MEMORANDUM TO: FROM: Susan Thorneloe, EPA Paul Lemieux, EPA Aaron Osborne DATE: November 23, 2004 SUBJECT: Investigation of Previous BDR Disposal Incidents As ERG continues to develop the Building Decontamination Residue Decision Support Tool (BDR DST), we have investigated several previous biological/chemical contamination cleanup efforts to assist in the development of guidance in the event of future decontamination activities. This memorandum summarizes the findings of this investigation applicable to the development of the BDR DST. Five incidents involving biological/chemical contamination are discussed in this memorandum. The incidents were chosen based on availability of applicable information, such as, building decontamination methods, BDR removal techniques, PPE worn during BDR handling, waste classification (e.g., municipal, infectious, hazardous), and any additional information related to worker safety, packaging, storage, and transportation of the BDR. The sources of this information are cited throughout the memorandum. Several key findings of this research are: For the cases examined, BDR was not completely decontaminated prior to removal from the facility. This impacts worker safety concerns during the removal, packaging, storage, and transportation of BDR and influences the waste classification of the BDR for final disposal. Anthrax contaminated wastes were treated as infectious waste, and the associated regulations (DOT, etc.) were applied to the storage, packaging, and shipping of anthrax contaminated wastes. PCB and explosive residue contaminated wastes were classified as hazardous waste, and the associated regulations were applied to storage, packaging, and shipping of these wastes. Note that no case studies were found for the cleanup of facilities contaminated with chemical agents (e.g., VX, mustard). PCB and explosive residue contamination cleanups were used as the best available case studies. While bleach solutions were found to be 100% effective at eliminating anthrax on hard surfaces, neither bleach nor foams were 100% effective at eliminating anthrax in carpet and porous surfaces. Therefore, porous surfaces will be contaminated during the storage, packaging, and shipment.
Page 2 Incident #1 Reston Ebola, Reston, VA, 1989 Incident Summary: A research lab was contaminated with the Ebola virus when infected monkeys were imported from the Philippines. The strain of Ebola was later found to be non-infectious to humans. Decontamination Method: The facility was first hosed down with a bleach solution. Later, final decontamination consisted of fumigation with paraformaldehyde at 10,000 ppm for 48 hours. BDR Handling: All straw, bedding, and porous material was removed and sent to incineration. The source was not clear whether this happened prior to bleach decontamination or not. It is clear that this occurred prior to fumigation. PPE: During the decontamination process workers wore (the source does not clearly say what was worn during BDR removal): Green surgical scrubs; Tyvek suits; Triple gloves (one heavy latex glove like those used when washing dishes); Tennis shoes and rubber boots; Clear plastic helmet; and Positive pressure HEPA filtered air supply. After use, PPE was collected as infectious waste, bagged, and shipped for incineration. Workers complained about poor dexterity while trying to perform decontamination activities in this PPE. Shipping Information: Contaminated waste was drenched in bleach and double bagged. The bags were placed in paraffin-impregnated hatboxes. The boxes were double bagged and placed in Styrofoam chests. Lots of absorbent material (e.g., kitty litter) was also placed in the bags and in the hatboxes. Wastewater Disposal: Wastewater from the first decontamination with bleach apparently went down the drain. All drains in the facility were thoroughly drenched with bleach. Wastewater from personnel decontamination was collected and sent for some unknown special treatment. Additional Safety Information: Only two people were allowed in the facility at a time. It took 30 minutes to suit up workers in this level PPE, and approximately the same time to decontaminate them after work. Workers were only allowed to work for one-hour intervals, then they were required to sit down and rest for 30 minutes.
Page 3 Sources: U.S. Department of Health and Human Services, 1995. Proceedings of the Seminar on Responding to Consequences of Chemical and Biological Terrorism, Bethesda, MD, July 11-14, 1995. Alexander, L. 1998. Decontaminating Civilian Facilities: Biological Agents and Toxins, Institute of Defense Analysis, Alexandria, VA. Incident #2 State Department Mail Facility, Sterling, VA, 2001 Incident Summary: A letter containing anthrax spores contaminated the facility. Two postal workers died from inhalation anthrax. Decontamination Method: Hot spots were first cleaned with a bleach solution, followed by fumigation with vaporized hydrogen peroxide. BDR Handling: Our strategy is to dispose of as much of the contents of the building as possible, thereby significantly reducing the exposed surface area for fumigation. (U.S. Department of State, 2002) BDR items removed included documents, furniture, insulation, and drywall. The BDR removal occurred before hot spots were decontaminated with bleach. Some of the BDR was sent directly to an incinerator in Macon, GA. Other BDR items were sent to an autoclave in Jacksonville, FL, and subsequently landfilled or returned for use. Additional Information: In response to this incident and the release of anthrax at several other facilities, EPA released guidance for these decontamination efforts. The key points from this guidance document are summarized later in this memorandum. Sources: Laris, M. 2002. Crews Begin Cleanup of State Department Mail Site in Northern Virginia, Washington Post, December 17, 2002. http://www.ph.ucla.edu/epi/bioter/anthraxcleanupstatedept.html U.S. Department of State, 2002. Press Releases, Decontamination of Sterling Mail Facility. December 16, 2002. http://www.state.gov/r/pa/prs/ps/2002/15992.htm Incident #3 Hart Senate Office Building, Washington, DC, 2001 Incident Summary: A letter containing anthrax spores was opened in Senator Tom Daschle s office. The entire building required extensive decontamination.
Page 4 Decontamination Method: Hard surfaces were first decontaminated with a bleach solution. The solution was 1 part household bleach, 1 part white vinegar, and 8 parts water. The building was later fumigated with chlorine dioxide gas. Several mailrooms through which the letter was shipped were decontaminated using an anti-bacterial foam. BDR Handling: Moving furniture, papers, and other BDR items around was found to reaerosolize anthrax; therefore, BDR items were removed prior to vapor phase decontamination. However, prior to disposal, BDR items were rinsed with a 500-ppm aqueous chlorine dioxide solution. All BDR was sent to an incinerator. The source indicates that larger items were also incinerated, but does not provide the specific size reduction techniques. PPE: In response to the incident, CDC issued official guidance stating workers performing environmental sampling for anthrax (i.e., testing to see if decontamination was effective) should wear the following PPE: Powered air-purifying respirator with full facepiece and HEPA filter; Disposable PPE with integral hood and bootie; and Disposable gloves made of lightweight nitrile or vinyl so as not to compromise dexterity. After use, PPE was collected and shipped to a medical waste incineration. Wastewater Disposal: Decontamination wastewater was collected and sampled. Even though sampling did not detect anthrax, the water was steam sterilized as a conservative step. The source specifically states that the water was not sent to a POTW for final disposal, but does not state the final destination of the water. Additional Information: In response to this incident and the release of anthrax at several other facilities, EPA released guidance for these decontamination efforts. The key points from this guidance document are summarized later in this memorandum. Sources: Vogt, B. and Sorensen, J. 2002. How Clean is Safe? Improving the Effectiveness of Decontamination Structures and People Following Chemical and Biological Incidents. Oak Ridge National Laboratory, Oak Ridge, TN. Powell, M. 2002. Disposal of Wastes From Anthrax Contaminated Sites, HAZWOPER Training, Palm Beach, FL, October 4, 2002.
Page 5 Incident #4 Mercury Released in a School, Indiana, 1999 Incident Summary: A student brought 50 cc of mercury to school and played with it throughout the day. Decontamination Method: A commercial vendor preformed the decontamination. The vendor first identified where mercury contamination was located using a field screen with a black light. A substance that absorbs mercury, Mercsorb, was applied to contaminated areas and subsequently vacuumed up. A special powder that turns blue in the presence of mercury was also used to determine if mercury was present in the air. BDR Handling: Books, clothes, and carpet were thrown away prior to decontamination efforts, but other items, such as desks, were decontaminated. PPE: Cleanup personnel wore (the source does not clearly say what was worn during BDR removal): Saranix suits; Booties; Double layered latex gloves; and Respirators. Wastewater Disposal: People were decontaminated over a storm drain. Source: Vogt, B. and Sorensen, J. 2002. How Clean is Safe? Improving the Effectiveness of Decontamination Structures and People Following Chemical and Biological Incidents. Oak Ridge National Laboratory, Oak Ridge, TN. Incident #5 PCBs Released at the Commerce Building, Washington, DC, 1999 Incident Summary: An electrical surge caused capacitors to leak oil containing PCBs. Parts of the building were closed for three months to clean up the PCBs. Decontamination Method: Absorbent materials were used to collect standing pools of liquid. Surfaces were then decontaminated using solvent (turpentine, PipeX, and MetalX) rinses. BDR Handling: Non-metal items were discarded. Metal items were decontaminated. Additional Information: In response to several other PCB leaks, guidance was released on the PCB decontamination. The key points from this guidance document are summarized later in this memorandum.
Page 6 Source: Vogt, B. and Sorensen, J. 2002. How Clean is Safe? Improving the Effectiveness of Decontamination Structures and People Following Chemical and Biological Incidents. Oak Ridge National Laboratory, Oak Ridge, TN. Guidance Documents on Anthrax Decontamination This information is from the following EPA guidance documents on anthrax decontamination. They were written in response to the anthrax releases at the Hart Senate Office Building and other facilities. Arduino, M. and Sweeney, M., 2001. Draft Interim Recommendations for the Cleanup of Commercial and Residential Buildings Following Bacillus anthracis Spore Release. U.S. Environmental Protection Agency. U.S. EPA, 2004. Federal Anthrax Decontamination Efforts. http://www.epa.gov/epahome/hianthrax.htm Decontamination Method: The following conditions apply to the use of a bleach solution for anthrax decontamination: Only hard surfaces may be treated. A bleach solution close to but not above ph 7 (neutral) and 5,000 to 6,000 parts per million (ppm) should be prepared by mixing one part bleach (5.25%-6.00%) to one part white vinegar to eight parts water. Bleach and vinegar must not be combined together directly; rather some water must first be added to the bleach (e.g., two cups water to one cup of bleach), then vinegar (e.g., one cup), and then the rest of the water (e.g., six cups). The ph of the solution should be tested with a paper test strip. Treated surfaces must remain in contact with the bleach solution for 60 minutes (repeated applications will be necessary to keep the surfaces wet). (U.S. EPA, 2004.) BDR Handling: Porous surfaces (carpets, drapes, ceiling tiles, wallpaper) can be treated with bleach solutions to decrease spore count, but must be removed and properly discarded after treatment, because decontamination methods are not 100% effective on porous BDR. Anthrax contaminated solid and liquid wastes must be handled in a manner no less stringent than as medical waste. Disposal of porous items should only occur after a personnel decontamination station has been established. This implies that workers disposing of BDR will be wearing extensive PPE.
Page 7 Because dirt and other material on a surface will decrease the efficiency of decontamination agents, all surfaces should be precleaned with a surfactant prior to decontamination. Similar to asbestos abatement, strategies must be developed for the minimization of anthrax aerosolization: Do not use compressed air for cleaning; Only use wet operations or HEPA filters; and Do not dry sweep or dry dust. Objects with internal cooling fans (computers) may be a contamination concern, and should be specially treated for decontamination or disposal PPE: PPE should be selected based on HAZWOPER standards. Contaminated clothing and PPE must be either disposed of as pathological waste or sent to an autoclave. People cleaning areas adjacent to, but not identified as contaminated with anthrax, should wear the following PPE: Filtering full face piece respirator (N-95); and Nitrile or vinyl gloves. Packaging, Storage, and Transportation: Wastes must be: DOT Division 6.2 (Infectious Substances) requirements should be followed for the packaging of anthrax contaminated wastes. For storage, wastes must be: Properly packaged; Protected from weather; Protected from unauthorized human access; Protected from vermin access; and Stored in a manner following any state specific regulations, such as, time limits. DOT Hazardous Materials Regulations (49 CFR 171-180) should be followed to the transportation of anthrax contaminated wastes. Additional Information: All HAZWOPER standards apply, including: Health and safety plan development; Medical surveillance; PPE program; and Appropriate training. The contaminated area should be sealed the same way an asbestos abatement area would be sealed.
Page 8 All ducts should be tested for contamination. Decontaminating vents may be especially difficult if they are lined with fiberglass. Waste packaging fell under DOT Division 6.2 (Infectious Substances) requirements Transportation fell under DOT Hazardous Materials Regulations (49 CFR 171-180) Guidance Document on PCB Decontamination - This information is from the Mitchel report document written in response to several PCB contamination incidents. Hazardous contamination levels were taken from OSHA s website. Mitchel, Scadden, and Weston. PCB Decontamination Methods for Achieving TSCA Compliance During Facility Decommissioning Projects. NDIA Environmental Symposium and Exhibition, Austin, TX, April 25, 2001. OSHA, 2001. Chemical Agent Multi Media/Toxicity Table. http://www.osha.gov/sltc/emergencypreparedness/chemical/pdf/cwa-mediatable3-19-01.pdf Decontamination Method: PCB contaminated materials can be decontaminated using double wash-rinses with solvents. BDR Handling: The easiest and most cost effective way to dispose of porous surfaces contaminated with PCB is disposal as hazardous waste. Decontamination is difficult and more expensive. Materials containing less than 50 mg of PCB/kg of bulk media and less than 10- micrograms of PCB/100 cm 2 of exterior surface can be disposed of in a regular municipal landfill. Above these concentrations, BDR items must be treated as hazardous waste. Similar hazardous contamination levels have been developed by DOD for several chemical agents. The following are maximum concentrations for disposal at a nonhazardous waste facility: Mustard 0.3 mg/kg GA 68 mg/kg GB 32 mg/kg GD/GF 5.2 mg/kg VX 1.1 mg/kg Lewisite 3.7 mg/kg
Page 9 Guidance Document on Explosive and Chemical Agent Disposal The following information is from the Navy s guidance document on the disposal and decontamination of explosives and chemical agents. Naval Sea System Command (NAVSEA), 2004. Ammunition and Explosive Safety Ashore, OP 5, Revision 7, Change 3. BDR Handling: M8 Chemical Test Strips may be used to determine if an item is contaminated with a chemical agent. Contaminated BDR should be treated as hazardous waste in accordance with all applicable regulations. Packaging, Storage, and Transportation: A fence should be placed around the storage facility at a minimum of 30 feet from the facility. All items should be properly tagged, including its type and degree of contamination and appropriate handling restrictions. Extensive information on shipping regulations for explosives are also contained in the manual, similar to DOT regulations. Wastewater Disposal: Discharging ammunition or material contaminated with explosive or chemical agents into watersheds, sewers, streams, lakes, or waterways is prohibited.