final report testing for mercury vapor

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Environmental Design Inc. Professional Environmental Consultants 5434 King Avenue, Suite 101 Toll Free (888) 306-4545 Pennsauken, New Jersey 08109 Fax (856) 616-9519 Service Disabled Veteran Owned Small Business Final Report Testing for Mercury Vapor Conducted At: Pine Grove Manor School 130 Highland Avenue Somerset, NJ 08873 Conducted For: Franklin Township Public Schools 1760 Amwell Road Somerset, NJ 078873 Tim Gromen Report Dated: Director, Industrial Hygiene & Safety March 5, 2020

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Environmental Design Inc. Professional Environmental Consultants

5434 King Avenue, Suite 101 Toll Free (888) 306-4545

Pennsauken, New Jersey 08109 Fax (856) 616-9519

Service Disabled Veteran Owned Small Business

Final Report Testing for Mercury Vapor

Conducted At:

Pine Grove Manor School 130 Highland Avenue Somerset, NJ 08873

Conducted For:

Franklin Township Public Schools 1760 Amwell Road

Somerset, NJ 078873 Tim Gromen Report Dated: Director, Industrial Hygiene & Safety March 5, 2020

EDI EXECUTIVE SUMMARY

Environmental Design Inc. prepared this final report on behalf of the Franklin Township Public Schools, hereafter referred to as the Client, to document the results of the investigative sampling conducted at the Pine Grove Manor School in relation to mercury in the rubberized synthetic floor in the gymnasium. On February 20, 2020, EDI collected bulk samples of the rubberized synthetic flooring material in the gymnasium at the Pine Grove Manor School. The analytical lab report for the bulk samples indicated there was 120 to 170 parts per million (ppm) of mercury in the gym floor. Based on the bulk sample results and in accordance with the New Jersey Department of Health (NJ DOH) guidance document “Evaluation and Management of Mercury-Containing Floors in New Jersey Schools” (dated February 6, 2020), EDI recommended that air samples be collected at the school to document the level of mercury vapor associated with the gym floor, if any. On March 3, 2020, EDI sampled for mercury vapor at the Pine Grove Manor School with a Jerome J505 Mercury Vapor Analyzer and via the NIOSH 6009 Method following procedures outlined by the New Jersey Department of Health guidance document reference above. The NJ DOH established that mercury vapor levels should be no more than 0.80 micrograms per cubic meter of air (0.80 µg/m3) in order to protect student health; note that the recommended level is not zero. The results of the investigative air testing are summarized, as follows:

• Jerome J505 Mercury Vapor Analyzer: A total of 54 readings were taken at 22 different locations spread between the gym, the hallways and classrooms surrounding the gym, and outdoors. The highest mercury vapor level recorded in the gym was 0.17 micrograms per cubic meter of air (0.17 µg/m3). The highest level of mercury vapor recorded in the surrounding hallways and classrooms was 0.08 µg/m3. Testing took place over three hours with the same locations evaluated multiple times. All of the test data indicates mercury vapor levels are lower than the NJ DOH recommended value of 0.80 µg/m3.

• NIOSH 6009 Method: A total of 5 air samples were collected: two samples were collected in

the gym, two samples were collected in the hallways surrounding the gym, and one sample was collected outdoors. The analytical lab results for the samples collected in the hallway were reported by lab as “None Detected” for mercury vapor, meaning no mercury vapor was detected in the hallway. The sample collected outdoors was also reported as None Detected. The analytical results for samples collected in the gym were reported by lab as 0.29 µg/m3 and 0.28 µg/m3, respectively. All lab data indicates mercury vapor levels are lower than the NJ DOH recommended value of 0.80 µg/m3.

For teachers and other district employees, occupational exposures are governed by NJ Public Employees Occupational Safety & Health regulations. NJ PEOSH establishes a Permissible Exposure Limit (PEL) for mercury at 100 micrograms per cubic meter of air (100 µg/m3). Compared to the PEL, the level of mercury vapor detected in the school was several orders of magnitude lower than the PEOSH regulatory limit.

EDI BACKGROUND & FINDINGS

New Jersey Department of Health (NJ DOH) guidance documents indicate rubberized synthetic floors manufactured and installed up until the early 2000’s may contain organic mercury compounds. These mercury compounds were added to some types of rubberized synthetic flooring material either during the manufacturing process at the factory or during the installation process in the field. The primary health concern with mercury-containing floors is that the mercury compounds may volatilize (i.e. off-gas) under certain conditions, releasing mercury vapor into the air. Exposure to mercury vapor can cause adverse health effects depending on exposure levels. On February 20, 2020, EDI collected two bulk samples of the rubberized synthetic flooring material in the gymnasium at Pine Grove Manor School. The physical samples were analyzed for mercury content by a certified, third-party laboratory per US EPA Method 7471B, which is the NJ DOH recommended analytical method for determining mercury content in synthetic flooring. The analytical lab report for the bulk samples collected at the school indicated there was mercury present in the gym floor above one part per million (1 ppm). The bulk sample data is summarized in the table below:

Location Result Average

Gym floor – stage left 120 ppm 145 ppm

Gym floor – stage right 170 ppm Based on the results of the bulk sample analysis and in accordance with NJ DOH guidelines, EDI recommended that air samples be collected to determine if any mercury vapor was present and if so, at what level. According to NJ DOH, not all mercury-containing floors emit mercury vapor. On March 3, 2020, EDI sampled for mercury vapor at the Pine Grove Manor School with a Jerome J505 Mercury Vapor Analyzer and via the NIOSH 6009 Method, in accordance with the New Jersey Department of Health (NJ DOH) guidance document “Evaluation and Management of Mercury-Containing Floors in New Jersey Schools” (dated February 6, 2020). The Jerome J505 Mercury Vapor Analyzer is a portable, handheld, direct-read instrument that has a low resolution (0.01 ug/m3) and very little cross-sensitivity to chemicals other than elemental mercury. Inside the device the ambient air is exposed to a light source that emits a beam of light at 245nm (nanometer) wavelength. Mercury atoms absorb light at 245nm wavelength, so any mercury vapor present in the ambient air will absorb the light from the source and then re-emit 245nm wavelength light, albeit at a “stronger” level. This re-emitted light is then measured by a specialized detector (i.e. photo multiplier tube) which captures the amount of 245nm light and correlates the value into a mercury vapor concentration. For the Jerome J505 data, the highest mercury vapor level recorded in the gym was 0.17 micrograms per cubic meter of air (0.17 µg/m3). The highest level of mercury vapor recorded in the surrounding hallways and classrooms was 0.08 µg/m3. Testing took place over several hours with the same locations evaluated multiple times.

EDI The Jerome J505 Mercury Vapor Analyzer data is presented in the table below. The values are expressed as micrograms per cubic meter of air (µg/m3).

Location Round 1

Round 2

Round 3 Avg.

Hallway by rear door 0.00 0.02 - 0.01 Hallway by Art/Music Room 0.06 0.06 - 0.06 Hallway by Boys Room 0.07 0.05 - 0.06 Hallway by Girls Room 0.00 0.08 - 0.04 Hallway by Dance Room 0.01 0.03 - 0.02 Dance Room (Room 35) 0.00 0.01 - 0.01 Art/Music Room (Room 38) 0.01 0.06 - 0.04 Faculty Room 0.01 0.00 - 0.01 Hallway between Boiler Room & Storage 0.05 0.02 - 0.04 Storage Room (adj. to Boiler Room) 0.05 0.03 - 0.04 Nurse Suite 0.02 0.05 - 0.04 Room 34 0.01 0.05 - 0.03 Gym @ 5' Location (near doors) 0.12 0.11 0.12 0.12 Gym @ 3' Location (near stage) 0.14 0.16 0.11 0.14 Stage - in front of curtain 0.11 0.15 0.11 0.12 Stage - behind the curtain 0.15 0.10 0.12 0.12 Gym - inside yellow circle 0.14 0.10 0.1 0.11 Gym - inside green circle 0.12 0.13 0.09 0.11 Gym - inside black circle 0.16 0.17 0.13 0.15 Gym - inside blue circle 0.10 0.15 0.14 0.13 Gym - inside red circle 0.09 0.14 0.12 0.12 Outdoors 0.02 0.00 0.02 0.01 Round 1 testing - 11:00 AM; Round 2 testing - 12:30 PM; Round 3 testing - 2:00 PM

The NIOSH 6009 Method employs a glass sorbent tube attached to a portable sampling pump calibrated to run at 0.2 liters per minute. Each sample is allowed to run for 8- hours for a total air volume of 96 liters. The sorbent tubes are then delivered to a certified, third-party laboratory (EMSL Analytical, Inc.) for analysis. The NIOSH Method 6009 air sampling data is summarized in the table below:

School Result

Gym 5’ sample (near doors) 0.28 µg/m3 Gym 3’ sample (near stage) 0.29 µg/m3 Hallway by rear door None Detected Hallway by Nurse None Detected Outdoors by rear door None Detected

EDI According to the NJ DOH, a mercury vapor level less than 0.80 µg/m3 is considered to be protective of the health of preschool-aged children. Note that the level of mercury vapor detected in all areas tested at Pine Grove Manor, regardless of testing methodology, was several times lower than the NJ DOH recommended maximum level of 0.80 µg/m3. It is important to understand that the NJ DOH recommended maximum level for mercury vapor exposure is a risk-based Maximum Contaminant Level (MCL) value. Understanding how the MCL value was derived and what it actually represents helps put the mercury vapor concentrations detected into perspective and it also serves to explain why it is acceptable to occupy the gym without the need for remedial actions. The MCL is derived from a calculation which uses conservative exposure variables to evaluate health risks. The MCL for mercury vapor factors a child’s exposure at 8-hours per day for 180 days per year. According to the NJ DOH, a child’s health is still protected if they are exposed to 0.80 µg/m3 of mercury vapor for 8-hours per day (which is longer than the typical school day) for 180 days per year (which is every day of the typical school year). In reality, however, students may not stay in the gym for 8-hours per day and they may not even participate in activities in the gym every day of the school year. Thus, the MCL value essentially represents a “worst-case scenario” condition that for all practical purposes may never be experienced by students since they are unlikely to ever have 180 days of exposure let alone 8-hours per day of exposure. Consequently, the health risks associated with the very low mercury vapor levels in the school are significantly lower than the potential health risks associated with exposures at NJ DOH MCL level. Occupational exposures for teachers and other district employees are governed by NJ PEOSH regulations, which establish a statutory Permissible Exposure Limit (PEL) for occupational exposure to mercury vapor at 100 micrograms per cubic meter of air (100 µg/m3). Similar to the NJ DOH MCL value, the NJ PEOSH PEL is a calculated value that reflects a level of exposure whereby worker health is not compromised. The PEL is based on a daily 8-hour time-weighted average factored over a 40-hour work week for a working life-time. The time-weighted average allows for short-term exposures in excess of the PEL provided the overall daily exposure (averaged over 8 hours) does not exceed the PEL. Understanding the NJ PEOSH PEL helps put the mercury vapor concentrations detected at the school into perspective, and it also serves to explain why the gym can be considered acceptable for occupancy without the need for immediate remedial action. Because the levels of mercury vapor detected at the school were several orders of magnitude lower than the PEL, and because staff are unlikely to have a full 8-hour exposure every day of the week, the potential health effects associated with the very low mercury vapor levels in the school are exponentially lower than the potential health risks associated with exposures at the PEL. The temperature, humidity, and barometric pressure in the gym at Pine Grove Manor were measured with a TSI IAQ Q-Trak 7575 monitor with data logging set at one (1) minute intervals over the entire 8-hour sampling period. The temperature ranged from 73.2°F to 77.5°F during the testing period, while the relatively humidity ranged from 33.0% to 41.6%. The barometric pressure fluctuated between 29.45 inHg and 29.71 inHg during the testing.

EDI CONCLUSIONS/RECOMMENDATIONS

In consideration of the NJ Department of Health guidance and the NJ PEOSH Permissible Exposure Limit, and based on the NIOSH 6009 analytical laboratory results and the Jerome J505 Mercury Vapor Analyzer data, it is the professional opinion of Environmental Design Inc. that the Pine Grove School gymnasium can continue to be utilized without the need for removal of the current floor. However, the Client is encouraged to follow the recommendations contained in this report regarding the on-going use of the gymnasium. • The gym should continue to be operated in "normal" mode with respect to heating/cooling and

ventilation, even when the gym is vacant, including nights, weekends, and holidays. It is important to supply fresh make-up air and to provide sufficient of air exchange to prevent mercury vapor from accumulating in the gym.

• Maintaining the condition of the gym floor is important in controlling the level of mercury vapor in the air. A damaged floor may release more mercury vapor than a tight, well-kept floor. However, the Client should not encapsulate or cover the floor; this is specifically addressed in the NJ DOH guidelines.

• Industry guidelines suggest keeping the temperature in the gym between 68°F and 70°F to

minimize the amount of mercury volatilization. It is important to note, however, that the gym was warmer than this during the testing period and the mercury vapor levels were still very low and well below the NJ DOH threshold. NJ DOH guidelines do not recommend stress-testing the gym by heating the space upwards to 90°F.

• The Client should consider implementing a periodic air monitoring program at the school to measure the mercury vapor levels at selected intervals throughout the year (i.e. quarterly or semi-annually), as referenced in the NJ DOH guidelines.

• Teachers, staff, custodial, and maintenance personnel should be informed of the nature of the mercury hazards associated with the gym floor.

EDI is not recommending the removal of the mercury-containing floor at Pine Grove Manor School. If the Client decides to embark on a floor removal project, then the Client should conduct core sampling of the concrete slab and underlying soil to determine the extent of mercury contamination. It is possible that portions of the slab or even the entire concrete slab may need to be excavated. At a minimum, the top layer of the concrete slab will need to be scarified. If there are cracks in the slab, then the likelihood of deeper contamination is increased, dictating a more complicated, time-consuming, and costly project. In addition to the direct costs for removal and disposal of a mercury-containing floor, the Client will need to factor the cost of a replacement floor and the ancillary engineering, architectural, and environmental services required for the project.

EDI

PHOTO LOG & DRAWINGS

Environmental Design Inc. 1-888-306-4545

Franklin Township Public Schools Pine Grove Manor School Mercury Vapor Testing

Testing in the Gymnasium and adjacent areas was conducted using two methods approved by New Jersey Department of Health: 1. Sorbent tube sampling per the NIOSH 6009 Method 2. Direct-read Jerome J505 Mercury Vapor Analyzer

Environmental Design Inc. 1-888-306-4545

Franklin Township Public Schools Pine Grove Manor School Mercury Vapor Testing

- outdoors

- outdoors

- Jerome J505 test location

- NIOSH 6009 sample location

KEY

Testing & Sampling Locations March 3, 2020

Environmental Design Inc. 1-888-306-4545

Franklin Township Public Schools Pine Grove Manor School Mercury Vapor Testing

Jerome J505 Mercury Vapor Analyzer Testing Equipment & Set-up

Environmental Design Inc. 1-888-306-4545

Franklin Township Public Schools Pine Grove Manor School Mercury Vapor Testing

NIOSH 6009 Method Testing Equipment & Set-up

Franklin Township Public SchoolsPine Grove Manor School

Bulk sampling conducted February 20, 2020

Photo Log 1

GymnasiumLab results indicate the rubberized floor contains 120 to 170 ppm of mercury.

Environmental Design Inc. 1-888-306-4545

Franklin Township Public SchoolsPine Grove Manor School

Bulk sampling conducted February 20, 2020

Photo Log 2

Cross-section of actual floor samples from PGM Gymnasium.

Environmental Design Inc. 1-888-306-4545

Franklin Township Public SchoolsPine Grove Manor School

Bulk sampling conducted February 20, 2020

Photo Log 3

Environmental Design Inc. 1-888-306-4545

Bulk samples collected under storage areas on left & right side of stage are considered representative of the entire floor.

EDI

LAB REPORTS & DATA

EMSL Analytical, Inc.200 Route 130 North, Cinnaminson, NJ 08077Phone/Fax: (856) 303-2500 / (856) 858-4571http://www.EMSL.com [email protected]

012001955CustomerID: EDI50CustomerPO:ProjectID:

EMSL Order:

Analytical Results

Attn: Tim GromenEnvironmental Design, Inc.5434 King AvenueSuite 101Pennsauken, NJ 08109

Received: 02/21/20 11:50 AM

PR-200219-1500 PGM

Fax: (586) 616-9517Phone: (856) 616-9516

Project:

Client Sample Description Lab ID:13-0220-101 012001955-0001Gym floor; stage left

Collected: 2/20/2020

Method Parameter Result UnitsAnalysis

Date & AnalystRLPrep

Date & Analyst

METALS

7471B Mercury SW120 mg/Kg 02/26/20 0:009.2 2/26/2020 SW

Client Sample Description Lab ID:13-0220-102 012001955-0002Gym floor; stage right

Collected: 2/20/2020

Method Parameter Result UnitsAnalysis

Date & AnalystRLPrep

Date & Analyst

METALS

7471B Mercury SW170 mg/Kg 02/26/20 0:009.8 2/26/2020 SW

MDL - method detection limitJ - Result was below the reporting limit, but at or above the MDLND - indicates that the analyte was not detected at the reporting limitRL - Reporting Limit (Analytical)D - Dilution Sample required a dilution which was used to calculate final results

Definitions:

ChemSmplw/RDL/NELAC-7.52.0 Printed: 2/26/2020 5:45:11 PM

EMSL Analytical, Inc.200 Route 130 North, Cinnaminson, NJ 08077Phone/Fax: (856) 303-2500 / (856) 858-4571http://www.EMSL.com [email protected]

012002440CustomerID: EDI50CustomerPO:ProjectID:

EMSL Order:

Analytical Results

Attn: Tim GromenEnvironmental Design, Inc.5434 King AvenueSuite 101Pennsauken, NJ 08109

Received: 03/04/20 9:00 AM

FTPS-PGM

Fax: (586) 616-9517Phone: (856) 616-9516

Project:

Client Sample Description Lab ID:58-0303-01 012002440-0001Gym Adj Doors

Collected: 3/3/2020

Method Parameter Result UnitsAnalysis

Date & AnalystRLPrep

Date & Analyst

METALS

NIOSH 6009 Mercury SW0.00028 mg/m³ 3/5/20200.00010 3/4/2020 SW

Client Sample Description Lab ID:58-0303-02 012002440-0002Gym Adj Stage

Collected: 3/3/2020

Method Parameter Result UnitsAnalysis

Date & AnalystRLPrep

Date & Analyst

METALS

NIOSH 6009 Mercury SW0.00029 mg/m³ 3/5/20200.00010 3/4/2020 SW

Client Sample Description Lab ID:58-0303-03 012002440-0003Hall- Steps of rear door #1

Collected: 3/3/2020

Method Parameter Result UnitsAnalysis

Date & AnalystRLPrep

Date & Analyst

METALS

NIOSH 6009 Mercury SWND mg/m³ 3/5/20200.00010 3/4/2020 SW

Client Sample Description Lab ID:58-0303-04 012002440-0004Hall- Dance stage

Collected: 3/3/2020

Method Parameter Result UnitsAnalysis

Date & AnalystRLPrep

Date & Analyst

METALS

NIOSH 6009 Mercury SWND mg/m³ 3/5/20200.00010 3/4/2020 SW

Client Sample Description Lab ID:58-0303-05 012002440-0005Outdoor Rear Door #1

Collected: 3/3/2020

Method Parameter Result UnitsAnalysis

Date & AnalystRLPrep

Date & Analyst

METALS

NIOSH 6009 Mercury SWND mg/m³ 3/5/20200.00010 3/4/2020 SW

Client Sample Description Lab ID:58-0303-06 012002440-0006Blank

Collected: 3/3/2020

Method Parameter Result UnitsAnalysis

Date & AnalystRLPrep

Date & Analyst

METALS

ChemSmplw/RDL/NELAC-2.4.0.0 Printed: 3/5/2020 5:03:40 PM

EMSL Analytical, Inc.200 Route 130 North, Cinnaminson, NJ 08077Phone/Fax: (856) 303-2500 / (856) 858-4571http://www.EMSL.com [email protected]

012002440CustomerID: EDI50CustomerPO:ProjectID:

EMSL Order:

Analytical Results

Attn: Tim GromenEnvironmental Design, Inc.5434 King AvenueSuite 101Pennsauken, NJ 08109

Received: 03/04/20 9:00 AM

FTPS-PGM

Fax: (586) 616-9517Phone: (856) 616-9516

Project:

Client Sample Description Lab ID:58-0303-06 012002440-0006Blank

Collected: 3/3/2020

Method Parameter Result UnitsAnalysis

Date & AnalystRLPrep

Date & Analyst

METALS

NIOSH 6009 Mercury SWND mg/tube 3/5/20200.000010 3/4/2020 SW

Client Sample Description Lab ID:58-0303-07 012002440-0007Blank

Collected: 3/3/2020

Method Parameter Result UnitsAnalysis

Date & AnalystRLPrep

Date & Analyst

METALS

NIOSH 6009 Mercury SWND mg/tube 3/5/20200.000010 3/4/2020 SW

MDL - method detection limitJ - Result was below the reporting limit, but at or above the MDLND - indicates that the analyte was not detected at the reporting limitRL - Reporting Limit (Analytical)D - Dilution Sample required a dilution which was used to calculate final results

Definitions:

ChemSmplw/RDL/NELAC-2.4.0.0 Printed: 3/5/2020 5:03:40 PM

Franklin Township Public Schools

Pine Grove Manor School

Mercury Vapor Testing - March 3, 2020

TrakPro Version 4.70 ASCII Data File

Model: VelociCalc/Q-Trak 7575

Model Number: 7575-X

Serial Number: 7575X1844002

Probe Model Number 982

Probe Serial Number P18440066

Test ID: 1

Test Abbreviation: Test 001

Start Date: 3/3/2020

Start Time: 10:58:15

Duration 8:04:59

Log Interval (mm:ss): 1:00

Number of points: 485

Notes: Test 001

Data TemperatureRelative

Humidity

Carbon

dioxide

Carbon

monoxide

Barometric

Pressure

Units: deg F %rh ppm ppm inHg

Average: 75 36.3 382 0 29.55

Minimum: 73.2 33 364 0 29.45

Time of Minimum: 15:42:14 12:02:15 15:19:14 10:59:15 18:17:14

Date of Minimum: 3/3/2020 3/3/2020 3/3/2020 3/3/2020 3/3/2020

Maximum: 77.5 41.6 449 0 29.71

Time of Maximum: 18:29:14 19:03:14 10:59:15 10:59:15 11:03:15

Date of Maximum: 3/3/2020 3/3/2020 3/3/2020 3/3/2020 3/3/2020

EDI LIMITATIONS AND SERVICE CONSTRAINTS

Environmental Design Inc. (EDI) has presented professional opinions in this report based on information provided to us by the Client and gathered by EDI personnel on site. Conditions described in this report are as found at the time of the investigation, unless stated otherwise. The Client selected the date and time of our evaluation. Sample results represent a snapshot of environmental conditions at a specific time. Indoor and outdoor environmental conditions can change daily, weekly, monthly, and even throughout the day. EDI has done nothing to create or contribute to the presence of any hazardous waste, pollutants, chemicals, or other hazardous materials at the Client’s property. A full and complete determination as to whether a certain property is or is not free from environmental hazards cannot be made with 100% certainty. The Client retained EDI for the sole purpose of assisting them in evaluating indoor mercury levels in the gym. EDI is only responsible for the limited evaluation of specific areas of the school that the Client requested EDI to assess, and only for the specific samples collected. The evaluation conducted by EDI was non-destructive (i.e. walls were not broken open, drop ceilings were not removed, etc.). EDI did not evaluate nor are we qualified to assess the operational effectiveness of the mechanical systems providing heating and air conditioning. Mechanical systems that are not operating properly or that do not adequately provide sufficient fresh air or air exchanges can be a significant contributing factor in any indoor quality problem. The tests EDI conducted were based on the problem described by the Client and site conditions at the time of our evaluation. These tests may not be the only testing methodologies available for this type of evaluation. Further, the test results represent a “snap shot in time” of the conditions at the site and are reflective of the conditions at the time of the evaluation only. EDI receives no remuneration for any products suggested for use in cleaning or remediation. EDI will not be held liable for any disclosures, notifications, or reports that may be required to be made to third parties, including the governmental agencies.

EDI

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