HEALTH CONSULTATION
MERCURY IN ST. PAUL RESIDENCE
ST. PAUL, RAMSEY COUNTY, MINNESOTA
ATTACHMENT 2: LUMEX READINGS (cont.)
Lumex Readings, XXXXXXXXXXXXXXXX, June 21, 2001
The Lumex was operated by Judy Grant, Xcel Energy Environmental Services
- readings below were recorded by Sarah Meyers from Weston and Judy Grant
Location of Readings |
Lumex Readings |
||
ng/m3 |
|||
Max* | Ave | R (%) | |
Readings taken at 10:15 AM by Judy Grant using the Lumex: (Sarah Meyers recording readings) |
|||
Outside - on back steps, no hose | 32 | 160 | |
Outside - in yard, no hose | 7 | 40 | |
Outside - in yard, with hose attached | 4 | 16 | |
1st Floor - 4' above floor in middle of kitchen - kitchen ambient | 202 | 198 | 4 |
1st Floor - 4' above floor at the top of the stairs with containment open | 370 | 337 | 14 |
Basement - 4' above the floor in front of the stairs | 406 | 396 | 5 |
Basement - 4' above the floor in middle of the basement between the two posts - basement ambient | 442 | 430 | 4 |
Basement - 4' above the floor in the NE corner where the device was removed | 453 | 439 | 8 |
Basement - 4' above the floor over the area where the wooden partition had been removed | 516 | 511 | 2 |
Basement - 2" above the floor over the area where the wooden partition had been removed | 609 | 572 | 12 |
Basement - 5.5' above floor in the NE corner on the wall where higher levels were detected before | 765 | 687 | 22 |
Basement - scan of NE corner wall patch | ~520 | ||
Basement - 4' above the floor in where the old wash tub had been removed (new not yet installed) | 473 | 468 | 2 |
Basement - 3" above the floor drain | 486 | 469 | 8 |
Basement - 1" to 2" from drain cover | 515 | 497 | 6 |
Basement - 1" to 2" from cement patch by east post, north side of patch | 702 | 659 | 10 |
Basement - 5" from indents in floor near NE corner | 1,878 | 1,433 | 67 |
Basement - 5" from the floor in the NE corner | 1,287 | 958 | 58 |
Basement - 4' above the floor in the middle of the basement between the two posts - basement ambient | 497 | 476 | 10 |
Basement - 1" to 2" above new cement at the foot of the stairs | 400 - 500 | ||
Basement - 1" to 2" above new cement at the foot of the stairs, between cement patches | 1,500 - 2,100 | ||
Basement - 4' above the floor west side of the hot water heater, east of furnace | 527 | 513 | 13 |
Basement - 4' above the floor east side of the hot water heater | 517 | 493 | 10 |
Readings taken at 12:26 PM by Judy Grant using the Lumex: (Judy Grant recording readings) |
|||
1st Floor - 4' above floor in middle of kitchen, gas off, door and window closed, air movement coming from upstairs to basement through kitchen | 10 8 9 8 |
9 8 8 8 |
6 16 14 6 |
1st Floor - 5" from front right burner of stove, oven open, 4" above surface of stove - Gas Off | 12 11 11 |
11 10 10 |
24 22 9 |
1st Floor - 5" from front right burner of stove, oven open, 4" above surface of stove - Gas/Flame On | 12 13 12 10 10 |
10 11 11 10 9 |
36 27 30 15 18 |
1st Floor - 5" from front right burner of stove, oven open, 4" above surface of stove - As Gas Turned Off | 13 | 11 | 22 |
1st Floor - 5" from front right burner of stove, oven open, 4" above surface of stove - Gas On No Flame | 47 | 31 | 109 |
1st Floor - just inside open oven door - Gas Off | 7 | 7 | 16 |
1st Floor - just inside open oven door - Gas On and oven set at 205 degrees | 8 | 7 | 14 |
1st Floor - just inside open oven door - Gas On and oven set at 205 degrees - smelling gas | 28 | 27 | 3 |
1st Floor - just inside open oven door - Gas On and oven set at 205 degrees - not smelling gas air becoming hot (may be exceeding) | 49 123 |
41 96 |
41 50 |
1st Floor - just inside open oven door - Gas On and oven set at 205 degrees - holding hose higher because of heat from oven (may be | 120 90 |
112 80 |
11 35 |
Readings taken at around 4:00 PM by Judy Grant using the Lumex: (Sarah Meyers & Mueller Pipeliners recording) |
|||
Basement - 4' above the floor east side of the hot water heater | 94 | 86 | 27 |
Basement - east side of the hot water heater - inside bag, near trap, trap ON | 150 179 216 |
120 175 206 |
38 4 14 |
Basement - east side of the hot water heater - inside bag, near end of pipe where trap had been, trap Off | 236 175 155 |
215 154 137 |
18 28 23 |
Basement - east side of the hot water heater - inside bag, inside trap which was not attached to the pipe | 287 263 |
271 259 |
12 2 |
Basement - 4' above the floor east side of the hot water heater | 312 | 240 | 64 |
Basement - east side of the hot water heater - inside bag, near end of pipe where trap had been, trap OFF Taken after Mueller put gas | 317 311 |
309 300 |
6 7 |
* - The maximum value is the maximum of the three ten second averages which are recorded by the Lumex. The average of these is the average value provided and the R(%) is the variability which applies to this average.
Lumex Readings, XXXXXXXXXXXXXXXXX, June 22, 2001
The Lumex was operated by Judy Grant, Excel Energy Environmental Services
- readings below were recorded by XXXXXXXXXXXX and Judy Grant
Location of Readings |
Lumex Readings | ||
ng/m3 | |||
Max* | Ave | R (%) | |
Readings taken at 12:15 PM by Judy Grant using the Lumex: (XXXXXXXXXXXXX recording readings) | |||
1st Floor - 4' above floor in middle of kitchen - kitchen ambient | 143 146 |
141 141 |
3 5 |
1st Floor - 4' above the floor at the top of the stairs | 152 | 149 | 3 |
Basement - 4' above the floor, in front of the stairs | 166 | 165 | 1 |
Basement - 4' above the floor, in the middle of the basement between the two posts - basement ambient | 185 176 |
173 174 |
1 2 |
Basement - 4' above the floor, 3' in front of the east corner of the firebox on the edge of the epoxy | 180 | 179 | 1 |
Basement - 4' above the floor, under the middle of the stairs | 180 189 |
179 182 |
1 7 |
Basement - 4' above the front right corner of the washing machine | 209 | 206 | 3 |
Basement - inside washer | 235 | 228 | 8 |
Basement - 4' above the floor drain area at the edge of the epoxy | 232 | 217 | 16 |
Basement - 4' above the floor, in the middle of the basement between the two posts - basement ambient | 207 | 203 | 3 |
Basement - 4' above the floor, in the middle of the basement between the two posts after walking around | 215 | 210 | 4 |
Basement - 4' above the floor, 3' west of the over the area where the wooden partition had been removed | 211 | 209 | 2 |
Basement - 4' above the floor, 2' west of the over the area where the wooden partition had been removed | 215 | 212 | 3 |
1st Floor - 4' above floor in middle of kitchen - kitchen ambient | 172 | 168 | 4 |
1st Floor - 4' above the floor in the dining room above the dining room table - dining room ambient | 119 | 113 | 9 |
1st Floor - 4' above the floor in the middle of the living room in front of the fireplace | 115 | 115 | 1 |
Stairs 1 to 2 - 4' above the floor on the landing of the stairs | 106 | 106 | 0 |
2nd Floor - 4' above the floor at the top of the stairs by the bathroom | 102 | 101 | 1 |
2nd Floor - 4' above the floor in the SE bedroom near the corner of the bed | 101 | 100 | 2 |
2nd Floor - 4' above the floor in the sun porch | 103 | 100 | 6 |
2nd Floor - 4' above the floor in the NE bedroom, over SW corner of bed | 95 | 92 | 5 |
2nd Floor - 4' above the floor in the hallway | 100 | 99 | 1 |
2nd Floor - 4' above the floor in the NW bedroom | 103 | 103 | 0 |
Readings taken at 2:15 PM by Judy Grant using the Lumex: (Judy Grant recording readings) | |||
1st Floor - 4' above floor in middle of kitchen - kitchen ambient | 173 | 171 | 1 |
1st Floor - 4' above the floor in the dining room above the dining room table - dining room ambient | 162 | 156 | 8 |
1st Floor - 4' above the floor in the middle of the living room in front of the fireplace | 148 | 144 | 6 |
2nd Floor - 4' above the floor in the SE bedroom near the corner of the bed | 127 | 127 | 0 |
2nd Floor - 4' above the floor in the sun porch | 119 | 118 | 1 |
2nd Floor - 4' above the floor in the NE bedroom, over SW corner of the bed | 112 | 111 | 1 |
Basement - 4' above the floor, in front of the stairs | 214 | 204 | 10 |
Basement - 4' above the floor, in the middle of the basement between the two posts - basement ambient | 235 | 228 | 6 |
Basement - 4' above the floor, 3' in front of the east corner of the firebox on the edge of the epoxy | 197 | 193 | 4 |
Readings taken at around 5:00 PM by Judy Grant using the Lumex: (Judy Grant recording readings) | |||
Outside - on south steps | 57 | 40 | 86 |
Outside - foot of the south steps | 3 | 1 | 121 |
1st Floor - 4' above floor in middle of kitchen - kitchen ambient | 113 | 110 | 8 |
1st Floor - 4' above the floor in the dining room above the dining room table - dining room ambient | 125 | 124 | 0 |
1st Floor - 4' above the floor in the middle of the living room in front of the fireplace | 134 | 132 | 1 |
2nd Floor - 4' above the floor in the SE bedroom near the corner of the bed | 127 | 125 | 1 |
2nd Floor - 4' above the floor in the sun porch | 119 | 118 | 1 |
2nd Floor - 4' above the floor in the NE bedroom, over SW corner of bed | 108 | 108 | 1 |
Basement - 4' above the floor, in front of the stairs | 256 | 244 | 9 |
Basement - 4' above the floor, in the middle of the basement between the two posts - basement ambient | 261 | 256 | 6 |
Basement - 4' above the floor, 3' in front of the east corner of the firebox on the edge of the epoxy | 238 | 235 | 3 |
Basement - 4' above the floor, near the drier where the certification sample was set up | 272 267 |
270 265 |
1 1 |
Readings taken at 8:00 PM by Judy Grant using the Lumex: (Judy Grant recording readings) | |||
Outside - in yard | 5 3 |
4 2 |
47 47 |
Outside - foot of the south steps | 8 | 6 | 76 |
Outside - on south steps near certification sample | 15 | 9 | 114 |
1st Floor - 4' above floor in middle of kitchen - kitchen ambient | 94 99 |
93 96 |
3 4 |
1st Floor - 4' above the floor in the dining room above the dining room table - dining room ambient | 106 | 105 | 0 |
1st Floor - 4' above the floor in the dining room, SE corner of table near certification sample (done) | 107 | 102 | 9 |
1st Floor - 4' above the floor in the middle of the living room in front of the fireplace | 120 | 119 | 2 |
1st Floor - 4' above the floor in the living room, north side of table near certification sample (done) | 121 | 121 | 0 |
2nd Floor - 4' above the floor in the SE bedroom near the corner of the bed | 118 | 115 | 4 |
2nd Floor - 4' above the floor in the SE bedroom, NE corner of the dresser near certification sample (done) | 121 | 121 | 1 |
2nd Floor - 4' above the floor in the sun porch | 111 100 |
108 97 |
6 7 |
2nd Floor - 4' above the floor in the NE bedroom, over SW corner of bed | 116 | 114 | 4 |
2nd Floor - 4' above the floor in the NE bedroom, over NE corner of bed near certification sample (done) | 113 | 112 | 0 |
Basement - 4' above the floor, in front of the stairs | 233 241 |
231 238 |
1 1 |
Basement - 4' above the floor, in the middle of the basement between the two posts - basement ambient | 245 249 |
241 245 |
4 2 |
Basement - 4' above the floor, 3' in front of the east corner of the firebox on the edge of the epoxy | 262 265 |
258 260 |
4 5 |
Basement - 4' above the floor, near the drier where the certification sample was set up | 259 256 |
251 252 |
7 3 |
* - The maximum value is the maximum of the three ten second averages which are recorded by the Lumex. The average of these is the average value provided and the R(%) is the variability which applies to this average.
Lumex Readings, XXXXXXXXXXXXXXXX, June 25, 2001
The Lumex was operated by Judy Grant, Xcel Energy Environmental Services
# NAME?
Location of Readings |
Lumex Readings | ||
ng/m3 | |||
Max* | Ave | R (%) | |
Outside - with tube on (prior to bag sampling) | 5 | 5 | 6 |
Outside - without tube on (prior to bag sampling) | 8 6 |
7 6 |
31 20 |
Outside - with tube on (after bag sampling) | 10 | 10 | 6 |
1st Floor - 4' above floor in middle of kitchen - kitchen ambient | 20 14 22 12 |
17 12 16 11 |
41 21 55 9 |
1st Floor - 4' above the floor in the dining room above the dining room table - dining room ambient | 33 44 20 |
32 37 18 |
8 32 25 |
1st Floor - 4' above the floor in the middle of the living room in front of the fireplace | 29 25 |
26 22 |
16 21 |
2nd Floor - 4' above the floor at the top of the stairs | 7 7 |
7 7 |
6 6 |
2nd Floor - 4' above the floor in the SE bedroom near the corner of the bed | 6 8 |
6 7 |
2 11 |
1st Floor - 4' above floor in middle of kitchen - kitchen ambient | 5 7 7 |
5 6 7 |
4 16 5 |
Basement - 4' above the floor, in front of the stairs | 170 175 |
169 175 |
1 0 |
Basement - 4' above the floor, in the middle of the basement between the two posts - basement ambient | 199 194 |
184 191 |
13 4 |
Basement - 4' above the floor in the NE corner where the device was removed | 188 188 |
183 185 |
5 3 |
Basement - 4' above the floor over the area where the wooden partition had been removed | 192 | 189 | 2 |
Basement - 5" above the floor over the area where the wooden partition had been removed | 227 234 |
218 232 |
9 2 |
Basement - 4' above the paint in the storage area to the west at the bottom of the stairs | 142 | 137 | 5 |
Basement - 4' above the floor over the new wash tub | 183 | 183 | 0 |
Basement - 5" above the floor drain | 213 | 208 | 5 |
Basement - inside the drier | 190 | 189 | 1 |
Basement - 5" from cement patch by east post, NE side of patch | 250 | 249 | 2 |
* - The maximum value is the maximum of the three ten second averages which are recorded by the Lumex. The average of these is the average value provided and the R(%) is the variability which applies to this average.
Lumex Readings, XXXXX, July 3, 2001
The Lumex was operated by Carol Hubbard from the MPCA, readings below were recorded by Judy Grant
Location of Readings |
Lumex Readings | ||
ng/m3 | |||
Max* | Ave | R (%) | |
Outside | 9,7 | 9,6 | 15,16 |
Garage - 4' above the floor in the middle of the garage | 21 | 20 | 1 |
Garage - 4' above the floor in the SW corner, 4' from each wall (drums had been stored in this area) | 17 | 16 | 5 |
Garage - 4' above the floor in the NW corner, 4' from each wall | 16 | 15 | 10 |
Garage - 3" to 6" above the floor in the middle of the garage | 17 | 16 | 3 |
Garage - 3" to 6" above the floor in the SW corner, 4' from each wall (drums had been stored in this area) | 18 | 17 | 19 |
Garage - in bag of detergent (106 ng/m3 previously) | 45 | 44 | 7 |
Garage - in bag of old tools (433 ng/m3 previously) | 17 | 17 | 4 |
Garage - in bag of chalk tools (313 & 309 previously) | 19 | 18 | 8 |
Garage - in blue garbage can that contained the new tool (161 and 29 previously) | 16 | 15 | 3 |
Garage - above the 45s (25 previously) | 16 | 15 | 4 |
Garage - 1" to 2" from brooms which were used in the basement before the spill on 6/5/01 | 14 | 14 | 3 |
Garage - 1" to 2" from new over yellow plastic disposable boots from Weston on table | 14 | 13 | 5 |
Garage - 1" to 2" from partial roll of red duct tape from Weston on table | 17 | 16 | 14 |
1st Floor - 4' above floor in middle of kitchen - kitchen ambient | 20 | 18 | 13 |
Basement - 4' above the floor, in front of the stairs | 143 | 142 | 0 |
Basement - 4' above the floor, in the middle of the basement between the two posts - basement ambient | 153 | 152 | 1 |
Basement - 4' above the floor in the NE corner where the device was removed | 162 | 159 | 4 |
Basement - 4' above the floor, 5' in front of the NE corner where the device was removed | 175 | 174 | 1 |
Basement - 4' above the floor over the area where the wooden partition had been removed | 171 | 170 | 1 |
Basement - 5" above the floor, in front of the stairs | 146 | 144 | 2 |
Basement - 5" above the floor, in the middle of the basement between the two posts - basement ambient | 179 | 175 | 4 |
Basement - 5" above the floor in the NE corner where the device was removed | 225 | 212 | 9 |
Basement - 5" above the floor, 5' in front of the NE corner where the device was removed | 189 | 186 | 3 |
Basement - 5" above the floor over the area where the wooden partition had been removed | 181 | 171 | 9 |
Basement - 5" above the floor 5' in front of the firebox | 157 | 149 | 7 |
Basement - 4' above the floor 5' in front of the firebox | 157 | 150 | 8 |
Basement - 1" above the floor drain | 164 | 162 | 1 |
Basement - 4' above the floor drain | 159 | 157 | 3 |
Basement - 5.5' above the floor in the NE corner where the device was, 1" from the lip which was removed | 189 | 181 | 9 |
Basement - 5" above the floor in the NE corner, 4' from each wall | 189 | 180 | 10 |
Basement - 5" above the NE corner of the drier where the certification sample was taken | 165 | 163 | 2 |
Basement - in washer | 164 | 162 | 2 |
Basement - in drier | 144 | 143 | 1 |
Basement - 4' above the floor of the paint storage area to the west of the foot of the stairs | 138 | 138 | 0 |
Basement - 5" from cement patch by east post, north side of patch | 199 | 188 | 10 |
* - The maximum value is the maximum of the three ten second averages which are recorded by the Lumex. The average of these is the average value provided and the R(%) is the variability which applies to this average.
Lumex Readings, XXXXX, July 13, 2001
The Lumex was operated by Carl Herbrandson from the Department of Health
Readings were recorded by Judy Grant and observed by XXXXX.
Location of Readings | Lumex Reading
ng/m3 |
|
Ave* | R(%) | |
1st Floor - 4' above floor in middle of kitchen - kitchen ambient | 8 | 25 |
1st Floor - in the pots on the lowest shelf, open shelving in the kitchen on the west wall | 16 | 50 |
1st Floor - 6" above the floor in the middle of the living room in front of the fireplace | 2 | 2 |
Basement - 1' above the floor, in front of the stairs | 93 | 8 |
Basement - 1' above the floor 1' north of the area where the wooden partition had been removed | 128 | 13 |
Basement - 1' above the floor in the NE corner where paint was removed, 4' from each wall | 125 | 15 |
Basement - 1' above the floor in the NE corner where the device was removed | 269 | 10 |
Basement - 4' above the floor in the NE corner where the device was removed | 154 | 11 |
Basement - 1' above the floor drain | 119 | 2 |
Basement - 2" from the east wall, 5' above the floor where the wooden partition had been removed | 126 | 3 |
Basement - 4' above the floor, in the middle of the basement between the two posts-basement ambient | 120 | 1 |
Basement - in washer | 154 | 13 |
Basement - in drier | 106 | 2 |
* - The average values is the average of the three ten second averages which were recorded by the Lumex. The R(%) is the variability which applies to this average.
July 11, 2001
Ms. XXXXXXXX
XXXXXXXXXXXXXXXXX
St. Paul, Minnesota 551XX
Dear Ms. XXXX:
This letter is written in response to your request for a report on the mercury contamination in your house.
We were informed that in early June service personnel under contract with Xcel Energy, removed a piece of equipment containing mercury from your natural gas line. It was reported that a small amount of mercury was spilled on your basement floor. Xcel hired BayWest to cleanup the mercury spill. Mercury vapor in the basement was measured with a Jerome Meter after the cleaning process was complete. The maximum Jerome reading after the cleanup was reported to be 349,000 ng/m3. This high concentration was not expected and therefore, questions about possible interference from ammonia in a cat litter box were raised. It was confirmed that kitty litter and other odorous material can interfere with correct readings on the Jerome meter.
Carol Hubbard, from the Minnesota Pollution Control Agency, and I accompanied Xcel Energy into the house on the afternoon of June 8th. Using a Lumex Mercury Vapor Analyzer, mercury levels were measured outside the house, on the main floor, and in the basement. Mercury concentrations in ambient air outside the house fluctuated between less than 30 ng/m3 and more than 150 ng/m3. The instrument readings appeared to stabilize below 30 ng/m3 when the instrument was held in the shade. Typical mercury concentrations outdoors are less than 10 ng/m3.
We entered the house through the back door into the kitchen and measured the mercury concentration to be between 1,500 and 3,500 ng/m3 in the kitchen. The mercury concentration increased on the stairs to the basement. Mercury concentrations in the basement ranged from 20,000 to 51,000 ng/m3. The Lumex is not thought to be sensitive to ammonia, and readings near the kitty litter box were consistent with what was encountered in other areas of the basement. According to the manufacturer, the sensitivity of the Lumex flattens out as mercury concentrations in air approach 50,000 ng/m3. Therefore, the actual mercury concentrations in air in the basement may have been higher in some areas.
Exposure to mercury concentrations above 6,000 ng/m3 for a long time (years) has been associated with hand tremors; increases in memory disturbances and other neurological effects. MDH advised Xcel that you, the owner of the house, be temporarily removed from the house until the house was re-cleaned to levels below the EPA Reference Concentration for mercury of 300 ng/m3. The RfC is considered protective for the general public, including sensitive sub-populations such as children, for life-time exposures. It is my understanding that you were relocated for the duration of most of the cleanup.
According to Xcel Energy, on Wednesday, June 13 contractors experienced in cleaning up mercury spills in basements (Weston, Chicago, IL) began cleanup operations. Cleaning methods included use of a mercury cleanup (amalgamating) kit, washing and scraping. Cleanup continued until all levels of mercury vapor, except those near the floor drain, were below the low-end calibration limit (1,000 ng/m3) on a Nippon mercury vapor survey meter. On Friday afternoon they sealed the floor with an enamel paint. Friday night the house was sealed up and heated to about 80º F.
On Saturday, June 16, I accompanied you and Xcel on what was to be a final inspection prior to clearance, or approval of reoccupancy. Mercury vapor concentrations on the main floor of your house were between 265 and 589 ng/m3. Mercury concentrations in the basement ranged from 881 ng/m3 to 1231 ng/m3.
Areas of the floor near the bottom of the basement stairs and a small partition on the north side of the eastern wall, as well as the washtub drain, were subsequently identified as areas which may be the source of some mercury vapor. The washtub and partition were removed. Some concrete was also excavated from the floor in areas where high mercury readings were recorded. Concrete patches were put in the floor and clear epoxy was used to seal these and other areas of the floor.
On June 20 Lumex sampling showed mercury vapor levels throughout the house to be below 300 ng/m3. On June 22, final clearance sampling was conducted by Franklin Dickson, Certified Industrial Hygenist, Applied Environmental Services, Inc. Following established protocols, the house was heated to between 75 and 80º F for two hours prior to drawing air samples over a 6 hour period. These sampling protocols were developed by the U.S. Environmental Protection Agency, and the Agency for Toxic Substances and Disease Control, a part of the U.S. Public Health Service.
Mercury concentrations throughout the house were below the identified level-of-concern of 300 ng/m3. Analytical results (Braun InterTech) are listed in the table below.
Sample # | Location | Mercury Concentration |
1. |
Living Room | 210 ng/m3 |
2. | Dining Room | 180 ng/m3 |
3. | Master Bedroom | 140 ng/m3 |
4. | Second Bedroom | 100 ng/m3 |
5. | Basement | 270 ng/m3 |
6. | Outdoors - back porch | less than 100 ng/m3 |
MDH recommends that follow-up sampling be performed in the future to assure that these concentrations decrease over time, as expected.
MDH has concluded:
In the next month, I will be writing a larger technical report on this incident. If I can be of further assistance, please let me know.
Sincerely,
Carl Herbrandson, Ph.D.
Site Assessment and Consultation Unit
cc: Judy Grant, Xcel Energy
Edward Swain, Ph.D., MPCA
Carol Hubbard, MPCA
CH:rlk
ATTACHMENT 4: FINAL CLEARANCE SAMPLING PROTOCOL FOR MERCURY WITHIN A RESIDENTIAL HOME
This protocol is designed to be implemented once the on-site remediation service feels that the environment has been adequately cleaned and for the sole purpose of gathering valid data to be further assessed by and applicable governmental authorities.
Quantitative Sampling: