm Beach,
FL.

Lindberg, S.E., Meyers, T.P., and Miles, C. 1997.  Everglades Mercury Air/Surface Exchange
'Study (E-MASE): First Annual Report. South Florida Water Management District, West Palm
Beach, FL.

Wilken, R:D.; Lindberg, S. E.; Horvat, M.; Petersen, G.; Porcella, D.; Schroeder, B.;
Wisniewski, J. R.; Wisniewski, J.; Wheatley, B., Wheatley, M.; and Wyzga, R.  1996. Fourth
International Conference on Mercury as a Global Pollutant: Conference Summary Report. GKSS
Research Centre, Hamburg, Germany.

Expert Panel on Mercury (22 authors). 1994. Mercury Atmospheric Processes: A Synthesis.
Report. Workshop Proceedings, R. H. Osa (Coord. Ed.), EPRLTR-104214, Electric Power
Research Institute, Palo Alto, CA.

Turner, R.S., R.B. Cook, H. Van Miegroet, D.W. Johnson, J.W. Elwood, O.P. Bricker, S.E.
Lindberg, and G.M. Hornberger.  1990. Watershed and Lake Processes Affecting Chronic
-------
Surface Water Acid-Base Chemistry. National Acid Precipitation Assessment Program State-of-
Science/Technology Report 10,167 pp., NAPAP, Washington, DC.

Lindberg, S. E. 1990. Throughfall and foliar extraction. Section 5.3.2.2, pp. 206-208. In: Hicks,
B.B., R. R. Draxler, D. L. Albritton, F. C. Fehsenfeld, M. Dodge, S. E. Schwartz, R. L. Tanner,
J. M. Hales, T. P. Meyers, and R. L. Vong.  Atmospheric Processes Research and Process Model
Development. National Acid Precipitation Assessment Program State-of-Science/Technology
Report 2,298 pp., NAPAP, Washington, DC.

Lindberg, S.E. and D.W. Johnson (eds.). 1989. 1988 Annual Report of the Integrated Forest
Study, ORNL/TM 11121, Oak Ridge National Laboratory, Oak Ridge, Tennessee.

Lindberg, S.E. and D.W. Johnson, (eds.). 1989.1988 Annual Report of the Integrated Forest
Study, ORNL/TM 11121, Oak Ridge National Laboratory, Oak Ridge, Tennessee.

Lindberg, S.E. and D.W. Johnson, (eds.). 1989.1987 Annual Group Leader Reports of the
Integrated Forest Study, ORNL/TM 11052, Oak Ridge National Laboratory, Oak Ridge,
Tennessee.

Lindberg, S. E.} D.W. Johnson, G. M. Lovett, G. E. Taylor, H. Van Miegroet, and J.G. Owens.
1989. Sampling and Analysis Protocols and Project Description for the Integrated Forest  Study.
ORNL/TM 11214, Oak Ridge National Laboratory, Oak Ridge, Tennessee.

Fox, D.G., A. Bartuska, J. Byrne, E. Cowling, R. Fisher, G. Likens, S. Lindberg, R. Linthurst, J.
Messer, and D. Nichols. 1989. A screening procedure to evaluate air pollution effects on class I
wilderness areas. U.S. Department of Agriculture Forest Service, Rocky Mt. Forest and Range
Experiment Station,General Technical Report RM-168.

Lindberg, S. E. Bowersox, V., Bigelow, D., Knapp, W., Olsen, T. (Eds).  1985. Annual data
summary of precipitation chemistry in the United States. National Atmospheric Deposition
Program, Colorado State University, Fort Collins, CO.

Lindberg, S. E., Lovett, G. M., and  Coe, J. M. 1984. Acid deposition/forest canopy interactions.
Final report RP-1907-1, Electric Power Research Institute, Palo Alto, CA.

McLaughlin, S. B., D. J. Raynal, A. H. Johnson, and S. E. Lindberg. 1983. Forests, In the Acidic
Deposition Phenomenon and Its Effects, Section E3, Effects on Vegetation. The Acid Deposition
Phenomenon, Critical Assessment Review Papers, EPA-600/8-83-016BF.

Lindberg, S. E. 1983. Dry deposition to petri dish and foliar surfaces, Final report to Carnegie-
Mellon University, In Davidson, C. I., and S.  E. Lindberg, Final Report to EPA on Illinois
Intel-comparison Deposition Studies.

Turner, R. R., P. Lowry, M. Levin,  S. E. Lindberg, and T. Tamura.  1982. Leachability and
aqueous speciation of trace  constituents in coal fly ash. EPRI report EA 2588. Electric Power
Research Institute, Palo Alto, CA.
-------
Hildebrand, S. G., S. E. Lindberg, R. R. Turner, J. W. Huckabee, R. H. Strand, J. R. Lund, and
A. W .Andren. 1980. Biogeochemistry of Mercury in a River-Reservoir System: Impact of an
Inactive Chloralkali Plant on the Holston River - Cherokee Reservoir, Virginia and Tennessee,
ORNL/TM-6141, Oak Ridge, National Laboratory, Oak Ridge, TN.

Davidson, C. I., and S. E. Lindberg.  1980. Alternative viewpoints on surrogate surfaces. IN B.
B. Hicks, M. L. Wesley, and J. L. Durham, Critique of methods to measure dry deposition:.
Workshop summary, pp. 66-70.  EPA-600/9-80-050, Environmental Protection Agency, RTF, •
NC.                                                             '

Lindberg, S. E., R. C. Harriss, R. R. Turner, D. S. Shriner, and D. D. Huff. 1979. Mechanisms
and rates of atmospheric deposition of trace elements and sulfate to a deciduous forest canopy.
ORNL/TM-6674.  Oak Ridge National Laboratory, Oak Ridge, Tennessee. 510 pp.

Turner, R. R., J. W. Elwood, C. Feldman, and S. E. Lindberg. 1978. Chemical speciation in fly
ash leachates: Importance and determination with specific reference to arsenic. Project
Completion Report to the Electric Power Research Institute, Palo Alto, CA.

Turner, R. R. and S. E. Lindberg. 1976. Interlaboratory comparison of trace metal analyses by
graphite furnace atomic absorption spectroscopy. ORNL/TM-5422.  Oak Ridge National
Laboratory, Oak Ridge, TN. 21pp.

Andren, A. W., S. E. Lindberg, and L. C. Bate. 1975. Atmospheric input and geochemicai
cycling of selected trace elements in Walker Branch Watershed. ORNL/NSF/EATC-13. Oak
Ridge National Laboratory, Oak.Ridge, TN. 68 pp.

Turner, R. R., S. E. Lindberg, and A. W. Andren. 1974. Concentrations of C, N, "?Cs, and
selected heavy metals in a sediment core from Lake Jackson, Florida. IN Job Completion Report
for the State of Florida Game and Freshwater Fish Commission, Study VI, Lake Jackson
Investigations.
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                           Michael McLinden, M.S., C.I.H.
                         PO Box 1081,  112 Central Avenue
                       Island Heights, New Jersey  08732-1081
                                  (732)573-0560


EDUCATION:
M.S., Occupational and Environmental Health Science
Hunter College, City University of New York  (1994)
B.S., Zoology
San Diego State University  (1982)
A.A., History
Ocean County College (1978)

PROFESSIONAL ASSOCIATIONS:
Certified in the comprehensive practice of industrial hygiene by the American Board of
Industrial Hygiene (ABIH)

Diplomat of the American Academy of Industrial Hygiene (AAIH)

Full member of the American Industrial Hygiene Association (AIHA)

EXPERIENCE:
Research Scientist I (Industrial Hygienist) (8/04 - Present)
Center for Occupational Medicine
New Jersey Department of Environmental Protection
Senior industrial hygienist responsible for the development and implementation of occupational
health policies, procedures and health and safety programs throughout the Department.
Performed workplace exposure evaluations, air monitoring and training in order to maintain
compliance with applicable regulations. Major projects included work on asbestos management,
bloodborne pathogens, chemical hygiene plans, confined  space entry, ergonomics, indoor air
quality, mercury and other metals, noise, nuclear emergency preparedness, pesticides and
respiratory protection.

Research Scientist I (5/98-8/04)
Office of Pollution Prevention & Right to Know
New Jersey Department of Environmental Protection
Promote pollution prevention initiatives in an effort to reduce environmental and occupational
health exposures. Provide regulatory and technical assistance to industrial facilities to help
increase efficiency and reduce the quantity of toxic (TRI) substances used, generated as waste
and released to the environment. Represent the Office of Pollution Prevention on the DEP
Mercury Workgroup.  Former co-chair of the Pollution Prevention workgroup for the National
Environmental Performance Partnership System (NEPPS) Steering Committee. Under an EPA
grant, provide industrial hygiene technical assistance to the Office of Occupational Training and
Education Consortium (OTEC) at Rutgers University. This project develops training programs
designed to integrate pollution prevention and occupational health. Chairmen of the health &
safety committee for the Division of Environmental Safety and Health (DESH).
                                                        I            ,
Research Scientist II (8/96 - 9/98)
Division of Environmental and Occupational Health
New Jersey Department of Health and Senior Services
Working as a Health Assessor in the Hazardous Site Health Evaluation Program, performed
health hazard investigations to evaluate potential public exposure to chemical and physical
hazards associated with National Priority List (NPL) sites in New Jersey. Working with the
-------
Agency for Toxic Substances and Disease Registry (ATSDR) reviewed environmental,
demographic and public health data and evaluated potential human exposure pathways. Primary
responsibilities included assisting with the development of a dose reconstruction model of a
municipal water distribution system and the development of the occupational exposure portion of
an epidemiological case-control study in support of a childhood cancer cluster investigation in
Toms River, NJ.

Research Scientist HI (7/94 - 7/96)
Office of Air Quality Management
New Jersey Department of Environmental Protection
Acted as project manager for a team of administrators, engineers and scientists developing State
air Pollution control regulations for stationary sources.  Major rules included Mercury Emissions
from MSWIs, VOC-RACT, and Architectural and Industrial Maintenance Coatings Rules.
Member of the Air Toxics Steering Committee providing advice to the Department concerning
health exposure issues.

Research Scientist II (Industrial Hygienist) (9/89-7/94)
Center for Occupational Medicine
New Jersey Department of Environmental Protection
Senior industrial hygienist responsible for the development and implementation of occupational
health policies and program specific health and safety programs for approximately 4,000
employees throughout the Department. Performed workplace exposure evaluations, air
monitoring and training in order to maintain compliance with applicable regulations. Major
projects included work on asbestos management, bloodborne pathogens, chemical hygiene plans,
confined space entry, ergonomics, indoor air quality, mercury and other metals, noise, nuclear
emergency preparedness, pesticides and respiratory protection.

Occupational Health Consultant (12/87 - 9/89)
Division of Environmental and Occupational Health
New Jersey Department of Health and Senior Services
Responsible for industrial hygiene activities related to asbestos including review and approval of
asbestos management plans, abatement project inspections and air monitoring, and emergency
response activities. Participated in various NJDHSS / EPA research projects concerning
environmental exposure to asbestos.

PUBLICATIONS
Release of Mercury from Broken Fluorescent Bulbs. Journal of the Air & Waste
Management Association, (February 2003) 53: 143-151.     ,

Chromium Exposure Assessment of Outdoor Workers in  Hudson County, NJ.  The Science
of the Total Environment, (July 1992) 122: 291-300.
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5-Year OCS Oil and Gas Leasing Program
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5-Year OCS Leasing Program

What is the 5-Year Program?

OCS Oil & Gas Leasing Program 2007- 2012:
  %  Information on the 2007-2012 Oil & Gas Leasing Program:
                         [apl
      a  Proposed Program \*&.I(140pages)

      a  Draft Environmental Impact Statement (EIS)
        Draft Proposed Program
                                \ (110 pages)
      9 Commenting on the Program or its supporting EIS


OCS.Oil & Gas Leasing Program 2002 - 2007:
   %  Information on the 2002-2007 Oil & Gas Leasing Program
          : Proposed Program
                      	    I (86 pages)

  *  Proposed Program ||p| (1 1 spages)

  *  Proposed Final Program GUI (121 pages)

  «  Draft Environmental Impact Statement, October 2001.2 vol. Available from HD
      paper or CD ROM. OCS EIS/EA, MMS 2001 -079. Ordering Information.

  *  Final Environmental Impact Statement. 2 vol. Available from HDQRS on paper
      ROM. OCS EIS/EA, MMS 2002-006. Ordering Information.


OCS Oil & Gas Leasing Program  1997- 2002

  *  Proposed Final Program \jj\doa pages)
  *  Draft Environmental Impact Statement, February 1996.952 p. 2 vol. Available
      HDQRS as reading copy only. MMS 95-0061. Ordering Information.
  *  Draft Environmental Impact Statement references. 117 p. Available from HDQ
      reading copy only. MMS 95-0068. Ordering Information.
  *  Final Environmental Impact Statement, 2 vol. Available from HDQRS (limited s
      MMS 96-0043. Ordering Information.


OCS Oil & Gas Leasing Program 1992 -1997

  *  Proposed Final Program \W\ (52 pages)
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Outer Continental Shelf Oil & Gas Leasing Program: 2007-2012 Draft Environmental Im...   Page 1 of 2
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   Home   :j   Search    . Topic Index  „•  About IVtWIS    What's New
"      ~       ~~"""""'"*	."	"	"'	"      ;  "~"
 Minerals Management  Service
0uter Continental Shelf Oil & Gas Leasing Program
2007-2012 Draft Environmental Impact Statement (updated July 2006)
This draft Environmental Impact Statement (EIS) analyzes potential environmental and
socioeconomic impacts associated with the 2007-2012 Outer Continental Shelf Oil and C
Leasing Program. The analyses in this programmatic EIS adopt a broad regional perspei
more detailed and geographically focused analyses will be done as the Program progres
the planning to the leasing to the exploration and development stages.
These MMS 2006-004 reports (chapters, appendices, figures and tables) are in Adobe A
format. Click IPJ1 to download the Adobe Acrobat reader

 * Volume 1:
    *  Purpose And Need For The Proposed Action (Introduction through Chapter 1
KB)
    «  Alternatives Including the Proposed Action (Chapter 2; 327 KB)
    »  Affected Environment (Chapter 3; 374 KB)
    •  Environmental Consequences - Impacts of Alternative 1 (Chapter 4 - Propa
     •  Action; 234 KB)
 * Volume 2:
    «  Environmental Consequences - Impact of Other Alternatives & Cumulative
       (Chapter A; 1612KB)
    *  Consultation & Preoarers (Chapters 5 & 6; 39 KB)
    *   Index (Chapter 7; 63 KB)
    a  Appendices:
       •   Appendix A (Glossary; 95 KB)
       •   Appendix B (Acronyms; 63 KB)
       •   Appendix C (Mitigation Measures; 72 KB)
       •   Appendix P - Federal Laws and Executive Orders (145 KB)
       •   Appendix E (References; 786 KB)
    »  Figures:
       •   Figures 11-1 through 11-10 (5455 KB)
       •   Figures 111-1 through III-6 (6054 KB)
       •   Figures III-7 through IIM2Y66f 7 KBJ
http://www.mms.gov/5%2Dyear/2007-2012_DEIS.htm
                                                               8/28/2006
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Outer Continental Shelf Oil & Gas Leasing Program: 2007-2012 Draft Environmental Im...  Page 2 of 2





                               •  Figures 111-13 through III-24 (6410 KB)


                               •  Figures III-25 through III-38 (6238 KB)


                               • . Figures HI-39 through IV-1 (4421 KB)


                            «   Tables:                              .


                               •  Tables 111-1 through MM 7 (3107 KB)


                               • . Tables 111-18 through \\\-25(4916 KB)


                              ' •  Tables III-26through III-45 (7516KB)'


                               •  Tables IIM6 through III-52 (771 KB)


                               •  Tables III-53 through lil-56 (649 KB)


                               •  Tables III-57 through lii-63 (264 KB)                   .


                               •  Tables IV-1 through  IV-28 (444 KB}-





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