United States
            Environmental Protection
            Agency
           Hazardous Waste Engineering
           Research Laboratory
           Cincinnati OH 45268
EPA/600/2-85/028
March 1985
            Research and Development
v>EPA
Guide for
Decontaminating
Buildings,
Structures, and
Equipment at
Superfund Sites

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                                                    EPA/600/2-85/028
                                                    March 1985
                       GUIDE FOR DECONTAMINATING
                  BUILDINGS, STRUCTURES, AND EQUIPMENT
                          AT SUPERFUND SITES
                                  by

      M. P. Esposito, J. L. McArdle, A. H. Crone, and J. S. Greber
                          PEI Associates, Inc.
                        Cincinnati, Ohio  45246

                                  and

R.  Clark, S. Brown, J. B. HalloweTl, A. Langham, and C. D. McCandlish
                     Battelle Columbus Laboratories
                          Columbus, Ohio  43201
                         Contract No. 68-03-3190
                             Project Officer

                             Naomi P. Berkley
                     Land Pollution Control Division
             Hazardous Waste Engineering Research Laboratory
                         Cincinnati, Ohio  45268
             HAZARDOUS WASTE ENGINEERING RESEARCH LABORATORY
                   OFFICE OF RESEARCH AND DEVELOPMENT
                  U.S. ENVIRONMENTAL PROTECTION AGENCY
                        CINCINNATI, OHIO  45268


                             U.S.  Environ'—"-*-M Fraction Agency,
                             Region V  '
                             230  Souiii L :  . .  ••   • -~ t
                             Chicago, Illinois  60f.04

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                                 DISCLAIMER
     The information in this document has been funded wholly or in part by
the United States Environmental Protection Agency under Contract No. 68-03-
3190 to PEI Associates, Inc., with a subcontract to Battelle Columbus Labora-
tories.  It has been subject to the Agency's peer and administrative review
and has been approved for publication.  The contents reflect the views and
policies of the Agency.  Mention of trade names or commercial products does
not constitute endorsement or recommendation for use.
           U,S. Environments! Protection

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                                  FOREWORD
     Today's rapidly developing and changing technologies and industrial
products and practices frequently carry with them the increased generation of
solid and hazardous wastes.  These materials, if improperly dealt with, can
threaten both public health and the environment.  Abandoned waste sites and
accidental releases of toxic and hazardous substances to the environment also
have important environmental and public health implications.  The Hazardous
Waste Engineering Research Laboratory assists in providing an authoritative
and defensible engineering basis for assessing and solving these problems.
Its products support the policies, programs, and regulations of the Environ-
mental  Protection Agency, the permitting and other responsibilities of State
and local governments, and the needs of both large and small businesses in
handling their wastes responsibly and economically.

     This report presents information on decontamination of buildings, struc-
tures,  and equipment at Superfund sites.  Decontamination methods, types  of
contaminants, site-specific technology selection, effectiveness evaluation,
case studies, and worker health and safety are discussed.  The intended
audience for this document includes those involved in developing a decontam-
ination strategy for cleanup of buildings, structures, and equipment at
Superfund sites.  For further information, please contact the Land Pollution
Control Division of the Hazardous Waste Engineering  Research Laboratory.
                                        David G.  Stephan,  Director
                              Hazardous Waste Engineering  Research Laboratory

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                                    ABSTRACT
     This handbook describes methods  of decontaminating  buildings,  struc-
tures, and equipment at Superfund sites.   Types  of contaminants  most  likely
to occur in buildings and structures  at remedial  sites or  on  removal  equip-
ment such as drum grapplers or bulldozers  include asbestos, acids,  alkalis,
dioxins, explosives, heavy metals and cyanides,  low-level  radiation,  organic
solvents, pesticides, and polychlorinated  biphenyls.

     Use of this general  guide for developing  a  decontamination  strategy will
assist Superfund personnel in determining  an efficient,  practical,  and  safe
course of action in a given situation.   Steps  in the  process  include  1) de-
termining the nature and extent of contamination, 2)  developing  and imple-
menting e site-specific decontamination plan,  and 3)  evaluating  decontamina-
tion effectiveness.  Step 1 includes  querying  former  employees,  searching old
records, conducting a visual inspection of the site,  and collecting/analyzing
samples.  Step 2 is further divided into the following steps:  evaluating
hazards, identifying the future intended uses  of buildings, structures, or
equipment, establishing decontamination target levels for  the  contaminants
present, identifying and evaluating potential  decontamination  methods,  se-
lecting the most cost-effective method(s)  for  achieving  the decontamination
target levels, determining worker health and safety requirements (training,
medical surveillance, personal protective  equipment,  site  safety),  writing
the site decontamination plan, and hiring  the  contractor to initiate  cleanup.
Step 3 includes reinspecting the site after cleanup,  collecting  and analyzing
samples, comparing the results to target levels, repeating or modifying the
cleanup procedures as necessary, and  determining the  need  for long-term
monitoring.  Descriptions of actual building decontamination  efforts  at both
Superfund and non-Superfund sites are included as case studies.

     The handbook contains descriptions of a number of example decontam-
ination methods for treating or removing contaminants:   asbestos abatement,
absorption, demolition, dismantling,  dusting/vacuuming/wiping, encapsulation,
gritblasting, hydroblasting/waterwashing,  painting/coating, scarification,
solvent washing, steam cleaning, vapor-phase solvent extraction, acid etching,
bleaching, flaming, drilling and spall ing, microbial  degradation, and photo-
chemical degradation.

     This report was submitted in fulfillment  of Contract  No.  68-03-3190  by
PEI Associates, Inc., and Battelle Columbus Laboratories (subcontractor)
under the sponsorship of the U.S. Environmental  Protection Agency.   The
report covers a period from September 1983 to  August 1984, and work was
completed as of October 31, 1984.

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                                  CONTENTS
Foreword	   iii
Abstract	    iv
Figures	   vii
Tables	viii
Acknowledgments  	    ix

   1.  Introduction  	     1

   2.  Conclusions and Recommendations 	     4

   3.  Development of a Decontamination Strategy 	     6

             Determination of the nature and extent of
             contamination 	     6
             Development of a site-specific decontamination plan .  .     9
             Evaluation of decontamination effectiveness 	    13
             Case studies	    14

   4.  Decontamination Methods 	    15

             Asbestos abatement (Method 1) 	    15
             Absorption (Method 2) 	    31
             Demolition (Method 3) 	    34
             Dismantling (Method 4).	    37
             Dusting/vacuuming/wiping (Method 5) 	    39
             Encapsulation/enclosure (Method 6)  	    42
             Gritblasting (Method 7)  	    44
             Hydroblasting/waterwashing (Method 8) 	    48
             Painting/coating (Method 9) 	    52
             Scarification (Method 10) 	    59
             RadKleen (Method 11)	    64
             Solvent washing (Method 12) 	    67
             Steam cleaning (Method 13)	    71
             Vapor-phase solvent extraction (Method 14)  	    76
             Acid etching (Method 15)	    80
             Bleaching (Method 16) 	    83
             Flaming (Method 17)	    85
             Drilling and spall ing (Method 18)	    91
             K-20 Sealant (Method 19)	    96
             Microbial degradation (Method 20) 	    98
             Photochemical degradation (Method 21) 	   101

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                             Contents (continued)

                                                                        Page

   5.   Worker Health and Safety	    105

             Training	    105
             Medical surveillance 	    106
             Personal protective equipment  	    108
             Site safety plan	    Ill

References	    117
Appendices

   A.   Superfund site survey	    121
   B.   Sampling methods 	    143
   C.   Cost analysis	    151
   D.   Case study:  Seveso, Italy	    179
   E.   Case study:  Binghamton state office building  	    194
   F.   Case study:  Sontag Road area	    202
   G.   Case study:  One Market Plaza office complex 	    208
   H.   Case study:  Frankford Arsenal 	    213
   I.   Case study:  New England office building  	    229
   J.   Case study:  Luminous Processes, Inc	    235
   K.   Case study:  Chemical Metals Industries,  Inc	    248
                                      VI

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                                   FIGURES

Number                                                                Page
  1       Flow Diagram Illustrating Sequence of Steps for Developing
            a Decontamination Strategy 	     7
  2       Demolition Process Flow Diagram	    35
  3       Gritblasting Process Flow Diagram	    45
  4       Equipment Components of a Gritblasting System	    47
  5       Schematic Diagram of the Hydroblasting Process 	    48
  6       Hydroblasting Process Flow Diagram 	    50
  7       Scarifier Tools	    61
  8       Scarification Process Flow Diagram 	    62
  9       Schematic Diagram of the Solvent Circulation Apparatus .  .    68
 10       Steam Cleaning of a Vehicle	    72
 11       Steam Cleaning Process Flow Diagram	    73
 12       Steam Generator	    74
 13       Schematic Diagram of the Vapor-Phase Solvent Extraction
            Process	    76
 14       Vapor-Phase Solvent Extraction Process Flow Diagram. ...    78
 15       Schematic Diagram of the Acid Etching Process	    80
 16       Hand Flamer	    87
 17       Remotely Operated Wall Flamer	    88
 18       Flaming Process Flow Diagram 	    89
 19       Drilling and Spelling Rig	    92
 20       Concrete Spaller 	    93
 21       Drilling and Spelling Process Flow Diagram 	    94
                                     vii

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                                   TABLES
Number                                                                Page

  1       Examples of Practical  Decontamination Methods for Various
            Contaminants and Structural  Materials 	   12

  2       Summary of Case Studies	   14

  3       Summary of the Advantages and Disadvantages of Various
            Decontamination Methods 	   16

  4       Summary of Potential Health and Safety Hazards Related to
            the Use of Various Decontamination Methods  	  114
                                     vm

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                                ACKNOWLEDGMENTS


     The direction and extensive review of Naomi P. Barkley, U.S. Environmen--
tal Protection Agency Project Officer, are greatly appreciated.

     Mr. Jack Greber served as PEI's Project Director, and Ms.  Pat Esposito
was Project Manager.  Battelle's efforts were managed by Mr. Ron Clark.  Key
investigators included Ms. Judy L.  McArdle of PEI, and Messrs.  Scott Brown and
John B. Hallowell of Battelle.  Others contributing to the work were Ms. Ann
Crone and Mr. Mike Hessling of PEI, and Ms. Ann Langham and Ms.  Cindy McCand-
lish of Battelle.

     The authors wish to acknowledge the cooperation and assistance of several
other persons who have contributed to the development of the handbook.  In
particular we wish to thank our peer review committee members:

     Mr. William F. Martin, P.E., of the National  Institute for Occupational
     Safety and Health, who serves as chairman of the four-agency committee
     (NIOSH, EPA, USCG, and OSHA) to coordinate occupational safety and health
     aspects of PL96-510 (CERCLA/Superfund).

     Mr. Salvatore Torrisi of the U.S. Army Toxic and Hazardous  Materials
     Agency, who was responsible for the decontamination of Frankford Arsenal,
     the Alabama Army Ammunition Plant (AAP), and the Gateway AAP.

     Karen B. Webb, M.D., M.P.H., Division Head of the Department of Occupa-
     tional Medicine, St. Louis University School  of Medicine,  who coordinated
     the medical examination of Times-Beach, Missouri, residents.

     Dr. Walter Youngblade of the O.H. Materials Company, who has been in-
     volved in emergency response activities, project scoping,  field opera-
     tions, and laboratory services for a variety of waste treatment, waste
     removal, and decontamination efforts.

These individuals monitored the progress of the handbook from inception
through final review, providing guidance and technical input along the way.
Their efforts and comments are deeply appreciated

     We also wish to thank Messrs.  Ron McCutcheon and Gary-Kepko of EPA Region
VII for their assistance in gathering case study information on  the Sontag
Road dioxin sites in Missouri; Dr.  Alessandro di Domenico of the Istituto
Superiore di Sanita in Rome, Italy, for his response to our inquiries on the
sampling methods used to detect dioxins on building surfaces in  Seveso, Italy;
Mr. Al  Cherry of EPA Region IV for providing information on the  cleanup of the
                                       IX

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Luminous Processes, Inc., site in Athens, Georgia;  Mr.  Virgil  G.  Rose at
Pacific Gas and Electric Company for his help in preparing the One Market
Plaza case study; and Mr. Bob Westin of Versar, Inc., for information on the
cleanup of the Binghamton State Office Building.

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                                   SECTION 1

                                 INTRODUCTION
BACKGROUND
     Cleanup of the Nation's abandoned hazardous  waste sites  is  the  top  envi-
ronmental  priority of the decade.   In 1980, Congress  passed the  Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA, or  Super-
fund), which established a dual-phase program for responding  to  environmental
problems caused by hazardous substances.   The removal  program involves cleanup
or other actions that are taken  in response to emergency conditions  or on a
short-term or temporary basis.   The remedial  program  involves response actions
that tend to be long-term in nature and that permanently remedy  problem  sites.
The U.S. Environmental  Protection  Agency (EPA) is charged with implementation
of the Superfund legislation.

     To be eligible for remedial cleanup under Superfund, a site must be
included on the National Priorities List (NPL).  As of this writing, 538 sites
appear on the NPL and an additional 248 sites have been proposed for inclusion
on the list.  In a Superfund reauthorization bill before the  House (HR 5640),
a mandatory cleanup schedule is  being considered  that  would require  EPA  to
list 1600 sites on the NPL by January 1, 1988, and to  begin remedial investi-
gations and feasibility studies  at each site within 6  months  of  the  date it  is
listed.1

     With the increasing level  of  Superfund activity  has come a  need for basic
guidance on decontamination of buildings, structures,  and equipment. Decon-
tamination of these items is important in preventing  the spread  of contamina-
tion offsite and in reducing exposure levels to future users  of  the  buildings
or equipment.  Also, a successful  decontamination program can offset the high
costs of dismantling and disposing of contaminated structures, while at  the
same time salvaging or increasing  the value of the reconditioned buildings,
equipment, or property.  The objective of a decontamination program, there-
fore, is to return contaminated  buildings, structures, and equipment to  ac-
tive, productive status.

     In the fall of 1983, a survey was conducted  of the decontamination  activ-
ities at 50 selected Superfund sites across the country.  The results of the
survey, presented in Appendix A, revealed that the current state of  the  art  in
this area is not well developed.  Removal equipment is generally steam-cleaned
(typically, no testing is performed to verify contaminant removal),  and  build-
ings and structures are frequently torn down instead  of being decontaminated.
These findings clearly pointed to  the need for basic  guidance material dealing

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Section I/Introduction
with decontamination methods and their application to various contaminants and
structural materials.
PURPOSE

     This handbook was developed to assist EPA headquarters program offices
and regional Superfund personnel in planning the restoration of sites with
contaminated buildings, structures, and/or equipment, as required by the
National Contingency Plan.  Its purpose is twofold:

     1.   To provide general guidelines for developing a decontamination
          strategy.

     2.   To provide method descriptions of example  decontamination tech-
          niques.


ORGANIZATION

     The handbook is organized into three main sections (Sections 3, 4, and 5)
and is supplemented by 11 appendices.   Section 3 presents general guidelines
for developing a decontamination strategy.  Three principal steps and several
substeps are identified and discussed  under separate headings.   Section 3 also
introduces eight case studies (from the appendices)  as examples of decontamin-
ation strategies that have been developed for both Superfund and non-Superfund
sites.

     Section 4 presents descriptions of example methods for decontaminating
buildings, structures, and equipment.   The methods are grouped  according to
their mode of action--physical/mechanical, solvent/extraction,  chemical, and
thermal.  Developmental methods are also described.   The following aspects are
discussed for each method:  general description, advantages, disadvantages,
state of the art, variations, applicability, effectiveness, engineering,
safety, waste disposal, costs, and future work required.

     Section 5 describes the key elements necessary  to ensure the health and
safety of decontamination workers during site operations.  Topics covered
include personnel training, medical surveillance, personal  protective equip-
ment, and site safety.

     Supplemental information is included in the appendices.  Appendix A
contains a tabular summary of the initial survey of  decontamination activities
at selected Superfund sites.  Also included are site data summary forms for
selected entries in the table.  Appendix B describes methods of measuring
contamination in or on buildings, structures, and equipment. Appendix C
presents cost analyses of several of the decontamination methods described in
Section 4.  Cost estimates for equipment, materials, labor, overhead, etc.,

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                                                       Section I/Introduction
are based on a model building.   Appendices D through K are case studies illus-
trating various decontamination strategies that have been implemented at both
Superfund and non-Superfund sites.   The subjects of the case studies are as
follows:  the town of Seveso, Italy; a state office building in Binghamton,
New York; the Sontag Road area  in St.  Louis, Missouri; the One Market Plaza
office complex in San Francisco, California; the Frankford Arsenal  in Phila-
delphia, Pennsylvania; a New England office building; the Luminous  Processes,
Inc., facility in Athens, Georgia;  and the Chemical Metals Industries, Inc.,
sites in Baltimore, Maryland.

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                                  SECTION 2

                       CONCLUSIONS AND RECOMMENDATIONS
CONCLUSIONS
     This handbook has been prepared to assist EPA headquarters program
offices and regional Superfund personnel in planning the restoration of sites
with contaminated buildings, structures, and/or equipment.   While this docu-
ment provides much of the needed guidance for developing a  decontamination
strategy, the reader should be aware of three 1 imitating areas in the current
state-of-the-art technology.

     First, surface and subsurface sampling techniques are  not yet standard-
ized.  Sampling of contaminated equipment and structural materials is the
foundation upon which a decontamination strategy is built and the means by
which the effectiveness of that strategy is evaluated.  Surface sampling
generally employs a variation of the wet-wipe or dry-wipe technique as a
means of assessing the nature and extent of contamination.   This approach
often suffers from two major deficiencies:   variable collection efficiency
and long sample turnaround time.  Subsurface sampling techniques (e.g.,
corings) have not been validated for determining the depth  of contaminant
penetration in porous substrates.

     Second, the applicability and effectiveness of the methods described in
this handbook generally have not been documented.  Many of  the techniques
were developed specifically for the U.S. Army's Installation Restoration
Program and have not been applied or tested on all of the
contaminant/structural material combinations encountered at Superfund sites.
Pilot-scale testing of the methods on a site-by-site basis  prior to
full-scale implementation is recommended.

     Third is the question of how clean is  clean?  This is  often the most
perplexing one surrounding decontamination  activities.  Decontamination
target levels have been, and continue to be, established on a case-by-case
basis by a variety of Federal, state, and local agencies.  The EPA is in the
midst of developing a novel site-by-site risk-assessment approach to deter-
mining the appropriate extent of remedy at  Superfund sites.  Draft guidance
is currently undergoing review.


RECOMMENDATIONS FOR FUTURE STUDY

     Standard surface and subsurface sampling techniques need to be developed
for buildings and equipment.  Such techniques should use readily obtainable

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                                   Section 2/Conclusions and Reaormendations
equipment and should be relatively inexpensive to perform.   Sampling proto-
cols should specify the materials and reagents needed, the  procedures to be
followed, the number of samples to be taken, the analytical  methods to be
used, and the quality assurance/quality control (QA/QC) procedures to be
adopted.  In cases where the contaminant of interest is very expensive to
sample and analyze (e.g., dioxin), methods should be developed with other
less costly sampling parameters and testing techniques that  can indicate
(with acceptable accuracy) the presence and level of the contaminant of in-
terest.  A matrix tha,t identifies sampling techniques applicable to specific
contaminant/structural material combinations would be useful.

     Studies are needed to document the applicability and effectiveness of
the decontamination methods presented in this handbook.  Recommendations for
further engineering development of existing technologies should be followed.
New technologies should be evaluated and added to the handbook as they become
available.

     A formal, systematic approach needs to be developed for determining
acceptable levels of contaminants in and on building and equipment surfaces.
Related methods for determining acceptable levels of contaminants in soils at
contaminated sites may be useful for developing such an approach.  Examples
of methods that should be evaluated include the multimedia  environmental
goals (MEG's), the composite hazard index, the preliminary  pollutant limit
values, and the monitoring trigger levels (MTL's).2

     There will often be considerable merit in assuring that future owners of
decontaminated buildings and structures on Superfund sites  are made aware of
the nature and levels of any residual contamination and of  the cleanup meth-
ods used.  Ensuring the transfer of such information from one site owner to
the next will require a method for permanently recording this information.
Regulations requiring the addition of such information to the property deed
(as required in the deed of all RCRA-permitted facilities)  may be a workable
solution.

     Finally, this document (especially Tables 1 and 2, Sections 3 and 4, and
Appendix B) should be periodically updated to add the results of studies in
the areas described above.

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                                  SECTION 3

                  DEVELOPMENT OF A DECONTAMINATION  STRATEGY


     For a decontamination program to proceed safely and cost-effectively,
considerable effort should be devoted to development of a decontamination
strategy.  Strategy development involves three principal steps:

     1.   Determination of the nature and extent of contamination.

     2.   Development and implementation of  a site-specific  decontamination
          plan.

     3.   Evaluation of decontamination effectiveness.

As shown in the flow diagram (Figure 1), each step  in the sequence  entails
several substeps.  These steps and substeps  are discussed in this section.


STEP 1.  DETERMINATION OF THE NATURE AND EXTENT OF  CONTAMINATION

     Development of an overall decontamination strategy revolves around the
proper identification and evaluation of the  contaminants present.  This
knowledge is necessary for selection of decontamination methods that will
effectively reduce the contamination to acceptable  levels while providing
adequate protection to workers.  Remedial site investigations of buildings
and structures should include a records search, visual  inspection,  and
sampling survey to determine the nature and  level of contaminants present.
Equipment used in removal operations should  routinely be decontaminated
before leaving the site to minimize the spread of contamination.

Records Search

     A knowledge of past operations at the site will generally yield informa-
tion regarding the nature of contaminants likely to be present.  Such infor-
mation may be available through onsite records (operating logs, manifest
records), reports of Federal or state site investigations, local fire and
police departments, former employees of the  facility, and neighboring resi-
dents or business employees.

Inspection

     Visual inspection can identify areas of gross chemical  contamination as
well as  reveal the condition or soundness of a building or structure.  Such

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STEP 1
DETERMINE
NATURE AND
EXTENT OF
CONTAMINATION
L
1 1
QUERY
FORMER
EMPLOYEES

SEARCH
OLD
RECORDS






1
CONDUCT
VISUAL •
INSPECTION


!
COLLECT
AND
ANALYZE
SAMPLES


STEP 2
DEVELOP
SITE-SPECIFIC
DECONTAMINATION
PLAN




STE
EVAL
DECONTAC
EFFECT

1 1
P 3
UATE
11 NATION
VENESS


REINSPECT COLLECT COMPARE
SITE AND TO TARGET
ANALYZE LEVELS
SAMPLES




1 1
REPEAT OR DETERMINE
MODIFY NEED FOR
PROCEDURE LONG TERM
AS NEEDED MONITORING

Figure 1.  Flow diagram illustrating  sequence of steps for developing a decontamination
                                       strategy.

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Section Z/Nature and Extent of Contamination
an inspection will help determine whether a building or structure has any
potential for future use or should be dismantled and disposed of (see Identi-
fication of Future Use, p. 9).

     During the inspection, rafters, ventilation ducts, sumps, crawl  spaces,
window wells, tanks, etc., should be inspected for evidence of deterioration
as well as chemical residues or contaminated dust/particulate matter.
Buildings that are suspected of containing asbestos should be inspected
according to EPA-recommended guidelines.3  Similar guidelines for other types
of contaminants have not been developed.

     Personnel involved in initial inspections should be thoroughly trained
in appropriate safety precautions and hazard awareness.  Level B protective
equipment is commonly used during initial site entry unless the records
search indicates that a potential radiation hazard exists or that there may
be tanks, cellars, or other closed areas containing high concentrations of
toxic gas (see Section 5).

Sampling Survey

     Complete characterization of the contamination in or on buildings,
structures, and equipment requires that a detailed sampling survey be per-
formed as part of the overall site remedial investigation.  Standard sampling
techniques can often be used to determine the presence of solid, liquid, or
airborne contamination.  Methods for sampling and analysis of contaminants in
solids and liquids can be found in EPA's Test Methods for Evaluating Solid
Wastes (EPA SW-846).4  Methods for sampling and analysis of airborne contami-
nants are contained in the NIOSH Manual of Analytical Methods (Volumes 1
through 7).5"9

     Sampling methods for determining the nature and extent of contamination
on building and equipment surfaces are not yet standardized.  Variations of
wet-wipe and dry-wipe techniques that have been used in the field are de-
scribed in Appendix B.  In some instances, it may be necessary to determine
the depth of penetration of contaminants into porous materials such as wood,
wallboard, or concrete.  This information may be used to determine when
dismantling or demolition are appropriate.  In these cases, small sections of
the contaminated structural materials (e.g., corings) should be collected for
analysis and handled as a solid waste per SW-846 guidelines.

     During sampling, the maximum level of personal protective equipment
commensurate with the hazard should be worn (see Section 5).  Representative
samples should be collected and analyzed in accordance with the quality
control guidelines described in the EPA and NIOSH handbooks cited above.
Several locations at the site should be sampled in order to identify all
contaminated areas.  The survey results should identify all contaminated sub-
strates and report contaminant levels by sampling location.

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                                 Section 3/Site-Speaific Decontamination Plan
STEP 2.  DEVELOPMENT OF A SITE-SPECIFIC DECONTAMINATION PLAN

     Once contaminants have been identified, a decontamination plan tailored
to the site characteristics can be developed.

Hazard Evaluation

     Hazard evaluation is a decision-making process in which the benefits and
risks associated with not treating the contaminated buildings, structures, or
equipment (i.e., the "do nothing" alternative) are weighed against the
potential benefits and risks of decontamination.  Two types of hazards need
to be evaluated:  those associated with the contaminants themselves, and
those associated with the cleanup process.

     Evaluating the hazards associated with exposure to the contaminants
present is important in developing proper handling procedures and safety
controls.  This hazard evaluation consists of gathering information on the
physical and chemical properties of the contaminants, the fire and explosion
hazards, the toxicity and health hazards, and chemical reactivity.  Physical
and chemical properties (e.g., vapor pressure, boiling point, and solubility)
may be obtained from standard chemical reference texts.  The National Fire
Protection Association publishes information on the flammability of approxi-
mately 1500 substances.10  Information on chemical toxicity is available from
the National Institute for Occupational Safety and Health (NIOSH) in two data
collections that are published annually.11'12  Data on the toxic effects from
known doses of hazardous substances entering the body are available in NIOSH
Criteria Documents13 and also from the American Conference of Governmental
Industrial Hygienists (ACGIH).11*

     All existing exposure limits for particular contaminants must be includ-
ed in the contaminant hazard evaluation.  Such exposure limits represent
concentrations to which nearly all workers can be repeatedly exposed, day
after day, without adverse effect.  The OSHA 29 CFR 1910 Subpart Z currently
lists exposure limits for approximately 400 substances.  The ACGIH annually
publishes exposure limits for approximately 800 chemical substances.15

     Health and safety aspects associated with the use of various cleanup
techniques or processes must also be considered as part of the overall hazard
evaluation.  If two methods are judged to be equally effective in removing or
treating a particular contaminant, the method that presents lower risks to
the workers would be preferrable.  Sections 4 and 5 contain additional
information on the potential  hazards associated with various decontamination
methods.

Identification of Future Use

     Another early step in the development of a site decontamination plan
entails identification of the intended or potential future use of contami-
nated buildings, structures, and equipment.  Building and equipment release

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Section 1 / Site-Sped fie Decontamination Plan
following decontamination will  fall  into one of three categories:

     0    Unrestricted/public use

     0    Restricted/industrial  use

     0    No future use

In most cases, it will be necessary  to develop a decontamination plan geared
to meet the intended or potential future use of the site or equipment.
Buildings and structures that have no potential for future use will  either be
dismantled or demolished, or left standing, fenced, and guarded (see the
Appendix D case study of Seveso, Italy).  In such cases, a decontamination
plan can often be developed that will both reduce the costs of disposal
(contaminated debris often must be disposed of in a secure landfill  whereas
decontaminated debris can be sent to a less costly sanitary landfill) and
reduce potential exposure hazards to demolition workers, waste transportation
and disposal employees, and the general public.

     Although the level of intended  reuse generally dictates the extent of
contamination reduction required, the planner must be aware that the state-
of-the-art decontamination technology is not well advanced.  Thus, in some
cases, the level of reuse will  be limited by the degree of contaminant
reduction that can be achieved.

     All future owners of decontaminated buildings and structures on Super-
fund sites should be advised of the nature of the contamination that was
present, the cleanup methods used, and levels of any residual contaminants.
Ensuring the transfer of such information from one site owner to the next
will require a method for permanently recording this information, e.g. by
including a notice in the deed to the property (or some other instrument that
is normally examined during title search).  Federal regulations promulgated
by EPA under the Resource Conservation and Recovery Act (RCRA) require such a
notice for land that has been used to manage hazardous wastes (40 CFR
§264.120).

Establishment of Target Levels

     When a future use has been identified, decontamination target levels for
all contaminants present should be established.  This has been a major obsta-
cle to decontamination activities at Superfund sites.  Target levels have
been, and can be, set by a number of groups, including local and state health
departments and Federal agencies such as EPA, NIOSH, the Occupational Safety
and Health Administration (OSHA), the Nuclear Regulatory Commission  (NRC),
the Centers for Disease Control  (CDC), and the Surgeon General's Office.
Target levels for Army-unique materials  (i.e., explosives) are proposed by
the U.S. Army Toxic and Hazardous Materials Agency  (USATHAMA), and approved
by the Army Surgeon General.
                                     10

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                                 Section 3/Site-Specific Decontamination Plan
     Target levels generally should be more stringent in cases where the
buildings, structures, or equipment are to be released for unrestricted/pub-
lic use as opposed to restricted/industrial use.   The EPA has not prescribed
levels of contaminants that are acceptable at all  Superfund sites; one reason
for this is that potential synerqistic effects of combinations of wastes
cannot be adequately predicted.^  The Agency is  currently preparing draft
guidance on the issue of "How clean is clean?"1

Determination of Potential Cleanup Methods

     Determining the most appropriate cleanup method or combination/sequence
of methods to be used on buildings, structures, and equipment is central to
the development of a decontamination plan.  The matrix presented in Table 1
was prepared to assist in the identification of potential cleanup methods.
This matrix shows the applicability of several decontamination methods in
relation to contaminants and structural materials.  Each cell in the matrix
represents a specific contaminant/structural material combination and con-
tains numbers corresponding to decontamination methods that would be practi-
cal in that application.  Each method can be used alone or possibly in
conjunction with one or more of the other procedures listed in that cell to
improve the effectiveness of the decontamination project.

     To illustrate how the matrix works, assume that sampling and analysis of
a concrete surface revealed the presence of dioxin contamination.  In the
cell representing the intersection of the column headed "Concrete" and the
row labeled "Dioxin," 15 potential cleanup methods applicable to dioxin-
contaminated concrete surfaces are indicated:  Methods 2, 3, 5, 6, 7, 9, 10,
11, 12, 13, 14, 18, 19, 20, and 21.  The methods are identified using the key
at the bottom of the table.  Method descriptions are presented in Section 4.
The key words at the top of each page can be used to locate the descriptions
easily.  Each description indicates whether that technique has actually been
used to treat a particular contaminant/structural material combination, or
whether the method is viewed as potentially applicable.

Evaluation of Decontamination Methods

     The decontamination methods indicated in Table 1 for a particular
contaminant/structural material combination should be evaluated as part of
the site feasibility study.  Each technique should be judged on effective-
ness, equipment and support facilities needed, time and safety requirements,
wastes generated, structural damage, and costs.  For example, the hydroblast/
waterwash method is a relatively inexpensive surface decontamination tech-
nique that utilizes off-the-shelf equipment; however, it produces large
amounts of liquid residues that have to be collected and treated.  Limita-
tions in manual dexterity and productivity imposed by the use of personal
protective gear should be included in the evaluation of potential methods.
The method descriptions presented in Section 4 will assist the reader in
evaluating all applicable techniques.
                                      11

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          TABLE  1.    EXAMPLES  OF  PRACTICAL DECONTAMINATION  METHODS FOR  VARIOUS
                                CONTAMINANTS AND STRUCTURAL MATERIALSa
Contaminant
Asbestos
Acids
Alkalis
Dioxins
Explosives
Heavy metals and
cyanide
Low-level
radiation
Organic solvents
Pesticides
PCB's
Material
Brick
1,3,4,5.6
2,3,4,6.7,8.
9,13
2,3,4,6,7,8,
9,13,15
2,3,4,5,6.7,
9,11,12,13,
14,19,20,21
2.3,4.6,7,8.
9,11,12,13.
14.17
2,3,4.5,6.7.
8,9,12,13.14.
15,19
2,3,4.6,7,8.
9,11,12,13,
14,17
2,3,4,6.7,8,
9,11,12,13,
14,20,21
2,3,4,5,6.7,
8,9,11,12,13,
14,16,19,20,
21
2,3,4,5,6.7.
8,9.11,12,13,
14,19.20,21
Concrete
1,3,5.6
2.3.6.7,8,9.
10,13,18
2,3.6,7,8,9.
10,13,15.18
2,3,5,6,7.9,
10,11,12,13,
14,18,19,20,
21
2,3,6,7,8,9,
10.11,12,13,
14.17.18
2.3.5,6,7,8.
9.10,12,13,
14,15,18,19
2,3,6,7,8,9,
10,11,12,13,
14,17,18
2,3,6,7,8,9,
10,11.12,13,
14,18.20,21
2,3.5.6,7,8,
9,10.11,12.
13,14.16,18,
19.20,21
2,3,5,6,7,8.
9,10,11.12.
13.14,18.19,
20,21
Glass
1,3,4,5,6
2.3,4,6,9.13
2.3.4,6.9,13
15
2.3.4.5,6,9.
11.12,13.14.
20.21
2.3,4.6,11.
12,13,14
2.3.4,5,6,12.
13,14,15
2.3.4,5,6.11,
12.13,14
2,3,4,6,9,11,
12,13,14,20,
21
2.3.4,5,6.9,
11,12.13.14,
20,21
2.3,4,5,6,11,
12,13,14,20,
21
Metal
1,3.4,5,6
2.3,4,6,7.8,
9,13
2,3,4,6,7,8,
9,13,15
2,3.4,5,6,9,
11,12,13,14.
20,21
2,3.4.6,7,8,
9,11,12,13,
14,17
2,3,4.5,6,7,
8,9,12,13,14,
15
2,3,4.6,7,8,
9.11,12.13,
14,17
2,3,4,6,7,8.
9.11.12.13,
14,20.21
2,3,4,5.6.7.
8,9.11.12.13,
14,16.20,21
2,3,4,5,6.7,
8,9,11,12,13,
14.20,21
Plastic
1,3.4.5,6
2,3,4,6,9,13
2,3,4,6,9,13
2,3,4.5.6,9.
11.12.13,14,
20,21
2,3,4,6,9,11.
12,13,14
2.3.4.5.6,9,
12.13,14
2,3,4,6,9,
11,12,13,14
2,3,4;6,9,11,
12,13,14,20,
21
2,3,4,5,6,9,
11.12,13,14,
20,21
2,3,4,5,6.9,
11,12,13,14.
20,21
Wood
1,3,4,5.6
2.3,4,6,7.9,
13
2,3.4,6.7,9,
13,15
2.3.4,5.6,9.
11,12.13.14.
19,20,21
2.3.4,6.7.9.
11,12,13.14
2,3.4,5,6,7.
9,12.13,14,
15,19
2,3.4,6,7,9,
11,12,13,14
2,3,4,6,7,9,
11,12,13,14.
20,21
2.3.4,5,6.7.
9,11,12.13.
14,16,19,20,
21
2,3,4,5,6.7,
9.11,12,13.
14,19,20,21
Equipment
and
auxiliary
structures
1,3.4,5,6
2,3.4,6,7,8,
9.13
2,3,4.6,7,8,
9,13,15
2,3,4,5,6,7,
8,9,11,12,13,
14,20,21
2,3,4,6.7.8.
9.11,12,13,
14,17
2,3,4.5,6,7,
8,9,12,13.14,
15
2.3,4,6,7,8,
9,11,12,13,
14,17
2,3.4,6,7,8,
9,11.12,13,
14,20,21
2.3.4.5,6.7.
8.9.11.12,13.
14,16,20,21
2,3.4,5,6,7,
8.9,11,12,13.
14,20,21
Key for decontamination methods:
1.   Asbestos abatement
2.   Absorption
3.   Demolition0
4.   Dismantling
5.   Dusting/vacuuining/wiping
6.   Encapsulation
7.   Gritblasting6
 8.   Hydroblasting/waterwashing
 9.   Painting/coating
10.   Scarificatione>f
11.   RadKleen
12.   Solvent washing
13.   Steam cleaning
14.   Vapor-phase solvent extraction
15.   Acid etching
16.   Bleaching
17.   Flaming
18.   Drilling and sp«111nge>f
19.   K-20 sealant
20.   Microbitl degradation
21.   Photochemical degradation
  Refer to individual method descriptions in Section 4 to determine whether an  indicated technique has actuajly been used
  to treat a particular contaminant/structural material combination, or whether the method is viewed as potentially
  applicable.
  Applicable only to  liquids.
c Some contaminant residues (e.g.,  asbestos, explosives, toxic  residues) may have to be neutralized, stabilized, or removed
  prior to demolition to prevent explosions or emissions.
  Applicable only to  partlculates and solids.
e Not recommended for removing highly toxic residues or highly  sensitive explosives, unless particulars can be central led.
  Applicable only to  concrete.
                                                        12

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                                      Section Z/Decontamination Effectiveness
Selection of the Most Appropriate Method(s)

     Based on the requirements of the National Contingency Plan, the decon-
tamination method(s) of choice in a Superfund-financed cleanup should always
be the least-costly, technologically feasible alternative that can reduce the
contamination to predetermined levels.  This philosophy was demonstrated at
the Sontag Road Area Superfund site (Appendix F), where dusting/vacuuming/
wiping techniques were chosen over painting and coating methods because of
cost considerations.

Determination of Worker Health and Safety Requirements

     The hazard evaluation data developed earlier should be used to determine
the worker health and safety precautions required during decontamination
operations.  Personnel training, medical surveillance, personal protective
equipment, and site safety are covered in Section 5.

Preparation of Site Decontamination Plan

     Before cleanup is initiated, a detailed site decontamination plan should
be written and incorporated into the remedial design specifications.  This
plan should specify the decontamination method to be implemented, the QA/QC
procedures to be followed, the equipment and support facilities needed, the
method of residue disposal, worker health and safety precautions, and sche-
duling.

Initiation of Cleanup

     Following approval of the decontamination plan by EPA headquarters, a
contractor(s) can be hired to initiate cleanup.  Decontamination should
proceed according to plan.  Contaminant levels should be monitored throughout
the course of the operation so that decontamination effectiveness can be
evaluated.
STEP 3.  EVALUATION OF DECONTAMINATION EFFECTIVENESS

     The extent of residual contamination following decontamination must be
determined so the effectiveness of the cleanup methods can be assessed.  A
visual inspection and detailed sampling survey should be conducted in the
same manner as described previously.  The results of this survey should then
be compared with the decontamination target levels.  If the target levels
have not been reached, the decontamination procedure or sequence must be
repeated or amended as necessary.  Once target levels have been achieved, the
need for long-term monitoring to provide assurances that the target levels
will be maintained should be considered.  This is especially important in
situations where contaminants have not been removed but have been left in
place behind protective coatings or barriers.
                                     13

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Section 3/Case Studies
CASE STUDIES

     Appendices D through K present case studies illustrating decontamination
strategies that have been implemented at both Superfund and non-Superfund
sites.  The summary of these case studies, presented in Table 2, lists the
contaminants present and the decontamination methods used at each site.
Limited factual data are available on the concentrations of contaminants
present and the degree of decontamination achieved following cleanup.  This
is reflective of the inadequacies in the techniques used to sample and
analyze for hazardous constituents on building and equipment surfaces.

                      TABLE 2.  SUMMARY OF CASE STUDIES
Appendix
D
E
F
G
H



I
J
K
Site
Homes and other buildings
Seveso. Italy
State Office Building
Binghamton, New York
Sontag Road area8
St. Louis County, Missouri
One Market Plaza Office
Complex
San Francisco, California
Frankford Arsenal
Philadelphia, Pennsylvania



Office building
New England
Luminous Processes, Inc.*
Athens. Georgia
Chemical Metals Industries,
Inc.
Baltimore, Maryland
Contaminants present
TCDD
PCB's, TCDD, TCDF
TCDD
PCB's. PCDD, PCDF
Explosives
Asbestos
Radiological residues
Heavy metals
Asbestos
Low-level radiation
Heavy metals, adds,
alkalis, cyanide-
and ammonia-bearing
compounds, salts, and
solids and sludges of
unknown composition
Decontamination methods
Dusti ng/vacuum1 ng/wi pi ng
Painting/coating
Dismantling
Demolition
Dusting/vacuuming/wiping
Dismantling
Dust ing/vacuumi ng/wi ping
Insulation removal
Scrubbing (equipment only)
Steam cleaning (equipment
only)
Insulation removal
Dusting/vacuuming/wiping
Solvent washing
Scraping
Painting/coating
K-20
Grltblasting
Scari f i cati on/ jackhammeri ng
Dismantling
Hydroblasting/waterwashing
(equipment only)
Flaming
Demolition
Asbestos removal
Dusti ng/vacuumi ng/wi pi ng
Hydroblasting/waterwashing
Scarification
Grltblasting
Dismantling
Painting/coating
Asbestos encapsulation
Paint stripping/sanding
Hydroblasting/waterwashing
Dismantling
Grltblasting
Dismantling
          * Superfund site.
                                      14

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                                  SECTION 4

                            DECONTAMINATION METHODS


     The matrix introduced  in  Section 3  (Table 1) identified several methods
(established and potential)  for decontaminating various combinations of con-
taminants and structural  materials encountered at Superfund sites.  More
detailed descriptions  of  those methods are presented in this section.  Using
this information, the  reader should be able to assess each method for its
applicability to the decontamination requirements of a specific site.

     The methods presented  range  from classical techniques to developmental
concepts.  For example, abrasive  gritblasting and vacuuming are traditional
procedures whose applications  have been  extended to the cleanup of hazardous
waste sites.  At the other  end of the spectrum are methods that are in devel-
opmental stages, such  as  the drill-and-spall procedure.  The developmental
methods included here  either have been applied in at least one demonstration
or have shown the likelihood of being useful techniques.  Use of these tech-
niques in concert with, or  in  place of,  the more classical techniques should
be considered when developing  a decontamination strategy.

     Table 3 summarizes the advantages and disadvantages of the decontamina-
tion methods presented in this section.  Method descriptions include a general
discussion of the procedure, advantages, disadvantages, state of the art,
applicability, effectiveness,  engineering considerations (including building
preparation, process description, equipment needs, and time requirements),
safety requirements, waste  disposal, costs, future work required, and informa-
tion sources.  Comparative  cost information developed for each of the methods
is further detailed in Appendix C.
ASBESTOS ABATEMENT (METHOD  1)

     Four techniques are available  for the abatement of asbestos contamination
in buildings:  removal,  encapsulation,  enclosure, and special operations
(e.g., maintenance and monitoring).  Each technique is discussed separately.
                                       15

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TABLE  3.    SUMMARY  OF THE  ADVANTAGES AND DISADVANTAGES  OF  VARIOUS  DECONTAMINATION METHODS*
          Method
                        Advantages
                   Disadvantages
 1.  Asbestos abatement
   •  a) Removal
     b) Encapsulation
Permanently eliminates the  source of asbestos fibers.
Initially, may be lower In  cost than removal; does not
require replacement of the  asbestos-containing material.
     c) Enclosure
Initially, may be lower 1n  cost than removal.
     d) Special  operations
2.  Absorption
3.  Demolition
Initially, may be lower 1n cost than removal.
Quickly  contains gross contamination.
Achieves  total decontamination by removing all  con-
taminated building materials, structures, and equip-
ment from the site.
Is costly and  time-consuming if complex surfaces
(pipes,  ducts, crevices, etc.) are involved; may
require  sealing of porous surfaces after  removal

May be more costly than removal over the  long term
because  periodic reinspectlons are required to
check for damage and deterioration and because
subsequent repair of the encapsulated surface may
be necessary;  can affect (I.e., reduce) the fire-
proofing properties of the asbestos-containing
materials; may make the eventual removal  of asbes-
tos-containing materials more difficult.

May be more costly than removal over the  long term
because  periodic reinspectlons are required to
check for damage and because subsequent repair of
the damage may be necessary; requires controlled
access for maintenance or renovation activities;
requires eventual removal of the asbestos source,
particularly prior to building renovation or demo-
lition.

Applies  only to nonfriable asbestos. Requires
periodic relnspection of the asbestos-containing
materials and other future control measures.

Normally requires secondary decontamination to
clean up surface residues and subsurface contam-
ination.

Completely destroys the building, structure, or
equipment; generates large quantities of contami-
nated debris for disposal; may expose workers or
nearby residents to airborne contamination.
      (continued)

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Table  3  (continued)
          Method
                    Advantages
               Disadvantages
4.  Dismantling
5.  Dusting/vacuuming/
     wiping
6.  Encapsulation/
     enclosure

7.  Gr1tblast1ng
8.  Hydroblastlng/
     water-washing
9.  Painting/coating
     a) Lead-based paint
          removal

     b) Fixative/stabilizer
          coatings
     c) Strlppable coatings
10.  Scarification
Is less costly than  complete demolition because only
those structures  that are contaminated are removed.

Generates small volumes  of waste/wastewater, which
are contained and easily disposed of 1n vacuum cleaner
bags or on wipe cloths.

Doet not create large volumes of contaminated debris.
Can simultaneously  and  readily remove paint and contam-
inants near the surface.
Offers a relatively  Inexpensive, nonhazardous surface
decontamination technique  that uses off-the-shelf
equipment; can very  easily Incorporate variations such
as hot or cold water,  abrasives, solvents, surfactants,
and varied pressures.
Does not require  large  Investments 1n equipment.
Reduces the level  of contamination to which building
occupants are exposed;  does  not create any hazardous
     wastes.

Physically holds  or traps  the contaminant for easier
handling and disposal.
Can achieve a deeper penetration  (removal) than
most other surface removal  techniques;  1s suitable
for application to both  large open areas and small
areas.
Generates large quantities of contaminated  debris
for disposal.

May spread contamination by creating  fugitive
dusts; may have to be repeated until  the  source of
contamination 1s controlled.

May render structures Inaccessible or Inoperable.
Generates large amounts of dust and debris;  Is
slow, and effective only as a surface treatment;
has the potential for detonating pockets  of
combustible contaminants.

May not effectively remove contaminants that have
penetrated the surface layer; requires collection
and treatment of large amounts of contaminated
liquids.
Involves labor-intensive operations that cannot
be automated.

Does not remove toxic contaminants; requires
lifetime monitoring of the effectiveness of the
barrier coating.

May bind to the surface of the wall or Item on
which 1t Is applied, resulting In large volumes  of
wastes or damage to the surface.

Requires resurfacing of the treated surface;
generates contaminant-laden dust  and substantial
amounts of contaminated debris (water and con-
crete) that require further processing; presents
a potential explosion hazard 1f pockets of com-
bustible wastes are encountered;  1s restricted to
use on concrete or concrete-like  materials; can
only be used in obstruction-free  areas.
    (continued)

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                Table 3  (continued)
                           Method
00
                 11.   RadKleen
                 12.   Solvent washing
                 13.   Steam  cleaning
                 14.   Vapor-phase solvent
                       extraction
                 15.   Add etching



                 16.   Bleaching





                 17.   Flaming
                    Advantages
Uses Freon 113 (a  stable, nonpolar, noncombustlble
organic solvent),  which  permits rapid wetting of
surfaces and easy  participate separation; allows
for solvent recovery  If  used in a closed system.

Can remove contaminated  paint 1f the proper solvent 1s
selected.
Is relatively Inexpensive and simple; depending on the
contaminant, may  cause thermal decomposition and/or
hydrolysis to occur.
Enhances solvent  permeability and d1ffus1b1Hty; 1s well
suited to all  areas of a building, Including Intricate
structures;  can remove contaminated paint 1f the proper
solvent 1s selected.

Certain contaminants are decomposed as they are removed
from the surface.
Is an effective decontaminating agent when used against
metal surfaces.
Provides complete and rapid destruction of all  residues
contacted.
                  Disadvantages
Requires secondary treatment of the used Freon.
Is not suitable for intricate structures;  may  tend
to carry contaminants farther Into the  wall  before
outward movement occurs; may require removal and/
or decomposition of residual solvent in building
materials.

Is known to be effective only for surface  decon-
tamination; Is labor-intensive and costly  1f auto-
mated; generates large volumes of contaminated
water.

May require long treatment times for outward dif-
fusion of contaminant-laden solvent.
Requires a large volume of add (hazardous) and
special application equipment;  1s  applicable only
to metals that will readily corrode.

Depending on the concentration  and composition of
the bleach slurry, may cause corrosion  of applica-
tion equipment and/or the surfaces being treated;
may also cause periodic clogging of application
equipment.

Is primarily a surface decontamination  technique;
would probably result in extensive damage to the
material 1f used for subsurface decontamination;
may detonate combustible residues; can  involve
high fuel costs.
                  (continued)

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  Table  3  (continued)
          Method
                   Advantages
                                                                                                          Disadvantages
18.  Drilling and spall Ing



19.  K-20 sealant


20.  Microblal  degradation
21.   Photochemical  degra-
       dation
Can achieve  deeper  penetration (removal) of surfaces
than other surface-removal techniques; Is good for
large-scale  application.

Immobilizes  contaminants  in situ; does not generate
hazardous  wastes.

Is specific  to  targeted contaminants.
Can be relatively  s.imple or scaled-up (accompanied by
increased  technical efforts); is inexpensive when sun-
light is used  as the UV light source.
Requires resurfacing of the treated  surface; may
expose rebars;  generates substantial  amounts of
contaminated debris.

Is in the developmental stages;  has  not yet gained
Federal approval  for widespread  use.

Requires a large  development effort  to achieve a
workable system;  would probably  require supplemen-
tary treatment; may give rise to biological degra-
dation products containing carcinogenic compounds.

Will not work on  contaminants imbedded in  dense
particulate matter (such as thick carpet or deep
soil) because UV  light cannot penetrate through
these surfaces; may result in exposure hazards
from the use of intense UV radiation sources
other than the sun (mercury and  xenon-arc  lamps)
and from the use  of flammable solvents as  hydro-
gen donors.
8 The methods described  In this table are examples of techniques  currently  available.  The list is not exhaustive; other methods may be available.

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Section 4/Asbestos Removal (Method 1A)
ASBESTOS REMOVAL (METHOD 1A)

General Description

     Asbestos-containing building materials are removed to prevent the release
of asbestos fibers into the air.  Replacement of the removed material  with a
nonasbestos material  may be necessary to comply with building or fire  codes.

Advantages

     Removal permanently eliminates the source of asbestos fibers.

Disadvantages

     If removal from complex surfaces (pipes, ducts, crevices, etc.) is re-
quired, this technique may be costly and time-consuming.  After removal,
porous surfaces may require sealing with a chemical penetrant (see Method IB).
Because improper work practices may increase asbestos fiber levels in  air,
removal operations must be carefully planned and closely supervised.

State of the Art

     Removal has been used in many buildings (schools, public, and commercial
buildings) where friable (easily crumbled) asbestos-containing materials posed
a potential health hazard to building occupants.

Variations of  Idea

     Unless the asbestos-containing material is damaged, deteriorating, or
exposed, fiber release may be controlled by other methods such as enclosure,
encapsulation, or special operations.

Applicability

     Removal eliminates the source of asbestos and precludes the development
of future problems.  It is especially suitable for damaged and deteriorating
asbestos-containing materials.

Effectiveness

     Complete  removal of asbestos-containing insulation from the area  elimin-
ates the asbestos hazard.

Engineering Considerations

Building Preparation--
     Prior to  the removal (or disturbance) of asbestos-containing materials,
the work area  is isolated so that all asbestos fibers released by the removal
activity will  be confined to the work area.  Temporary partitions are con-
structed, and  all exposed surfaces (other than those that are being removed)


                                      20

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                                        Section 4/Asbestos Removal (Method 1A)
are covered with plastic sheeting.  Ventilation to and from the work area is
sealed off.  High-efficiency participate air (HEPA) fiHration of the work
area air is desirable to afford stringent control of fiber levels and to
minimize the risk of asbestos exposure to removal workers and/or building
occupants  (if the building remains occupied during removal).  To do this,
powered exhaust equipment is used to exhaust air from the work area through a
high-efficiency filter  (defined as a filter that is at least 99.9 percent
efficient  in collecting particles with aerodynamic diameters of 0.3 ym) to the
environment outside the building.

Process Description—
     After the work area has been enclosed and plastic sheeting placed over
all exposed surfaces, the asbestos-containing material is wetted in place with
amended water*.  While still wet, the material  is physically removed and
placed in  sealable bags or containers.  When removal is complete, the work
area is subjected to a thorough cleaning.  All  surfaces are wet-wiped or
mopped.  Vacuums equipped with high-efficiency filters may be used to vacuum
up any visible debris deposited on building floors, ledges, other equipment,
etc.  Porous surfaces may require sealing with a chemical penetrant to prevent
the release of any residual fibers (see Method IB).

     For prevention of possible spread of fibers, equipment and persons leav-
ing the work area must pass through a partitioned area designated as the
decontamination chamber.  In this chamber, equipment is wet-wiped to remove
asbestos contamination, and used protective clothing is discarded into seal-
able containers to be disposed of later as asbestos-containing waste.  A
portable shower and a change area may be provided for the use of workers
exiting the work area.  Spent shower water is filtered with a high-efficiency
filter that is later disposed of as asbestos-containing waste.

     A visual inspection is conducted following removal of the asbestos-con-
taining material to detect incomplete work or inadequate cleanup.  Following a
satisfactory visual inspection, the work area remains undisturbed for 24 to 72
h to allow time for fibers to settle.  Air monitoring is then conducted to
measure the level of residual asbestos fibers according to the NIOSH method
for asbestos fibers in air (Method No. P & CAM 239, 1977).5  When air monitor-
ing results indicate that the work area is adequately decontaminated of asbes-
tos, the isolation barriers are disassembled, placed in sealable containers,
and later disposed of in approved landfills.   The removed asbestos-containing
material  may be replaced with a nonasbestos substitute to comply with building
or fire codes.

Equipment and Support Facilities Needed--
     The following equipment is needed:  temporary partitions and plastic
sheeting; water sprayer; shears and scraping  tools; sealable bags and contain-
ers; portable HEPA-filtration devices, such as  the Micro-Trap (Asbestos Con-
trol Technology, Inc., New Jersey) or the Air Tech 2000 (Industrial  Safety
*
  Water with surfactant added to increase wetting action.
                                      21

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Section 4/Asbestos Removal (Method 1A)
Products, Inc.); HEPA-filter-equipped vacuums,  such as those manufactured by
Nilfisk of America, Inc., or the Minuteman Asbestos Vacuum Model  80315 by
Minuteman, Inc.; Level C protective equipment including full-body protective
coveralls and NIOSH/MSHA-approved respirators;  and air monitoring equipment.
In addition, major abatement jobs will require  a shower area and  change room.

Time Requirements—
     Approximately 30 percent of the total time necessary to remove asbestos-
containing material involves preparation of the work area.  Actual time de-
pends upon the size and complexity of the removal  task.

     Personnel time requirements depend upon the amount of material removed,
and whether a nonasbestos replacement material  is  installed.

     Approximately the same time is required for tear-down as that for prepar-
ation of the work area.  More time may be required if final air tests are
unsatisfactory and the work area must be recleaned.

Safety Requirements

     Potential hazards to personnel include inhalation of asbestos fibers
(known to be fibrogenic and carcinogenic); electrical shock from the use of
water (for wetting) in proximity to electrical  equipment; and heat stress
caused by high temperatures and humidity, no or minimal ventilation, and the
full protective clothing worn by workers.

     The release of fibers should be controlled by wetting all asbestos-con-
taining material prior to its removal (EPA regulation 40 CFR 61).  Workers
must wear NIOSH/MS'HA-approved respirators (selected from among those approved
under the provisions of 30 CFR Part 11, 37 F.R. 6244, March 25, 1972) and
full-body protective coveralls while in the work area.  Major abatement pro-
jects will require a portable shower room and a secure change area (for chang-
ing from protective clothing to street clothes).

     Work areas where asbestos fibers are released must be monitored to eval-
uate workers' exposures to asbestos fibers compared with the exposure limits
prescribed in OSHA regulation 29 CFR 1910.1001, paragraph  (b).  Sampling
equipment and methods are described fully in 1919.1001, paragraphs (e) and
(f), and in the NIOSH method for asbestos fibers in air (Method No. P & CAM
239, 1977).5  Air samples should be taken during actual removal of the asbes-
tos-containing material and after removal has been completed.  See Section  5
for additional worker health and safety requirements.

Waste Disposal

     All asbestos-containing waste must be sealed  into impermeable bags or
containers.   These containers are  labeled in accordance with OSHA  regulation
29  CFR 1910.1001 and  disposed of in approved landfills in  accordance with EPA
regulation 40 CFR  61.25.
                                      22

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                                  Section 4/Asbestos Encapsulation (Method IB)
Costs

Structural Damage and Repair Costs--
     Physical damage to the building should be minimal.   Wet removal  with
inadequate floor protection may cause warping of wooden floors.   Disassembling
the containment barriers may cause wall or ceiling paint to crack or peel.

Treatment and Disposal Costs--
     Costs for utilities and fuel should be low.  Equipment and  disposal  costs
should be moderate.  Personnel costs should be moderate to high; removal  of
asbestos-containing material is generally the most labor-intensive asbestos-
abatement technique.  Hourly wages for asbestos workers range from approxi-
mately $17 to $25 (1983 dollars).17  See the cost analysis in Appendix C  for
additional information.

Information Sources

     The bulk of the information in this subsection came from References  3 and
18.  Use of this method is illustrated in the case study presented in Appendix
H.
ASBESTOS ENCAPSULATION (METHOD IB)

General Description

     A chemical penetrant or bridging-type sealant is spray-applied to asbes-
tos-containing materials to bind together asbestos fibers and other material
components for reduction of asbestos fiber release into the air.

Advantages

     The initial cost of encapsulation may be lower than that of asbestos
removal.  Also, the asbestos-containing material does not need to be replaced.

Disadvantages

     Because periodic reinspections are required to check for damage or deter-
ioration and because subsequent repair of the encapsulated surface may be
necessary, the long-term costs of encapsulation may be higher than the cost of
asbestos removal.  Encapsulating agents can affect (i.e., reduce) the fire-
proofing properties of the asbestos-containing materials.  In addition, encap-
sulation .of asbestos-containing material makes their eventual removal more
difficult.
                                     23

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Section 4/Asbestos Encapsulation (Method IB)
State of the Art

     Encapsulants are, at best, a temporary control  measure.   Control  effec-
tiveness depends partially on the correct choice of  encapsulant.   Encapsulants
are evaluated according to adhesive/cohesive strength,  ability to adhere to
substrate, impact resistance, and toxicity.

Variations of Idea

     If the asbestos-containing material  is in poor  condition or  easily acces-
sible, other methods of asbestos hazard abatement (e.g.,  removal  or enclosure)
should be used.

Applicability

     Encapsulation is only appropriate for asbestos-containing materials that
are in good condition, that have excellent adhesive  and cohesive  properties,
and that are not highly accessible.   Asbestos-containing  pipe insulation
should not be encapsulated.  Pipe lagging discourages the encapsulant's pene-
tration into the asbestos-containing material  and reduces binding of the
asbestos fibers  and other material  components.

Effectiveness

     Encapsulation satisfactorily controls release of asbestos fibers  as long
as the treated asbestos-containing materials remain  in  good condition, are
free from water  damage, and are not subject to physical contact.

Engineering Considerations

Building Preparation—
     Encapsulants are usually spray-applied.  This contact disturbance has the
potential for releasing asbestos fibers.   Thus, prior to  encapsulation, the
entire work area must be isolated so that all  asbestos  fibers are confined to
this area.  Ventilation to and from the work area should  be shut  off.   Once
encapsulation work begins, high-efficiency filtration of  the work area air is
desirable for stringent control of fiber levels (see Method 1A).

Process Description—
     After the work area has been isolated with temporary partitions and
plastic sheet barriers, all surfaces except the material  to be encapsulated
are covered with plastic sheeting.   The sealant is spray-applied  with  very low
nozzle pressure  to minimize contact disturbance.  After the encapsulant is
allowed to dry,  a second coat may be applied.   The work area is then inspected
for completeness of the work.

     To prevent  the possible spread of asbestos fibers, equipment and  persons
leaving the work area should pass through a decontamination chamber as de-
scribed in Method 1A.
                                     24

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                                  Section 4/Asbestos Encapsulation (Method IB)
     Before the containment barriers are disassembled, the work area must be
thoroughly cleaned.  All surfaces are wet-wiped or mopped.  Vacuums  equipped
with high-efficiency filters may be used to vacuum up any visible debris
deposited on floors, ledges, other equipment, etc.  The plastic sheeting  used
as isolation barriers is rolled up and placed in sealable containers and  later
disposed of as asbestos-contaminated waste.

Equipment and Support Facilities Needed—
     Temporary partitions and plastic sheeting, encapsulants, spray  applica-
tion equipment, sealable bags and containers, HEPA-equipped vacuums, Level  C
protective gear, and air monitoring equipment are required.

Time Requirements —
     The time necessary to construct containment barriers and cover  exposed
surfaces is the same as for Method 1A.  If the area is complex (i.e., diffi-
cult corners or areas with difficult access), more time will be required.

     Spray application proceeds fairly rapidly.  Encapsulant drying  time  may
require from several hours to one or two days, especially if more than one
coat is necessary.

     Tear-down time should be minimal.

Safety Requirements

     Potential hazards to personnel include inhalation of asbestos fibers;
inhalation of toxic vapors from sealants; and heat stress caused by  high
temperatures and humidity, no or minimal ventilation, and the full protective
clothing worn by workers.  Workers should wear NIOSH/MSHA respirators approved
under 30 CFR Part 11 for asbestos and any toxic vapors that may be present in
the encapsulant.  Full-body protective coveralls should be worn.

     Work areas where asbestos fibers are released must be monitored to evalu-
ate workers' exposures to asbestos fibers against the exposure limits pre-
scribed in OSHA regulation 29 CFR 1910.1001, paragraph (b).  Sampling equip-
ment and methods are described fully in 1910.1001, paragraphs (e) and (f), and
in the NIOSH method for asbestos fibers in air (Method No. P & CAM 239,
1977).5  Air samples should be taken during and after encapsulation.  See
Section 5 for additional worker health and safety requirements.

Waste Disposal

     The plastic barriers used to contain the work area during encapsulation
are treated as asbestos-contaminated waste.  All asbestos-contaminated waste
is sealed into impermeable bags or containers, labeled in accordance with OSHA
regulation 29 CFR 1910.1001, and disposed of in landfills in accordance with
EPA regulation 40 CFR 61.25.
                                      25

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Section 4/Asbestos Enclosure (Method 1C)
Costs

Structural Damage and Repair Costs—
     Building damage and repair costs should be minimal.

Treatment and Disposal Costs--
     Costs for utilities and fuel  should be low.  Equipment costs should be
moderate; encapsulants and special airless sprayers will  have to be purchased.
Labor costs should be moderate.  Waste disposal costs should be low.  See the
cost analysis in Appendix C for additional information.

Information Sources

     The bulk of the information in this subsection came  from References 3 and
18.  Use of this method is illustrated in the case study  presented in Appendix
I.
ASBESTOS ENCLOSURE (METHOD 1C)

General Description

     A permanent barrier is erected between the asbestos-containing material
and all portions of the occupied building.  Release of asbestos fibers is
contained behind the barrier.

Advantages

     The initial cost of enclosure may be lower than that of asbestos removal.

Disadvantages

     Long-term costs may be higher than the costs of asbestos removal because
of the required periodic reinspections of the enclosure to check for damage
and the repair of any damage found.  Access to the enclosure for maintenance
or renovation activites will need to be controlled through a special opera-
tions program.  The asbestos source remains and must be removed later (parti-
cularly prior to building renovation or demolition).

State of the Art

     Properly constructed and maintained enclosures can prevent emission of
fibers to other building areas for the remaining life of the building.
                                      26

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                                      Section 4/Asbestos Enclosure  (Method 1C)
Variations of Idea

     If the asbestos-containing materials are in areas  where frequent entry or
activity occurs or if these materials are damaged and deteriorating,  enclosure
is not a suitable control technique, and complete removal  should be considered
to abate the asbestos hazard.

Applicability

     Enclosure is a suitable asbestos-hazard-abatement  technique, particularly
when the asbestos-containing materials are located in building areas  where
entry or disturbance is unlikely.  Enclosure isolates asbestos-containing
materials from building occupants.  For example, enclosing asbestos-insulated
steam pipes located in a busy corridor protects occupants  from that asbestos
source.

Effectiveness

     Release of asbestos fibers is contained behind the barrier so that poten-
tial exposures outside the enclosure are reduced.  Fiber release continues
behind the enclosure.

Engineering Considerations

Building Preparation—
     During construction of an enclosure, asbestos fiber release is likely to
occur.  Therefore, containment barriers should be constructed to isolate the
work area from the rest of the building.  Ventilation to and from the work
area should be shut off.  Once enclosure work begins, high-efficiency filtra-
tion of the work area air is desirable for stringent control of fiber levels
(see Method 1A).

Process Description--
     After the work area is isolated with temporary partitions and plastic
sheet barriers, an enclosure is constructed around the asbestos-containing
material so that it is totally contained within the enclosure.  Examples of
enclosure construction include gypsum panels taped at the seams, tongue and
groove boards, and boards with spline joints.  Lighting fixtures, plumbing
lines, and electrical cables may have to be relocated.

     To prevent the possible spread of fibers, equipment and persons leaving
the work area should pass through a decontamination chamber as described in
Method 1A.

     Before the containment barriers are disassembled, the work area must be
thoroughly cleaned.  All surfaces are wet-wiped or mopped.  Vacuums equipped
with high-efficiency filters may be used to vacuum up any visible debris
                                      27

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Section 4/Asbestos Enclosure (Method 1C)
deposited on floors, ledges, other equipment, etc.  The plastic sheeting used
as isolation barriers is rolled up and placed in sealable containers and later
disposed of as asbestos-contaminated waste.

Equipment and Support Facilities Needed--
     Equipment requirements include enclosure construction materials, sealable
bags and containers, HEPA-equipped vacuums, Level C protective gear, and air
monitoring equipment.

Time Requirements--
     Work area preparation time should be the same as that required for asbes-
tos removal.  The time necessary to construct enclosure barriers should be
less than that required to remove asbestos.  Cleanup time is approximately the
same for both techniques.

Safety Requirements

     Because asbestos fibers are released to the air by the disturbance of
asbestos-containing materials during work activity, inhalation of asbestos
fibers is a potential hazard.  To prevent this, workers should wear NIOSH/
MSHA-approved respirators and full-body protective clothing while in the work
area.  If drilling into asbestos-covered surfaces is required, drills should
be equipped with HEPA-filter-equipped vacuums to reduce fiber levels in work
area air.

     Work areas where asbestos fibers are released must be monitored to evalu-
ate exposures to asbestos fibers with reference to the exposure limits pre-
scribed in OSHA regulation 29 CFR 1910.1001, paragraph (b).  Sampling equip-
ment and methods are described fully in 1910.1001, paragraphs (e) and (f), and
in the NIOSH method for asbestos fibers in air (Method No. P & CAM 239,
1977).5  Air samples should be taken during construction of the enclosure.
Worker exposure should also be monitored whenever work is performed behind the
enclosure (such as periodic maintenance activity).  See Section 5 for addi-
tional worker health and safety requirements.

Waste Disposal

     Plastic sheeting used to contain the work area during construction of the
enclosure is disposed of as asbestos-contaminated waste.  Sealed containers of
asbestos-contaminated material are disposed of in accordance with EPA regula-
tion 40 CFR 61.25.

Costs

Structural Damage and Repair Costs—
     Total costs may be equivalent to those accrued in asbestos removal be-
cause periodic inspection and repair of the enclosure will be required for the
life of the building.  Building utilities may need to be relocated.
                                      28

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                                      Section 4/Special Operations (Method ID)
Treatment and Disposal Costs--
     Costs for utilities, fuel, equipment, labor, and disposal  should be
minimal.

Information Sources

     The bulk of the information in this subsection came from References 3 and
18.
SPECIAL OPERATIONS (METHOD ID)

General Description

     Building cleanup, special maintenance procedures, repair of asbestos-con-
taining materials, and periodic reassessment of the need for other control
measures are used to control the potential for asbestos exposure to building
occupants.

Advantages

     These procedures minimize initial costs, while providing reasonable
assurance of protection to building occupants.

Disadvantages

     Because the asbestos source remains, other control measures will be
required at some future time.  Periodic reinspections of the asbestos-contain-
ing materials are required.

State  of the Art

     Special operations have been used in many instances to defer the initial
costs  of other asbestos abatement control techniques.

Variations of Idea

     The asbestos-containing materials may require other control measures,
depending upon future reassessments of material condition.

Applicability

     Special operations are appropriate when asbestos-containing materials are
nonfriable and in good condition, and the potential for disturbance or erosion
is low.
                                      29

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Section 4/Special Operations (Method W)
Effectiveness

     Asbestos fiber release is adequately controlled by special  operations  as
long as the asbestos-containing materials remain in good condition.

Engineering Considerations

Process Description--
     Special operations include conducting a thorough building cleanup,  re-
pairing damaged asbestos-containing materials, implementing special  mainten-
ance procedures, and instituting an ongoing inspection program.

     Carpets are steam-cleaned or vacuumed with HEPA-filtered vacuum cleaners.
Furniture, floors, equipment, and other exposed surfaces should be vacuumed
(HEPA-equipped vacuum) or wet-wiped or mopped with a mild soap solution.

     Missing panels in suspended tile ceilings that conceal asbestos-contain-
ing materials should be replaced.  Open joints or exposed edges on asbestos-
containing pipe insulation should be sealed with duct tape.

     Special written procedures should be developed for maintenance personnel
who must perform work in areas where there is a potential for disturbing
asbestos-containing materials.  Procedures should designate proper work and
cleanup practices and recommend personal protective equipment.

     At regular intervals, asbestos-containing materials should be visually
inspected.  Other control measures, such as removal, encapsulation, and enclo-
sure, should be evaluated for their appropriateness at that time.

Equipment and Support Facilities Needed—
     Equipment requirements include wipes, mops, HEPA-equipped vacuums,
Level C protective gear, and air monitoring equipment.

Time Requirements--
     Initial building cleanup and repair of asbestos-containing materials may
take from a few days to a week, depending upon the size of the building.
Special maintenance operations and an inspection program are ongoing activi-
ties.

Safety Requirements

     Personnel hazards may include inhalation of asbestos fibers.  Workers
should wear respirators approved for use with asbestos fibers when engaged  in
operations that have the potential for disturbance of asbestos-containing
materials.  Maintenance employees should be trained  in asbestos hazards and
proper work practices and precautions.
                                      30

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                                               Section  4/Absorption  (Method  2)
     Maintenance operations that are likely to disturb  asbestos-containing
materials and cause release of asbestos fibers should be  periodically moni-
tored to typify workers' exposures to asbestos fibers during  those  operations.
Exposure limits are prescribed in OSHA regulation  29  CFR  1910.1001, paragraph
(b).  Sampling equipment and methods are described fully  in  1910.1001,  para-
graphs (e) and (f), and in the NIOSH method for asbestos  fibers  in  air  (Method
No. P & CAM 239, 1977).5  See Section 5 for additional  worker health and
safety requirements.

Waste Disposal

     Few asbestos-contaminated wastes will  be generated,  but  cloths, mops, and
filters may need to be treated as hazardous wastes.   Asbestos-contaminated
materials are disposed of in accordance with EPA regulation  40 CFR  61.25.

Costs

Structural Damage and Repair Costs--
     Little or no damage to the building is expected.   Repair costs for pipe
insulation or suspended ceilings should be  minimal.

Treatment and Disposal Costs--
     Costs for utilities and fuel should be very low; no  unusual  utility
consumption is involved.  Equipment costs should be minimal;  purchase of
HEPA-equipped vacuums, which range in cost  from a  few hundred to  several
thousand dollars, is one possible expense.   Labor  costs should be minimal;
current building maintenance employees may  be trained and utilized. Disposal
costs should be low.

Information Sources

     The bulk of the information in this subsection came  from References  3 and
18.
ABSORPTION (METHOD  2)

General Description

     Absorbent materials are used to pick up liquid contaminants.   This  method
is most applicable immediately following liquid contaminant spills.   Spills
rapidly penetrate most surfaces, and absorbents act to contain  contaminants
and prevent such penetration.  Depending on the surface and time  elapsed since
the spill, further decontamination procedures may have to  be employed.
                                     31

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Section 4/Absorption (Method 2)
Advantages

     Absorbents act quickly to contain gross contamination.

Disadvantages

     Secondary decontamination is normally required to clean up surface resi-
dues and subsurface contamination.

State of the Art

     Absorbents are widely used in industrial  settings to clean up liquid
chemical spills.  They are also commonly used by emergency response teams such
as fire departments to absorb accidental spills on highways  and other
surfaces.

Variations of Idea

     Many different absorbent materials can be used.  Among  them are attaclay,
sand, anhydrous filler, sandy loam soil, and sawdust.   If possible, a clay-
based material should be used; however, if one is not  available, soil and any
other immediately available absorbent material should  be used.

Applicability

     Absorbents can be used to remove liquid contaminants from  all surfaces.

Effectiveness

     The efficiency of absorbents differs among specific absorbent materials
and with the building materials on which they are used.   Experimental studies
have indicated clay is most efficient followed by anhydrous  filler, soils, and
sawdust.  Greatest recovery of liquid contaminants can be expected from smooth
metal surfaces followed by wood or concrete surfaces.

Engineering Considerations

Process Description—
     The absorbent application process is fairly simple.  As soon as possible
following the contaminant spill, the absorbent material  is applied to the
liquid puddle(s).  Application can be by hand, shovel, dump  truck, or other
mechanical or manual means.  After time has been allotted for the absorbents
to soak up the contaminated liquid, the contaminated absorbent  is removed by
shovel or other means and placed in containers for delivery  to  a disposal
site.  Depending on the surface and time elapsed since the spill, secondary
decontamination may be required to clean up surface residues and subsurface
contamination.
                                      32

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                                               Section 4/Absorption (Method 2)
Equipment and Support Facilities Needed--
     Absorbent materials, application and removal equipment, and Level C
personal protective gear are needed.  All equipment can be purchased from
commercial manufacturers.

Time Requirements—
     Decontamination time is relatively short; most absorbents reach removal
capacity after 1 or 2 h.

Safety Requirements

     Basic safety requirements applicable to hazardous waste spills should be
followed.  All possible sources of ignition must be eliminated from areas
containing spills of volatile, flammable liquids.  Gloves, coveralls, safety
glasses, suitable respiratory protection, and boots should be worn in all
cases.  The need for additional safety equipment and procedures will depend on
the specific contaminant being cleaned up.  See Section 5 for additional
worker health and safety requirements.

Waste Disposal

     Because the used absorbent material will contain the contaminant, it may
require handling as a hazardous waste.  Consult 40 CFR Part 261 and appropri-
ate EPA guidance for definitions and listings of hazardous waste.  If the used
absorbent material is considered hazardous, it must be treated or disposed of
in a RCRA-permitted facility.

Costs

Structural Damage and Repair Costs—
     If the surface material is metal or wood and an absorbent is applied
quickly, building repair costs should be minimal.  Secondary decontamiantion,
if required, may lead to more extensive structural damage and more costly
repairs.

Treatment and Disposal  Costs--
     Treatment costs should be relatively low; absorbent materials and appli-
cation equipment should not be very expensive.  Disposal costs may be appreci-
able if the wastes are considered hazardous.  See Appendix C for an analysis
of costs associated with the use of this method.

Future Work

     Efforts should be made to increase the applicability of this method to
wood and other porous surfaces, and to develop methods for recycling absor-
bents in large cleanup efforts.
                                      33

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Section 4/Demolition (Method S)
 Information Sources

     The bulk of the information in this subsection came from Reference 19.




DEMOLITION (METHOD 3)

General Description

     Demolition refers to the total destruction of a building,  structure,  or
piece of equipment.  Specific demolition techniques include complete burndown,
controlled blasting, wrecking with balls or backhoe-mounted rams,  rock split-
ting, sawing, drilling, and crushing.  Many of these techniques have been  used
in the cleanup of nuclear facilities and military arsenals.

Advantages

     Decontamination of the site is achieved by removing all  contaminated
building materials, structures, and equipment.

Disadvantages

     Buildings, structures, and equipment are completely destroyed.   Large
quantities of contaminated debris must be disposed of.   Airborne contamination
may occur through fugitive emissions, and workers or nearby residents may  be
exposed.

State of the Art

     Demolition technology is well  developed.  Many types of demolition tech-
niques have been successfully used in the demolition of nuclear facilities.
Demolition also was used in a section of the Frankford  Arsenal  site  (Appendix
H).  Demolition is used extensively by the construction industry.

Variations of Idea

     Demolition may be limited to only those parts of a building or  structure
that cannot be decontaminated by any other means.

Applicability

     Demolition is potentially applicable to all  contaminants;  however, if the
building is highly contaminated with combustibles, explosions may  occur during
demolition.  All materials used to construct buildings, structures,  and equip-
ment may be demolished.
                                      34

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                                               Section 4/Demolition (Method 3)
Effectiveness

     Complete removal of contaminated structural materials from the site is
expected.

Engineering Considerations

Building Preparation—
     Considerable building preparation activites are required.  First, all
surfaces must be washed down to minimize dust.  Some contaminant residues
(e.g., explosives, asbestos, or other toxic contaminants) may have to be
neutralized, stabilized, or removed prior to demolition activities to prevent
explosions or emissions.  Also, some structures within the building may have
to be dismantled and removed prior to demolition activities (see Method 4).

Process Description--
     Figure 2 is a flow diagram of the demolition process.
PRETREATMENT
OF CONTAMINANT
RESIDUES


STRUCTURES
REMOVAL


DEMOLITION


DEBRIS
COLLECTION


WASTE
TREATMENT
AND/OR DISPOSAL
                  Figure 2.  Demolition process flow diagram.
     After the building preparation steps have been completed, controlled
blasting, wrecking balls, hydraulic rams, controlled burndown, or other me-
thods are used to demolish the building.  The debris is then collected or con-
tained for treatment (possibly incineration) and disposal.

Equipment and Support Facilities Needed--
     Demolition requires the use of explosives or other demolition equipment,
cleanup equipment, water hoses, and personal protective gear.

Time Requirements—
     Personnel time could be extensive if considerable building preparation is
required.  Equipment setup and teardown depend on the demolition technique,
but they should require little time.  Cleanup time may constitute the largest
portion of the total time required.  Complete burndown of a 3.6-ha parcel
containing 32 small one-story buildings at the Frankford Arsenal site took
approximately 12 h.

Safety Requirements

     Dynamite or other explosives and heavy machinery constitute process
hazards.  Accidental detonation of the building is possible if it is heavily
                                      35

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Section 4/Demolition (Method 3)
contaminated with combustible, explosive, or reactive residues.   Residues
should be pretreated before demolition to eliminate fire and explosion  hazards
and atmospheric release of toxins.

     Personnel hazards may result from high noise and dust levels, and  from
explosions.  Proper eye, ear, head, and clothing protection should be worn.
See Section 5 for additional worker health and safety requirements.

Waste Disposal

     The debris resulting from demolition will be contaminated and may  require
handling as a hazardous waste.  In some cases, it may be cost-effective to
decontaminate the debris before landfilling.  Rotary kiln incineration  should
be evaluated as a treatment method on a case-by-case basis depending on the
availability of a permitted incinerator and the Btu value of the waste.  Other
decontamination techniques described in this manual may also be used to reduce
the volume of contaminated waste.  Consult 40 CFR Part 261 and other appropri-
ate EPA guidance for definitions and listings of hazardous waste.  If the
waste is considered hazardous, it must be disposed of in a RCRA-permitted
landfill.

Costs

Structural Damage and Repair Costs--
     Buildings and structures are completely destroyed.  Costs for construc-
tion of replacement structures may be incurred.

Treatment and Disposal Costs--
     Costs for utilities and fuel for operating the demolition and cleanup
equipment should be moderate to high.  Costs associated with treating and
disposing of the debris may be appreciable.  Incineration costs will increase
with the noncombustible content of the debris (brick, cement, etc.).  See
Appendix C for an analysis of costs associated with the use of this method.

Future Work

     Methods for desensitizing combustible contaminants prior to demolition
need to be developed.

Information Sources

     The bulk of the information in this subsection came from References 20
and 21.  Use of this method is illustrated  in the case studies presented in
Appendices D and H.
                                      36

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                                              Section 4/Dismantling  (Method  4)
DISMANTLING  (METHOD 4)

General Description

     Dismantling refers to the physical  removal  of selected  structures  (such
as contaminated pipes, tanks, and other process  equipment) from buildings  or
other areas.  Dismantling can be the sole activity of decontamination efforts
(e.g., removal of contaminated structures from an otherwise  clean  building),
or it can be used in the initial stage of a more complex building  decontamina-
tion effort (e.g., removal of structures prior to flaming, demolition,  or
other cleanup techniques).

Advantages

     Dismantling is less costly than complete demolition because only those
structures that are contaminated are removed.

Disadvantages

     Large quantities of contaminated debris must be disposed  of.

State of the Art

     Dismantling has been used in many decontamination procedures  (chiefly in
conjunction with asbestos removal and replacement), in the decommissioning of
nuclear facilities, and in the cleanup of military arsenals.

Variations of Idea

     If no direct contamination hazards  are present or if local  protection is
used effectively, dismantling may be done manually.  Remote  removal  may be
necessary if highly contaminated areas prevent direct worker access.  Whole
structures may be removed at one time (furniture, drains, light fixtures), or
segmenting may be necessary prior to removal (piping, tanks, interior vessels
of nuclear facilities).

Applicability

     Dismantling is potentially applicable to all types of contaminants and to
building materials that can be segmented/disassembled.

Effectiveness

     In the case of the removal of contaminated  structures from an otherwise
clean building, complete physical decontamination is possible.   When dismant-
ling precedes other decontamination efforts, only partial cleanup  can be
expected.
                                      37

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Section 4/Dismantling (Method 4)
Engineering Considerations

Process Description--
     First, the components to be dismantled are identified,  and  then  a  con-
trolled work area is established, isolated, and sealed.   Any contaminated
loose debris (such as wood or metal  scraps) should be removed after a light
water spray has been applied to minimize airborne particulates.   Penetrating
oil is then applied to joints, screws, and nuts that will  be removed.  A
second coat of oil, just prior to their removal, may be  necessary.  Major
structures to be dismantled are then removed by physical  labor and/or disman-
tling equipment.  Care should be taken in the use of saws or other  friction-
producing tools if combustible contaminants are present.   Segmenting  of large
metallic components may be necessary; this can be accomplished through a
number of processes, including plasma arc cutting, oxygen burning,  explosive
cutting, hacksaw and guillotine sawing, and circular and abrasive cutting.
Once dismantling is complete, all removed materials are  decontaminated or
placed in suitable containers and marked for shipment to a suitable disposal
site.

Equipment and Support Facilities Needed—
     Dismantling requires the following:  major tools (saws, blades,  etc.)  for
segmenting and complex removals, depending on the process selected; nonspark-
ing tools, including wrecking bars;  water and water sprayer; safety equipment
(glasses, coveralls, gloves, hardhats, dust masks, hearing protection, and
respirators); air compressor; and miscellaneous items such as storage contain-
ers, spare saw blades, penetrating oil, plastic sheeting, fire extinguisher,
and heavy duty plastic bags for disposal of the waste.  Most equipment needed
for dismantling procedures is readily available from commercial  manufacturers.

Time Requirements--
     The decontamination time requirements will vary depending on the type  and
quantity of the structures to be dismantled and the magnitude of removal
operations (simple physical removal  of furniture, for example, versus segment-
ing or removal of fixed internal structures such as floor drains or ventila-
tion systems).

Safety Requirements

     Basic safety requirements should include the use of all safety equipment
described  in the equipment section.   Depending upon the nature of the contami-
nant, additional safety precautions may be necessary.  Sparkproof tools are of
particular importance when working on equipment or structures contaminated by
combustibles.  Toxic fumes are possible from metal welding, cutting, or burn-
ing operations.  Safety glasses  should offer protection from ultraviolet
radiation  generated by welding arcs.  See  Section 5 for additional worker
health and safety requirements.
                                      38

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                                 Section  4/Dusting-Vacuuming-Wiping (Method 5)
Waste Disposal

     Dismantled and removed structures will  still be contaminated with resi-
dues and cannot be reused or sold  for scrap  without further treatment.  De-
pending on the recycle value of the  dismantled materials, additional decontam-
ination steps (such as acid etching  or solvent washing) may be warranted.  If
not, the contaminated material  may require disposal as a hazardous waste.
Consult 40 CFR Part 261 and appropriate  EPA  guidance for definitions and
listings of hazardous waste.  If the wastes  are considered hazardous, they
must be disposed of in a RCRA-permitted  facility.

Costs

Structural Damage and Repair Costs—
     Unless decontaminated, dismantled parts cannot be reused.  Replacement
costs may be incurred.

Treatment and Disposal Costs--
     Treatment costs should be  moderate  to high, depending on the quantity and
magnitude of operation.  Costs  for utilities and fuel should be low.  Equip-
ment, materials, and personnel  comprise  the  bulk of the treatment costs, and
their magnitude will depend on  the size  and  type of the dismantling operation.
Costs will be incurred for decontamination or disposal of the dismantled
structure.  See Appendix C for  an  analysis of costs associated with the use of
this method.

Future Work

     Research could be devoted  to  developing less expensive dismantling equip-
ment for use in major segmenting operations.

Information Sources

     The bulk of the information is  this subsection came from References 20
and 21.  Use of this method is  illustrated in the case studies presented in
Appendices D, E, G, H, J, and K.
DUSTING/VACUUMING/WIPING  (METHOD 5)

General Description

     This method is simply the physical  removal of  hazardous dust and parti'
cles from building and equipment  surfaces  by  common cleaning techniques.
                                      39

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Section 4/Dusting-Vacuuming-Wiping (Method 5)
Advantages

     Small volumes of waste or wastewater are generated.  Wastes are contained
in vacuum cleaner bags or on wipe cloths and easily disposed of.

Disadvantages

     Fugitive dusts created by the dusting or vacuuming action may spread
contamination.  Also, if the source of the contaminated particulates is from
outside a building, vacuuming/dusting efforts inside may be ineffective until
the external source is controlled.  See the Sontag Road area case study (Ap-
pendix F) for an example.

State of the Art

     Dusting/vacuuming/wiping is the state-of-the-art method for removing
dioxin-contaminated dust from the interior of homes and buildings (see Appen-
dices D and F).

Variations of Idea

     Variations include vacuuming with a commercial or industrial-type vacuum;
dusting off surfaces such as ledges, sills, pipes, etc., with a moist cloth or
wipe; and brushing or sweeping up hazardous debris.

Applicability

     Dusting and vacuuming are applicable to all  types of particulate contami-
nants, including dioxin, lead, PCB's, pesticides, and asbestos fibers.  The
methods are applicable to all  types of surfaces.

Effectiveness

     Residue levels should be low after thorough  vacuuming or dusting.  If
residue levels are unacceptable after vacuuming or dusting, wiping with a
water- or solvent-soaked cloth may be necessary.

Engineering Considerations

Process Description--
     Vacuuming is performed using a commercial  or industrial  vacuum equipped
with a high-efficiency particulate air (HEPA) filter.  The vacuum cleaner bag
containing the contaminated particulates is disposed of as a hazardous waste.

     Dusting/wiping uses a damp cloth or wipe (soaked with water or solvent)
to remove dust from surfaces not practically treatable with a vacuum.  The
cloth or wipe is also disposed of as a hazardous  waste.

     Brushing or sweeping is used to clean up coarse debris.


                                      40

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                                 Section 4/Dusting-Vaauwning-Wiping (Method 5)
Equipment and Support Facilities Needed—
     Needed equipment includes a HEPA-filter-equipped vacuum (commercial  or
industrial), cloths or wipes, water, solvent, containers for packaging contam-
inated waste or debris, and Level C protective gear.

Time Requirements--
     Minimal time will be required for setup of the equipment.   Labor require-
ments for the process should be moderate, depending on the size and complexity
of the surface area to be cleaned.  Minimal time will be required for packag-
ing debris and dismantling and removing equipment.

Safety Requirements

     Toxic dust could be hazardous to personnel.  Protective clothing and
appropriate respirators should be required for workers.  See Section 5 for
additional worker health and safety requirements.

Waste Disposal

     The collected dust and debris may be considered a hazardous waste.
Consult 40 CFR Part 261 and appropriate EPA guidance for definitions and
listings of hazardous waste.  If the waste is considered hazardous, it must be
disposed of in a RCRA-permitted facility.

Costs

Structural Damage and Repair Costs--
     These costs should be negligible or zero.

Treatment and Disposal Costs—
     The costs associated with this type of treatment are relatively low.
Disposal costs should also be low.  See Appendix C  for an analysis of costs
associated with the use of this method.

Future Work

     The efficiency of this method needs to be documented.

Information Sources

     The bulk of the information in this subsection came from References 20
and 22.  Use of this method is illustrated in the case studies  presented in
Appendices D, E, F, G, and H.
                                      41

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Section 4/Encapsulation-Enclosure  (Method 6)
ENCAPSULATION/ENCLOSURE  (METHOD 6)

General Description

     Contaminants or contaminated structures are physically separated from
building occupants and the ambient environment by a barrier.  An encapsulating
or enclosing physical barrier  may take different forms; among them are plas-
ter, epoxy resins, and concrete casts and walls.  Acting as an impenetrable
shield, a barrier keeps contaminants inside and away from clean areas, thereby
alleviating the hazard.  As a  result, contamination of part of a structure
will not result in the contamination of  adjacent areas.

     Painting and coating techniques may also be classified under encapsula-
tion.  These techniques are discussed separately in Methods 9 and 19.  Encap-
sulation and enclosure of asbestos-containing materials are discussed in
Methods IB and 1C.

Advantages

     Large volumes of contaminated debris are not created.

Disadvantages

     Encapsulated structures are  usually rendered inaccessible or inoperable
since they are physically sealed  off by  the barrier or enclosure.

State of the Art

     Encapsulation has been used  on damaged asbestos insulation, leaky PCB-
contaminated electrical transformers, and open maintenance  pits and  sumps
contaminated by heavy metals.

Variations of  Idea

     See also Methods  IB, 1C,  9,  and  19.

Applicability

     Encapsulation is  applicable  to all  contaminants if there  is a means  of
constructing a physical barrier.   It  can be used on all building materials.

Effectiveness

     Complete  establishment of an impenetrable  barrier  is  anticipated.  This
would allow for complete  (100 percent)  isolation of contaminated structures.
                                      42

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                                  Section 4/Encapsulation-Enclosure (Method 6)
Engineering Considerations

Process Description--
     Any loose contaminants (liquids, sludges) are first removed and/or
cleaned so the contaminated structure is easily accessible.   The impenetrable
barrier is then constructed.  At the Frankford Arsenal, for  example, where
asbestos and PCB encapsulation procedures were used, loose frayed insulation
and spill material were first cleaned up; then the insulation was encapsulated
with a plaster cast (medical type), and the RGB-contaminated transformers were
coated with epoxy resins.  Sludge was removed from contaminated sumps and
pits, and the structures were filled with concrete and/or sand to render them
inoperable (see Appendix H).

Equipment and Support Facilities Needed--
     Encapsulation requires shearing equipment (scissors, etc.) to remove
loose solid materials, pumping equipment to remove liquid contaminants, bar-
rier materials (e.g., plaster cast, water, epoxy, sand, concrete), application
equipment, and personal protective gear.  Most equipment needed for encapsula-
tion procedures is readily available from commercial manufacturers.

Time Requirements--
     Moderate time is needed for the removal of loose solid or liquid contami-
nated wastes, application of encapsulating materials, and a period for the
encapsulating material to take final form (hardening of concrete, etc.).

Safety Requirements

     Basic safety requirements for all encapsulating procedures should include
full-body protective coveralls and foot cover.  Additional equipment needed
will depend on the specific contaminant that is being encapsulated.  For
example, when encapsulating asbestos, workers should wear appropriate respira-
tors.  See Section 5 for additional worker health and safety requirements.

Waste Disposal

     Depending on the situation, contaminated liquid or solid debris may have
to be removed and disposed of before encapsulation takes place.  Because the
hazard is alleviated through isolation of the contaminants, no structural
materials must be removed.

Costs

Structural Damage and Repair Costs--
     In most cases, encapsulated sections of structures will be unable to
perform their original functions.  As a result, costs may be incurred for
replacement structures.
                                      43

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Section 4/Gritblasting (Method 7)
Treatment and Disposal  Costs—
     Overall costs should be moderate;  costs  for  utilities and  fuel should be
low.  Equipment and materials costs will  make up  most  of  the  treatment costs.
Personnel costs should  not be very large.  Disposal  costs should  be low.

Future Work

     This technique is  generally well  developed.   Research should concentrate
on developing encapsulating materials  and techniques that are relatively
inexpensive and contaminant-specific.

Information Sources

     The bulk of the information in this  subsection  came  from References  20,
21, 23, and 24.
GRITBLASTING  (METHOD  7)

General Description

     Gritblasting is a surface removal  technique  in  which  an  abrasive material
is used for uniform removal  of contaminated surface  layers from  a  building  or
structure.

Advantages

     Gritblasting is a widely used surface-removal technique.   It  can simul-
taneously and readily remove paint and  contaminants  near the  surface.

Disadvantages

     Large amounts of dust and debris are generated.   This method  is effective
only as a surface treatment.  Gritblasting can potentially detonate pockets of
combustible contaminants.   A large quantity of abrasive  is required, and  this
method is relatively slow.

State of the Art

     This technology is well developed.  Gritblasting has  been  used since 1870
to remove surface layers from metallic  and ceramic surfaces,  and is currently
used extensively throughout industry.  For example,  sandblasting is commonly
used to clean the surfaces of old brick and stone buildings.  A large number
of gritblasting equipment manufacturers and contractors  are available.
                                     44

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                                             Section 4/Gritblasting (Method 7)
Variations of  Idea

     Steel pellets, sand, alumina, or glass beads may be used as the abrasive.
Remote-control gritblasters are available.

Applicability

     The gritblasting method is potentially applicable to all surface contami-
nants except highly toxic residues (e.g., asbestos, dioxins) and some highly
sensitive explosives (e.g., lead azide, lead styphnate).  This method is
applicable to  all surface materials except glass, transite, and Plexiglas.

Effectiveness

     Surface layer contaminants are completely removed by gritblasting; how-
ever, this method is ineffective for depths greater than about 0.5 to 1.5 cm.
Corners may not be gritblasted as effectively as flat surfaces.  Because
abrasive is "sprayed," the method is applicable to many hard-to-reach areas
(ceilings, behind equipment, etc.).

Engineering Considerations

Building Preparation--
     Obstructions, such as pipes bolted to a wall, may require removal  prior
to treatment.

Process Description--
     Figure 3  presents a flow diagram of gritblasting operations.
  OBSTRUCTION
    REMOVAL
GRITBLASTING


DEBRIS
COLLECTION


SECONDARY
DECONTAMINATION


SURFACE
CAPPING
                                WASTE TREATMENT
                                  AND DISPOSAL
                 Figure 3.  Gritblasting process flow diagram.
     Once all obstructions have been removed, an abrasive (steel  pellets,
sand, alumina, or glass beads) is spray-applied to the building surface.   The
removed surface material  and abrasive are collected and placed in appropriate
containers for treatment and/or disposal.  The building is then cleaned of
residual  dust by vacuuming and/or waterwashing.  If necessary, secondary
                                     45

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Section 4/Gritblasting (Method 7)
decontamination is performed to remove contaminants  that have  penetrated
building materials beyond the surface layer.

Equipment and Support Facilities Needed—
     Gritblasting equipment requirements include a  blast-gun,  pressure  lines,
abrasive, and an air compressor.  These components  are illustrated in Figure
4.  In addition, a debris/dust collection system, cleanup equipment,  and
personal protective gear are required.

Time Requirements—
     Minimal setup time is required, depending on whether obstructions  must be
removed.

     Personnel time is needed for gritblasting, collection of  debris, trans-
port of debris to a waste management facility, and  cleanup—all  labor-inten-
sive tasks.  Remote control units may decrease labor time, but at the expense
of capital cost.  Approximately 35 m2 can be gritblasted per 8-h day.

     Equipment removal (mainly of blasting equipment) requires minimal  tear-
down time.  Cleanup requires the vacuuming or waterspraying of walls  and  the
collection of all removed material and spent abrasive for transport to a  waste
disposal site.

Safety Requirements

     Potential personnel hazards consist of dust inhalation and dust explosion
(if combustible material is gritblasted).  To minimize these hazards, the area
should be washed down and wet processes should be used.  Personal protective
equipment should include face hoods, respirators, and protective clothing.
See Section 5 for additional worker health and safety requirements.

Waste Disposal

     The mixture of contaminated surface debris and spent abrasive material
can be thermally decontaminated (e.g., by kiln incineration) before disposal.
However, large amounts of  residue still can be expected because the abrasives
normally do not burn.  If  the wastes are not treated to remove contamination,
they may require disposal  as hazardous wastes.  Consult 40 CFR Part 261 and
appropriate EPA guidance for definitions and listings of hazardous waste.   If
the wastes are considered  hazardous, they must be disposed of in a RCRA-per-
mitted facility.

Costs

Structural Damage and Repair Costs--
      In most  cases, minimal structural damage will  result because only the
surface layer  is removed.   Costs for capping the treated surface may be in-
curred.
                                     46

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                                                                     Points to Check
                                                                      1. Large Compressor
                                                                      2. Large Air Hose and Couplings
                                                                      3. Portable High Production
                                                                        Sandblast Machines
                                                                      4. Large Size Sandblast Hose
                                                                        with External Couplings
                                                                      5. Large Orifice Venturi Nozzle
                                                                      6. Remote Control Valves
                                                                      7. Moisture Separators
                                                                      8. High Nozzle Air Pressure
                                                                      9. Proper Sandblasting Abrasive
                                                                     10. Safety Air Fed Helmet
                                                                     11. Training of Operators
               Figure  4.   Equipment components of a  gritblasting system.
Manufacturer's  brochure.

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Section 4/Hydroblasting-Waterwashing (Method  8)
Treatment and Disposal  Costs--
     Costs for utilities and fuel  for  electric air compressors and vacuum
systems will be incurred.  Equipment costs may be moderate, as this method
requires a gritblaster, air compressor,  debris collection system, and dust-
suppression system.   Material  costs for  abrasives should be moderate.  This
method is labor-intensive and  costly as  manhours are required for manual
operation of gritblasting equipment, collection of debris, waste disposal, and
cleanup.  If the waste  material  is considered hazardous, waste disposal costs
will be high.  See Appendix C  for  an analysis of costs associated with the use
of this method.

Future Work

     Experimental effort should  be made  to determine if gritblasting will
detonate residual combustible  wastes on  building surfaces.  Engineering devel-
opment is needed for methods of  collecting dust and treating waste materials
generated during the process to  recover  the  abrasive.

Information Sources

     The bulk of the information in this subsection came from Reference 20.
Use of this method is illustrated  in the case studies presented in Appendices
6, H, and K.
HYDROBLASTING/WATERWASHING (METHOD 8)

General Description

     A high-pressure (3500 to 350,000 kPa)  water jet  is used to remove contam-
inated debris from surfaces.  The debris  and  water  are then collected and
thermally, physically, or chemically decontaminated.  Figure 5 is a schematic
diagram of the hydroblasting process.
            MAKEUP,
            WATER

1
STORAGE
TANK
RECYCLE
WATER
t
t] H

J~\
*y™
WASTE-
WATER
TREATMENT
1GH- \.
ESSURE N^.
ATER X
L
7*
n i UKU-
BLASTER
^<
r
J ^_,^r—
SUMP
^ 	 1 	
                                                                WALL
                                             PUMP
          Figure 5.  Schematic diagram of the hydroblasting  process.
                                      48

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                               Section 4/Hydrobla.sting-Watenjashing (Method 8)
Advantages

     Hydroblasting offers a relatively inexpensive, nonhazardous surface
decontamination technique that uses off-the-shelf equipment.   Hydroblasting
can very easily incorporate variations such as hot or cold water, abrasives,
solvents, surfactants, and varied pressures.  Many manufacturers produce a
wide range of hydroblasting systems and high-pressure pumps.

Disadvantages

     Hydroblasting may not effectively remove contaminants that have pene-
trated the surface layer.  Also, large amounts of contaminated liquids will
have to be collected and treated.

State of the Art

     Hydroblasting has been used to remove explosives from projectiles, to
decontaminate military vehicles, and to decontaminate nuclear facilities.
Hydroblasting also has been employed commercially to clean bridges, buildings,
heavy machinery, highways, ships, metal coatings, railroad cars, heat ex-
changer tubes, reactors, piping, etc.  Off-the-shelf equipment is available
from many manufacturers and distributors.

Variations of Idea

     Remotely operated hydroblasting rigs can be designed and used on walls or
floors.  Surfactants, caustic solutions, or commercial cleaners can be added
to the water to decrease surface tension and increase effectiveness, and
possibly increase the depth of penetration.  Solvents such as acetone can be
used in combination with water or can replace water altogether to solubilize
contaminants.  Sand or other abrasives can be used to increase surface removal
effectiveness (add-on attachments are available from the manufacturers).

Applicability

     At present, hydroblasting is applicable to explosives, heavy metals, and
radioactive contaminants.  The potential exists for applicability to other
contaminants.  This method can be used on contaminated concrete, brick, metal,
and other materials.  It is not applicable to wooden or fiberboard materials.

Effectiveness

     Complete removal of surface contamination is anticipated.  On the aver-
age, hydroblasting removes 0.5 to 1.0 cm of concrete surface at the rate of
35 m2/h.  High pressures and chemical additives can remove contaminants from
below the surface.

     Other methods may be needed to remove or decontaminate any residual
contaminants that have penetrated beyond the surface layer of material.
                                      49

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Section 4/Hydroblasting-Wateruashing (Method 8)
Engineering Considerations

Building Preparation—
     Before decontamination activities begin, existing sumps or water collec-
tion systems are checked for leaks.   Installation of sumps and external  water
storage tanks may be necessary.

Process Description--
     A flow diagram of the hydroblasting process is presented in Figure  6.
High pressure water (3500 to 350,000 kPa) is applied to building or equipment
surfaces.  The removed surface debris and spent water are collected in a sump
and treated to separate the solids.   The water is recycled to storage tanks
where makeup water is added.  Secondary decontamination techniques may be
required to remove subsurface contamination.
                    HYDROBLASTING
   SECONDARY
DECONTAMINATION
                                           DEBRIS
                                       DECONTAMINATION
                                         AND DISPOSAL
                Figure 6.  Hydroblasting process flow diagram.
Equipment and Support Facilities Needed—
     Hydroblasting requires a water-blasting system consisting of high-pres-
sure pump hoses and nozzles, water collection sumps, water storage tanks, and
conventional water pumps.  In addition, protective clothing is required for
workers.

Time Requirements--
     Minimal time is required to inspect an existing sump system or to install
a new one (if necessary), and to set up the hydroblast system.

     Personnel time could be extensive because all surfaces must be treated.
Automated hydroblasting systems will decrease personnel time, but will in-
crease equipment costs.  Decontamination time could be moderate to long de-
pending upon the technique chosen for the decontamination of debris and the
secondary treatments.

     Equipment removal and cleanup times should be low to moderate.  The
collection system will need to be rinsed of debris and all contamination, and
the spent water must be treated.
                                      50

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                               Section 4/Hydroblasting-Watenjas'hing (Method 8)
Safety Requirements

     No process hazards are anticipated.   High-pressure water lines  are a
potential  hazard for workers.   Glasses, gloves, and protective clothing should
be worn by all personnel  to avoid contact with the contaminant.   If  sand,
solvents,  or caustic solutions are added to the water, personal  protection
should be  increased accordingly.   Hearing protection may also be required.
See Section 5 for additional worker health and safety requirements.

Waste Disposal

     The removed surface  debris and spent water are collected in a sump sys-
tem.  Solids are separated by settling, and the liquid portion is recycled.
Solids and spent liquids  may be considered hazardous wastes.   Consult 40 CFR
Part 261 and appropriate  EPA guidance for definitions and listings of hazar-
dous wastes.  If the solids or liquids are considered hazardous, they must be
disposed of in a RCRA-permitted landfill.  Alternatively, the solids may be
treated in a RCRA-permitted incinerator and the liquid pretreated to remove
contaminants prior to discharge to an NPDES-permitted wastewater treatment
facility.   Activated charcoal  alone or in combination with sand may  be used as
the filter media, but it  will  also require treatment or disposal as  a hazar-
dous waste.

Costs

Structural Damage and Repair Costs--
     Water may damage insulation and wooden surfaces.  The treated surface of
some materials may require painting or other refinishing methods.  Repair
costs should be low to moderate.

Treatment and Disposal Costs--
     A hydroblaster can be powered by .gas, electricity, or diesel fuel, thus
costs for utilities and fuel should be moderate.  Equipment costs should be
moderate to high.  Other  material costs to be incurred include those for water
and solvents, surfactants, and abrasives (if added).  Personnel  costs could be
high.  Automated systems  can decrease personnel costs but will increase equip-
ment costs.  Disposal costs will  be moderate to high, depending on the volume
of waste generated and whether or not it is considered hazardous.  See Appen-
dix C for an analysis of costs associated with the use of this method.

Future Work

     More  information and experimental testing are needed for selecting a
treatment  technique to remove small quantities of contaminants from large
quantities of water.  Decontamination and disposal techniques are also needed
for the surface debris.
                                      51

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Section 4/Painting-Coating (Method 9)
Information Sources

     The bulk of the information in this subsection came from References  20,
21, and 25.  Use of this method is illustrated in the case studies  presented
in Appendices G, H, and J.
PAINTING/COATING (METHOD 9)

     Four specific decontamination techniques fall  under the general  heading
of painting/coating:  1) the removal  of old layers  of paint containing  high
levels of toxic metals such as lead,  2) the use of  fixative/stabilizer  paint
coatings, 3) the use of adhesive-backed strippable  coatings, and 4)  the use of
the K-20 sealant.

     The K-20 sealant method of decontamination is  still in the developmental
stages and so is described separately in Method 19.  The other three tech-
niques are discussed here.
LEAD-BASED PAINT REMOVAL (METHOD 9A)

General Description

     In previous years, paints containing high levels of lead were often  used
on the walls of interior building surfaces.   Such paints are still used indus-
trially to coat piping and other metal  structures.   With age, these paints  can
crack and peel, presenting a potential  health hazard to building occupants.
Restoration of Superfund buildings in which  lead-based paints were previously
used may require their removal.

     Paint containing lead in excess of 0.06 percent is removed from building
surfaces by commercially available paint removers and/or physical  means
(scraping, scrubbing, waterwashing).  The removed paint waste is placed in
sealed containers and disposed of appropriately.   Surfaces are then repainted
with new paint having a lead content of no more than 0.06 percent by weight.

     Repainting does not always take place immediately after removal of the
old paint.  Action following paint removal depends  on the projected future  use
of the area and the degree of contamination.  Resurfacing or futher decontam-
ination efforts may be necessary.
                                      52

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                                Section 4/Lead-Based Paint Removal (Method 9A)
Advantages

     This method is simple, and large investments in equipment are not re-
quired.

Disadvantages

     Stripping/painting are labor-intensive operations and cannot be auto-
mated.

State of the Art

     Paint removal and replacement have been used as cleanup techniques in
many buildings (commercial, industrial, residential) containing high-lead-
based and other heavy-metal-based paints, and in buildings contaminated with
radioactive residues.

Variations of Idea

     Other toxic metals such as cadmium, chromium, or mercury were also used
in interior paints.  Similar concern for toxic effects on occupants should  be
considered if such compounds are found inside Superfund buildings that are
being restored for future use.  Buildings found to contain radiation contami-
nation may also require paint removal to eliminate all contamination.

Applicability

     This method can be used on all painted surfaces; it is most useful when
contaminants are on the surface or between layers of paint.

Effectiveness

     Decontamination efforts have indicated that paint removal can result in
reduced ambient air concentrations of lead, cadmium, chromium, mercury, and
radioactive contaminants.

Engineering Considerations

Process Description--
     A controlled area is initially established that surrounds the areas to be
decontaminated, and plastic sheeting is placed beneath the working area.
Peeling paint is then removed from surfaces through a combination of commer-
cial paint removers (such as methylene chloride preparations), hand scraping,
waterwashing, and detergent scrubbing.  This combination of removal methods
should allow all surface areas of a building to be reached and affected.

     Paint wastes accumulate on the plastic ground covering.  When paint
removal is complete, the plastic is rolled up, securely sealed, labeled,
                                      53

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Section 4/Lead-Based Paint Removal (Method 9A)
placed into storage containers, and disposed of appropriately.   Building
surfaces are then repainted in a conventional  manner.

Equipment and Support Facilities Needed--
     Paint removal requires hand-scraping tools, wire  brushes,  paint removers,
water-wash hoses, detergent, plastic sheeting  material, safety  equipment
(coveralls, head covers, goggles, disposable breathing masks),  low-lead paint,
and paint applicators (brushes, rollers).  All equipment needed for paint
removal and replacement is available from commercial manufacturers.

Time Requirements--
     Decontamination time will depend on the total surface area to be treated.
Paint removal will usually take longer than the application of  new paint.

Safety Requirements

     Because of the possibility of exposure to airborne contaminants, a train-
ing program should be conducted and safety equipment (described earlier)
should be used.  Respirators to protect against organic solvents in paint
removers may be necessary.  Biological monitoring methods are available for
lead, cadmium, chromium, and mercury.  See Section 5 for additional worker
health and safety requirements.

Waste Disposal

     Since the wastes generated are known to be contaminated with lead or
other heavy metals, they may be considered hazardous under RCRA.  Consult 40
CFR Part 261 and appropriate EPA guidance for definitions and listings of
hazardous wastes., If the paint wastes are considered  hazardous, they must be
disposed of in a RCRA-permitted facility.

Costs

Structural Damage and Repair Costs--
     Paint removal will not result in large building renovation costs.  Major
costs incurred will be for repainting or resurfacing.

Treatment and Disposal Costs—
     Treatment costs should be moderate and composed primarily of materials
and labor.  Disposal costs will depend on whether or not the residues must be
handled as a hazardous waste.  See Appendix C for an analysis of costs associ-
ated with the use of this method.

Future VJork

     This technique is fairly  straightforward and well developed.  Research
into remotely operated paint removal equipment  is a possibility.
                                      54

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                            Section 4/Fixative-Stabilizer Coatings  (Method 9B)
FIXATIVE/STABILIZER COATINGS (METHOD 9B)

General Description

     Various agents can be used as coatings on contaminated residues to fix or
stabilize the contaminant in place and decrease or eliminate exposure hazards.
Potentially useful stabilizing agents include molten and solid waxes, carbo-
waxes  (polyoxyethylene glycol), organic dyes, epoxy paint films, and polyester
resins.  The stabilized contaminants can be left in place or removed later by
a secondary treatment.  In some cases, the stabilizer/fixative coating is
applied in situ to desensitize a contaminant (such as an explosive residue)
and prevent reaction or ignition during some other phase of the decontamina-
tion process (for example, to prevent explosions during dismantling or demoli-
tion).

Advantages

     The level of contamination to which building occupants are exposed is
reduced.  No hazardous wastes are generated.  Explosion and ignition hazards
are avoided.

Disadvantages

     Toxic contaminants remain on the site; monitoring of the effectiveness of
the barrier coating is required over its lifetime.  Removal at a later date
may be required.

State  of the Art

     Stabilizers are widely used to desensitize combustible contaminants from
detonation by accidental shock and also have been used to reduce radioactive
contaminant levels at nuclear facilities.

Variations of Idea

     Waxes can be dissolved in a volatile organic solvent before application
or loaded with a reactant that will help dissolve and/or decompose contami-
nants  upon contact.  The contaminant-bearing wax can be left in place or
physically removed.

Applicability

     Documented use has been found only for  PCB's, explosives, and radioactive
contaminants, although coatings have the potential to be used against other
types  of hazardous contaminants.  See also Method 19.

     This technique is applicable to all building materials.
                                      55

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Section 4/Fixative-Stabilizer Coatings (Method 9B)
Effectiveness

     No removal of contaminants is achieved; contaminants remain in place in
stabilized, immobilized, or desensitized condition.   The efficiency, as mea-
sured by reductions in ambient air levels, ranges from about 10 percent to a
factor of two- to three-fold, depending on the fixative/stabilizer used.

Engineering Considerations

Process Description--

     Coatings can be applied in several ways:  1) in molten form as fine
particles (<20 ym) in an aqueous solution containing a wetting agent; 2) by
drying and simultaneously coating residues; 3) by dissolving in a solvent,
with the option of evaporating the solvent; and 4) by first soaking the con-
taminant with water and then applying a dye solution.

     Coatings are usually applied in the manner of conventional painting.
After the coating has dried, a secondary treatment may take place (if neces-
sary).  In some cases, a solvent wash can be used after a stabilizer coating
has been applied to remove the desensitized contaminants.

Equipment and Support Facilities Needed--
     An agitation tank for preparation of the mix, and painting equipment for
application of the mix are needed.

Time Requirements--
     Minimal setup time is required.  Personnel time shojld b<; e'qi"i\ alent to
the time required for Method 9A.  Desensitization occurs rapidly; however, the
time required to verify adequate desensitization is not known.  Minimal tear-
down time is required for the removal of application equipment.

Safety Requirements

     Hazards due to solvent flammability and toxicity should be considered.
Proper personal protective equipment is required during applications and will
vary with the type of solvent and contaminant.  See Section 5 for additional
worker health and safety requirements.

Waste Disposal

     Little or no wastes other than used applicators (such as paint brushes or
rollers) are generated.

Costs

Structural Damage and Repair Costs--
     None are anticipated.
                                      56

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                                     Section 4/Strippable  Coatings  (Method 9C)
Treatment and Disposal Costs--
     Treatment costs include those for utilities and fuel,  equipment,  mater-
ials (the cost of stabilizer compounds may be substantial,  depending on the
quantity required), and manpower for the coating application.   Disposal  costs
should be minimal.

Future Work

     Experimental work to determine the degree of immobilization or desensiti-
zation necessary for complete safety is needed.  Also, methods need to be
established to ensure intimate and lasting contact of the stabilizer with the
contaminants of concern.
STRIPPABLE COATINGS (METHOD 9C)

General Description

     Compounds that bind with contaminants are mixed with a polymer, applied
to a contaminated surface, and subsequently removed to achieve decontamina-
tion.

Advantages

     The stripped coating physically holds or traps the contaminant for easier
handling and disposal.

Disadvantages

     The polymer may bind not only to the contaminant, but also to the surface
of the wall or item on which it is applied (strippability depends on its
properties and those of the surface).  In this case, large volumes of wastes
may result, and the building or structural surface may be damaged.

State of the Art

     Polymer coating technology has been studied extensively and used in
decommissioning nuclear facilities.

Variations of Idea

     A chemical reactant could be added to the polymer, which would react with
the contaminant in situ to detoxify it or eliminate its hazardous properties,
thereby circumventing the need for secondary decontamination.
                                      57

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Section 4/Strippable Coatings (Method 9C)
Applicability

     The method should be applicable to all  contaminants  and materials.
Different polymer formulations may be required for various building materials.

Effectiveness

     Ideally, a strippable coating should remove all  the  contaminants it
contacts, especially on smooth surfaces.  There is a  potential  for the coating
not to reach all the contamination on rough  surfaces, especially if it has a
high surface tension or if the polymer molecules are  too  large  to fit in the
surface pores.  Secondary treatment may be needed, depending on how effective
the polymer is in removing the contaminant,  and how deeply the  contaminant has
penetrated the material.  Secondary treatment of metallic surfaces is not
expected.

Engineering Considerations

Building Preparation--
     Paint removal may be needed prior to application of  the coating.

Process Description--
     A polymer mixture is applied to the surface and  allowed to react (poly-
merize) and coat the surface.  As it polymerizes, the contaminant becomes
entrained in the lattice or attached to the polymer molecules.   The polymer
layer is peeled off and the residue is removed with it.  It may be possible,
in some cases, to add chemicals to the mixture to inactivate the contaminants.

     Cleanup requirements involve the removal of the  strippable coating from
all surfaces.

Equipment and Support Facilities Needed—
     The following equipment and support facilities will  be necessary:  tanks
for storage of either the polymer mixture or components of the mixture; spray-
ing, brushing, or other application equipment; and scraping or peeling equip-
ment.  Heating equipment may be needed to initiate the reaction that activates
the polymer.

Time Requirements--
     Setup and personnel time should be equivalent to that required for Method
9A.  Decontamination time will depend on the nature of reactants  in the coat-
ing and the contaminant diffusion rates.  The time required to verify decon-
tamination is not known.  Minimal tear-down time will be needed for equipment
removal.  Cleanup will  require removing the strippable coating for disposal.

Safety Requirements

     The necessary personnel protection and safety requirements will be deter-
mined by the  hazards associated with the contaminant as well as with the
                                      58

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                                           Section 4/Scarification  (Method  10)
polymer.  Personnel should avoid contact with the polymer.   Protective  cloth-
ing, gloves, and eye protection are recommended.   If the monomer  is  hazardous
(e.g., vinyl chloride, solvent-based, etc.), additional  protection such as
respirators will be required.  See Section 5 for  additional  worker health and
safety requirements.

Waste Disposal

     Debris resulting from use of this method may be considered a hazardous
waste.  Consult 40 CFR Part 261 and appropriate EPA guidance for  definitions
and listings of hazardous wastes.  If the waste is considered hazardous, it
must be treated in a RCRA-permitted incinerator or disposed  of in a  RCRA-
permitted landfill.

Costs

Structural Damage and Repair Costs--
     No damage to the building is expected.

Treatment and Disposal Costs--
     Costs for utilities and fuel should be minimal.  Equipment is available
at low cost.  Manpower costs should be similar to those  required  for painting.
If the waste is hazardous under RCRA, the costs for disposal  will be relative-
ly high.

Future Work

     Polymer coating formulations, application and removal techniques,  and
maximization of removal efficiencies need development through experimental
work.

Information Sources

     The bulk of the information in this subsection came from References 20
and 22.  Use of this method is illustrated in the case studies presented in
Appendices D, G, H, and J.
SCARIFICATION  (METHOD  10)

General Description

     This technique is capable of removing up to  2.5  cm  of  surface  layer from
concrete or similar materials.  The scarifier tool  (Scabbier*)  consists of
*
  Macdonald Air Tool  Corp., Hackensack,  New Jersey.
                                      59

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Section 4/Scarification (Method 10)
pneumatically operated piston heads that strike the surface, causing concrete
to chip off.  The piston heads (pictured in Figure 7)  consist of multipoint
tungsten carbide bits.

Advantages

     Scarification can achieve a deeper penetration (removal) than most other
surface removal techniques.  It is suitable for application to both large open
areas and small areas.

Disadvantages

     The treated surface retains a rough appearance that requires resurfacing.
Substantial amounts of contaminated debris (water and  concrete) are generated.
Contaminant-laden dust is also generated.  An explosion potential exists if
pockets of combustible wastes are encountered.  This method is restricted to
use on concrete or concrete-like materials and can only be used in obstruc-
tion-free areas.

State of the Art

     The scarification technique has been used in the  decommissioning of
nuclear facilities and in the cleanup of military arsenals.

Variations of Idea

     Wall, floor, and hand-held scarifiers are available (see Figure 7).  The
units may be modified to include a HEPA-filtered vacuum exhaust system to
capture contaminated dust.

Applicability

     Scarification is potentially applicable to all contaminants except highly
toxic residues  (e.g., asbestos, dioxins) or highly sensitive explosives.

     This method is applicable only to concrete (not concrete block) and
cement.  It is  not suitable for hard-to-reach areas such as behind pipes and
equipment, unless these obstructions can be removed during building prepara-
tion.  Applicability is also dependent on interior building configuration.
Other treatments must be employed for metal, wood, terracotta, etc.

Effectiveness

     Complete removal of contaminants is possible from the surface layer.
Drilling and spalling or other techniques may be required as a secondary
decontamination treatment procedure for contaminants that have penetrated the
surface deeper  than 2.5 cm.
                                      60

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       Piston heads
                          Floor model
Source:  Reference 21.
          Wall model



Figure 7.  Scarifier tools.





              61

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Section 4/Scarification (Method 10)
Engineering Considerations

Building Preparation--
     Pipes and other equipment are removed where possible to present an ob-
struction-free area to the scarifier tool.

Process Description--
     Figure 8 presents a flow diagram of the scarification method.   Obstruc-
tions to the scarifier tool are removed during building preparation.  The
pneumatic scarifier is then used to chip the surface away with its  tungsten
carbide bits.  Water is used to keep dust down.

     The removed contaminated debris must be collected with a vacuum or some
other system and packaged for either treatment (by incineration or  other tech-
nique) or disposal.  A secondary decontamination treatment can then be used to
remove any remaining contaminants that have penetrated deep into the concrete
(more than 2.5 cm).

     Several variations to the main process are possible.  Floor and wall
models can be fitted with dust collection systems, hand-held models can be
developed for corners or other hard-to-reach areas, and remotely operated
scarifier rigs can be used.
  OBSTRUCTION
    REMOVAL
SCARIFICATION
   SECONDARY
DECONTAMINATION
                               WASTE TREATMENT
                                 AND DISPOSAL
                Figure 8.  Scarification process flow diagram.
Equipment and Support Facilities Needed—
     A scarifier unit requires a pressurized air source.  A portable generator
and air compressors are necessary to furnish the supply of compressed air.  A
debris collection/packaging system is also needed.  The tungsten-carbide bits
have an average working life of 80 h under normal conditions.

Time Requirements—
     Minimal setup time is required unless obstructions (pipes or other equip-
ment) require removal.

     Manhour requirements will be high because removing the surface layer is
quite time-consuming, depending on the size of the building and the amount of
equipment/obstructions.  A remote-control unit may decrease labor time, but
                                      62

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                                           Section 4/Scarification (Method 10)
also may be quite costly unless large open surface areas are present.   Decon-
tamination time is probably long because large amounts of material  will  have
to be processed.  Actual experiences have shown that a seven-piston floor
scarifier can remove approximately 30 m2 of surface material per hour  and a
three-piston wall scarifier can remove 7 to 10 m2 of surface material  per
hour.

     Equipment removal requires minimal  tear-down time.  Cleanup requires
considerable time to remove all debris.

Safety Requirements

     Personnel hazards may result from high noise levels.  Contaminant-laden
dust and flying chips could be hazardous.  Vibration injury can occur  if the
vibrating device is hand-held.

     Protective clothing, dust respirators, eye protection, and ear protection
should be worn.  A dust-suppression system such as periodic washdown with
water is recommended.  See Section 5 for additional worker health and  safety
requirements.

Waste Disposal

     Contaminanted debris may be considered hazardous.  Consult 40 CFR Part
261 and appropriate EPA guidance for definitions and listings of hazardous
wastes.  If the waste is considered hazardous, it must be disposed of  in a
RCRA-permitted facility.

Costs

Structural Damage and Repair Costs—
     Scarification leaves a very coarse surface, which may have to be  capped
with concrete or covered with other materials.  Repair costs should be moder-
ate.

Treatment and Disposal Costs—
     Costs for utilities and fuel should be low to moderate for the use of
electricity for portable power generation.  Equipment costs for a scarifier,
tungsten-carbide replacement bits, and an air compressor should be moderate to
high.  Manpower costs will probably be high because the removal rate is quite
slow.  Disposal costs should be moderate to high, depending on whether or not
the wastes are considered hazardous.

Information Sources

     The bulk of the information in this subsection came from References 20
and 21.  Use of this method is illustrated in the case studies presented in
Appendices G and H.
                                      63

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Section 4/RadKleen (Method 11)
 RADKLEEN  (METHOD  11)

General Description

     Fluorocarbon extraction of contaminants from building  materials  involves
the pressure-spraying of a fluorocarbon solvent onto the  contaminated surface
followed by collection and purification of the solvent.   RadKleen* is an
example of a commercial process that uses Freon 113 (l,l,2-trichloro-l,2,2-tri-
fluoroethane or C2F3C13) as the solvent.

Advantages

     Freon 113 is a stable, nonpolar, noncombustible organic solvent  suitable
for extracting many organic compounds.   The compound's low  surface tension
permits rapid wetting of surfaces, and its low viscosity  permits  easy particu-
late separation.   Because Freon 113 is a  volatile liquid  at normal  room tem-
peratures, it can be recovered and reclaimed if used in a closed  system.

Disadvantages

     Secondary treatment is required to treat the used Freon containing the
solubilized contaminant.  Also, diffusion rates may  limit the rate of applica-
tion.

State of the Art

     The RadKleen process is currently used for cleaning  radioactive  material
from various surfaces.  It has been applied to chemical agents on small objects,
and thus field capability has been demonstrated.  Studies have been conducted
for agent-contaminated clothing materials, such as polyester-cotton,  Nomex,
butyl rubber gloves, and charcoal-impregnated cloth.  This  method has not been
demonstrated for removing contaminants from building surfaces, but it looks
very promising.

Variations of Idea

     Variations include a system that uses an additive to simultaneously
extract and decompose the contaminant, and a system  that  automatically recy-
cles the used solvent through a reactive  bed (e.g.,  activated carbon) for
removal of contaminants.  Also, the solvent is sometimes  heated and applied  in
the vapor phase to enhance permeability (see Method  14).

Applicability

     Because of its solvent properties, Freon 113 may be  applicable to many
organic contaminants found at Superfund sites.  This system has the potential
*
  Health Physics Systems, Inc., Gainesville, Florida.
                                       64

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                                                Section 4/KadKleen (Method 11)
for use on many types of building materials:   metal, concrete, tile, brick,
etc.; painted and unpainted surfaces.   Because Freon 113 is electrically
nonconductive and compatible with electrical  and electronic components, it may
be possible to use it to decontaminate operating electronic equipment.

Effectiveness

     RadKleen should provide complete  removal of Freon 113-soluble contami-
nants from surfaces.  It should be especially effective in the removal  of
organics and particulates from surfaces, and should penetrate readily into
porous materials.

Engineering Considerations

Building Preparation—
     The area to be treated is enclosed to facilitate recovery of the solvent
and to limit exposures outside the treatment area.  Installation of a sump or
other collection system for the liquid may also be required.

Process Description—
     The solvent (Freon 113) is sprayed under pressure (1400 to 150,000 kPa)
for surface cleaning.  The solvent removes the contaminating material and is
collected, filtered, and distilled for reuse.  Washdown or heat may be re-
quired to clean and remove all final traces of Freon.

     There are several variations of the process.  The solvent may be applied
to equipment in a vapor phase at atmospheric pressure to enhance permeability.
A reactant may be added to the Freon to allow simultaneous extraction/decompo-
sition of the contaminant.

Equipment and Support Facilities Needed--
     Fluorocarbon extraction requires  a pump, spray system, collection tank,
filters, distillation column, enclosure, and electricity.

Time Requirements--
     Moderate time may be required to set up and seal the building to prevent
release of vapors.

     Personnel time is required to apply the spray; however, the method is
potentially semiautomatic.  Decontamination time for removal of contaminants
from surfaces is expected to be quite fast.

     Minimal tear-down time is needed to remove the enclosure from the build-
ings.  Equipment removal and cleanup require minimal time.

Safety Requirements

     Precaution should be taken when working with high-pressure fluids.
Personnel hazards from the inhalation of Freon 113 vapors must be avoided.
                                       65

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Section 4/RadKleen (Method 11)
The NIOSH/OSHA permissible exposure limit in the workplace environment is 1000
ppm Freon 113.  Monitoring and respiratory protection may be required for
personnel inside the enclosure.  See Section 5 for additional worker health
and safety requirements.

     Freon 113 should not be used in the presence of chemically active metals
such as calcium, powdered aluminum, magnesium or beryllium; contact with
alloys containing more than 2 percent magnesium results in decomposition.

Waste Disposal

     Used solvent will contain contamination and should be treated and recy-
cled wherever possible.  Distillation and filtration residues from solvent
recycle operations may be considered hazardous wastes.  Consult 40 CFR Part
261 and appropriate EPA guidance for definitions and listings of hazardous
waste.  If the residues are considered hazardous, they must be disposed of in
a RCRA-permitted facility.

Costs

Structural Damage and Repair Costs—
     There should be little or no structural damage or building repair costs.

Treatment and Disposal Costs—
     Costs for utilities and fuel should be minimal.  Equipment costs should
be moderate to provide for recycling of the solvent.  Material costs should be
low because the used solvent can be recycled.  Personnel costs may be substan-
tial, depending on how much automation is possible.  Disposal costs should be
moderate to high, depending on whether or not the wastes are considered hazar-
dous.

Future Work

     Three areas require further definition.  First, studies are needed to
establish the effectiveness of removal of contaminants from walls and other
building materials.  Second, the solubility of contaminants in Freon 113 and
other fluorocarbon solvents likely to be found at Superfund sites should be
studied.  Third, the recycle system needs further engineering development.

Information Sources

     The bulk of the information in this subsection came from Reference 20.
                                       66

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                                         Section 4/Solvent  Washing  (Method  12)
SOLVENT WASHING (METHOD 12)

General Description

     An organic solvent is circulated  across the surface  of  a  building  to
solubilize contaminants.  A schematic  diagram of the solvent circulation
apparatus is presented in Figure 9.   Spent solvent is either thermally  or
chemically treated to remove contaminants and recycled if no degradation of
the solvent occurs during treatment.

Advantages

     Removal of contaminated paint is  possible if the proper solvent  is se-
lected.  Depending on the solvent-contaminant match, this can  be  a  very effi-
cient removal system.

Disadvantages

     This method is not suitable for intricate structures.   Penetration of the
solvent into the material matrix, followed by outward diffusion,  may  require a
long time.  Residual solvent in building materials may require removal  and/or
decomposition.  The solvent may tend to carry contaminants  farther  into the
wall before outward movement occurs.

State of the Art

     The hot solvent soaking process has been shown to be effective in  decon-
tamination of PCB-contaminated transformers.  This technique has  not  yet
achieved widespread use in building decontamination, although  it  is beginning
to be used in the decommissioning of nuclear facilities.   The  method  needs
further development in application, recovery, collection, and  efficiency.

Variations of Idea

     With a Stanley Steamer configuration, a chemical can be added  to the
solvent to decontaminate residues.  After solvent application, a  vacuum may  be
applied to remove the solvent and the  contaminants.  A hot solvent  soaking
process in which contaminated pieces of equipment are filled with a solvent  is
also possible.  Solvent may be applied to buildings in the vapor  phase  (see
Method 14).

Applicability

     This, method has potential application to a wide range of  contaminants,
depending on the solvent used.  It should also be applicable to most  all
building materials.
                                      67

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             WALL
            SOLVENT
          CIRCULATION
             UNIT
      FILTER
      PUMP
                SOLVENT
               FEED TANK
  FILTER, CHEMICAL
DECONTAMINATION, ETC.
Figure 9.  Schematic diagram of the solvent circulation apparatus.
                                68

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                                         Section 4/Solvent Washing (Method 12)
Effectiveness

     If the proper solvent is selected, it should extract most,  if not all,  of
the contaminants it contacts on structural surfaces.   The primary difficulty
is to achieve an inward flux of neat solvent into porous building materials
followed by (or concurrent with) an outward flux of solvent contaminated with
residues.  It is unknown whether this may be accomplished within a realistic
period of time; however, the use of a gaseous (i.e.,  vaporized)  solvent may
enhance diffusion into and out of building materials.

     This technique probably will require more than one application of sol-
vent.

Engineering Considerations

Building Preparation--
     All obstructions to the solvent circulation apparatus are removed during
building preparation.

Process Description--
     Solvent is introduced into a box placed against  a wall.   The side of the
box facing the wall is open with all edges sealed.  The solvent  is allowed to
circulate and penetrate (wet) the surface to dissolve and remove the contami-
nant.  The contaminated solvent is collected at the bottom of the box, passed
through a filter or packed carbon bed, and recycled.

     It may be extremely difficult to get a tight seal around the solvent
circulation apparatus and surface, especially around  uneven areas and in
hard-to-reach places.  This method is only suitable for large open areas of
buildings.

     Multiple solvent washes and/or some type of secondary treatment may be
needed for total removal of the contaminants.  Water-wash after  decontamina-
tion may be necessary to remove the solvent contained in porous  materials.
Alternatively, heating may be used to volatilize any  residual solvent.

Equipment and Support Facilities Needed--
     Solvent washing requires a solvent pump, circulation box, collection
tank, and recovery system (e.g., filter, neutralizer,  distillation column).
It may require a condenser if the solvent is vaporized during processing.

Time Requirements—
     This method will probably require extensive setup time,  depending on
obstructions that require removal, the size and configuration of equipment
used, and the number of applications required.

     Personnel time will probably be low to moderate  because  of  extensive
involvement in setup and tear-down, although solvent  washing  is  a passive
                                      69

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Section 4/Solvent Washing (Method 12)
process (only monitors are required during decontamination).   Decontamination
time is dependent on diffusion and the number of applications required;  it
could require hours or days.

     Equipment removal and tear-down time depends on the size and configura-
tion of equipment.

Safety Requirements

     Process hazards consist of explosion or fire hazards from flammable
solvents.  Personnel hazards depend on the toxicity of the solvent as well as
the contaminant.  If a volatile flammable solvent is used, explosion-proof
equipment and ambient air concentration monitors will be required.  Personnel
must wear protective clothing and possibly respirators.  See  Section 5 for
additional worker health and safety requirements.

Waste Disposal

     The spent solvent and filter residue from the solvent recovey system may
be considered hazardous wastes.  Consult 40 CFR Part 261 and  appropriate EPA
guidance for definitions and listings of hazardous wastes.  If the wastes are
considered hazardous, they must be disposed of in a RCRA-permitted facility.

Costs

Structural Damage and Repair Costs--
     No structural damage or repair costs are anticipated.

Treatment and Disposal Costs--
     Costs for utilities and fuel should be low.  Some electricity and possi-
bly steam will be required.  Equipment costs should be moderate to high,
depending on the complexity of the solvent recovery system.  Moderate to high
material costs  (solvent) can be expected, depending on the feasibility of
recovery.  Manpower costs will depend on the operating personnel needed to
move the equipment during decontamination as well as for setup and tear-down,
which may be extensive.  Disposal costs should be moderate to high, depending
on whether the wastes are considered hazardous.

Future Work

     Specification and design of equipment and process parameters, and solvent
selection guidelines are needed.

Information Sources

     The bulk of the information in this subsection came from References  20
and 26.
                                      70

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                                          Section  4/Steam  Cleaning  (Method  15)
STEAM CLEANING (METHOD 13)

General Description

     Steam cleaning physically extracts contaminants  from  building materials
and equipment surfaces.   The steam is applied by hand-held wands  or  automated
systems, and the condensate is collected for treatment.  Figure  10 shows  a
vehicle being decontaminated by steam cleaning.

Advantages

     Steam cleaning is a relatively  inexpensive  and simple technique.   Depend-
ing on the contaminant,  thermal decomposition and/or  hydrolysis may  occur.

Disadvantages

     This technique is known to be effective only for surface  decontamination.
Steam cleaning is a labor-intensive  process that is costly if  automated.
Probably only mechanical removal  of  contaminants actually  takes  place  because
of the limited solubility of many residues in water.   Large volumes  of contam-
inated water are generated (although these volumes are less than  those gener-
ated by the hydroblasting/waterwashing method).

State of the Art

     Steam cleaning is the state-of-the-art technique for  removing contami-
nated soil particles from earth moving and drilling equipment.   It is  also
used by explosives handling and manufacturing facilities to remove contam-
inants from walls, floors, and equipment.  Several manufacturers  make  portable
steam cleaning equipment.

Variations of Idea

     Variations of the process include generating steam in the form  of a
water/acetone mixture to enhance contaminant solubility, mixing  a wetting
agent with the steam, superheating the steam, or using steam-jet  systems  for
high fuel efficiency.  Steam can also be externally generated  and used to
flood an entire building.

Applicability

     Currently, steam cleaning is used mainly to remove contaminated particu-
lates and explosive residues; however, an industrial  contact indicated that
tetryl may detonate in the presence  of steam.  Laboratory  testing has  shown
steam cleaning to be effective against some chemical  warfare agents.  These
agents are similar in structure to pesticides (especially  organophosphates).
Steam cleaning is applicable to a wide variety of contaminants and structural
materials.


                                      71

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Figure 10.   Steam cleaning of a vehicle.

-------
                                          Section 4/Stecm Cleaning (Method 12)
Effectiveness

     Removal or reaction of contaminants from the surface should be very good
because steam can physically remove the contaminants from the surface.   Remo-
val or reaction of contaminants from the subsurface is probably poor as many
contaminants have low solubilities in water.  Theoretically, steam can  be used
to remove contaminants from the subsurface if steaming is continued for a long
period of time, but this has not been demonstrated.  Paint may act as a bar-
rier.

Engineering Considerations

Building Preparation--
     Building preparation may require setup of piping ductwork from the sump
to exterior holding tanks.  Plastic sheeting and other moisture barriers may
be needed to protect uncontaminated portions of the s-tructure from water
damage.  Paint removal may also be required unless a suitable water/solvent
system is employed.

     If earth-moving and drilling equipment are to be steam cleaned, plastic
sheeting should be spread on the ground under the contaminated equipment, and
containment barriers should be constructed to allow for collection of the
condensate.

Process Description—
     Figure 11 presents a flow diagram of the steps involved in the steam
cleaning method of decontamination.
EQUIPMENT
SETUP


STEAM
CLEANING


CONDENSATE
COLLECTION


WASTE TREAMENT
AND DISPOSAL
              Figure 11.  Steam cleaning process flow diagram.
     The steam is generated with oil-, gas-, or electric-fired steam genera-
tors, and it is applied to building and equipment surfaces by a hand-held wand
or an automated system.  Figure 12 is a photograph of a steam generator.  The
condensate, which contains the removed contaminants, is collected and treated
to remove and destroy the waste residues.

Equipment and Support Facilities Needed--
     Steam cleaning requires steam generators, spray systems, collection
sumps, and waste treatment systems.  Commercial-scale steam cleaners are
available from many manufacturers.
                                      73

-------
Figure 12.   Photograph  of a  steam  generator.

-------
                                          Section 4/Steam Cleaning (Method 15)
Time Requirements--
     Minimal setup time is required, but different collection systems may have
to be designed if floor sumps are inadequate.   Existing sumps will  need to be
checked for leaks.  A pumping system may be set up to remove condensate con-
tinuously.

     Personnel time for steam application to equipment is low; personnel time
for steam application to buildings may be extensive, depending on the size and
complexity of the structure and the effectiveness of the steam in removing the
contaminant.  Automated steam wands can reduce personnel time for decontamina-
tion of large buildings.

     Equipment removal requires minimal time.   Cleanup may require a water
rinse of the building interior or equipment surface.  Condensate will need to
be rinsed from sumps and collection systems and treated.

Safety Requirements

     Potential personnel hazards include steam burns and solvent/steam mix-
tures that may be toxic.  Respiratory protection may be required if a steam/
acetone or other steam/solvent mixture is used.  Protective clothing (includ-
ing boots) is recommended in all cases.  Additional protection depends on the
level and nature of the contaminant.  See Section 5 for additional  workers
health and safety requirements.

Waste Disposal

     The contaminated wastewater collected in the sump or containment area
must be treated to remove or destroy any waste residues.  (An exception to
this requirement was made in Times Beach, Missouri, where the contaminated
soil will eventually be excavated.)  Pretreatment on site or in a municipal
wastewater treatment facility will be needed.   Treatment residues may be
considered hazardous waste.  Consult 40'CFR Part 261 and appropriate EPA
guidance for definitions and listings of hazardous waste.  If the treatment
residue is considered hazardous, it must be disposed of in a RCRA-permitted
facility.

Costs

Structural Damage and Repair Costs--
     These should be minimal.

Treatment and Disposal Costs--
     Costs for utilities and fuel should be low because steam is relatively
inexpensive to generate.  Equipment costs include steam cleaners (which cost
$2000 to $5000), spray systems, collection sumps, and waste treatment systems.
Material costs may include additives, such as surfactants or acetone.  Man-
power costs may be high because steam must be applied to all surfaces and
                                      75

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Section 4/Vapor-Phase  Solvent  Extraction  (Method 14)	

because more than one  application may be  necessary.  Automated steam wands can
reduce labor costs,  but they increase equipment costs.  Waste disposal  costs
should be moderate to  high, depending on  whether or not the waste is consi-
dered hazardous.   See  Appendix C for an analysis of costs associated with the
use of this method.

Future Work

     The degree to which various contaminants can be removed from equipment
surfaces and building  materials (especially porous materials such as concrete)
must be determined.  Techniques for treatment of contaminated condensate are
needed.  Additives and/or co-solvents should be evaluated for their useful-
ness.

Information Sources

     The bulk of the information in this  subsection came from References 20
and 21.  Use of this method is illustrated in the case study presented in
Appendix F.
VAPOR-PHASE SOLVENT EXTRACTION (METHOD 14)

General Description

     An organic solvent with a  relatively  low boiling point (such as acetone)
is heated to vaporization and allowed  to circulate in a building.  The vapors
permeate into porous building materials, where they condense, solubilize
contaminants, and diffuse outward.   The contaminant-laden liquid solvent is
collected in a sump and treated to  allow recycling of the solvent.  Figure 13
is a schematic diagram of the process.
                                                      CONTAMINANT
   MAKEUP
  SOLVENT"
VENT-/*.
LER U
t
STOF
H "
	 ^
>


BUILDING

\ CONDENSATE 	 T^1"!
SUMP 1 	 *.
IAGE
INK
.
. t
f| SOLVENT 	
=C~^ I TREATMENT j=
s^-4.
PUMP ' '

RECYCLE SOLVENT

•sJ
PUMP

 Figure 13.  Schematic diagram of the vapor-phase solvent extraction process.
                                     76

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	Section 4/Vapor-Phase Solvent Extraation (Method 14)

Advantages

     This method is well suited to all areas of a building, including intri-
cate structures.  Solvent permeability and diffusibility are enhanced by the
solvent being in the vapor phase.  Removal of contaminated paint is possible
if the proper solvent is selected.  Depending on the solvent-contaminant
match, this may be a very efficient removal system because of the enhanced
solubility of contaminants in heated solvent.

Disadvantages

     Outward diffusion of solvent laden with contaminants may require long
treatment times.  The solvent may tend to carry residues deeper into the wall
before outward movement occurs.

State of the Art

     Although this technique has not yet been applied to building decontamina-
tion, an ethanol/Freon mixture (volatilized in a manner similar to that de-
scribed here) has been used as a degreasing treatment.

Variations of Idea

     Laboratory testing has indicated that beta-propiolactone (BPL) may be an
effective vapor-phase agent for the treatment of biologically contaminated
enclosed areas.  Its effectiveness thus far has been limited to bacterial
spores, vegetative cells, viruses, and rickettsiae.

     It may be feasible to use supplemental heating  (e.g., microwaves) to
maintain solvent at the boiling point in the building materials, thereby
enhancing solubility of the contaminant.

Applicability

     Depending on the choice of solvent, this method has potential for many
contaminants of interest and a wide range of building materials.

Effectiveness

     If the proper solvent is used, it should remove most or all surface
contamination.  The primary difficulty is achieving  an outward flux of contam-
inated solvents from porous building materials.  Whether this can be accom-
plished within a realistic period of time is not known.  A secondary decontam-
ination treatment may be necessary to remove any residual contaminants not
removed by the solvent.
                                     77

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Section 4/Vapor-Phase Solvent Extraction (Method 14)
Engineering Considerations

Building Preparation--
     Buildings are sealed to prevent undue release of solvent vapors.  Windows
may have to be insulated.  Pipes and tanks are opened to allow penetration of
solvent vapors.  Adequate air circulation during the process should be en-
sured.

Process Description—
     Figure 14 presents a flow diagram of the vapor-phase solvent extraction
procedure.
EQUIPMENT
SETUP

^

VAPORIZED
SOLVENT
APPLICATION




CONDENSATE
COLLECTION
i
i


WASTE TREATMENT
AND DISPOSAL

SECONDARY
DECONTAMINATION

       Figure 14.  Vapor-phase solvent extraction process flow diagram.


     The solvent is vaporized in a boiler external to the building.  The
vapors enter the building through a series of insulated pipes and vents.  The
solvent permeates through the building, condensing as it cools below the
boiling point.  The contaminant-laden liquid solvent is collected in a sump,
from which it is pumped to a waste treatment system, where the contaminants
are removed.  The solvent is then recycled to the boiler.  Cleanup entails
washing the walls with water or heating to volatilize the residual solvent.

Equipment and Support Facilities Needed--
     Pumps, a solvent boiler, and a waste treatment system are needed for this
method.

Time Requirements—
     Low to moderate setup time is needed for the boiler, ductwork, etc.
Personnel time will probably be low to moderate, mainly for setup and tear-
down.  This method is basically a passive process (only monitors are required
during decontamination).  Decontamination time depends on the rate of diffu-
sion and the number of applications required (hours to days).  Equipment
removal requires low to moderate tear-down time.  Cleanup time should be low.
                                      78

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	Section 4/Vapor-Phase Solvent Extraction (Method 14)

Safety Requirements

     Process hazards consist of explosion or fire hazards from flammable
solvents.  The toxicity of the solvents may present a personnel hazard.  If a
flammable solvent is used, explosion-proof equipment is required.  Personnel
must wear protective clothing.  Adequate air circulation is needed while
personnel are in the treated area.  Depending on the solvent, respirators may
be necessary.  See Section 5 for additional worker health and safety require-
ments.

Waste Disposal

     Spent solvent waste from the treatment process may be considered hazar-
dous.  Consult 40 CFR Part 261 and appropriate EPA guidance for definitions
and listings of hazardous wastes.  If the wastes are considered hazardous,
they must be treated or disposed of in a RCRA-permitted facility.

Costs

Structural Damage and Repair Costs--
     No damage or repair costs are expected.

Treatment and Disposal Costs—
     Costs for utilities and fuel should be low to moderate for boiler fuel
and pumps.  Equipment costs should be low to moderate for the boiler, duct-
work, and pumps, depending on the complexity of the solvent recovery/recycle
system.  Material costs may be moderate to high, depending on the recovery
system (i.e., a high cost if solvent cannot be recovered and recycled).
Manpower costs should be low to moderate for equipment setup and tear-down,
monitoring the boiler, etc., during decontamination.  Disposal costs may be
moderate to high, depending on whether or not the wastes are considered hazar-
dous.

Future Work

     Equipment specifications and process designations (application, recovery,
collection, efficiency, solvent selection, temperature, and time) must be
made.  Experimental testing for this will be required.

Information Sources
     The bulk of the information in this subsection came from Reference 20.
                                      79

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Section 4/Ac-id Etching (Method 15)
ACID ETCHING  (METHOD 15)

General Description

     Acid is applied to a contaminated surface to promote  corrosion  and  remo-
val of the surface layer.  The resulting debris is then neutralized  and  dis-
posed of.  Thermal or chemical treatment of the removed material  may be  re-
quired to destroy the contaminant before disposal.  Figure 15  is  a schematic
diagram of a typical acid etching system.
                 ACID
              RESERVOIR
            RECYCLE
             ACID
                                                                  WALL
                   PUMP

          Figure 15.  Schematic diagram of the acid etching  process.
Advantages

     Acid etching may cause decomposition of the contaminant  as  it  is  removed
from the surface.

Disadvantages

     This technique is hazardous and requires special  application equipment.
Primarily applicable to metals that will  readily corrode,  this technique
requires a large volume of acid.

State of the Art

     The effect of acids on various materials is well-established.   Muriatic
acid (hydrochloric acid) is used to remove dirt and grime  from brick building
surfaces in urban areas and to clean metal parts (e.g.,  pickle liquors  from
metal finishing operations).  Hydrofluoric acid is also  commonly used  to  etch
window glass.  This technique is not known to have been  applied  to  chemically
contaminated building surfaces.
                                     80

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                                            Section 4/Acid Etching  (Method 15)
Variations of Idea

     Acid can be applied as a mixture in steam, or it can be sprayed or
brushed on at ambient or elevated temperatures.  It can also be applied as  a
gas (e.g., HC1 gas).

Applicability

     This method may be applicable to many contaminants.  It is applicable
primarily to mild steel and wood surfaces; it may be ineffective on other
surfaces, such as concrete.  Acid etching is only a surface treatment;  it is
not effective on subsurface contaminantion of building materials.

Effectiveness

     This technique removes contaminants from metal surfaces (e.g., light
steel) and wood very effectively and completely.  It may also be effective  on
concrete, brick structures, and some plastic materials.  Secondary methods
(physical, chemical, and/or thermal) may be required to decontaminate or
remove contaminants that have penetrated the surface layer through cracks and
pores.

Engineering Considerations

Building Preparation--
     Corrosion-resistant paint is removed from equipment and pipes prior to
application of the acid.

Process  Description--
     Acid is spray-applied to the surface and allowed to induce corrosion.
The surface is then neutralized and washed with water to remove residual oxide
coatings.  A secondary decontamination treatment may be required to further
remove contaminants from concrete, brick, etc.

Equipment and Support  Facilities Needed--
     Acid etching requires spraying equipment and a pump, water spraying
equipment (hose), an acid source, an acid neutralizer, and a steam source
(optional).  Available equipment may not be corrosion-resistant; thus, consid-
erable maintenance and periodic replacement will be required.

Time Requirements--
     Setup time for paint removal may be required before treatment.  Personnel
time is  required only  for spraying and cleanup.  The process may be time
consuming if all surfaces are treated and if repeated applications are re-
quired.  Decontamination time may be long because of the slow reaction rate.
Equipment removal and  tear-down time should not take very long, but cleanup
could be lengthy.  All the acid must be completely washed off the equipment to
avoid further corrosion.
                                      81

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Section 4/Acid Etching (Method 15)
Safety Requirements

     Acid skin burns and inhalation of toxic fumes are potential  personnel
hazards.  Personnel protection requires rubber suits, boots, and gloves, and
eye and respiratory protection.   A safety shower and emergency eyewash should
be readily available.   See Section 5 for additional  worker health and safety
requirements.

Waste Disposal

     Waste treatment and disposal  may be necessary.   Insoluble metal  oxides
and salts require treatment such as filtration.   Large amounts of soluble
salts must be concentrated before they can be disposed of in a chemical  land-
fill.  Low concentrations of some salts (NaCl or NajSOiJ  can be placed in a
city sewer.  Decomposed wood can either be incinerated or landfilled.

Costs

Structural Damage and Repair Costs--
     This method may weaken structural members,  depending on their design,
initial thickness, material of construction, and the number of applications of
acid.  Metal parts will be damaged, and wood may need replacement.  Concrete,
however, will probably be undamaged.  Repair costs should be moderate to high.

Treatment and Disposal Costs--
     Costs for utilities and fuel, primarily to  power the spraying pump,
should be low.  Costs for corrosion-resistant equipment should be moderate  to
high.  The kilogram material cost should be low, but a large quantity will  be
required.  Manpower costs, which represent application and cleanup time,
should be moderate to high.  Waste disposal costs should  be moderate.  See
Appendix C for an analysis of costs associated with  the use of this method.

Future Work

     The effectiveness of acid removal of contaminants must be established,
and any necessary secondary decontamination treatments must be stipulated.
Experimental testing for this will be required.

Information Sources

     The bulk of the information in this subsection  came  from Reference  20.
                                     82

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                                              Section 4/Bleaching  (Method 16)
BLEACHING (METHOD 16)

General Description

     Bleach formulations are applied to  a  contaminated  surface, allowed to
react with contaminants, and removed.  Application  usually occurs in conjunc-
tion with other decontamination efforts, such  as  the  use of absorbents and/or
waterwashing.

Advantages

     Bleach is an effective decontaminating  agent when  used against metal
surfaces.

Disadvantages

     Solid bleach formulations are generally applied  as a slurry, which can
result in periodic clogging of application equipment.   Depending on concentra-
tion and composition, bleach slurries  may  cause corrosion of application
equipment and/or the surfaces being treated.

State of the Art

     Bleach has been used as a decontaminant against  mustard, G and V chemical
agents, and (experimentally) organophosphorous pesticides.

Variations of Idea

     Various types of bleach formulations  have been used as decontaminating
agents.  Traditionally, calcium hypochlorite has  been used, although recently
sodium-based bleach formulations have  had  some application.  The various
bleaches used include Grades I, II, and  III, with >35 percent, 29 to 35 per-
cent, and <29 percent available chlorine,  respectively; STB (supertropical
bleach), a British formula containing  >30  percent available chlorine; HTB
(High Test Bleach), which has approximately  42 percent  chlorine content; and
liquid household bleach (sodium hypochlorite and  sodium hydroxide).

Applicability

     Bleach is most effective against  chemical agents and liquid pesticide
spills.  Bleach has been used on metal,  wood,  and concrete surfaces, but it is
most effective against metal.
                                      83

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Section 4/Bleaching (Method 16)
Effectiveness

     Bleach formulations chemically degrade and detoxify many contaminants,
especially pesticides.  Chemical degradation rates can be affected by other
pre- or post-bleach decontamination efforts.

     Bleach formulations are normally used in conjunction with other decontam-
ination techniques, most often as a followup for detoxifying pesticides on
surfaces where a physical procedure did not produce satisfactory results
(e.g., safe ambient contaminant levels).

Engineering Considerations

Process Description—
     The bleach solution is added in generous amounts to the contaminated
surface.  The surface is scrubbed for 15 to 60 s, allowed to stand for about
15 min, and then flushed thoroughly with water.  The bleach application and
wash can be repeated a second time if necessary.

Equipment and Support Facilities Needed—
     Bleach application and waterwashing equipment (hoses, scrubbers, contain-
ers), waste recovery system, and safety equipment are needed.  Most equipment
is readily available from commercial manufacturers and chemical companies.

Time Requirements—
     Decontamination time is low.  Although bleach application and chemical
detoxification should proceed rather rapidly, contaminated surfaces should be
allowed drying time (approximately 5 h).

Safety Requirements

     Basic safety requirements  that are used when working with chemical agents
and pesticides should be adhered to.  At a minimum, workers should go through
a training program and be equipped with glasses, full-body protective cover-
alls,  impermeable gloves, and foot cover.  Additional safety equipment depends
on the toxicity of contaminants.  See Section 5 for additional worker health
and safety requirements.

Waste  Disposal

     Because application of bleach slurries is usually performed in conjunc-
tion with waterwashing, hazardous sludges and liquids may result.  A con-
trolled area should be set up so that all waste slurries and liquids can be
collected  in a sump or other recovery system.  The waste materials can then be
properly disposed of.  Consult  40 CFR Part 261 and appropriate EPA guidance
for definitions and listings of hazardous waste.  If the wastes are considered
hazardous, they must  be disposed of in a RCRA-permitted facility.
                                      84

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                                                 Section 4/Fleming (Method 17)
Costs

Structural Damage and Repair Costs—
     Building damage depends on the surface material,  contaminants,  and  sup-
plementary decontamination efforts.  Repair costs should be low to moderate.

Treatment and Disposal Costs--
     Treatment and disposal costs should be moderate.   Bleach  supplies,  appli-
cation equipment, and recovery system will  constitute  most of  the costs.
Labor costs should be low.  See Appendix C  for an analysis of  costs  associated
with the use of this method.

Future Work

     Work is needed to improve the technique for applying bleach to  porous
surfaces, and to lessen the corrosive impact of bleach on equipment  and  build-
ing materials.

Information Sources

     The bulk of the information in this subsection came from  References  19
and 25.
FLAMING (METHOD  17)

General Description

     Controlled high temperature flames are applied  to  noncombustible  surfaces
to thermally degrade all contaminants.

Advantages

     Flaming provides complete and rapid destruction of all  residues con-
tacted.

Disadvantages

     Flaming is primarily a surface decontamination  technique.   Subsurface
decontamination of building materials may be possible,  but  extensive damage  to
the material would probably result.  This technique  may detonate combustible
residues.   It also can involve high fuel costs.
                                     85

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Section 4/Flaming (Method 17)
Stata of the Art

     Flaming is the state-of-the-art technique for decontaminating building
surfaces at explosives installations.  The technique has been applied to the
decontamination of Frankford Arsenal (see Appendix H).

Variations of Idea

     Flaming may either be accomplished by a hand-held flamer or by a remotely
operated flamer.  The use of a remotely operated flamer is restricted to
expansive open surfaces, whereas hand-held flamers are required for complex
areas, cracks, etc.  Figures 16 and 17 are photographs of a hand-held flamer
and a remotely operated wall flamer.

Applicability

     The flaming process is applicable to all explosives and some low-level
radioactive contaminants.  Its applicability to other contaminants is not well
known.  This technique is applicable to painted and unpainted concrete, ce-
ment, brick, and metals.

Effectiveness

     The contaminants thermally decompose to volatile products by combination
ring-splitting or fragmentation.  In all cases, the reaction is exothermic and
autocatalytic.  Complete decomposition of all contaminant residues that are
near the flame front should be accomplished because of the intensity of the
heat and the action of free radicals developed by the flame.

     The adsorption of the contaminant on a particular substrate may inhibit
the decomposition reaction; however, this effect is expected to be small, and
it is believed that complete destruction of contaminants on surfaces can be
achieved.

Engineering Considerations

Building Preparation—
     Combustible materials  (e.g., wood and plastic) and friable materials
(e.g.,  asbestos and transite) are removed prior to flaming operations.  To
achieve complete surface decontamination, all areas must be accessible to the
flame front; thus, obstructions to  the flame must be removed.  Heat conduction
to inaccessible areas is dependent  on the building material and flame dwell
t i me.

Process Description--
     Figure 18 presents a flow diagram of the flaming process.  If a building
has  large,  open, continuous surface  areas, a remotely operated flamer is
preferred.  Otherwise, a hand-held  flamer is preferred.
                                      86

-------
                                                                  8505-559-CN
Source:  Reference 20.
                         Figure 16.  Hand flamer.
                                    87

-------
               Figure 17.  Remotely operated wall  flamer.



Source:  Reference 20.





                                    88

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                                                 Section 4/Fleming  (Method 17)
FRIABLE AND
COMBUSTIBLE
MATERIALS
REMOVAL


OBSTRUCTION
REMOVAL


FLAMING


CHAR
REMOVAL
^

SECONDARY
DECONTAMINATION
                  Figure 18.  Flaming process flow diagram.
     Because of the high temperature of the flame, its dwell  time is held to a
minimum to minimize material damage.  If subsurface decontamination of build-
ing materials is required, the dwell time of the flame can approach 10 min or
longer (time is dependent on material).  This can cause excessive damage to
the building materials.  The requirements for a supplemental  treatment depend
on both the depth of contamination and thermal penetration.

     Removal and cleanup of surface paint char may be required prior to re-
painting.  Washdown of concrete may be advantageous to allow  it to regain its
strength.

Equipment and Support Facilities Needed--
     This technique requires a torch (hand-held or remotely operated), fuel
source, hoses, regulators, fire extinguishers, and tools to remove obstruc-
tions and combustible material.

Time Requirements--
     The setup time depends on the number of obstructions and the amount of
combustible materials that must be removed prior to flaming.

     Personnel time is long if a hand-held flamer is used extensively, and
short if a remotely operated flamer is used.  Surface decontamination time is
very short.  At the Frankford Arsenal, a remotely operated flamer was used
along the walls at a rate of 3m/min.  For niches and cracks,  a 2-min dwell
time is suggested for decontaminantion.  For subsurface treatment, decontamin-
ation time increases greatly.  To achieve a thermal penetration of 300°C at a
depth of 5 cm requires dwell times of 16 min for concrete and 25 min for
brick.

     No tear-down time is needed for equipment removal if only a hand-held
flamer is used; otherwise, moderate time is needed.  Removal  of char from the
wall will not require much cleanup time.

Safety Requirements
     Thermal decomposition of contaminants may produce gaseous pollutant
hazards that would require scrubbing to prevent release to the atmosphere.
If
                                      89

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Section 4/Flaming (Method 17)
lead paint was used in the building, toxic lead vapors may form during flam-
ing.  If combustible residues are heated, either directly by flame or indi-
rectly by heat conduction, an explosion may occur.   There is the possibility
of personnel being burned by the flames or hot surfaces.

     Shielding, safety glasses, fire extinguishers, nonstatic clothing, res-
pirators, and remotely operated equipment may be employed as protective meth-
ods to reduce potential safety hazards.  Local exhaust hoods may be used to
vent gases and collect lead vapors.  See Section 5 for additional worker
health and safety requirements.

Waste Disposal

     The wastes or debris generated by flaming (char) may be considered hazar-
dous.  Consult 40 CFR Part 261 and appropriate EPA guidance for definitions
and listings of hazardous waste.  If the wastes are considered hazardous, they
must be disposed of in a RCRA-permitted facility.

Costs

Structural Damage and Repair Costs--
     Building damage is expected to be minimal if flaming is used only as a
surface decontamination technique; otherwise, damage is expected to be exten-
sive.

Treatment and Disposal Costs--
     Costs for utilities and fuel may be high, as flaming requires a large
supply of gas  (propane or acetylene and either oxygen or air).  Equipment
costs will be moderate.  Hand-held flamers are off-the-shelf equipment.
Remotely operated flamers can  be modeled after the design used at Frankford
Arsenal.  No material costs  should be encountered unless repainting is re-
quired.  Manpower costs may  be high, as flaming  is labor-intensive, especially
if  hand-held flaming is performed to a large  extent.

      If  a structure is ultimately to be torn  down, this treatment may mean the
difference  in  costs between  disposing of the  debris  in a hazardous waste
landfill versus a solid waste  landfill.  Such a  cost differential could be
substantial.   See Appendix  C for an analysis  of  costs associated with the use
of  this  method.

Future Work

      More  information  is  needed  on  the selection of  a secondary  treatment if
surface  flaming  is  performed.   In  any case, concentration gradients of contam-
 inants  in  building  materials must  be determined.   Experimental testing for
this  will  be  required.
                                       90

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                                   Section 4/Drilling and Spoiling  (Method  18)
Information Sources

     The bulk of the information in this subsection  came  from  Reference  20.
Use of this method is illustrated in the case study  presented  in Appendix H.
DRILLING  AND SPALLING (METHOD  18)

General Description

     The drilling and spelling technique can  remove  up  to  5  cm  of  surface from
concrete or similar materials.  This technique consists of drilling  holes (2.5
to 4 cm diameter) approximately 7.5 cm deep.   The  spalling tool  bit  is  in-
serted into the hole and hydraulically spreads to  spall  off  the contaminated
concrete.  Figure 19 is a photograph of a drilling and  spalling rig.  Figure
20 is a sketch of a concrete spaller.

Advantages

     The technique can achieve deeper penetration  (removal)  of  surfaces  than
other surface-removal techniques.   It is good for  large-scale application.

Disadvantages

     The treated surface is very rough and coarse  and may  require  resurfacing
(i.e., capping with concrete).  Rebars may be exposed.   Substantial  amounts of
contaminated debris are generated.

State of the Art

     The drilling and spalling method has been used  in  the decommissioning of
nuclear facilities.  A drilling and spalling  rig is  being  designed and  tested
by Battelle Pacific Northwest Laboratories to increase  the concrete  removal
rate.

Variations of Idea

     Vacuum filter systems and water sprayers can  be used  to control  dust
during drilling and spalling operations.  A remotely operated drill  and  spall
rig may also be used.

Applicability

     Drilling and spalling is applicable to concrete only  (not  to  concrete
block).  This technique is not suitable for hard-to-reach  areas such  as  behind
pipes and equipment.  Its applicability depends on interior  building  configur-
ation.  It should be useful in removing all types  of contaminants, with  the
                                     91

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•6u 6u.LLieds  pua
'61
                                          C\J
                                          01

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ID
OO
                                     HYDRAULIC
                                      CYLINDER
15 cm
                                                                                       5 en
                                            Figure 20.  Concrete spaller.
                     Source:  Reference 20.

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Section 4/Drilling and Spoiling (Method 18)
exception of highly toxic residues of primary explosives such as lead azide
and lead styphnate.

Effectiveness

     Complete removal  can be obtained for contamination up to 5 cm deep in
concrete.

Engineering Considerations

Building Preparation—
     Building preparation involves removing obstructions to the drilling and
spalling rig and assuring that pockets of combustible residues are not pre-
sent.

Process Description—
     A flow diagram of the drilling and spalling decontamination method is
presented in Figure 21.
OBSTRUCTION
REMOVAL
>»

DRILLING
AND
SPALLING
»,

DEBRIS
COLLECTION


SECONDARY
DECONTAMINATION


SURFACE
CAPPING
                             WASTE TREATMENT
                               AND DISPOSAL
            Figure 21.  Drilling and spalling process flow diagram.


     Holes to 4 cm in diameter, approximately 7.5 cm deep, and 30 cm apart are
drilled into the concrete surface.  Hydraulically operated spalling tools are
inserted into the holes; the spalling tool bit is an expansible tube of the
same diameter as the hole.  A tapered Mandril is hydraulically forced into the
hole to spread the fingers and spall off the concrete.  The removed concrete
is collected and, if necessary, a secondary treatment is then performed to
remove any remaining contaminants that have penetrated deeper than 5 cm.
Surface capping is performed last.

Equipment and Support Facilities Needed--
     A drilling and spelling rig, a scaffolding/hydraulic positioning system,
and cleanup equipment are required.
                                      94

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                                   Section 4/Drilling and Spoiling (Method 18)
Time Requirements--
     Minimal setup time is required as scaffolding will  have to be assembled
for wall treatment.  Any obstructions must be removed.

     Personnel time is extensive because this is a relatively slow process.   A
remote control device may decrease labor time, but it may not be cost-effec-
tive.  Battelle Pacific Northwest reports that its drilling and spelling rig
has an average removal rate of 6 m3/h for standard concrete.  Decontamination
time is expected to be extensive because of the slow process and the require-
ment for secondary treatment.

     Equipment removal entails minimal tear-down time, but cleanup time is
extensive.  Large quantities of concrete will have to be collected, and sur-
faces may require washdown.

Safety Requirements

     High dust and noise levels, high-pressure air lines, and flying debris
may present personnel hazards.  Debris and dust may be contaminated.  Eye and
ear protection and protective clothing should be worn.  A dust-suppression
system (such as periodic wash-down) may be required.  See Section 5 for addi-
tional worker health and safety requirements.

Waste Disposal

     Contaminated debris must be collected and held for treatment (e.g.,
incineration) and for disposal.  It may require management as a hazardous
waste.  Consult 40 CFR Part 261 and appropriate EPA guidance for definitions
and listings of hazardous waste.  If the waste is considered hazardous, it
must be disposed of in a RCRA-permitted facility.

Costs

Structural Damage and Repair Costs--
     The spalled surface is very rough and will require concrete capping or
some other treatment to yield smooth surfaces.  Cost is expected to be moder-
ate.

Treatment and Disposal Costs--
     Costs for utilities and fuel should be low to moderate.  Major equipment
costs will be for the drilling and spalling apparatus.  A drilling and spall-
ing rig (without positioning equipment) costs approximately $10,000 (1980
dollars).  Material costs for the concrete cap are expected to be low.  Man-
power costs will be high, as the concrete-removal rate is relatively slow and
cleanup time is high.  Disposal costs will range from moderate to high, depen-
ding on whether or not the debris must be disposed of as a hazardous waste.
See Appendix C for an analysis of costs associated with the use of this meth-
od.
                                      95

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Section 4/K-20 Sealant (Method 19)
Future Work

     Techniques for treating contaminated concrete  are  needed.   Dust  control
systems need to be designed.  The drilling and spelling technique  will  have  to
be modified or another technique chosen to decontaminate block,  brick,  wood,
and other building materials.   More information is  needed to  select secondary
treatment.

Information Sources

     The bulk of the information in this subsection came from References  20
and 21.
 K-20 SEALANT  (METHOD  19)

General Description

     Sealing is the application of a material  that penetrates  a  porous  surface
and immobilizes contaminants  in place.   One example of a  sealant is  a newly
developed commercial product, K-20.*  This material, which  was originally
developed as a waterproofing  agent, is  now being  marketed as a building decon-
taminant.  The manufacturer claims that the product is nontoxic, noncorrosive,
nonvolatile, and odorless, and contains at least  eight chemicals.

     K-20 acts by bonding with contaminants and carrying  the residue deeper  as
it penetrates the structural  material.   K-20 can  penetrate  most  porous  mater-
ials up to 4 cm.

     Although it is believed  to act more like a barrier than a detoxifier,
manufacturer evidence indicates K-20 may facilitate chemical degradation as
well as physical separation of some contaminants.   Testing  performed for the
manufacturer by a private laboratory over a period of approximately  8 mo has
indicated incomplete recovery of a known amount of applied  contaminant, which
indicates possible chemical interaction.

Advantages

     Contaminants are stabilized in situ.  No hazardous wastes are generated.

Disadvantages

     The effectiveness and applicability of K-20  to various contaminants and
structural materials have not been verified.
*
  Lopat Enterprises, Inc., Wanamassa, New Jersey.
                                       96

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                                            Section 4/K-20 Sealant (Method 19)
State of the Art

     K-20 has been used on a RGB-contaminated office building and duct system,
an oil spill (liquid PCB's) that occurred on a Navy vessel, and a chlordane-
contaminated house.

Variations of Idea

     K-20 may be applied to contaminated surfaces by painting or by spraying.

Applicability

     K-20 has been used against PCB's and chlordane.  It may be effective
against lead, asbestos, and dioxins.   Additional  testing of the product is
expected some time in 1984.  K-20 has been used on cinders, concrete, tile,
brick, marble, and other porous materials.

Effectiveness

     The effectiveness of this product as a permanent barrier has not yet been
established.

Engineering Considerations

Process Description--
     The application process described by the manufacturer is very simple.
First, all loose dirt and debris are  wiped off the surface to be treated.  The
K-20 mixture is applied to large open areas by painting with a brush or rol-
ler, and to small irregular areas (inside heating ducts, behind pipes and
fixtures) by spraying with a low-pressure spray gun.  A second coating may
follow 24 h later.  When the final  coat has been  applied, time must be allowed
for the mixture to thoroughly dry.

Equipment and Support Facilities Needed--
     The following equipment and supplies are needed:   brushes, brooms, and
other equipment to remove excess surface debris;  a container for mixing the
sealant; a paint brush, roller, or spray gun, and (possibly) a drop cloth; and
safety equipment.  All equipment can  readily be obtained from commercial
manufacturers.

Time Requirements—
     The time required for removal  of loose surface debris, application of
K-20, and drying (longest part of the process) should be moderate.

Safety Requirements

     Safety requirements have not yet been documented for this product.  The
eight ingredients contained in K-20 have not been disclosed by the manufac-
turer; the toxicity of the product is not known.   At a minimum, workers should
                                       97

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Section 4/Microbial Degradation (Method 20)
 go through a training program and be equipped with  eye  protection,  respira-
 tors, full-body protective coveralls, and foot cover.   Showers  are  recommended
 at the end of the day.  See Section 5 for additional worker  health  and  safety
 requirements.

 Waste Disposal

     With the exception of the removed surface debris,  little or  no wastes are
 expected to be generated.  The debris may be contaminated  and require manage-
 ment as a hazardous waste.  Consult 40 CFR Part 261 and appropriate EPA guid-
 ance for definitions and listings of hazardous waste.   If  the debris is consi-
 dered hazardous, it must be disposed of in a RCRA-permitted  facility.

 Costs

 Structural Damage and Repair Costs--
     No structural  damage or repair costs are anticipated.

 Treatment and Disposal Costs--
     Costs should be moderate for equipment and low to  moderate for labor.
 Most of the cost will be for the sealant mixture.   Disposal  costs will  be
 relatively low due  to the low volumes of wastes generated.

 Future Work

     Because sealants such as K-20 are new and innovative  decontamination
 techniques, additional data substantiating their effectiveness  on various
 contaminants and materials are needed.  Also, the method must stand the test
 of time (as of May  1984, the longest period between application of  K-20 and
 contaminant testing had been 203 days).

 Information Sources

     The bulk of the information in this subsection came from Reference 26;
 personal communication from V. Rose, Pacific Gas and Electric Company,  San
 Francisco, California, April 17, 1984, and May 22,  1984; and personal communi-
 cation from D. R. Lincoln and L. Flax, Lopat Enterprises,  Inc., Asbury  Park,
 New Jersey, December 1983 and February 1984.   Use of this  method  is illus-
 trated in the case  study presented in Appendix G.
MICROBIAL DEGRADATION (METHOD 20)

General Description

     Contaminants are biologically decomposed  by microbes capable of utilizing
the contaminant as a nutrient source.  Microbes are  applied to the contami-
nated area in an aqueous medium and allowed to digest  the contaminant over
                                       98

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                                   Section 4/Miorobial Degradation (Method 20)
time.  The microbes are then destroyed chemically or thermally and washed
away.

Advantages

     Microbes are specific to targeted contaminants.  Decontamination opera-
tions are relatively safe.

Disadvantages

     A large development effort is needed to achieve a workable system.
Supplementary treatment probably would be required.   Carcinogenic compounds
have been detected in the biological  degradation products of some chemical
warfare and explosive contaminants.

State of the Art

     This technique has not yet been  applied to building and equipment decon-
tamination.  Development could take 2 to 3 years of research.  Aerobic bio-
degradation has been successfully applied in lagoon, soil and groundwater
cleanups.  Contaminants have included gasoline, oil  sludges, phenolics,  alco-
hols, acrylates, and solvents.  It has also been used to unclog city sewers
and clean up oily wastewater in the bilges of the ship Queen Mary.  Microbial
degradation has been shown to be effective against pesticide contamination  in
a laboratory situation.

Variations of Idea

     Variations include the use of aerobic and anaerobic microbes, and the  use
of enzymes produced by cultured microbes to degrade contaminants.

Applicability

     This method could be useful for  the in situ detoxification of hazardous
residues on walls and floors and in abandoned process equipment, storage
tanks, sumps, piping, etc.

Effectiveness

     Data on the effectiveness of microbial degradation as a building decon-
tamination technique is not available.

Engineering Considerations

Building Preparation--
     All areas to be treated are saturated with water to thoroughly moisten
them and are kept wet throughout the  treatment period.  Dry spots will not  be
decontaminated.  A saturated gel or thick polyurethane soft foam can be used
to keep the surface wet.
                                      99

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Section 4/Miorobial Degradation (Method 20)
Process Description--
     The microbial solution is applied to the contaminated area with a spray
gun, brush, or roller.  The microbes are allowed to penetrate and react with
the contaminants.  After complete reaction, a detergent or solvent wash re-
moves the reaction products and a major portion of the microbes.  Drying
should result in the destruction of residual microbes; if not, heating or a
chemical treatment (such as acid wash or surfactant wash) may be needed to
inactivate the microbes.  Finally, a wash with fresh solvent may be a neces-
sary secondary decontamination treatment to remove any remaining contaminants
or derivatives.

Equipment and Support Facilities Needed--
     This technique requires painting equipment (for application), storage and
collection tanks, and heaters and/or dehumidifiers (for drying).

Time Requirements--
     Setup time should be low.  Personnel time required for application to
building surfaces should be equivalent to the time required for painting.
Decontamination time depends on the kinetics of the microbial reaction and the
mass transfer of microbes into porous materials.

     Minimal time is required for removal of application equipment.  Minimal
cleanup is required; a fresh solvent or detergent wash may be sufficient.

Safety Requirements

     Contact with microbes could be hazardous to personnel.  Protective cloth-
ing, eye protection, and respiratory protection (such as a high-efficiency
particulate filter mask) should be worn by all workers.  See Section 5 for
additional worker health and safety requirements.

Waste Disposal

     Some degraded contaminants may still be hazardous and require disposal as
hazardous wastes.  All rinsates/washwaters should be properly disposed of.
Consult 40 CFR Part 261 and appropriate EPA guidance for definitions and
listings of hazardous wastes.  If the wastes are considered hazardous, they
must be disposed of in a RCRA-permitted facility.

Costs

Structural Damage and Repair Costs--
     These costs should be minimal as long as the attack by microbes on the
structural material is not appreciable.

Treatment and Disposal Costs—
     Costs for utilities and fuel should be minimal.  Costs of application
equipment should be low, and costs of drying equipment should be moderate.
                                     100

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                               Section  4/Photochemical Degradation (Method 21)
Cost of the microbes will  be the  only material cost incurred.  Personnel costs
should be low (similar to  painting  cost).   Disposal costs could be moderate to
high, depending on the volume of  wastes  generated and their disposition.

Future Work

     More information is needed on  the optimum type of microbial organisms
(aerobic vs. anaerobic, etc.); on product  identity, destruction efficiency,
and kinetics of specific microbe  reactions; and on the effect of microbes on
building materials.  Large research and  development efforts may be required.

Information Sources

     The bulk of the information  in this subsection came from References 20
and 27.
PHOTOCHEMICAL DEGRADATION (METHOD 21)

General Description

     In this process, intense ultraviolet  (UV) light is applied to a contam-
inated surface for some period of time.  Photodegradation of the contaminant
follows.  In recent years,  attention  has been focused on this method because
of its usefulness in degrading chlorinated dioxins (TCDD in particular).
Three conditions have been  found  to be essential for the process to proceed:
1) the ability of the compound to absorb light energy, 2) the availability of
light at appropriate wavelengths  and  intensity, and 3) the presence of a
hydrogen donor.

Advantages

     Photochemical degradation operations can be relatively simple or scaled-
up (accompanied by increased technical efforts).  It is inexpensive when
sunlight is used as the UV  light  source.

Disadvantages

     Photochemical degradation will not work on contaminants imbedded in dense
particulate matter (such as thick carpet or deep soil) because UV light cannot
penetrate through these surfaces.  Exposure hazards may result from intense UV
radiation when sources other than the sun  (mercury and xenon-arc lamps) are
used; exposure hazards may  also result from the use of flammable solvents as
hydrogen donors.
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Section 4/Photochemical Degradation (Method 21)
State of the Art

     Photochemical  degradation has been used to decontaminate vegetative and
soil surfaces and many inert surfaces.

Variations of Idea

     Various UV light sources and hydrogen donors may be used.  Possible light
sources include the sun and mercury and xenon-arc lamps.  Possible hydrogen
donors include the majority of organic  liquids that have a large proportion of
hydrogen atoms and that are not highly  UV-absorbing in the same range as the
target contaminant; examples are methanol, benzene, glycol, and glycol  ethers
such as Carbitols and Cellosolves, natural vegetable and mineral oils,  furni-
ture polish, and petroleum distillates.

     Photochemical  degradation has many different potential applications,
depending on the nature of the contaminated substrate.  These include:

     (1)  Use of a portable UV light and hydrogen donor to decontaminate
          interior surfaces and structures, or initially waterwashing,  then
          applying a hydrogen donor and UV light to the wet residue.

     (2)  Destruction of residues in building corners and other hard-to-reach
          places with a UV laser beam.

     (3)  Use of other decontamination  techniques (e.g., steam cleaning,
          waterwashing/hydroblasting, solvent extraction, and vapor-phase
          solvent extraction) followed  by condensate and/or solvent collection
          and the application of photodegradation techniques to the liquid
          wastes.

     (4)  Spray application of a hydrogen donor to contaminated outside sur-
          faces followed by exposure to the sun.

Applicability

     Photochemical degradation should be applicable to a wide range of contam-
inants, and specific data on the photodegradability of numerous chemicals
should be available in the literature.   The method has recently been used to
degrade dioxin (TCDD) residues in Italy and the United States.  Experiments
are ongoing to determine the method's usefulness for PCB destruction.

     Photochemical degradation is potentially applicable to all surfaces,
although best results can be expected on smooth surfaces.

Effectiveness

     Photodegradation efficiencies as related to actual building, structure,
and equipment decontamination efforts have not been well documented.   It is
                                      102

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                               Section 4/Photochemical  Degradation  (Method  21)
believed, however, that photodegradation could result  in  complete  in  situ
elimination of toxic residues on surfaces.   Deeply  imbedded  residues  will  not
be degraded, and a secondary treatment technique  may be required.

Engineering Considerations

Building Preparation—
     Minimal building preparation is required. Activities may  include  the
application of a hydrogen donor and the setting up  of  a UV light source (if
the sun is not used).

Process Description--
     A hydrogen donor is applied to the contaminated surface, which  is  then
exposed to UV light.  When used with other methods, surfaces are first
treated, and the liquid residues are then decontaminated  by  adding a  contami-
nant-specific organic solvent, followed by exposure to a  UV  light source.

Equipment and Support Facilities Needed--
     Required equipment includes a hydrogen donor,  equipment for application
of the hydrogen donor (spray or brush), a UV light  source, and  additional
equipment (as necessary) if other decontamination procedures are implemented.

     The hydrogen donor/contaminant match may be  hard  to  establish,  as  might
specific UV light sources for individual decontamination  efforts.

Time Requirements--
     Decontamination of the area under treatment  should be complete  within
24 h.  Time for total building decontamination may be  extensive depending upon
size, complexity, and number of light sources used concurrently.

Safety Requirements

     Care should be taken in dealing with specific hydrogen  donors.   Also,
personnel must be aware of hazards associated with artificial  UV light sources
(e.g., eye and skin damage).  Protective equipment should be the same as that
used in dioxin-contaminated areas.  In addition,  eye protection should be
worn.  See Section  5 for additional worker health and  safety requirements.

Waste Disposal

     Waste treatment and disposal should not be required  unless this method is
used in conjunction with another decontamination method in which a condensate
or liquid solution  is generated.
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Section 4/Photochemial Degradation (Method 21)
Costs

Structural Damage and Repair Costs—
     Ultraviolet light may cause bleaching of fabric surfaces.  Replacement
costs should be minimal.

Treatment and Disposal Costs--
     Treatment costs should be moderate to high depending on size and complex-
ity of the structure.  Waste disposal costs should be negligible unless a
second decontamination technique is used in conjunction with photochemical
degradation.

Future Work

     Research is needed for further establishing specific UV light/hydrogen
donor/contaminant procedures.

Information Sources

     The bulk of the information in this subsection came from References 28,
29, and 30, and personal communication from R. Kimbrough, Centers for Disease
Control, Atlanta, Georgia, February 16, 1984.
                                      104

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                                  SECTION 5

                          WORKER HEALTH AND  SAFETY


     Ensuring worker health and safety is of primary  importance  in  all  decon-
tamination operations.  A significant effort must be  put  into  developing  pro-
cedures and methodologies that will  protect  workers from  the contaminants  at
Superfund sites.  Training, medical  surveillance, personal  protective  equip-
ment, and site safety plans—the key elements necessary to  ensure the  health
and safety of decontamination workers during site operations—are described
in this section.  These elements should be incorporated into the site  decon-
tamination plan described in Section 3.


TRAINING

     All personnel who will be engaged in inspection, sampling,  or  decontami-
nation activities at Superfund emergency or  remedial  sites  should undergo
various levels of orientation and training.   Hazardous waste training  courses
can be developed in-house (under the direction of experts in the field),  or
workers may attend any number of commercial  courses available  throughout  the
United States.  These commercial courses, which have  become very popular  in
the 1980's, are sponsored by universities, private  firms, and  local,  state
and Federal agencies.  Every course should have the following  basic compo-
nents:  classroom training, hands-on field work, and  periodic  refresher
training.

     In the initial classroom training, individuals gain  basic familiarity
with standard operating procedures, program  policies  and  concepts,  protective
equipment, toxicology, industrial hygiene considerations, respiratory  protec-
tion, safety plan development, remedial planning, air characterization, field
sampling, chain-of-custody procedures, decontamination procedures,  field
investigation procedures, and emergency preparedness.31

     When trainees demonstrate an understanding of  the classroom topics,  they
should participate in hands-on training in a field  setting. Among  the bene-
fits participants will gain from such training are  the experience of putting
theory into practice, greater confidence in  themselves and in  the equipment
and techniques upon which they will  ultimately rely,  and  the building  of  a
decontamination "team."

     Refresher training courses should be offered every 6 to  12 mo  for indi-
viduals who will be working in the decontamination  field  over  an extended
                                     105

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Section 5/Medical Surveillance
period of time.  These courses should review the basic topics covered in the
initial training and inform workers of new regulations affecting their health
and safety.


MEDICAL SURVEILLANCE

     The purpose of a medical surveillance program is to maintain a record of
general worker health to ensure appropriate placement of workers in job cate-
gories, to prevent (or to detect at an early stage) any harmful effects of
hazardous substances on workers, and to provide resources for emergency medi-
cal care and treatment.  Responsibility for a medical surveillance program
should be assigned to medical personnel that are knowledgeable in toxicology
and experienced in occupational medicine.  Program development should be
coordinated with industrial hygienists, emergency response team members,
safety professionals, or other persons involved in the overall site safety
plan.  Fragmentation of the medical management of employees or of individual
medical records should be avoided, however.

Program Components

     The major components of a medical surveillance program are preassignment
physicals, periodic medical exams, exit exams at employment termination, and
emergency medical care plans.  Preassignment physicals are performed by a
physician prior to the initial placement of an employee in a particular job.
The preassignment physical provides a historical record of the worker's
previous exposures, shows his or her state of health prior to joining the
work force, and collects baseline medical and physiological information for
comparison with later health observations.  The preassignment physical is
particularly important for determining the ability of the employee to wear
personal protective equipment and for identifying those individuals who may
be hypersusceptible to known hazardous substances at the decontamination
site.  Detailed elements of a preassignment physical have been described by
Roos and Scofield.32

     During the course of decontamination work, periodic medical exams are
given  at regular  intervals to document worker health status, to quantitate
biological indicators of exposure, and to provide the earliest possible
detection  of adverse effects.  These exams also provide an excellent oppor-
tunity to  evaluate the effectiveness of control measures and safety proce-
dures, to  correlate environmental monitoring data with medical data, and to
refresh hazard awareness training.  The frequency and content of periodic
medical exams  may be designated,  in part, by pertinent government regula-
tions. For example, OSHA regulation 29 CFR 1910.1018, Section N, requires
the  semiannual administration of  a sputum cytology test, nasal and skin
examination, and  chest x-ray  for  employees with occupational exposures to
inorganic  arsenic, as well as semiannual documentation of respiratory medical
history.   Additional OSHA medical  surveillance  requirements are described in
29 CFR 1910, Subpart Z.
                                      106

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                                               Section  5/Medical  Surveillance
     Termination examinations are given at the close  of work  assignments  when
the potential for exposure to hazardous substances  is past.   These  exams  are
desirable because they record health status at the  end of exposure  and docu-
ment any health changes that may have occurred during the decontamination
project.  A typical termination examination should  repeat many of the tests
that were included in the preassignment physical.

     The medical surveillance program must include  provisions for emergency
medical care and treatment at the decontamination  site and at the nearest
properly equipped medical facilities.  These plans  should be  based  on the
hazardous properties of the identified contaminants and on the health and
safety risks associated with the actual work operations or equipment.  When
the potential health effects and injuries have been determined, the appropri-
ate medical materials can be ascertained, obtained, and stocked on  site or at
the closest medical facility.  Methods for obtaining  expedient medical atten-
tion in an emergency must be established and communicated to  all  workers.
The U.S. EPA Office of Emergency and Remedial Response "Interim Standard
Operating Safety Guides," Part 3, suggests specific steps to  accomplish this
objective.33

Biological Monitoring

     Biological monitoring consists of analytical  tests performed on physio-
logical samples such as blood, urine, feces, sputum,  exhaled  air, and other
body fractions to quantitate absorption of specific toxic agents, to detect
minor  physiological changes, and to diagnose early signs of disease.  This
type of monitoring should be included in all of the major components of a
medical surveillance plan (i.e., preassignment physicals, periodic  medical
examinations, and termination examinations).  Biological monitoring methods
should be chosen to reflect potential exposure to the contaminants  of concern
(when  such methods exist) and to maximize worker acceptance.314'35  Workers
will favor noninvasive tests over invasive, painful, or complicated proce-
dures.  Standard test protocols for detecting some chemical contaminants in
blood  and urine are published by NIOSH in a seven-volume set.5"9  A physician
should determine what type of medical monitoring is necessary.

Recordkeeping

     Because of the long  latent periods between exposure and the appearance
of  some chronic health effects and the potential legal  implications of occu-
pationally related disease, medical records should be retained for a minimum
of  40  years.  The medical surveillance requirements in many OSHA regulations
state  that records should be retained for 40 years or for the duration of
employment plus 20 years, whichever is longer.  Medical records are best kept
as  the property of a physician.  Prior to the start of work activities,  it
should be established which pieces of  information are to be made available to
project management.
                                     107

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Section 5/Personal Protective Equipment
PERSONAL PROTECTIVE EQUIPMENT

     Proper selection and use of personal  protective equipment are crucial  to
the preservation of worker safety and health.   Subpart I of OSHA Regulation
29 CFR 1910 states that "protective equipment...shall be provided, used, and
maintained...wherever it is necessary by reason of hazards of processes or
environment."  Personal protective equipment is often the sole barrier sepa-
rating workers from potentially hazardous  substances during decontamination
projects.  Headgear, protective clothing,  gloves, boots, goggles, and respir-
ators are designed to permit safe work operations by preventing skin contact,
dermal absorption, inhalation, and inadvertent ingestion of potentially toxic
agents.  Personal protective equipment is  also designed to protect the worker
from physical injuries such as eye wounds, bruises, abrasions, and lacera-
tions.  Four factors must be considered in the development of a program of
personal protective equipment:  1) selection of appropriate equipment, 2)
equipment distribution, 3) worker training, and 4) equipment decontamination
and/or disposal procedures.  Any personal  protective equipment program should
also meet the general requirements outlined by OSHA 29 CFR 1910, Subpart I.

Equipment Selection

     The hazards present at the decontamination site must be characterized
before the proper personal protective equipment can be selected.  The types,
toxicity, and concentrations of contaminants must be defined.  Points of
potential high-risk contact (splashes, high atmospheric concentrations, etc.)
during specific job operations should be identified when possible.  The
degree of hazard at the decontamination site will dictate the level of per-
sonal protective equipment required.

     The equipment necessary to protect the body against contact with known
or anticipated chemical hazards can be divided into four categories, each
affording a different level of protection:33

     Level A requires the highest level of respiratory, skin, and eye protec-
     tion.  Level A protective equipment consists of:

     0     Pressure-demand, self-contained breathing apparatus (MSHA/NIOSH
           approved)

     0     Fully encapsulating chemical-resistant suit

     0     Coveralls*

     0     Long cotton underwear*

      0     Gloves  (outer), chemical-resistant
 *
   Optional.
                                     108

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                                     Section 5/Personal Protective Equipment
     °     Gloves  (inner),  chemical-resistant

     0     Boots,  chemical-resistant,  steel  toe and shank  (depending on suit
          construction,  worn  over  or  under  suit  boot)

     0     Hard hat* (under suit)

     0     Disposable protective  suit, gloves  and boots*  (over fully encapsu-
          lating  suit)

     0     2-Way radio communications  (intrinsically  safe)

     Level B is selected when the  highest level  of respiratory  protection  is
     needed but a lesser level of  skin protection is sufficient.   It  consists
     of:

     0     Pressure-demand, self-contained breathing  apparatus (MSHA/NIOSH-
          approved)

     0     Chemical-resistant  clothing (overalls  and  long-sleeved  jacket;
          coveralls; hooded,  one-  or  two-piece chemical-splash  suit;  dispos-
          able chemical-resistant  coveralls)

     0     Coveralls*

     0     Gloves  (outer),  chemical-resistant

     0     Gloves  (inner),  chemical-resistant

     0     Boots (outer), chemical-resistant,  steel toe  and  shank

     °     Boots (outer), chemical-resistant (disposable)*

          Hard hat (face shield*)

     0     2-Way radio communications  (intrinsically  safe)

     Level C is selected when the  type of airborne substances are known  and
     the criteria for air  purifying respirators  are  met.  Level C protective
     equipment consists  of:

     0     Full-face, air-purifying, canister-equipped respirator  (MSHA/NIOSH-
          approved)

     0     Chemical-resistant  clothing (coveralls; hooded, two-piece  chemical-
          splash  suit;  chemical-resistant hood and apron; disposable  chemi-
          cal-resistant  coveralls)

*
  Optional.


                                     109

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Section 5/Personal Protective Equipment
     0    Coveralls*

     0    Gloves (outer), chemical-resistant

     0    Gloves (inner), chemical-resistant*

     0    Boots (outer), chemical-resistant, steel toe and shank*

     0    Boots (outer), chemical-resistant (disposable)*

          Hard hat (face shield*)

     0    Escape mask*

     0    2-Way radio communications (intrinsically safe)

     Level D is selected when there are no respiratory or skin hazards.
     Level D protective equipment consists of:

          Coveralls

          Gloves*

     0    Boots/shoes, leather or chemical-resistant, steel toe and shank

     °    Boots (outer), chemical-resistant (disposable)*

     0    Safety glasses or chemical-splash goggles*

          Hard hat (face shield*)

     0    Escape mask*

     The  level of protective equipment chosen should be able to handle the
 highest exposure conditions likely to be encountered during the scope of
 work.  Level B protection is the minimum level recommended on initial site
 entries until the hazards are further defined.  Level C protection is ade-
 quate for most decontamination operations.  Personal protective equipment
 requirements for some chemicals are designated by government regulations.
 For example, the OSHA Asbestos Regulation  (29 CFR 1910.1001) describes the
 types of  respirators that must be used by  workers occupationally exposed to
 asbestos  fibers.

      Specific details about equipment performance characteristics are avail-
 able  from manufacturers  of personal protective equipment.  In addition,
 several guides published by NIOSH describe types of personal protective
 equipment (including respirators) and their appropriate uses.36"38
 _
   Optional.
                                     110

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                                                   Section 5/Site  Safety  Plan
Equipment Distribution

     For effective management of a personal  protective equipment program,  one
particular location or locations should be established as  a center for all
equipment distribution, storage, repair, and maintenance.   The  responsibility
for these activities should be assigned to a specific individual or group  of
individuals.  All personnel should be made aware of the location of the per-
sonal protective equipment center.  Checkout procedures for some safety de-
vices, such as self-contained breathing apparatuses (SCBA), may be useful  to
track particularly hazardous operations.  Extra equipment  should be readily
available in case of emergency or for use by site visitors.

Training

     All personnel who will regularly work in contaminated areas, those who
might enter contaminated areas in unusual circumstances, and visitors must be
instructed in the proper use of the personal protective equipment.  The
topics covered in this training should include the nature  of the hazard the
personal protective equipment is designed to prevent; the  proper use and
limitations of the protective device; and cleaning, daily  inspection, and
routine maintenance of the equipment.

Equipment Decontamination and Disposal

     During use, personal protective equipment is subject  to physical damage
as well as contamination with hazardous substances.  Contamination must be
removed from equipment prior to its reuse.  If equipment is washed, the spent
wash and rinse solutions are treated as contaminated waste.  Damaged or non-
reusable equipment also should be disposed of as contaminated waste.  General
guidelines for decontamination of personal protective equipment are presented
in Part 7 of the "Interim Status Operating Safety Guides."33


SITE SAFETY PLAN

     The objective of a site safety plan is the establishment of standard
operating procedures and guidelines to ensure that all facets of the decon-
tamination operation are conducted in a safe and orderly manner.  Depending
on the  situation, the responsibility for developing a site safety plan may
lie with Federal agencies  (OSHA, NIOSH), state agencies (mainly Departments
of Health), site owners, or cleanup contractors.  Because  safety plans must
be site-specific, they are subject to modifications by onsite supervisory
personnel.

     The site safety plan  should appoint one individual as the  site safety
officer.  This individual  should be thoroughly knowledgeable of all Federal,
state,  and  local governmental regulations and guidelines pertaining to the
contaminant(s) at the site.  The site safety officer may consider consulting
                                     111

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Section 5/Site Safety Plan
other references (industry-wide publications,  private research documents,
industrial hygiene organizations) that address the specific contaminants of
concern.  The site safety officer should be given complete control  of the
safety aspects of the cleanup operations and should have the authority to
make on-the-spot decisions concerning job safety procedures.  In addition,
the safety officer should be responsible for reporting,  documenting,  and
correcting any infractions of safety-related rules and should have  the au-
thority to shut down the job site if severe and/or chronic rule infractions
occur.

     Within the organization responsible for overall  cleanup operations, a
QA/QC staff responsible for the monitoring of all site safety activities
should be established.  As part of their duties, QA/QC personnel should
review the site safety plan before its implementation and follow up with
periodic audits to assure compliance with the previously approved procedures.

     The site safety plan should focus on the standard operating procedures
necessary to ensure that all field work is conducted in  an efficient  yet safe
manner.  When a decontamination operation has been contractually agreed upon,
an extensive review and investigation of the job site should be conducted
before any field operations are begun.  During this time, site safety person-
nel should familiarize themselves with the layout of the cleanup area and
become thoroughly knowledgeable of the job specifications for the project,
particularly those affecting worker health and safety.

     In addition to an investigation of the job site, preoperational  activi-
ties should include obtaining, verifying, and posting emergency phone numbers
(fire department, hospitals, security); compiling a list of the type, amount,
and toxicity of wastes and potentially harmful substances found at  the site;
making sure an eyewash unit is available at the site; obtaining a first aid
kit suitable for treating minor injuries that are likely to occur during
cleanup operations; ensuring that all personnel who are  to work at  the site
have had the required medical tests and training; notifying all applicable
local, state, and Federal agencies; ensuring that all workers have  been
briefed on the hazards of the contaminant(s) they are about to encounter and
are aware of the proper way to carry out decontamination procedures;  and
maintaining an appropriate supply of protective equipment on site.

     When the initial safety precautions have been implemented, containment
barriers should be constructed to separate contaminated  areas from clean
areas.  An entry module, which provides for the safe entry and exit of those
who must enter and leave contaminated areas, usually takes one of two forms:
an airlock or a trailer.  Airlocks, which can be constructed on site, consist
of prefabricated wooden structures and polyethylene sheeting.  Whether a
portable trailer with airtight connections or an airlock structure is used,
the components are similar and provide like services.  Both should  include
showers,  locker areas, rest rooms, security offices, negative air filtration
systems, waste disposal operations, and a monitoring and recording  station.
                                     112

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                                                   Section 5/Site Safety Plan
     Table 4 has been prepared to assist planners and site safety personnel
in identifying potential health and safety hazards associated with the use of
various cleanup methods.  The table lists process-related hazards only.
Additional hazards posed by the contaminant(s) being treated or by the struc-
tural integrity of the building, structure, or equipment must also be taken
into consideration on a case-by-case basis.
                                    113

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TABLE 4.   SUMMARY OF  POTENTIAL HEALTH AND  SAFETY HAZARDS  RELATED TO THE USE OF
                         VARIOUS DECONTAMINATION METHODS9
                                   Potential Health and Safety Hazards
Method
1. Asbestos abatement
(removal, encapsulation,
enclosure, special
operations)
2. Absorption
3. Demolition
4. Dismantling
5. Dusting/vacuuming/wiping
6. Encapsulation/enclosure
7. Gritblasting
8. Hydroblasting/water-
washing
9. Painting/coating
(lead-based paint removal,
fixative/stabilizer coat-
ings, strippable coatings)
10. Scarification
(continued)
AN
F,V
V
P
P
P
V
P

V
P
A'-c?

, X



X


X

a/^<


X
X


X
X

X
»/'<:





X
X
X

X
A^
X
X
X
X
X
X
X
X
X
X
*/*\



X






7<%
X






X


y s










" //'~
/ ^

X
X
X


X

X
X
f/ 
-------
   Table  4 (continued)
                                           Potential Health and Safety Hazards
11. RadKleen
12. Solvent washing
13. Steam cleaning
14. Vapor-phase solvent ex-
traction
15. Acid etching
16. Bleaching
17. Flaming
18. Drilling and spalling
19. K-20 sealant
V
V
V
V
V
V
V,P
p
V
X
X
X
X
X
X
X

X






X
X












X



X
X
X




























X

X


X
X








X

Inhalation and skin hazards from the use of Freon 113.
Inhalation, skin, and fire hazards from the use of flammable and/or
toxic solvents.
Inhalation and skin hazards from the use of toxic solvent/steam mix-
tures; possible steam burns.
Inhalation, skin, and fire hazards from the use of flammable and/or
toxic solvents.

Skin hazards from bleaching agents, which are strong oxidizers; oxi-
dizing agents in contact with organic materials can result in the
production of heat and toxic gases.
Inhalation hazard from thermal decomposition products; skin hazard
(burns) from contact with flames or hot surfaces.
Fire and explosion hazard if pockets of combustible material are
contacted.
Hazards associated with K-20 are uncertain; neither the ingredients
nor the results of toxicity tests have been disclosed by the manufac-
turer.
(continued)

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                Table  4  (continued)
                                                                    Potential Health and Safety Hazards


20. Hicrobial degradation
21. Photochemical degradation
V,P
V

X







X


X





Inhalation hazard from microbes and biological degradation products.
Eye and skin hazards from the use of artificial UV light sources;
inhalation and skin hazards from the use of toxic hydrogen donors.
CT>
             This table presents  process-related hazards only.   Additional hazards posed by the contaminant(s)  being treated or by the structural  integrity of  the
             building,  structure, or  equipment must also be taken  into consideration on a case-by-case  basis.
             inhalation hazards  include  pulmonary deposition or  absorption of toxic or nuisance particulates  (P), carcinogenic asbestos fibers (F),  or  toxic chemical
             vapors  (V).
             Skin hazards include dermatoses, chemical burns, percutaneous absorption of chemicals,  etc.
             Ultraviolet radiation is  both a skin and eye hazard.
             Biohazard  is a  hazard directly due to a living organism, or the byproduct of a living organism.
             Physical contact  hazards  include lacerations,  injuries  to the eye from flying particulate,  strains, sprains, impacts, etc.

-------
                                 REFERENCES
 3.


 4.


 5.



 6.



 7.



 8.



 9.



10.
11.
     U.S. Environmental Protection Agency.  Aim Opts for Wide Range of Clean-
     up Remedies at Superfund Sites.   Inside E.P.A., April  20, 1984.

     Harper, R. H., G. L. Kingsbury,  and R.  M. Ray.   Interim Report:  Feasi-
     bility of Site Usage Following Hazardous Waste  Remedial Actions.  Pre-
     pared for U.S. Environmental Protection Agency  by Research Triangle
     Institute under Contract No. 68-03-3149, February 1984.
U.S. Environmental
School Buildings:
Protection Agency.  Asbestos-Containing Materials in
A Guidance Document.  Part 1.  March 1979.
U.S. Environmental Protection Agency.  Test Methods for Evaluating Solid
Waste.  Physical/Chemical Methods.  2nd Edition.  U.S. EPA SW-846, 1980.

U.S. Department of Health, Education, and Welfare.  NIOSH Manual of
Analytical Methods.  2nd Edition.  Volumes 1-3.  DHEW (NIOSH) Publica-
tion Nos. 77-157A, 77-157B, and 77-157C, 1977.
U.S. Department of Health, Education, and Welfare.
Analytical Methods.  2nd Edition.  Volume 4.  DHEW
No. 78-175, 1978.
                                 NIOSH Manual of
                                (NIOSH) Publication
U.S. Department of Health, Education, and Welfare.  NIOSH Manual of
Analytical Methods.  2nd Edition.  Volume 5.  DHEW (NIOSH) Publication
No. 79-141, 1979.

U.S. Department of Health, Education, and Welfare.  NIOSH Manual of
Analytical Methods.  2nd Edition.  Volume 6.  DHEW (NIOSH) Publication
No. 80-125, 1980.

U.S. Department of Health and Human Services.  NIOSH Manual of Analyti-
cal Methods.  2nd Edition.  Volume 7.  DHHS (NIOSH) Publication No.
82-100, 1981.

National Fire Protection Association.  Fire Hazard Properties of Flam-
mable Liquids, Gases, and Volatile Solids (325M).  In:  National Fire
Codes.  Volume 13.  National Fire Protection Association, Quincy, Massa-
chusetts, 1983.

U.S. Department of Health, Education, and Welfare.  The Toxic Substances
List.  H. E. Christensen (ed.).  National Institute for Occupational
Safety and Health, Rockville, Maryland, 1973.
                                   117

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References	

12.  U.S. Department of Health, Education, and Welfare.  Registry of Toxic
     Effects of Chemical Substances.  1981-82 Edition.  R. L. Tatken and R.
     J. Lewis (eds.).  National Institute for Occupational Safety and Health,
     Cincinnati, Ohio, 1983.

13.  U.S. Department of Health, Education, and Welfare.  Criteria for a
     Recommended Standard...Occupational Exposure to Polychlorinated Biphen-
     yls (PCBs).  DHEW (NIOSH) Publication No. 77-225, 1977.

14.  American Conference of Governmental Industrial Hygienists.  Documenta-
     tion of the Treshold Limit Values.  4th Edition.  American Conference of
     Governmental Industrial Hygienists, Inc., Cincinnati, Ohio, 1980.
                                                                     (B)
15.  American Conference of Governmental Industrial Hygienists.  TLVs --
     Threshold Limit Values for Chemical Substances and Physical Agents in
     the Work Environment With Intended Changes for 1982.  American Confer-
     ence of Governmental Industrial Hygienists, Inc., Cincinnati, Ohio,
     1982.

16.  Act II - How Clean is Clean?  Hazardous Waste Report, 5(9):13, 1983.

17.  Labor Rates for the Construction Industry, 1983.  10th Annual Edition.
     R. S. Godfrey  (ed.).  Robert Snow Means Company,  Inc., Kingston, Massa-
     chusetts, 1982.

18.  U.S. Environmental Protection Agency.  Guidance for Controlling Friable
     Asbestos-Containing Material in Buildings.  EPA-560/5-83-002, March
     1983.

19.  Wolfe, H. R'.,  et al.  Some Problems Related to Cleanup of  Parathion-Con-
     taminated Surfaces Following Spillage.  In:  Proceedings of the 1976
     National Conference on Control of Hazardous Material Spills.  EPA-600/5-
     76-002, 1976.

20.  Benecke, P., et al.  Development of Novel Decontamination  and Inerting
     Techniques  for Explosives-Contaminated Facilities.  Phase  I - Identifi-
     cation and  Evaluation of  Concepts.  Vols. 1 and 2.  DRXTH-TE-CR-83all,
     July 1983.

21.  Marion, W.  J.,  and Thomas, S.  Decommissioning Handbook.   DOE/EV/10128-
     1,  November 1980.

22.  Furhman, D.  Decontamination Operations at Gateway Army Ammunition
     Plant.  DRXTH-AS-CR-83250, November 1983.

23.  Battelle Columbus Laboratories.  Final Report on  Evaluation of Encapsu-
     lants  for Sprayed-on Asbestos-Containing Materials in Buildings.  Pre-
     pared  for U.S.  Environmental Protection Agency under Contract No. 68-03-
     2552,  1979.
                                    118

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	References

24.  Natale, A., and H. Levins.  Asbestos Removal and Control.  An Insiders
     Guide to the Business.  Sourcefinders, Vorhees, New Jersey, 1984.

25.  Jones, W. E.  Engineering and Development Support of General Decon
     Technology for the U.S. Army's Installation Restoration Program.  Task
     5, Facility Decontamination.  Defense Technical Information Center,
     Alexandria, Virginia.  Pub. No. 49-5002-0005, July 1982.

26.  Hawthorne, S. H.  Solvent Decontamination of PCB Electrical Equipment.
     In:  IEEE Conference Proceedings, Vol. IA-18, July 1982.

27.  Dempsey, K. B.  Biotechnology Aids Disposal.  Plants, Sites and Parks,
     September/October 1982, pp. 1-8+.

28.  Wong, A. S., and D. G. Crosby.  Decontamination of 2,3,7,8-Tetrachloro-
     dibenzo-p-dioxin by Photochemical Action.   In:  Dioxin:  Toxicological
     and Chemical Aspects.  Spectrum Publications, Inc., New York, 1978.

29.  Liberti, A., et al.  Solar and UV Photodecomposition of 2,3,7,8-Tetra-
     chlorodibenzo-p-dioxin in the Environment.  The Science of the Total
     Environment, 10:97-104, 1978.

30.  Crosby, D. G.  Methods of Photochemical Degradation of Halogenated
     Dioxins in View of Environmental Reclamation.  In:  Accidental Exposure
     to Dioxins.  Human Health Aspects.  Academic Press, Inc., New York,
     1983.

31.  CH2M Hill.  Hazardous Waste Site Investigation Training Course Guide.
     November 1983.

32.  Roos, K. S., and P. A. Scofield.  Health and Safety Considerations:
     Superfund Hazardous Waste Sites.  In:  National Conference on Management
     of Uncontrolled Hazardous Waste Sites, Washington, D.C., October 31 -
     November 2, 1983.  Hazardous Materials Control Research Institute,
     Silver Spring, Maryland, 1983.

33.  U.S. Environmental Protection Agency, Office of Emergency and Remedial
     Response, Hazardous Response Support Division.  Interim Standard Operat-
     ing Safety Guides.  Revised September 1982.

34.  Lauwenys, R. R.  Industrial Chemical Exposure:  Guidelines for Biologi-
     cal Monitoring.  Biomedical Publications, Davis, California, 1983.

35.  Baselt, R. C.  Biological Monitoring Methods for Industrial Chemicals.
     Biomedical Publications, Davis, California, 1980.

36.  U.S. Department of Health, Education, and Welfare.  A Guide to Indus-
     trial Respiratory Protection.  DHEW (NIOSH) Publication No. 76-189,
     1976.
                                    119

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References	

37.  U.S. Department of Health, Education, and Welfare.  NIOSH/OSHA Pocket
     Guide to Chemical Hazards.  DHEW (NIOSH) Publication No.  78-210, 1978.

38.  U.S. Department of Health and Human Services.  NIOSH Certified Equipment
     List as of June 1, 1980.  DHHS (NIOSH) Publication No.  80-144, 1980.
                                    120

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                                 APPENDIX A

                            SUPERFUND SITE SURVEY
     In the fall of 1983, a telephone survey was  conducted of the decontami-
nation activities at 50 selected Superfund sites  across  the country.   Sites
were chosen for the survey based on information indicating that contaminated
buildings, structures, or equipment may have been present.  The results  of
the survey are summarized in Table A-l.  In many  cases,  buildings and struc-
tures were not present or, if present, were not contaminated; thus,  no decon-
tamination activities were planned at these sites.   Decontamination  activi-
ties (planned, in progress, or completed) at sites  with  contaminated build-
ings, structures, and equipment are detailed in site data  summary forms  that
follow the summary table.  The information obtained through this survey  was
often sketchy, and as a result, the site data summary forms are often incom-
plete.
                                   121

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         TABLE A-l.   SURVEY  OF  DECONTAMINATION  ACTIVITIES AT  SELECTED SUPERFUND SITES   (FALL  1983)
                                 Site/location
ro
ro
                         Cannon Engineering  Corp.
                         Bridgewater, Massachusetts
                         PSC Resources
                         Palmer, Massachusetts
                         Silresim Chemical  Corp.
                         Lowell, Massachusetts
                         McKin Site
                         Gray, Maine
                         Keefe Environmental  Services
                         Epping, New Hampshire
                         Ottati and Goss/Kingston Steel
                          Drum
                         Kingston, New Hampshire

                         Somersworth Landfill
                         Somersworth, New Hampshire

                         Old Springfield Landfill
                         Springfield, Vermont
                         Region II

                         Brick Township Landfill
                         Ocean County, New Jersey
                         (continued)
              Background
The site  was used for the storage and  incinera-
tion of wastes; on-site structures include four
process buildi-ngs, an office/warehouse, and a
thermal oxidizer.

The facility, now inactive, reclaimed  waste oils
from Massachusetts collection points;  the prop-
erty includes two buildings and abuts  a resi-
dential area.

A chemical waste reclamation facility  with build-
ings and  tanks on site; residential  areas border
the site  on three sides.
The site  consists of a fenced enclosure, an in-
cinerator,  a concrete block building, an asphalt-
lined lagoon, several large storage  tanks, num-
erous 55-gallon drums, and other debris.
Served as  a waste bulking and waste  transfer
station between 1978 and 1981; the site in-
cludes two buildings that have been  used to
store various drummed waste materials and an
office building that acted as a laboratory
facility for the site while it was active.

Both operations reconditioned and resold used
55-gallon  drums; emergency response  action con-
taminated  equipment.

A municipal landfill with a garage facility.
A trailer  park was built on top of  an abandoned
landfill.
This site  is  located in a residential area, 50
feet from  a group of condominiums  and across
the street from the proposed site  for a school;
the site has  an old waste incinerator.
                                                                                                                     Decontamination
                                                                                                                       activities
Contamination of buildings  has
not been determined;  tanks
were drained; see site  data
summary form.

Buildings are not contaminated.
All surface structures  (build-
ings and tanks)  were  dismantled
or decontaminated and demolished;
see site data summary form.

Tanks were decontaminated, cut
up, and taken away; plans for
decontaminating  floors  have not
been finalized;  buildings will
be destroyed; see site  data
summary form.

Site is under remedial  investi-
gation; feasibility study has
not been completed.
Equipment was decontaminated
before leaving the  site;  see
site data summary form.

Garage is not contaminated.
Groundwater contamination site;
work plan for the remedial in-
vestigation/feasibility  study
is being developed.
Sheds used to store  equipment
were removed under an order to
close.

-------
                      Table A-l   (continued)
                                 Site/location
ro
oo
                         Chemical Control
                         Elizabeth, New Jersey
                         Ellis Property
                         Evesham Township,  New  Jersey
                         M&T Delisa Landfill
                         Asbury Park, New Jersey
                         Kont Clair/Glen Ridge
                         Essex County, New Jersey
                         Myers Property
                         Franklin Township,  New  Jersey
                         PJP Landfill
                         Jersey City, New Jersey
                         Syncon Resins
                         South Kearny, New Jersey
                         U. S. Radium Corp.
                         Orange, New Jersey
                               (conti nued)
               Background
Left on site were  two buildings  that were used
for the storage of chemicals  and pesticides;
the site was the scene of a massive fire in
April  1980.
At one time a drum recycling operation; the site
consists of a large two-story building housing
several wash tanks and troughs,  a  storage area,
and three nearby sheds.

A mall was constructed on  top of a  closed sani-
tary landfill.
Radioactive material  used as fill  in  a
residential neighborhood.
The site, currently used as a private  residence,
previously contained various types  of  commer-
cial facilities; solid chemicals  are stored  in
buildings on the site.
An elevated highway runs through the  site;  tenta-
tive plans call  for a truck stop,  motel, and
commercial stores to be built on the  property;
smoke from fires on the site often interferes
with traffic on  the skyway, and the leachate
is suspected of  corroding the bridge  supports.
An inactive paint, varnish, and resin manufac-
turing facility; drums are stored in warehouses.
A former radium processing facility  located  in
a highly populated area; seven commercial/indus-
trial buildings are currently on the  site.
                                                                                                                      Decontamination
                                                                                                                        activities
Buildings on site were destroyed
in the fire; however, buildings
across the street were in the
path of the plume and had to be
decontaminated; see site data
summary form.

Buildings are not contaminated.
Groundwater contamination site;
no plans to decontaminate the
mall or pavement.

The basements of forty homes
were ventilated to reduce radon
gas to acceptable levels; re-
moval of the soil is antici-
pated; see site data summary
form.

Wooden shacks store chemical
drums containing asbestos; no
testing has been done, but the
shacks will probably be torn
down.

Currently, there are no build-
ings on site; the landfill is
burning underground, and no
proposals for construction at
the site will be considered
until the fire is put out and
the site cleaned up.

The buildings are not considered
an asset to the property and
will probably be torn down.

Suspected as the source of the
contaminated fill material at
the Mont Clair/Glen Ridge site;
buildings are of slab construc-
tion, thus radon gas in not con-
fined; no remedial action has
been taken.

-------
                          Table  A-l  (continued)
                                   Site/location
ro
                           Love Canal
                           Niagara Falls, New York
                           Wide Beach Development
                           Brant, New York
                           Juncos Landfill
                           Juncos, Puerto Rico
                           Region III

                           Drake Chemical  Co.
                           Lock Haven, Pennsylvania
                           Lehigh Electric and Engineering
                            Co.
                           Old Forge, Pennsylvania
                           Region IV

                           SCRDI Bluff Road Site
                           Columbia, South Carolina
                           A & F Materials/Greenup
                           Greenup, Illinois
                           LaSalle Electrical  Utilities
                           LaSalle, Illinois
                           Seymour Recycling Corp.
                           Seymour, Indiana
               Background
In the mid to late 1970's, continued periods  of
high precipitation raised the water table,
carrying chemically contaminated leachate to
the surface and into contact with basement
foundations.
Waste oils were sprayed on roads in  this  de-
velopment of 66 homes for dust control  until
1978.

Thermometers containing mercury were dumped on
the site; a new housing development  has been
built over the landfill.
Made chemical intermediates for pesticides  and
other products during the 1960's and  1970's;
closed operations in 1981; the facility  is
abandoned.

Electrical equipment, including transformers  and
capacitors, are currently stored at the  facility;
high levels of PCB's have accumulated on the
property.
The site of the South Carolina Recycling  and
Disposal Co. has a central  metal-walled build-
ing in which salvageable wastes were  stored.
Operations at the site, which began  during  1977,
were originally intended to reprocess waste oil
and sludges from various generators.
A closed factory which used PCB's  to manufacture
capacitors from the late 1940's  until  late  1978;
waste oils were used for dust control  in  the
parking lot until  1969.

An abandoned industrial  waste reclamation oper-
ation located in Freeman Field Industrial Park,
about 2 miles from the center of Seymour.
                                                                                                                        Decontamination
                                                                                                                          activities
About 300 homes imemdiately ad-
jacent to the site were de-
molished; a habitability study
is being conducted in the
surrounding area where another
500 homes are located; see site
data summary form.

County sampled dust in homes; no
contamination was found.
As yet, there is no evidence of
contamination at the homes;
sampling is continuing.
Buildings will be torn down and
decontaminated or sent to a
secure landfill; feasibility
study has not been completed.

Concrete slabs will be decon-
taminated; see site data
summary form.
Building will be removed upon
site closure.
Emergency cleanup efforts
centered on the waste oil
lagoons; a remedial  investi-
gation/feasibility study is
under way.

A remedial investigation/fea-
sibility study has not been
conducted.
Several buildings are on site
that stored tanks and drums,
but contamination has not been
determined.
                            (cont i nued)

-------
                      Table A-l  (continued)
                                Site/location
ro
en
                         Wedzeb  Enterprises, Inc.
                         Lebanon,  Indiana
                         Anderson Development Co.
                         Adrian, Michigan
                         Auto  Ion
                         Kalamazoo, Michigan
                         Northernaire Plating
                         Cadillac, Michigan
                         National Lead-Taracorp Site
                         St.  Louis  Park, Minnesota
                         Chem-Dyne
                         Hamilton, Ohio
                         Old Mill
                         Rock Creek, Ohio
                         Old  Inger Oil Refinery
                         Darrow,  Louisiana
                         (continued)
               Background
Owns two warehouse facilities  that were used
to store capacitors,  many containing  PCB  in-
sulating oils,  for subsequent  distribution
and resale; a fire destroyed one warehouse,
and the debris  was left on site.

MBCOA was manufactured from 1971 to March 1979
and is a widespread environmental, residential,
and occupational  contaminant.
A former plating waste treatment  facility, liquid
plating wastes and sludges remain on  site in
three basement areas of a two-story brick build-
ing and in an outside concrete-lined  lagoon.

An inactive electroplating facility.
NL Industries, Inc., operated a  secondary lead
smelter from the 1930's until 1979; a portion
of the property was sold to Golden Auto  Parts,
Inc., in the early 1960's and the remainder to
Taracorp, Inc., in August 1979;  in May 1982
Taracorp permanently closed the  smelting plant;
Golden Auto Parts is now located over a  portion
of a large lead slag disposal site.

A chemical waste transfer and storage facility
in business since 1974.
About 4 years ago, the site owner was  involved
with a local  brine and oil  hauling  business in
an old grain  elevator complex consisting of three
or four buildings and several silos; the site
is close to a school  and several houses.
The site, now abandoned, reclaimed  oil  from
refinery wastes; a spill in 1978 contaminated
a large surface area; a small  employee  support
building is located on the site.
                                                                                                                      Decontamination
                                                                                                                        activities
Only rubble remains.
Remedial actions include weekly
street sweeping, paving of an
adjacent subdivision, cleaning of
253 households, and covering of
driveways and parking lots with
tar and stone; status of process
buildings has not been determined.

Building has been condemned.
Emergency response site; no
remedial investigation has
been done.

Buildings will be torn down.
Buildings are contaminated;
remedial investiation under-
way; decontamination may be  an
option; see site data summary
form.

Buildings have no salvage value,
but will probably be left on
site to be destroyed by a future
owner.
Waste oil lagoons were drained
during an emergency action; no
extensive decontamination of
the building is planned.

-------
                        Table A-l   (continued)
                                   Site/location
ro
CTi
                           Bio-Ecology Systems, Inc.
                           Grand Prairie, Texas
                           Triangle Chemical Co.
                           Bridge City, Texas
                           Region VII

                           Dico Co.
                           Des Moines, Iowa
                           Ellisville Site
                           Ellisville, Missouri
                           Shenandoah Stables
                           Moscow Mills, Missouri
                           Minker/Stout
                           Imperial , Missouri
                           Quail Run Mobile Manor
                           Gray Summit, Missouri

                           Region VIII

                           Denver Radium Site
                           Denver, Colorado
                             (cont i nued)
               Background
In June 1972, the site was permitted  for  inciner-
ation, chemical  treatment, biological  oxidation
of wastewaters,  and landfill  of solids  result-
ing from treatment processes; the  site  operated
through June 1978; small  buildings and  tanks
Produced antifreeze, windshield wash  solvent,
industrial cleaning compounds,  hand cleaners,
and brake fluids starting in the early  1970's;
in 1981 the company declared bankruptcy and
abandoned the facility.
Used TCE to degrease metal  parts,  and  in  the past
spread the oily waste from this  process to con-
trol dust on the property.
In 1980 a contractor unearthed  some  buried drums
of paint solvents and pesticides  while  construct-
ing a sewer line; further investigation revealed
two other areas where industrial  wastes had been
buried; a horse arena is on site.

The site became contaminated with dioxin  in May
1971 when a waste oil hauler sprayed  approxi-
mately 2,000 gallons of oil for dust  control;
in August 1971, the top 6 to 8  inches of  contami-
nated soil  was excavated from the area  and used as
fill material  in a new highway.

In 1971 the Bubbling Springs Ranch Arena  became
contaminated with dioxin when a waste oil hauler
sprayed oil for dust control; in  1973 the lessee
of the area excavated some of the dioxin-contam-
inated soil, which was later used as  fill mate-
rial in two residential areas.

Soil in this mobile home park is  contaminated with
dioxin.
Thirty-five Colorado sites  have  been  identified
where radium was processed, refined,  or fabricated
into various devices or products; of  these sites,
31 are located in the metropolitan  Denver area and
include vacant land, industrial  operations, build-
ings, and public streets;  all  of these have varying
levels of radioactivity due to the  residues of the
radium industry.
                                                                                                                         Decontamination
                                                                                                                           activities
Tanks were drained, cleaned,
dismantled, and removed; the
shack was dismantled and re-
moved as well; see site data
summary form.
Miscellaneous debris was cleaned
out of buildings; decontamina-
tion was not considered nec-
essary; the site is fenced.
Groundwater contamination site;
company continues to operate;
no building decontamination is
considered necessary.

Arena is not contaminated.
Remedial investigation/feasi-
bility study is being conducted.
Eleven families are being perm-
anently relocated; furniture,
appliances, and personal  items
will be cleaned according to
CDC recommendations.
Homes will be cleaned; see
site data summary form.
Difficult to characterize
because of multiple sites.

-------
                       Table  A-l  (continued)
                                Site/location
ro
                         Sand  Creek  Industrial Site
                         Commerce  City, Colorado
                         Anaconda  Smelter
                         Anaconda, Montana
                         Taputimu  Farm
                         American  Samoa
                         Mountain  View  Mobile Home
                          Estates
                         Slobe,  Arizona
                         MGM Brakes
                         Cloverdale,  California
                         PCB Warehouse
                         Saipan,  Northern Mariana
                          Islands
                         Western Processing  Co.,  Inc.
                         Kent,  Washington
               Background
The site is industrially zoned and  has  supported
a high volume of chemical  and  petroleum produc-
tion; the site includes  the former  Oriental Re-
finery, the 48th and Holly Streets  Landfill, the
Colorado Organic Chemical  Co., acid waste dis-
posal pits used by the L.C. Corp.,  and  several
small residences and businesses.

A copper smelter was operated  from  the  late
1800's until  September 1980; for  the  most part,
the wastes left on site  at closure  remain.
The site, part of an agricultural  experimental
farm, consists of a warehouse that has  been
used for more than 10 years for storage of un-
used chemicals and pesticides.
The subdivision is built on graded chrysotile
asbestos tailings and is directly adjacent  to
an active asbestos mill.
Between 1965 and 1972 the facility operated cast-
ing machines that used hydraulic fluids contain-
ing PCB's; these fluids were discharged to the
ground on site.

A temporary shelter served as an interim
storage facility for approximately 1400 gal-
lons of PCB transformer fluid.
A converted military base; principal  operations
are solvent recovery, acid and caustic neu-
tralization, and heavy metal precipitation.
                                                                                                                      Decontamination
                                                                                                                        activities
Remedial planning in the infant
stages; difficult to characterize
because of multiple sites.
Contaminated flue dust is being
removed so the buildings can be
demolished; see site data
summary form.
Currently developing a record
of decision; decontamination
of the building has been recom-
mended; see site data summary
form.

Too expensive to decontaminate;
families will be relocated;
homes will be crushed and
buried.

Buildings and equipment have
been decontaminated; see site
data summary form.
Drums in good condition; no
leaks or spills; building not
contaminated.
Remedial investigation/feasibil-
ity study has not been completed;
buildings probably will not be
left standing after cleanup;
some tanks may be saved.

-------
Appendix A:  Super1 fund Site Survey
REGION:  I                                        DATE:   December 5, 1983


SITE:  Cannon Engineering Corp.                   CONTACT:   Jim Ciriello
                                                            EPA Region I
                                                            617/223-5775

LOCATION:  Bridgewater, Massachusetts


HISTORY OF USE:  Storage and incineration of wastes.


WASTES ON SITE:  Chlorinated hydrocarbons, arsenic, cadmium, chromium, sol-
vents  (methylene, xylene, acetone, MEK).  Records are not complete.


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:  Located on site
are:   four process buildings (thin steel), an office/warehouse, a thermal
oxidizer, a brick garage, and several tanks (in and out of the buildings).
These  structures have some salvage value.


CRITERIA FOR DETERMINING CONTAMINATION:  A visual inspection revealed wastes
remaining in the tanks.  However it has not been determined that the build-
ings are contaminated.  Wipe tests may be done.


METHOD OF DECONTAMINATION:  Wastes were pumped out of the tanks, and a marine
chemist certified that the tanks were waste-free and gas-free.


EQUIPMENT:  Explosimeter.


WORKER PROTECTION:


EVALUATION OF DECONTAMINATION EFFECTIVENESS:


COSTS:
                                    128

-------
                                           Appendix A:  Superfund Site Survey
REGION:  I                                        DATE:  December 5, 1983

SITE:  Silresim Chemical Corp.                    CONTACT:   Rick Layton
                                                            EPA Region I
                                                            617/223-5775
LOCATION:  Lowell, Massachusetts

HISTORY OF USE:  Originally, the site was a tank farm for home heating oil.
Silresim used the existing buildings and tanks for a chemical waste reclama-
tion facility.

WASTES ON SITE:  129 priority pollutants have been detected.

DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:  Four single-
story cinder block or wood frame buildings with flat roofs  built on concrete
slabs are on site as well as one corrugated steel  building.

     Brick and cement block building (lab with garage portals)
          38 ft x 108 ft x 15 ft
          18-in. thick walls
     0    Flat roof made of wood
          Sampled 10 ft grids on floors and walls  at a height of 3-1/2 ft
          No contaminants (volatile)
o
     Wood frame building (lab)
          28 ft x 35 ft x 9 ft
     0    Pitched roof
     0    Wood studded with steel and sheet siding
     0    Wood pilings, wood floor
     Prefab steel frame building (boiler building)
          40 ft x 80 ft x 14-1/2 ft
     0    Corrugated aluminum sheet siding and roofing
     Perched tank field
     0    4 steel tanks surrounded by a concrete dike
     0    Steel pump house measuring 15 ft x 25 ft x 7 ft

CRITERIA FOR DETERMINING CONTAMINATION:  Swipe test.

METHOD OF DECONTAMINATION:  All surface structures were dismantled and taken
to a secure landfill or decontaminated with a steam cleaner, demolished, and
trucked to a landfill.

EQUIPMENT:  Steam cleaner.

WORKER PROTECTION:  Varied, level C or D.
                                    129

-------
Appendix A:  Superfund Site Survey
Silresim Chemical Corp. (continued)

EVALUATION OF DECONTAMINATION EFFECTIVENESS:  Swipe test.
COSTS:  Dismantling - $700,000.
Contact Paul Clay, NUS, 617/275-2970 for more information,
                                     130

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                                           Appendix A:   Superfund Site Survey
REGION:  I                                        DATE:   October 3,  1983


SITE:  McKin Site                                 CONTACT:   Elliot Thomas
                                                            EPA Region I
                                                            617/223-1591

LOCATION:  Gray, Maine


HISTORY OF USE:  A waste processing operation originally constructed, in
part, to accommodate waste generated from an oil  spill  by a Norwegian tanker.
The owners also accepted septic tank wastes and industrial  process wastes.


WASTES ON SITE:  Several organic chemicals.


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:  Concrete block
building with concrete floor, approximately 14 ft x 30 ft.   Attached to and
within the building is an incinerator unit and associated machinery.  There
are several large storage tanks on site as well.


CRITERIA FOR DETERMINING CONTAMINATION:  Sections of the floor are contami-
nated as the result of a spill of tetrachloroethane- and trichloroethane-con-
taining sludge.


METHOD OF DECONTAMINATION:  Tanks were decontaminated by draining the
sludges, chipping off the stuck-on material using brass (nonsparking) tools,
hand wiping with a stoddard solvent, rinsing, and wet vacuuming.  Tanks were
then cut up and taken away.  Plans for decontaminating the floor have not
been finalized; they are expected to be similar to those used on the tanks.
Buildings will be destroyed and the whole site capped.


EQUIPMENT:  Nonsparking tools, wet vacuum.


WORKER PROTECTION:


EVALUATION OF DECONTAMINATION EFFECTIVENESS:  Swipe test.


COSTS:
                                    131

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Appendix A:  Superfund Site Survey
REGION:  I                                        DATE:  September 23, 1983


SITE:  Ottati and Goss/Kingston                   CONTACT:  Bob Ankstitus
        Steel Drum                                          EPA Region I
                                                            617/223-7265
LOCATION:  Kingston, New Hampshire


HISTORY OF USE:  Both operations reconditioned and resold used 55-gal drums.
O&G also operated a hazardous waste TSD facility.


WASTES ON SITE:  O&G - 4300 drums; KSD - 40,000 to 60,000 drums.  Wastes
include flammables, nonflammables, caustics, cyanides, and PCB's.


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:   Emergency
response equipment including backhoes, bobcats, and drum grapplers.


CRITERIA FOR DETERMINING CONTAMINATION:  Decontamination procedure is rou-
tine.
METHOD OF DECONTAMINATION:  Equipment was steam cleaned.   Water was collected
in drums, pumped in with nonflammable wastes, and disposed of.


EQUIPMENT:  Steam geny.


WORKER PROTECTION:   Level C protection.  Operators wore raincoats or rubber
aprons.


EVALUATION OF DECONTAMINATION EFFECTIVENESS:  No machinery left the site
visibly contaminated.  Organic vapors were at background levels.


COSTS:  The costs are broken down as follows:

     Labor:  $30/h
     Machinery:  $35 to $85/h
     Steam generator:  $100/day
                                     132

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                                           Appendix A:  Super fund Site Survey
REGION:  II                                       DATE:  February 14, 1984


SITE:  Chemical Control                           CONTACT:  Fred Schmitt
                                                            NJDEP
                                                            609/292-1211

LOCATION:  Elizabeth, New Jersey


HISTORY OF USE:  A plume from an explosion and fire at the site in April 1980
contaminated a cement factory across the street.


WASTES ON SITE:  60,000 drums of assorted chemcials.


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:  Three cement
trucks, an office building, and elevator buildings.


CRITERIA FOR DETERMINING CONTAMINATION:  Swab samples.


METHOD OF DECONTAMINATION:  Washed down with water and solvent.


EQUIPMENT:  Spray gun.


WORKER PROTECTION:  Level C protection.


EVALUATION OF DECONTAMINATION EFFECTIVENESS:  Patch test.


COSTS:
                                    133

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Appendix A:  Superfund Site Survey
REGION:  II                                       DATE:  March 1, 1984
SITE:  Mont Clair/Glen Ridge                      CONTACT:  John Czapor
                                                            EPA Region II
                                                            212/264-1574

LOCATION:  Essex County, New Jersey


HISTORY OF USE:  Soil from the site of a radium processing facility was used
as fill material in a residential neighborhood.


WASTES ON SITE:  Radium.
DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:  Forty homes
with basements.


CRITERIA FOR DETERMINING CONTAMINATION:  An aerial survey of areas surround-
ing former radium processing facilities in New Jersey detected elevated
levels of gamma radiation in this neighborhood.


METHOD OF DECONTAMINATION:  Basements were ventilated until radon gas was
reduced to acceptable levels.  Removal of the contaminated soil is antic-
ipated.


EQUIPMENT:  Helicopters, gamma radiation detectors.


WORKER PROTECTION:


EVALUATION OF  DECONTAMINATION EFFECTIVENESS:  The acceptable level of radon
gas is defined as an annual average  (or equivalent) radon decay product
concentration  (including background) not to exceed 0.02 working level (40 CFR
192.12(b)(l),  July 1, 1983, amended  by 48 FR 45946, October 7, 1983).


COSTS:
                                    134

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                                           Appendix A:   Super fund Site Survey
REGION:  II                                       DATE:   February 8, 1984


SITE:  Love Canal                                 CONTACT:   Rob Raad
                                                            EPA Region II
                                                            212/264-0109

LOCATION:  Niagara Falls, New York


HISTORY OF USE:  Love Canal is a 16-acre below-ground landfill.  In the
mid-to-late 1970's, continued periods of high precipitation raised the water
table, carrying chemically contaminated leachate to the  surface and into
contact with basement foundations.
WASTES ON SITE:  Acids, chlorides, mercaptans, phenols, toluenes, pesticides,
chlorobenzenes, benzylchlorides, sulfides and sulfydrates.


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:   About 300 homes
are located immediately adjacent to the site, and another 500 homes are
located in the surrounding area.  The homes in the immediate  vicinity were
evacuated in 1978 and demolished in 1983.  Of the homes in  the surrounding
area, only 10 percent are still occupied.


CRITERIA FOR DETERMINING CONTAMINATION:
METHOD OF DECONTAMINATION:  Currently, the CDC, HHS, and NY State Department
of Health are conducting a habitability study to determine what must be done
in order for families to be able to move back into their homes.  Recommenda-
tions are 1-1/2 yr away.


EQUIPMENT:


WORKER PROTECTION:


EVALUATION OF DECONTAMINATION EFFECTIVENESS:


COSTS:
                                    135

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Appendix A:  Superfund Site Survey
REGION:  III                                      DATE:  September 26, 1983


SITE:  Lehigh Electric &                          CONTACT:  Tony Bartolomeo
       Engineering Co.                                      EPA Region III
                                                            215/597-8180

LOCATION:  Old Forge, Pennsylvania


HISTORY OF USE:  Electrical equipment, including transformers and capacitors,
were stored at the site.


WASTES ON SITE:  PCB's.


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:  Concrete slabs.


CRITERIA FOR DETERMINING CONTAMINATION:


METHOD OF DECONTAMINATION:  Slabs will be scrubbed with a solvent (probably
diesel fuel), sealed, and covered with dirt.


EQUIPMENT:


WORKER PROTECTION:


EVALUATION OF DECONTAMINATION EFFECTIVENESS:  Wipe sample.


COSTS:  The cost of the entire project is an estimated $5 million.
                                    136

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                                           Appendix A:  Superfund Site Survey
REGION:  V


SITE:  Chem-Dyne



LOCATION:   Hamilton, Ohio
DATE:  February 8, 1984
CONTACT:  Donald Bruce
          EPA Region V
          312/886-0399
HISTORY OF USE:  Chemical waste transfer and storage.
WASTES ON SITE:  Pesticide wastes and residues, organic solvents, fire
retardants, lab chemicals.
DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:   Several  build-
ings are situated on or near the site.  The principal  building is a combina-
tion office/warehouse.  The office portion burned in a fire in April  1983.
The warehouse portion had been used for equipment and waste storage.   It is
approximately 100 yd long by 75 ft wide with steel  beam construction  and
brick and wood floorboards.  The building is in a dilapidated condition with
severe structural damage.  Some of the other buildings are in better  shape.


CRITERIA FOR DETERMINING CONTAMINATION:  CH2M Hill  conducted  a facilities
inventory as part of their remedial investigation.   The inventory consisted
of photos, visual inspections, and observations.   There is considerable
evidence of waste spillage, i.e., soaked floorboards,  etc.


METHOD OF DECONTAMINATION:  A remedial investigation/feasibility study is
currently being conducted.  The principal building  will probably be removed;
however, some of the others may be candidates for decontamination.  The RI/FS
will be available for public distribution in July 1984 and may be obtained
from the Miami University library in Oxford, Ohio.
EQUIPMENT:
WORKER PROTECTION:
EVALUATION OF DECONTAMINATION EFFECTIVENESS:
COSTS:
                                    137

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Appendix A:  Superfund Site Survey
REGION:  VI                                       DATE:   February 14, 1984


SITE:  Bio-Ecology Systems, Inc.                   CONTACT:   Steve Romanow
                                                            EPA Regin VI
                                                            214/767-9716

LOCATION:  Grand Prarie, Texas


HISTORY OF USE:  Permitted for incineration, chemical  treatment, biological
oxidation of wastewaters, and landfill  of solids resulting  from treatment
processes.


WASTES ON SITE:  Heavy metal  sludges, chlorinated organics, volatile organ-
ics, PCB's.


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:  Sixteen tanks
ranging from 5000 to 20,000 gal  and a sheet metal shack.


CRITERIA FOR DETERMINING CONTAMINATION:   Tanks contained  hazardous materials.


METHOD OF DECONTAMINATION:  Tanks were emptied, cleaned with a heavy strength
industrial cleaner, double rinsed, and steam cleaned.   Water was collected
and taken to a secure landfill.   Tanks and the shack were cut up with a torch
and removed.


EQUIPMENT:  High-pressure hose,  organic vapor analyzer.


WORKER PROTECTION:  Level B.   To the extent possible,  nobody entered the
tanks.
EVALUATION OF DECONTAMINATION EFFECTIVENESS:   Tanks were checked with an OVA
until readings were at background levels.


COSTS:  Bid at $99,868 (includes safety requirements).
                                     138

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                                           Appendix A:   Superfund Site Survey
REGION:   VII                                      DATE:   January 1984


SITE:  Quail Run Mobile Manor                     CONTACT:   Bill Keffer
                                                            EPA Region VII
                                                            913/236-3880

LOCATION:  Gray Summit, Missouri


HISTORY OF USE:  Waste oil was sprayed on the roads in this mobile home park
to control dust.


WASTES ON SITE:  Dioxin-contaminated soil.


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:  Mobile homes.


CRITERIA FOR DETERMINING CONTAMINATION:  Dioxin-contaminated dust found in
household vacuum cleaner bags.


METHOD OF DECONTAMINATION:  Vacuuming using HEPA filters, damp wiping, and
cleaning of crevices with a soft bristle paint brush.


EQUIPMENT:  HEPA filter-equipped vacuums, soft bristle paint brushes.


WORKER PROTECTION:  Level C protection.


EVALUATION OF  DECONTAMINATION EFFECTIVENESS:  Stringent visual evaluation.


COSTS:   $870/residence
                                     139

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Appendix A:  Superfund Site Survey
REGION:  VIII
DATE:  February 14, 1984
SITE:  Anaconda Smelter                      CONTACT:  Bruce Schmitt
                                                       Cleveland Wrecking
                                                       406/563-3464

LOCATION:  Anaconda, Montana
HISTORY OF USE:  Copper smelter.
WASTES ON SITE:  Flue dust contaminated with arsenic (up to 30 percent),
lead, and cadmium (considered a mining waste).


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:   Over 100 build-
ings are on site, some of which are very old.  Hydrometallurgical  processes
concentrated the raw ore while pyrometallurgical  processes burned  off the
impurities.  Flue dust collected in the flue system associated with the
ovens.
CRITERIA FOR DETERMINING CONTAMINATION:   The ESP unit is full  of contaminated
flue dust (50 ft deep), as is the flue system (2400 ft long, 20 ft deep).
Process dust is in all of the buildings.


METHOD OF DECONTAMINATION:  The buildings are being torn down.   The dust is
handled as it is encountered.  A front-end loader picks up the  dust and de-
posits it in a dump truck to be taken to  a secure landfill.  Water is sprayed
continuously to keep fugitive emissions  down.
EQUIPMENT:  Front-end loaders, dump trucks, hoses.
WORKER PROTECTION:  Workers wear respirators (air-powered,  full  face,  or half
mask) and cloth suits with gauze to tie off the sleeves and pant legs.   (The
suits are laundered every night.)  "Dirty" rooms are separated from "clean"
rooms, and workers must take showers before leaving for the day.
EVALUATION OF DECONTAMINATION EFFECTIVENESS:
COSTS:  The cost of the whole project is an estimated $9 million;  $1 million
of which is allocated for the removal of contaminated flue dust and other
environmental and human health hazards.
                                    140

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                                           Appendix A:   Superfund Site Survey
REGION:   IX                                       DATE:   September 28, 1983


SITE:   Taputimu Farm                              CONTACT:   Marvin Young
                                                            EPA Region IX
                                                            415/974-8142

LOCATION:  American Samoa


HISTORY OF USE:  Part of an agricultural  experimental  farm used to store
unused chemicals and pesticides.


WASTES ON SITE:  Pesticides.


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT ON SITE:  Three rooms of
a warehouse and a trailer are suspected of being contaminated.  Once the
buildings have been decontaminated, they will  be used to store equipment.


CRITERIA FOR DETERMINING CONTAMINATION:  The warehouse floods regularly, and
some hazardous materials have reportedly been washed out of the facility.


METHOD OF DECONTAMINATION:  Currently a record of decision is being devel-
oped.   Remedial action which has  been recommended includes total removal of
all materials (pack or overpack,  ship to mainland to an approved disposal
site); sweeping, vacuuming, and wiping down of all buildings; and sealing
decontaminated surfaces.
EQUIPMENT:


WORKER PROTECTION:


EVALUATION OF DECONTAMINATION EFFECTIVENESS:  Surface sampling.


COSTS:  Projected $160,000.  Razing the site was not considered.
                                    141

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Appendix A:  Superfund Site Survey
REGION:  IX                                       DATE:  October 31, 1983


SITE:  MGM Brakes                                 CONTACT:   David Sykes
                                                            IT Corp.
                                                            415/228-8400

LOCATION:  Cloverdale, California


HISTORY OF USE:  Between 1965 and 1972, this facility operated casting ma-
chines that used hydraulic fluids containing PCB's.   These  fluids were
discharged to the ground on site.


WASTES ON SITE:  Waste oil containing PCB's.


DESCRIPTION OF BUILDINGS, STRUCTURES, AND EQUIPMENT  ON SITE:   Aluminum butler
buildings with concrete slab floors (40,000 ft2), aluminum  casting machinery
and other metal handling equipment, and concrete drainage grates.


CRITERIA FOR DETERMINING CONTAMINATION:  The State determined that the entire
facility is contaminated.


METHOD OF DECONTAMINATION:  High-pressure water, detergent, and solvent on
floors, walls, ceilings, roofs, and equipment.


EQUIPMENT:  10,000 psi water blaster.


WORKER PROTECTION:  Tie-back clothing, rainsuits, boots, gloves, respirators,
and continuous workplace monitoring.  A perimeter was established around the
contaminated area.
EVALUATION OF DECONTAMINATION EFFECTIVENESS:   Surfaces that tested <70 yg
PCB/100 cm2 were considered clean.
COSTS:  $300,000.  It would have cost several  million dollars to raze and
rebuild the site.
                                    142

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                                 APPENDIX B

                              SAMPLING METHODS


     This appendix presents two basic surface sampling techniques (wet-wipe
and dry-wipe sampling), as well as techniques for measuring asbestos fibers
in air and heavy metal and explosives contamination in sumps.

     In surface-wipe sampling, a surface is wiped with a cotton swab or
filter paper that may or may not be wetted with a solvent.   The sample is
then submitted to a laboratory for analysis of appropriate  chemical  contami-
nants.  This approach usually provides fairly reliable information on the
presence of contaminants, but it often suffers from two major  deficiencies.
First, the collection efficiency of this sampling procedure is unknown and
highly variable; therefore, maximum analytical sensitivity  must be used when
analyzing these samples.  Secondly, sample turnaround time  may be quite long.
Surface wipe sampling will confirm that a target concentration has been
reached or that additional cleanup is necessary, but it will not give a quick
or real-time check on decontamination efforts.  In these instances,  chemical
spot tests or direct reading instrumental evaluations may be preferable to
wipe tests (personal communication from C. L. Geraci, Jr.,  Division  of Physi-
cal Sciences and Engineering, National Institute for Occupational Safety and
Health, Cincinnati, Ohio, August 30, 1984).  These tests are described in
References 1, 2, 3, and 4 at the end of this appendix.


WET-WIPE TEST (VERSION A)

     Building surfaces and vents at Frankford Arsenal  were  tested with ace-
tone-saturated cotton swabs to determine explosives contamination.5

Materials

     The following materials are needed in this test:

          Q-tip, wooden stem
          Acetone, "distilled-in-glass" Nanograde
          2 dram vial with Teflon-lined cap
          Amber glass bottle, 1 pint
          Plastic Nalgene bottle, 1 quart
                                    143

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Appendix B:  Sampling Methods
Procedure

     Swab test procedures are as follows:

     0    Mark off five 5-cm-diameter circles distributed at the four corners
          and center of a 1-m2 area for building surfaces or one 5-cm-diame-
          ter circle for vents and other surfaces.

     0    Dip a wooden stem Q-tip in a 2-dram vial  containing 1.5 ml  of
          acetone.  Swab one circle at a time, dipping the Q-tip in the
          acetone before and after each circle is swabbed.

     0    When all circles have been swabbed, tightly seal the acetone-con-
          taining vial with a Teflon-lined cap and  discard the used swab.

     0    Preserve the collected sample at 4°C.

     0    Prior to analysis, allow the sample to warm to ambient temperature.

     0    To compensate for possible solvent evaporation during transport,
          adjust the final volume of the sample with acetone to 1.5 ml.

     0    Analyze the sample for explosive compounds by directly injecting
          20 yl of the acetone extract into a high-pressure liquid chromato-
          graph.

     0    When resampling an area following surface decontamination,  position
          the sampling grid 15 cm to the right of the initial sampling points
          or, if movement to the right is  restricted, 15 cm downward.


WET-WIPE TEST (VERSION B)

     Cotton swabs soaked in an acetone/hexane mixture were used to sample  for
dioxin on smooth, solid, nonabsorbing surfaces (e.g., ceramic tiles,  polished
marble, and glass panes) in Seveso, Italy.6

Materials

     The following materials are needed in this test:

          Cotton swab, degreased
          Acetone, pesticide grade
          Hexane, pesticide grade
          Isooctane, pesticide grade
          Metal clamp
          Glass-stoppered glass jar
          10-ml cone-shaped-bottom vial with glass  stopper or Teflon-lined
           screw cap
                                     144

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                                                Appendix B:  Sampling Methods
Procedure

     Wet wipe procedures are as follows:

     0    Mark off a square area of approximately 0.25 m2 on the surface to
          be wiped.

     0    While holding in a clean metal clamp, saturate a 10-g degreased
          cotton swab with 20 to 30 ml of a 1:4 acetone/hexane mixture.

     0    While still holding the cotton swab in the clamp, wipe the sampling
          area back and forth repeatedly in a vertical direction, applying
          moderate pressure.

     0    Turn the swab over and wipe back and forth in the horizontal  direc-
          tion.

     0    Store the used swab in a glass-stoppered glass jar until  extraction
          can be performed.

     0    Extract the used swab with three fractions (200 ml each)  of the 1:4
          acetone/hexane mixture.

     0    Pool the three fractions and dry under vacuum.

     0    Clean the extraction residue by column chromatographic techniques.

     0    Store the dried sample from the final cleanup step in a 10-ml
          cone-shaped-bottom vial sealed with either a glass stopper or a
          Teflon-lined screw cap.

     0    Analyze the sample for TCDD by dissolving the residue in  a known
          volume of isooctane and injecting an aliquot into a low-resolution
          gas-liquid chromatograph in combination with an MID/mass  spectrome-
          ter.  A detection threshold in the range of 1 to 20 ng/m2 for this
          analysis scheme has been reported in the literature.


DRY-WIPE TEST

     Building and vent surfaces suspected of radiological contamination at
Frankford Arsenal were sampled by a dry-wipe technique.7

Materials

     A 2.4-cm-diameter filter paper disk is required for this test.
                                     145

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Appendix B:  Sampling Methods
Procedure

     Dry wipe test procedures are as follows:

     0    Wipe a 2.4-cm-diameter filter paper disk in a Z or S pattern over a
          representative portion of the surface to be sampled, using the tip
          of the thumb.  The length of the wipe should be 50 cm.   (Since the
          pressure-bearing portion of the filter paper disk will  be about 2
          cm wide, the area of the surface sampled will be approximately 100
          cm2.)

     0    Avoid contacting excess dirt when wiping an area.

     0    Test the sample with appropriate instruments for determining radio-
          logical contamination.


ASBESTOS FIBERS IN AIR

     The NIOSH method for measuring asbestos fibers in air (Method No. P &
CAM 239, 1977) is the method currently used by OSHA for assessing occupation-
al exposures to airborne fiber concentrations.8

Materials

     The following materials are needed for sample collection:

          Battery-powered personal sampling pump capable of sampling at a
           flow rate of 1.0 to 2.5 liters per min.
          Rubber or plastic tubing
          Clothing spring clip
          Tubing-to-field monitor adaptor
          Field monitor (filter and holder) - manufactured by Millipore
           Corporation; a three-section styrene plastic case, 37-mm diameter
           plain white cellulose ester membrane with 0.8 ym pore  size, sup-
           port pad, and two plastic sealing caps

Procedure

     The principle of the sampling method is to draw air through  a membrane
filter by means of a personal sampling pump.  Asbestos fibers, collected on
the membrane filter, are sized and counted using phase-contrast microscopy.
Sample collection procedures are as follows:

     0    Calibrate personal sampling pumps in the laboratory before field-
          use to a flow rate of 1.0 to 2.5 liters per min.

     0    Attach the sampling pump to a worker's belt (for a personal  expo-
          sure measurement) or to a stationary location (for an area measure-
          ment).


                                     146

-------
                                                Appendix B:  Sampling Methods
     °    Remove the top cover of the field monitor.  Invert the monitor so
          that the exposed filter is facing downward.

     0    Turn on the sampling pump.

     0    Record the following information:  filter number, pump start time
          and date, flow rate, subject's name and job title (personal sample)
          or location (area sample), and type of operation or process.

     0    Periodically check the sampling equipment for proper operation and
          flow rate.

     0    Optimum sampling time is generally 6 to 8 h.

     0    At the end of the sampling time, turn off the pump and recap the
          field monitor.

     0    Analyze the sample by phase-contrast microscopy.  For sample vol-
          umes of approximately 1000 liters of air, the lower detection limit
          is about 0.03 fibers per cm3 of air.  This method does not distin-
          guish asbestos fibers from nonasbestos fibers.


SUMP SAMPLING

     The degree and character of sump contamination at the Frankford Arsenal
were assessed by collecting and analyzing sump samples for heavy metals and
explosives.5

Materials

     The following materials are required for sump sampling:

          Wastewater vacuum pump sampler
          Tygon tubing, 1 cm.i.d.
          Amber glass bottle, 500 ml
          Polyethylene bottle, 1 liter
          Rubber stopper

Procedure

     Procedures for sump sampling  are as follows:

     0    Attach a clean piece of  Tygon  tubing (about 0.3 to  0.5 m)  to the
          silicone rubber tubing outlet  of the sampler (see Figure B-l).

     0    Connect the other end of the Tygon tubing to the inlet tube in  the
          stopper of the sample container (polyethylene bottle  for heavy
          metal  contamination, glass bottle for explosives contamination).
                                     147

-------
               OUTLET
k
CONTROL
BOX 	 *•
f






i
PUMP 1
/
i
— i

i
SILICONE7
RUBBER



TUBING





























^t

I1 '
II \
/ /
/ /
INLET //
















1 (





RELIEF r=->
VALVE"^^7tn^









^















— ^
**^.
< 	 SILICONE
RUBBER
TUBING
OUTLET
< — TYGON
TUBING
SAMPLE
^--INLET TUB
rf 	 SAMPLE
BOTTLE






ING




STRAINER/WEIGHT 	 	

























Sj^














/
>
— *o
>
>
)
>










^ 	 TYGON
TUBING




Ii
oc
oc
oc
oc
oc
oc
Figure B-1.   Sump sampling  configuration.
                  148

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                                      Appendix B:  Sampling Methods
Place the sample container at the bottom of the sampler and secure
it with tape or padding.

Close the sampler lid.

Attach a second piece of Tygon tubing of sufficient length to reach
the bottom of the sump to the silicone rubber tubing inlet of the
sampler.

Connect the strainer/weight to the other end of the Tygon tubing.

Lower the strainer/weight-bearing end of the tubing into the sump.

Set the volume selector control to the desired volume corresponding
to the head height, and turn the pump switch to "auto."

When the sample has been collected, open the sampler, remove the
bottle, and replace it with an empty bottle.

Remove the tubing assembly from the well.

Flush out the sampler by running a large volume of distilled water
through it.

Clean the strainer/weight with lab glassware detergent and rinse
with distilled water.

Replace the Tygon tubing between sampling of wells to avoid cross-
contamination of sump samples.

Preserve the sample at 4°C.   Prior to analysis, allow the sample to
warm to ambient temperature.

Filter the sample through a  Whatman 2 filter to remove suspended
insoluble material.

Analyze the filtrate and residue for explosives by high-pressure
liquid chromatography.
                          149

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Appendix B:  Sampling Methods
                          REFERENCES FOR APPENDIX B
 1.  Weeks, R. V!., B. J. Dean, and S. K. Yasuda.  Detection Limits of Chemi-
     cal Spot Tests Toward Certain Carcinogens on Metal, Painted and Concrete
     Surfaces.  Analytical Chemistry, 48(14):2227-2233, 1976.

 2.  Schuresko, D. D.  Portable Fluorometric Monitor for Detection of Surface
     Contamination by Polynuclear Aromatic Compounds.  Analytical Chemistry,
     52(2):371-373, 1980.

 3.  Vo-Dinh, T., and R. B. Gammage.  The Lightpipe Luminoscope for Monitor-
     ing Occupational Skin Contamination.  American Industrial Hygiene Asso-
     ciation Journal, 42(2):112-119, 1981.

 4.  Jacot, B. J.  OVA Field Screening at a Hazardous Waste Site.  In:
     National Conference on Management of Uncontrolled Hazardous Waste Sites,
     Washington, D.C., October 31 - Novembsr 2, 1983.  Hazardous Materials
     Control Research Institute, Silver Spring, Maryland, 1983.

 5.  Rockwell International.  Final Report for the Frankford Arsenal Decon-
     tamination/Cleanup Program.  DRXTH-FE-CR-800, December 1980.

 6.  Di Domenico, A., et al.  Accidental Release of 2,3,7,8-Tetrachlorodi-
     benzo-p-dioxin  (TCDD) at Seveso, Italy.  I.  Sensitivity and Specificity
     of Analytical Procedures Adopted for TCDD Analysis.  Ecotoxicology and
     Environmental Safety, 4:283-297, 1980.

 7.  Tuttle, R. J.   Frankford Arsenal Decontamination/Cleanup Operation -
     Radiological Inspection for Release for Unrestricted Use.  Rockwell
     International.  Pub.  No. N505SRR000004, December  1980.

 8.  U.S.  Department of Health, Education, and Welfare.  NIOSH Manual of
     Analytical Methods.   2nd Edition.  Volume 1.  DHEW  (NIOSH) Publication
     No. 77-157A, 1977.
                                     150

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                                 APPENDIX C

                                COST ANALYSIS
     This appendix presents an order-of-magnitude cost analysis for several
of the well-established decontamination methods described in Section 4.   For
comparison of the costs of the different methods, a model building having the
following characteristics* was assumed:

     0    The building has two stories and is 60 ft long, 30 ft wide, and 25
          ft high (inside dimensions).

     0    Each of the two stories has 1800 ft2 of floor area and 1800 ft2 of
          ceiling area, and the building's total wall  area is 4500 ft2.

     0    The floor slabs and walls are constructed of concrete; the ceilings
          are covered with asbestos panels.

     0    The walls and foundation are 1 ft thick; the floor of the second
          story is 4 in. thick.

     0    The building contains 5 tons of steel, including 1 boiler, 60  ft of
          piping, and stairs.


COST ESTIMATE BASES

Capital Costs

     Costs for methods 5, 8, 13, 15, 16, and 18 were based on the assumption
that the needed equipment would have to be purchased.   (For all other meth-
ods, equipment rental was assumed.)  Capital equipment costs are based on
Peters and Timmerhaus,1 Means 1982,2 Means 1984,3 Decommissioning Handbook,4
The Chemical Marketing Reporter,5 and in-house estimates.

Equipment Rental Costs

     Costs for rental of equipment are based on Means2'3 or represent quotes
from vendors.
*
  Unit costs in the literature are expressed in U.S.  customary units.   For
  this reason, the dimensions of the building are also expressed in U.S.
  customary units, and metric conversion factors are  presented at the  end of
  this appendix (Table C-17).


                                    151

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Appendix C:  Cost Analysis
Operating Costs

     The operating cost components include labor, administration and over-
head, and materials/other.

Labor--
     The labor rate is estimated to be $12/h.   Labor encompasses setup,
operation, tear-down, waste disposal, and refinishing the building.   The
following assumptions were made for estimating labor times:

     0    Equipment tear-down time equals 75 percent of setup time.

     0    Normal cleanup requires 80 h per building and includes repainting.

Administration and Overhead--
     Administration and overhead costs are assumed to be four times  those of
labor costs.  These costs include purchasing,  safety analysis, verification
of decontamination, and normal amounts of utilities (steam,  electricity,
water, sanitary sewage).  Waste disposal costs are assumed to be part of
overhead unless the waste generated is hazardous and requires incineration or
disposal in a secure landfill.

Other Operating Costs--
     Material costs are assumed to be the delivered price of the material.
Material cost estimates are based on costs in The Chemical Marketing Repor-
ter5 or a specialty chemical catalog.

     The cost of Level C protective gear (consisting of coveralls, boots,
gloves, respirator, and hard hat) is assumed to be $1000.  If special protec-
tive gear (e.g., fully encapsulating suit, self-contained breathing  appara-
tus) is required, the cost would be considerably higher.

     It is assumed that hazardous wastes generated as a result of decontamin-
ation operations and requiring incineration or disposal in a secure  landfill
will be handled at $12/ft3.

     Costs for sampling and analysis of contaminants and long-term monitoring
of residuals are not included in this cost analysis.


RELATIVE COST PERSPECTIVE

     The costs presented  in this section are preliminary cost estimates with
a best accuracy of ±50 percent.  Site-specific factors, particularly the
nature of the contaminants present, will influence the actual decontamination
costs.  A summary of the  cost estimates developed in this appendix is pre-
sented in Table C-l.
                                    152

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   TABLE C-l.  SUMMARY OF ESTIMATED COSTS FOR SELECTED DECONTAMINATION METHODS
   Decontamination
       method
       Building
     applicability
Estimated
cost,  $
Building replacement
Asbestos removal
Asbestos encapsulation
Absorption
Demolition
Dismantling
Dusti ng/vacuumi ng/wi pi ng
Gritblasting
Hydroblasting
Painting/coating
Scarification
Steam cleaning
Acid etching
Bleaching
Flaming
Drilling and spelling
Entire building (3600 ft2)
Ceilings (3600 ft2), pipe (60 ft)
Ceilings (3600 ft2)
One floor (1800 ft2)
Entire building (3600 ft2)
Boiler, stairs, pipe (60 ft)
Floors (3600 ft2)
Walls, floors (8100 ft2)
Walls, floors (8100 ft2)
Walls (4500 ft2)
Walls, floors (8100 ft2)
Walls, floors (8100 ft2)
Walls, floors (8100 ft2)
Walls, floors (8100 ft2)
Walls, floors (8100 ft2)
Walls, one floor (6300 ft2)
 120,000
  24,540
   2,160
   3,760
  66,070
   5,038
   3,560
  53,863
 137,004
   3,365
  59,455
  22,760
  10,087
  16,162
   3,132
 109,922
  Includes labor, equipment, materials, waste disposal,  overhead,  and profit.
                                      153

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Appendix C:  Cost Analysis
     The summary in Table C-l permits a comparison of the order-of-magnitude
costs of each of the decontamination methods and serves as a perspective for
analysis of decontamination versus removal  and replacement.  Removal  and
replacement of the contaminated building and associated equipment would
require the following:

     Removal of asbestos from ceilings and  pipe             $ 24,540
     Dismantling of boiler, stairs, and pipe                   5,038
     Demolition of building (including disposal of debris)    66,070
                                        Subtotal            $ 95,648
     Construction of replacement building                    120,000
                                        Total               $215,648

     Decontamination of buildings, structures, and equipment at Superfund
sites should be considered only when such action is cost-effective; i.e.,
when the costs of decontamination are less  than those of removal  and disposal
of the contaminated structure and construction of a replacement building.


INDIVIDUAL COST ANALYSES

Asbestos Removal (Method 1A)

     Costing of this technique is based on  the assumption that asbestos was
present in the building as asbestos panels  covering the ceilings  and asbestos
insulation along the pipes.  Therefore, the total area of ceiling paneling to
be removed would be 3600 ft2, and the total length of insulation  to be re-
moved from pipes would be 60 ft.

     Price quotes obtained from an asbestos-removal company included labor,
labor protection, asbestos disposal, equipment, overhead, and profit.6

     The removed asbestos insulation would  have to be replaced with another
type of insulation.  A typical fiberglass insulation was chosen and costed
with prices taken from Means.3  These costs include labor, equipment, mater-
ials, overhead, and profit.

     A summary of the costs is given in Table C-2.

Asbestos Encapsulation (Method IB)

     The model building was assumed to have asbestos panels covering the
ceiling and asbestos  insulation along the pipes; therefore, 3600 ft2 of
ceiling and 60 ft of  pipe would require treatment.

     The method of encapsulation was assumed to be by sprayed sealant.  Labor
costs for this technique and labor output rates were found in Means.3  A rate
of 6666 ft2/day was given for ceiling encapsulation, and a rate of 1538 ft/
day was given for pipe encapsulation.  Therefore,  less than a day should be
required for treatment of the model building.


                                    154

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                  TABLE C-2.   ASBESTOS REMOVAL COST ANALYSIS
                                (1984 dollars)
                 Item
                                                              Cost,  $
Operating costs

  Removal of ceiling insulation

                           ,a,b
                            a,b
$6.00/ft2 x 3600 ft2 =
  Removal of pipe insulation

   $9.00/ft x 60 ft =
  Replacement of ceiling insulation


                               ,c.d
                                c,d
$0.45/ft2 x 3600 ft2 =
  Replacement of pipe insulation

   $13.00/ft x 60 ft =

  Protective gear6


     TOTAL OPERATING COSTS
21,600


   540


 1,620


   780

 	U_


24,540
3 Includes labor, labor protection, asbestos cleanup and disposal, equipment,
,  overhead, and profit.
  Reference 6.
^ Includes labor, materials, overhead, and profit.
a Reference 2.
e Cost of personnel protection is included in the decontamination costs (i.e.,
  removal).  No personal protective gear is expected to be necessary during
  insulation replacement.
                                     155

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Appendix C:  Cost Analysis
     Each gallon of sealant was estimated to cover 200 ft2  of ceiling  or
100 ft of pipe.  Therefore, the number of gallons of sealant required  to com-
plete the job would be:

          3600 ft2   ,  60 ft      _ 1Q   ,
         200 ft2/gal   100 ft/gal  " iy gai

     A summary of the costs is given in Table C-3.

Absorption (Method 2)

     Absorbents are only suitable  for spills on metal  and well-sealed  wood
surfaces; concrete tends to absorb the spill before it can  be retrieved.
Therefore, for the purpose of this cost analysis, the  first story of the
building is assumed to have a wood floor on which 100  gal of hazardous liquid
has been spilled.

     Assuming the use of diatomaceous earth at 20 Ib/gal  of liquid spilled,  a
total of 2000 Ib of absorbent would be needed.

     Costing of the disposal of the contaminated absorbent  was based on an
estimate that each 50-lb bag would assume a volume of  2 ft3 when wet.   There-
fore, the volume of hazardous debris requiring landfill  would be:

          2000 Ib absorbent x 2 ft3/50 Ib = 80 ft3

     A summary of costs is given in Table C-4.

Demolition (Method 3)

     The cost for demolition of the model concrete building was calculated
with a cost figure given in Means.3  This figure was given  in terms of the
volume of the building based on external dimensions.  For the model building,
these dimensions are 62 ft long x  32 ft wide x 27 ft high.   Thus, the  volume
of the building would be:

          62 ft x 32 ft x 27 ft =  53,568 ft3

     It was assumed that the debris generated would have to be disposed of in
a hazardous waste landfill.  Because of the large amount of debris involved,
a cost for bulk hazardous disposal was derived from a  combination of in-house
estimates and a vendor's quote.

     A summary of costs is given in Table C-5.

Dismantling (Method 4)

     This cost analysis is restricted to the 5 tons of steel equipment (boil-
er, stairs, 60 ft of pipe) included in the model building.   It was assumed
                                     156

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               TABLE C-3.  ASBESTOS ENCAPSULATION COST ANALYSIS
                                (1984 dollars)
               Item
                                Cost, $
Operating costs
Labor
  Encapsulation of ceiling panels
   $0.14/ft2 x 3600 ft2 =
  Encapsulation of pipes3'
   $0.59/ft x 60 ft =
Other operating costs
  Encapsulant0
   $31/gal x 19 gal =
  Sprayer rental
   $31/day x 1 day =
  Level C protective gear
     TOTAL OPERATING COSTS
a,b
               $  504

                   36
               $  589

                   31
                1,000
                                                                    540
                                                                  1,620
                                 2,160
? Includes setup, tear-down, overhead, and profit.
  Reference 3.
  Reference 2.
                                    157

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                   TABLE  C-4.  ABSORPTION  COST  ANALYSIS
                              (1984  dollars)
Item
Operating costs
Labor
Application of absorbent
6 h/building 6 h
Cleanup9
20 h/building 20 h
26 h
At $12/h, labor = 26 h x $12/h =
Overhead
At 4 x labor cost = 4 x $312 =
Other operating costs
Absorbent
$6/50-1 b bag x 40 bags = $ 240
Landfill ing of debris9
$12/ft3 x 80 ft3 = 960
Level C protective gear 1^000
TOTAL OPERATING COSTS
Cost, $





312

1,248



2.200
3,760
Estimate.
Vendor quote.
                                  158

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                     TABLE C-5.  DEMOLITION COST ANALYSIS
                                (1984 dollars)
               Item
                             Cost, $
Operating costs
  Demolition and cleanup of building
   $0.21/ft3 x 53,568 ft3 =
  Landfilling of debris (in bulk)0
   $7.80/ft3 x 6900 ft3 =
  Level  C protective gear
     TOTAL OPERATING COSTS
a,b
                              11,250

                              53,820
                               1.000

                              66,070
.  Includes labor, equipment, materials, overhead, and profit.
  Reference 2.
  Estimate.
                                     159

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Appendix C:  Cost Analysis
that none of the equipment was salvageable and that all of it must be dis-
posed of in a hazardous landfill.  A quote on a bulk rate for hazardous
disposal was obtained from a vendor.

     Costs for pipe and stair dismantlement (including labor, equipment,
materials, overhead, and profit) were taken from Means.3

     A summary of costs is given in Table C-6.

Dusting/Vacuuming/Wiping (Method 5)

     Almost all the cost for this decontamination method is for labor.  The
only capital cost would be for some small commercial vacuums.

     For this cost analysis, it was assumed that both floors of the building
were contaminated with hazardous dust, and that a single treatment would
satisfactorily clean the building surfaces.

     A summary of costs is given in Table C-7.

Gritblasting (Method 7)

     Gritblasting would be used to remove the contaminated surface of both
concrete walls and floors; therefore, the total area to be treated in the
model would be 8100 ft2.

     Means3 gave a cost for gritblasting that included labor, equipment,
materials, overhead, and profit.

     The daily amount of surface treated by a typical  machine (for 1/8-in.
surface removal) is 375 ft2, which would entail the use 6 tons (133.3 ft3) of
grit.  Thus, the number of days required for the surface removal  would be:

          8100 ft2
          375 ftVday      '

     The amount of debris generated by this process would include the con-
crete removed:

          8100 ft2 x 1/8 in.  x 1 ft/12 in.  = 85 ft3

and the grit used by the machine:

          133.3 ft3/day x 21.6 days = 2880  ft3

     The volume of concrete removed from walls and floors was multiplied by a
factor of 1.5 to account for  expansion (the density of solid concrete is
                                    160

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                     TABLE C-6.  DISMANTLING COST ANALYSIS
                                (1984 dollars)
                    Item
                   Cost,  $
Operating costs
Labor
  Dismantling of boiler9
   25 h/boiler
  Cleanup of building9
   30 h/building

  At $12/h, labor cost = 55 h x $12/h
Overhead
  At 4 x labor cost = 4 x $660 =
Other operating costs
  Dismantling of pipe
   $2.30/ft x 60 ft =
  Dismantling of stairs
   $15/riser x 20 risers =
  Landfilling of debris0
   $60/ton x 5 tons =
  Level C protective gear
     TOTAL OPERATING COSTS
  25  h

  30  h
  55  h
5   138

   300

   300
1,000
                      660
                    2,640
                   1,738

                   5,038
j* Estimate.
  Includes labor, equipment, materials,  overhead,  and profit.
  Vendor quote.
                                    161

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              TABLE  C-7.   DUSTING/VACUUMING/WIPING  COST ANALYSIS
                                (1984  dollars)
Item
Operating costs
Labor
Vacuuming/dusting/wiping of floors3
40 h/building 40 h
At $12/h, labor = 40 h x $12/h =
Overhead
At 4 x labor cost = 4 x $480 =
Other operating costs
Level C protective gear
TOTAL OPERATING COSTS
Capital costs
Small hand-he'ld vacuum (Dustbuster) ^
4 @ $40 = $ 160
TOTAL CAPITAL COSTS
TOTAL COST OF DUSTING/VACUUMING/WIPING
Cost, $
480
1,920
1,000
3,400
160
3,560
.  Estimate.
D Vendor quote.
                                    162

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                                                  Appendix C:   Cost Analysis
greater than that of concrete chips and dust).   Thus,  the total  volume of
hazardous debris to be disposed of is:

          85 ft3 x (1.5) + 2880 ft3 s 3008 ft3

     A summary of costs is presented in Table C-8.

Hydroblasting (Method 8)

     The cost of a basic hydroblaster unit with a rate of 11 gal/min at
10,000 lb/in.2 was quoted by a manufacturer at $27,100 plus $6850 for acces-
sories that allow cleaning the inside of tanks, pipes, and sumps.

     The Decommissioning Handbook1* cites that a removal  depth of 0.74 in. at
a rate of 10 ft2/h is typical.  The time required to decontaminate the model
building (8100 ft2 of concrete surface) when two shifts  are used is:

          8100 ft2   J_day_ a
          10 ft2/h x  16 h - bi Gays

     A pump will be required for continuous removal  of water from the sumps.
A maximum hydroblasting rate of 11 gal/min requires  a pump capable of
11 gal/min plus about 20 ft of head.  The cost of the pump is $870.:

     If the water is to be recycled, storage tanks are required.  At a rate
of 11 gal/min, a tank holding one day's supply must  have a capacity of:

          11 gal/min x 60 min/h x 16h/day x 1 day =  11,000 gal

The cost of a mild-steel 11,000-gal tank is estimated to be $16,350.  The
need for two tanks is assumed, one for recycle water to be fed to the hydro-
blaster and one for storage.  If the hydroblaster removes 0.75 in. of surface
from the walls and floors, then the amount of debris to be disposed of would
be:

          8100 ft2 x 0.75 in. x 1 ft/12 in. = 507 ft3

     A summary of the costs is given in Table C-9.

Painting/Coating (Method 9A)

     For costing purposes, it was assumed that the walls would be the only
area coated; therefore, the total area to be painted would be 4500 ft2.

     It was also assumed that 3 coats (1 coat primer, 2 coats semigloss) of
paint would be applied with a sprayer.  If another type of coating was de-
sired, the number of coats and cost of materials would probably be different.
                                    163

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                    TABLE C-8.   GRITBLASTING COST ANALYSIS
                                (1984 dollars)
                    Item
                               Cost, $
Operating costs
  Gritblasting of walls and floors
   $2.07/ft2 x 8100 ft2 =
  Landfill ing of debris
   $12/ft3 x 3008 ft3 =
  Level C protective gear
     TOTAL OPERATING COSTS
a,b
                                16,767

                                36,096
                                 1,000

                                53,863
.  Includes labor, equipment, materials, overhead, and profit.
  Reference 3.
  Estimate.
                                      164

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        TABLE  C-9.  HYDROBLASTING COST  ANALYSIS
                     (.1984 dollars)
Item
Operating costs
Labor
Setup of tanks/pump
80 h/building 80 h
Setup of equipment3
1 h/day x 30 days 30 h
Hydroblasting of building
1 h/10 ft2 x 8100 ft2 810 h
Hydroblasting of equipment3
80 h/building 80 h
Cleanup (painting)
40 h/building 40 h
1040 h
At $12/h, labor cost = 1040 h x $12/h =
Overhead
At 4 x labor cost = 4 x $12,480 =
Other operating costs
Landfill ing of debris3
$12/ft3 x 507 ft3 = $ 6,084
Level C protective gear 1,000
TOTAL OPERATING COSTS
Capital costs
Hydroblaster (10,000-lb/in.2)c $27,100
Pipe- and tank-cleaning
accessories0 6,850
Sump pump (11-gal/min) 870
Storage tanks (11,000-gal)
2 @ $16,350 = 32,700
TOTAL CAPITAL COSTS
TOTAL COST OF HYDROBLASTING
Cost, $
12,480
49,920
7,084
69,484
67,520
137,004
  Estimate.
  Reference 4.
c Vendor quote.
  Reference 1.
                            165

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Appendix C:  Cost Analysis
     The number of man-hours required to cover 4500 ft2 with 3 coats of paint
was calculated using an output rate given by Means:3

          4500 ft2 x 0.2 h/100 ft2/coat x 3 coats = 27 h or ~ 4 days

     The amount of paint required for the task was calculated with a coverage
rate given by Means:3

          4500 ft2 x 1 gal/550 ft2 = 8.2 gal or = 9 gal per coat

     A summary of these costs is given in Table C-10.

Scarification (Method 10)

     Scarification would be used to remove the contaminated surface of both
concrete walls and floors; therefore, the total area to be treated in the
model would be 8100 ft2.

     Costs for scarification, which include operating cost, air consumption,
dust and chip removal, and subcontractors' overhead and profit, were taken
from the Decommissioning Handbook.^  These costs were updated from 1980
dollars to 1984 dollars by use of Chemical Engineering Cost Indices (June 11,
1984).

     The removal rate of a typical seven-piston floor scarifier is 315 ft2/h.
The removal rate for a typical three-piston wall scarifier is 72 to 108
ft2/h.  These rates represent a removal depth of 1 in.  The number of man-
hours (one operator) required to complete scarification would then be:

          3600 ft2      4500 ft2    7. ,
          315 ft2/h     72 ft2/h    '* n

     The volume of concrete removed from walls and floors was multiplied by a
factor of 2 to account for expansion (the density of solid concrete is great-
er than that of concrete chips and dust).

     The approximate volume of hazardous debris to be disposed of is then:

          8100 ft2 x 1 in. x 1 ft/12 in. x  (2) = 1350 ft3

     Because the scarifier leaves behind a  rough and uneven surface, addi-
tional cost would be incurred to patch the  floors and walls.

     A summary of the costs is given in Table C-ll.

Steam Cleaning  (Method 13)

     Steam cleaning would be used to clean  the concrete walls and floors of
the model building; therefore, the total area to be treated would be 8100
ft2.


                                    166

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                TABLE C-10.   PAINTING/COATING COST ANALYSIS
                              (1984 dollars)
Item
Operating costs
Labor
Setup and tear-down of equipment3
1 h/day x 4 days = 4 h
Painting of walls
27 h/bu Tiding 27 h
31 h
At $12/h, labor cost = 31 h x $12/h =
Overhead
At 4 x labor cost = 4 x $372 =
Other operating costs
Sprayer rental
$31/day x 4 days = $ 124
Paint (primer)
$14/gal x 9 gal = 126
Paint (semigloss)
$15/gal x 17 gal = 255
Level C protective gear 1,000
TOTAL OPERATING COSTS
Cost, $




372

1,488




1,505
3,365
Estimate.
Reference  3.
                                 167

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                   TABLE  C-ll.   SCARIFICATION  COST ANALYSIS
                                (1984  dollars)
Item
Operating costs
Scarification and cleanup of walls9'
$0.92/ft2 x 4500 ft2 =
Scarification and cleanup of floors '
$0.21/ft2 x 3600 ft2 =
Patching of walls3 >c
$4.35/ft2 x 4500 ft2 =
Patching of floors3 'c
$4.94/ft2 x 3600 ft2 =
Landfill ing debris
$12/ft3 x 1350 ft3 =
Level C protective gear
TOTAL OPERATING COSTS
Cost, $
4,140
756
19,575
17,784
16,200
1,000
59,455
? Includes labor, equipment, materials, overhead,  and profit.
  Reference 4.
j Reference 3.
  Estimate.
                                     168

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                                                  Appendix C:   Cost Analysis
     The rental cost for a 200-gal/h steam cleaner was taken from Means.3  It
was estimated that this cleaner could treat 100 ft2/h of surface.  Thus, the
number of man-hours requried to decontaminate the model  building would be:


          lQ°0°fWh   = 81 h or ~ 11 days

The following amount of contaminated, condensed steam would have to be col-
lected:

          200 gal/h x 81 h = 16,200 gal

This contaminated water would be collected in a sump.  A pump would be needed
to remove the water from the sump to a storage tank at a rate of 200 gal/h.
The tank should hold about one day's supply or:

          200 gal/h x 8 h = 1600 gal

Thus, a 2000-gal tank would be required.

     A bulk disposal cost was assumed for this hazardous liquid, at an esti-
mated $0.50/gal.

     A summary of costs is given in Table C-12.

Acid Etching (Method 15)

     Acid etching would be used to treat the walls and floors of the model
building; therefore, the area to be cleaned would be 8100 ft2.

     In this cost analysis, a commercial technique of acid etching/washing
was assumed.  This method would preclude the need for a neutralizing wash
following the acid wash; a simple water rinse would suffice.  A cost for the
treatment was found in Means,3 and it includes labor, equipment, materials,
overhead, and profit.  It was assumed that the water wash was also included
in this cost figure.

     An estimated 1/3 gal of contaminated liquid/ft2 of treated surface is
generated by this process (including both acid etching and the rinse wash).
Therefore, the total amount of hazardous liquid requiring disposal would be:

          8100 ft2 x 0.33 gal/ft2 = 2700 gal or 361 ft3

     A pump would be needed to transfer this liquid from the sump (where it
is collected) to drums for disposal.

     A summary of costs is given in Table C-13.
                                     169

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TABLE C-12.  STEAM CLEANING COST ANALYSIS
             (1984 dollars)
Item
Operating costs
Labor
Setup and tear-down of equipment
1 h/day x 11 days 11 h
Steam cleaning of walls and floorsa
81 h/building 81 h
92 h
At $12/h, labor cost - 92 h x $12/h =
Overhead
At 4 x labor cost = 4 x $1,104 =
Other operating costs
Steam cleaner rental
$40/day x 11 days = $ 440
Disposal of hazardous liquid
(in bulk)a
$0.50/gal x 16,200 gal = 8,100
Level C protective gear 1,000
TOTAL OPERATING COSTS
Capital costs
Sump pump (200 gal/h) $ 70°
Storage tank (2000-gal) 7,000
TOTAL CAPITAL COSTS
TOTAL COST OF STEAM CLEANING
Cost, $
1,104
4,416
9,540
15,060
7,700
22,760
? Estimate.
Reference 2-
                 170

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                    TABLE C-13.   ACID ETCHING  COST  ANALYSIS
                                (1984 dollars)
Item
Operating costs
Acid washing and rinsing of walls
and floorsa'b
$0.55/ft2 x 8100 ft2 = $ 4,455
Disposal of hazardous liquid0
$12/ft3 x 361 ft3 = 4,332
Level C protective gear 1,000
TOTAL OPERATING COSTS
Capital costs
Sump pump0 $ 300
TOTAL CAPITAL COSTS
TOTAL COST OF ACID ETCHING
Cost, $
9,787
300
10,087
.  Includes labor, equipment,  materials,  overhead,  and profit.
  Reference 2.
  Estimate.
                                    171

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Appendix C:  Cost Analysis
Bleaching (Method 16)

     Bleaching would be used to clean the concrete floors and walls of the
model building; therefore, the area to be treated would be 8100 ft2.

     It was assumed that the bleach solution (10 percent sodium hypochlorite)
would be applied manually.  One gallon of the solution was assumed to be
sufficient to treat 1 yd2 of the concrete surface; thus, the total amount of
solution required to treat the building would be:

          8100 ft2 x 1 yd2/9 ft2 x 1 gal/1 yd2 = 900 gal

     After the bleaching treatment, an estimated 2 gal of water would be
required to rinse each yd2 of surface.  Thus, the total amount of contami-
nated liquid to be collected would be:

     900 gal bleach solution + (2 x 900 gal rinse) = 2700 gal or 361 ft3

     This contaminated liquid would be collected in a sump.   A small pump
would remove the water and bleach solution from the sump and transfer it to
drums for disposal.

     A summary of costs is given in Table C-14.

Flaming (Method 17)

     Flaming would be used for surface decontamination of the concrete walls
and floors in the model building; therefore, the total area  to be treated
would be 8100 ft2.

     If a hand-held torch were used to flame the interior concrete surfaces
of the building, the rate of decontamination would be about  400 ft2/h.  Thus,
the number of hours required for decontamination of the model building would
be:


          400°ft2/h  = 21 h or ~ 3 days

     After the flaming effort, labor time was allowed for wash-down of the
concrete.  The purpose of the wash-down is to allow the concrete to regain
strength.

     A summary of costs is given in Table C-15.

Drilling and Spelling (Method 18)

     Drilling and spall ing would be used to remove the contaminated surface
of both concrete walls and floors.  The drilling and spalling rig can remove
1 to 2 in. of surface; 2 in. is assumed here.  Because the 2nd floor of the
                                     172

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                     TABLE C-14.  BLEACHING COST ANALYSIS
                                (1984 dollars)
                    Item
Cost, $
Operating costs
Labor
  Bleaching of floors and walls (includes
   application, scrub, and rinse)9
   162 h/building                           162 h
  At $12/h, labor cost = 162 h x $12/h =
Overhead
  At 4 x labor cost = 4 x $1,944 =
Other operating costs
  Bleach solution
   $0.90/gal x 900 gal =                   $  810
  Disposal  of hazardous liquid
   (by drum)9
   $12/ft3 x 361 ft3 =                      4,332
  Level  C protective gear                    1,000

     TOTAL OPERATING COSTS

Capital  costs
  Sump pump3                               $  300
     TOTAL CAPITAL COSTS

     TOTAL  COST OF BLEACHING
 1,944

 7,776
 6.142
15,862
   300
16,162
  Estimate.
  Vendor quote.
                                    173

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                    TABLE  C-15.   FLAMING  COST  ANALYSIS
                              (1984  dollars)
Item
Operating costs
Labor
Setup and tear-down of equipment9
1 h/day x 3 days = 3 h
Flaming of walls and floors3
1 h/400 ft2 x 8100 ft2 = 21 h
Cleanup (rinse)3
10 h/building 10 h
34 h
At $12/h, labor cost = 34 h x $12/h =
Overhead
At 4 x labor cost = 4 x $408 =
Other operating costs
Flamer rental (includes gas
consumption)
$4.35/h x 21 h = $ 92
Level C protective gear 1,000
TOTAL OPERATING COSTS
Cost, $
408
1,632
1,092
3,132
Estimate.
Reference 2.
                                  174

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                                                  Appendix C:  Cost Analysis
model building is too thin (4 in.) to withstand treatment, it will  have to be
demolished and then rebuilt.   Thus, the total  area to be drilled and spalled
would be 6300 ft2.

     The Decommissioning Handbook4 defined a typical  drilling and spallirig
crew to consist of five laborers and a front-end loader.

     The working rate of the machine is 67.5 ft2/h.   The number of hours  and
days that would be required for the process would be:


          67°5 fWh  = 94 h or ~ 12 days

     The amount of debris generated by this method would include the 2 in. of
concrete removed from walls and the first floor and the concrete from the
demolished second floor.  The volume of concrete removed from the walls and
floor was assumed to expand by a factor of 2.   The volume of the demolished
floor was assumed to expand by a factor of 3.   Thus the appropriate volume of
debris would be:

     6300 ft2 x 2 in. x 1 ft/12 in. x (2) + 1800 ft2  x 4 in. x 1 ft/12 in.
          x (3) = 3900 ft3

     Because the drilling and spalling process leaves behind a rough and
uneven surface, additional cost would be incurred to  patch the floor and
walls.

     A summary of the costs is given in Table  C-16.
                                    175

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     TABLE  C-16.   DRILLING  AND SPALLING  COST ANALYSIS
                             (1984 dollars)
                    Item
                                                               Cost, $
Operating costs
Labor
  Setup and tear-down  of  equipment3
   1 h/day x 12 days =
  Drilling and spall ing of walls and floors
   (including cleanup  of  rubble)
   94 h/laborer x 5 laborers =

  At $12/h, labor cost =  482 h x $12/h =
Overhead
  At 4 x labor cost =  4 x $5,784 =
Other operating costs
  Front-end loader rental (2.25-yd3)c
   $448.40/day x 12 days  =
  Demolition of second floor (including
   cleanup)0
   $2.23/ft3 x 1800 ft3 =
  Reconstruction of second floor0'
   $1.30/ft3 x 1800 ft3 =
  Patching of first floorc'd
   $4.94/ft2 x 1800 ft2 =
   12 h
  470 h
  482 h
  Patching of wallsc>d
   $4.35/ft2  x 4500  ft2 =
  Landfilling of  debris3
   $12/ft3 x  1650 ft3 =
  Level  C protective gear
     TOTAL  OPERATING COSTS
Capital  costs
  Drilling  and  spelling rig (including
   positioning  equipment)3'
     TOTAL  CAPITAL COSTS

     TOTAL  COST OF DRILLING AND SPALLING
$ 5,381


  4,014

  2,340

  8,892

 19,575

 19,800
  1,000
$20,000
                         5,784

                        23,136
                      61.002
                      89,922
                      20.000

                     109,922
a Estimate.
  Reference  4.
  Reference  3.
  Includes  labor, materials, equipment,  overhead, and profit.
                                  176

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TABLE C-17.  METRIC CONVERSION FACTORS
  (U.S. CUSTOMARY UNITS TO SI UNITS)
To convert the
U.S. customary unit
Area
ft2
Length
ft
in.
Mass
1b
ton (2000 Ib)
Pressure
lb/in.2
Volume
ft3
gal
To the SI Unit
m2

m
cm
kg
Mg
kPa
m3
liter
Multiply by
9.2903 x 10"2

0.3048
2.54
0.4536
0.9072
6.8948
2.8317 x 10"2
3.7854
                 177

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Appendix C:  Cost Analysis
                          REFERENCES FOR APPENDIX C
 1.  Peters, M. S., and K. D. Timmerhaus.  Plant Design and Economics for
     Chemical Engineers.  3rd Edition.  McGraw-Hill Book Company, New York,
     1980.

 2.  Building Construction Cost Data, 1982.  40th Annual Edition.  R. S.
     Godfrey (ed).  Robert Snow Means Company, Inc., Kingston, Massachusetts,
     1981.

 3.  Building Construction Cost Data, 1984.  42nd Annual Edition.  R. S.
     Godfrey (ed).  Robert Snow Means Company, Inc., Kingston, Massachusetts,
     1983.

 4.  Marion, W. J., and T. S. LaGuardia.  Decommissioning Handbook.  DOE/EV/
     10128-1, 1980.

 5.  The Chemical Marketing Reporter.  Schnell Publishing Company, New York,
     October 11, 1982.

 6.  Natale, A. and H. Levins.  Asbestos Removal and Control - An Insider's
     Guide to the Business,  Source Finders Corp., Vorhees, New Jersey.
     1984.
                                     178

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                                 APPENDIX D

                         CASE STUDY:   SEVESO, ITALY
BACKGROUND
     On July 10, 1976, an explosion at the ICMESA (Industrie Chemich-Meda-
Societa Azionaria) chemical factory in the municipality of Meda, which bor-
ders the town of Seveso, Italy, released a cloud of toxic chemicals that
contaminated the surrounding community with tetrachlorodibenzo-p-dioxin
(TCDD) and other pollutants.  The ICMESA plant is owned by the Givaudan
Corporation, a subsidiary of the Switzerland-based Hoffman-LaRoche pharmaceu-
tical company.  Trichlorophenol (TCP), a starting material in the manufacture
of hexachlorophene (a disinfectant), was produced at the ICMESA facility for
export to Givaudan's plant in Clifton, New Jersey.

     Givaudan's patented method of TCP production involves partially hydro-
lyzing tetrachlorobenzene to sodium trichlorophenate with sodium hydroxide in
a mixed solvent of xylene and ethylene glycol.  Unreacted glycol is subse-
quently recovered by distillation.  When distillation is complete, water is
introduced into the reaction vessel and the entire mass is transferred to a
second reactor.  Trichlorophenate is then transformed to TCP by acidification
with hydrochloric acid.  A full production cycle can be completed in 24 h
(three 8-h work shifts).

     Tetrachlorodibenzo-p-dioxin is formed as an unwanted byproduct during
the synthesis of TCP by thermal condensation of trichlorophenate at tempera-
tures above 180°C.  During the tetrachlorobenzene hydrolysis reaction process
at the ICMESA facility, batch temperatures were maintained at 140° to 150°C.
Whenever reactor temperatures approached the danger threshold, further in-
creases were limited by manually opening a valve to introduce water into a
cooling coil.  The ICMESA plant was not equipped with automatic alarm devices
to signal unusual events in the production cycle or safety devices to halt
the cycle if necessary.

     The ICMESA factory explosion occurred in a 10-m3 reactor (designated
A101) in Building B of the plant.  At about 5:00 a.m. on Saturday, July 10,
workers began shutting down the production cycle for the weekend.  At that
point, distillation of the ethylene glycol solvent was only one-third com-
plete.  Interrupting the cycle before distillation had been completed and
washdown procedures had begun was not part of the normal operating routine.

     Because it was the weekend, only a few watchmen and maintenance people
were in the plant when, at 12:40 p.m., an exothermic reaction (cause unknown)
                                     179

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Appendix D:  Seveso, Italy
raised the reactor temperature and pressure beyond limits and caused a reac-
tor safety valve pressure disk to rupture.  Under the thrust of the built-up
pressure, part of the reactor contents were expelled through the valve ori-
fice at the top of the tank, which was vented to the open air.  (The plant
was not equipped with a collection and abatement system for substances that
could potentially be released in the event of an accident, as Italian law
requires.)  A visible plume, which rose to a height of approximately 50 m,
was dispersed by a light wind before it descended and settled over an area
southeast of the plant.

     The ICMESA plant is situated in an enclave of former farmland surrounded
by a densely populated suburban area incorporating the towns of Seveso,
Cesano Maderno, Meda, and Desio.  The inhabitants of the area are primarily
artisans from southern Italy and their families.  (Seveso's main industry is
furniture making.)  A heavily traveled freeway running northward from Milan
to the Swiss border skirts the ICMESA plant to the east.

     Houses on the fringes of the large business districts are primarily
two-story detached dwellings of stuccoed cement block with red tile roofs.
Many of the homes were built by their owners.  The area also has several two-
to four-story cement-block apartment buildings, schools, and small and me-
dium-sized artisan shops.  All houses, schools, and other buildings in the
path of the TCDD-containing cloud were contaminated as a result of aerial
desposition.

     The explosion in Reactor A101 also contaminated Building B of the ICMESA
factory.  The TCP production plant, which was located at one end of the
building, occupied two interconnecting rooms.  A third room was occupied by
the distillation plant.  The results of various investigations indicated that
the TCDD was confined to a few vessels and interconnecting pipes; the remain-
ing equipment was nominally clean on the inside, although some external
contamination was evident.  Contamination was also present on the building
roof and exterior walls.1
NATURE AND EXTENT OF CONTAMINATION

     The fact that local health and labor authorities had never been informed
of the TCP production activities at the ICMESA plant contributed to the
apparent lack of immediate understanding of the nature and seriousness of the
emergency and the extent of the area that was contaminated.

Contaminants Present

     Much of the area upon which the toxic cloud descended consisted of
garden plots and fields for growing crops and grazing cows.   The fallout
affected leaves, vegetables, and grass, as evidenced by withering,  burns, and
yellow spots.  Within a few days, small animals (rabbits, birds, mice, chick-
ens, and cats) began to sicken and die.  At the time of the  explosion, most
                                     180

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                                                   Appendix D:   Seveso,  Italy
of the people were indoors for their noon meal, but those who had been ex-
posed to the strongly alkaline cloud (mainly children) developed burnlike
dermal lesions.  Nine days after the accident, Givaudan administrators in-
formed Italian health officials that TCDD contamination had been found in
samples of soil and vegetation collected near the ICMESA plant (after the
explosion) and analyzed at Givaudan laboratories in Switzerland.2

Sampling and Analysis

     The nature of the contamination resulting from the explosion at the
ICMESA plant was such that all exposed surfaces in the area were affected.
Both soil and building contamination are addressed in this case study because
of their interdependence.

Soil —
     To define the extent of TCDD contamination, investigators took superfi-
cial soil samples at 50- to 100-m intervals along five radial lines extending
southward from the ICMESA facility.  A higher sampling frequency was used
within 0.6 km of the contamination's origin, where initial monitoring indi-
cated greater concentrations of TCDD.  Triplicate samples were taken at sites
in open meadows and agricultural fields; two of the sample specimens were
combined for analysis, and the third was reserved as a reference.  Sampling
was achieved by sinking steel  cylinders (0.6 m long, 7-cm i.d.) vertically
into the soil to a depth of a few centimeters.  Core samples were subsequent-
ly retrieved and stored in sealed plastic bags.3'1*  The procedures adopted
for the analysis of TCDD in soil involve combined gas chromatography/mass
spectrometry and have been described by di Domenico et al.4

     Based on the results of the soil survey, three contamination zones
(designated A, B, and R) were defined (Figure D-l).  Zone A (110 ha), which
contained most of the escaped TCDD (approximately 2 to 3 kg), is located
south-southeast of the ICMESA plant, in the same direction as the dominant
wind at the time of the accident.  Zone A was further divided into Subzones
Al through A8 (numbered according to their distance from the plant) based on
topographical and municipality features.  Zone B (170 ha) is the natural
extension of Zone A along the main diffusion pathway of the TCDD-containing
cloud.  An estimated 20 g of TCDD was deposited in Zone B.  Both Zone A and
Zone B are surrounded by a larger Zone of Restriction (1430 ha), which con-
tained an additional 20 g of TCDD.  The TCDD concentration in the soil at the
borderline between Zone A and Zone B was set at 50 yg/m2, whereas the concen-
tration between Zone B and Zone R was set at 5 yg/m2.  Zone R includes all
the remaining areas where detectable levels of TCDD (>0.75 yg/m2) were
found.3'6

Building Surfaces—
     The extent of contamination on interior surfaces of houses, schools, and
other buildings was established by means of swab tests on walls, floors, and
windows.4  Only smooth, solid, nonabsorbing surfaces such as polished marble,
waxed stoneware, ceramic tile, glass panes, formica, and varnished metal and
wood were wiped.


                                     181

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Figure D-l.   Zones A,  B,  and R,  showing major built-up areas (0) and
surrounding  farm lands.   The ICMESA plant appears within Meda municipal
boundaries  near the Meda-Seveso  borderline.   Most of Zone A lies within
the Seveso  Municipal  boundaries, while Zone  B comes within the Cesano
Maderno and  Desio municipal  boundaries.

Source:  Reference 5.
Copyright ?  1983 by Academic Press, Inc.

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                                                   Appendix D:  Seveso> Italy
     Sampling areas on walls were chosen within child's reach (i.e., less
than 1.5 m above ground).  Sampling areas on inside floors were generally
chosen in halls, near entrances, in restrooms, and near windows facing in the
direction of the ICMESA plant (personal communication from A. di Domenico,
Istituto Superiore de Sanita, Roma, Italy, June 25, 1984).

     A square sampling area of 0.25 m2 was wiped back and forth, vertically
and horizontally, with a 10-g degreased cotton swab saturated with 20 to 30
ml of a 1:4 acetone/hexane mixture.  (Cotton swabs were degreased by pro-
longed Soxhlet extraction with hexane previously deprived of GC/ECD-respond-
ing compounds.)  Before changing wiping directions, the swab was turned over
to present a clean surface for wiping.  The cotton swab was held in a clean
metal clamp while sampling was performed and stored in a glass-stoppered
glass jar prior to extraction.  (The jars, normally of dark glass, were
cleaned by repeated washing with purified hexane.)  Used cotton swabs were
extracted three times with 200 ml  of the acetone/hexane solvent.  The three
extracts were pooled, dried under vacuum, and treated as described for soil
extracts by di Domenico et al.*1

     The extent of TCDD contamination on exterior building surfaces was
established by scraping off the top layer (1 to 2 mm) of a square 0.25-m2
area using steel hand scrapers (similar to the spatulas used by building
workers).  Normally, painted walls were avoided.  Scraping samples (100 to
500 g) in the form of coarse dust were collected and stored in clean, dark
glass jars.  Extraction was achieved by mixing the scrapings with anhydrous
Na-jSOit and shaking vigorously with three fractions (400, 300, 300 ml) of a
1:4 acetone/hexane mixture.  The three fractions were pooled, evaporated to
dryness, and analyzed by the method described by di Domenico et al.4

     Interior and exterior building surfaces in Subzones A6 and A7 were not
extensively monitored prior to the initiation of decontamination efforts.
Available information, however, indicated that TCDD contamination was very
unevenly distributed.7  Maximum contamination on interior surfaces was found
to be 2 to 3 yg/m2 TCDD while exterior building surfaces (on walls facing the
ICMESA plant) were contaminated with up to 5 yg/m2 TCDD (personal  communica-
tion from G. U.  Fortunati, Regione Lombardie, Seveso, Italy, July 3, 1984).

Health Hazard Evaluation

     Accidents similar to the one  at the ICMESA factory have also occurred at
other TCP production facilities (in the United States, Germany,  England, and
Holland).   In each of these cases,  however,  contamination was contained
within the factory.   The accident  at Seveso  marks the first time that con-
tamination was dispersed over a wide area and affected the lives of thousands
of people.
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Appendix D:  Seveso,  Italy
     Tetrachlorodibenzo-p-dioxin is extremely toxic, even at very low concen-
trations.  The oral LD50 for male and female guinea pigs is 0.0006 to 0.0021
mg TCDD/kg of body weight.8  Virtually insoluble in water (0.2 yg/liter),
TCDD has a high affinity for soil colloids and particles and is extremely
persistent in the environment.   It can be absorbed through the skin, inhaled,
or ingested.  Symptoms of TCDD poisoning in humans include chloracne, liver
and kidney ailments, and nervous disorders.  This substance is an established
teratogen and a suspected carcinogen.

     Preliminary analytical findings from soil and vegetation samples plus
available information on the occurrence of toxic and pathological events and
on air movements at the time of the explosion prompted Italian authorities to
evacuate the 739 inhabitants of Zone A.  The evacuation took place in three
stages (July 26, 28, and August 2).*  Evacuees were officially forbidden to
remove household goods or any but their most essential personal possessions.
They were given allowances by the provincial authorities and housed temporar-
ily in a large apartment and hotel complex near Milan.  Access to Zone A was
restricted by construction of a barbed wire fence around its perimeter.  The
fence was guarded and patrolled continuously by carabinieri (military police
who were also entrusted with civil police duties).

     Although inhabitants of Zones B and R were not evacuated, children under
12 and women up to 3 mo pregnant were removed during the day to reduce their
exposure to the contamination.   Residents were instructed to follow several
hygienic rules and were temporarily advised against conceiving children.
Strict measures concerning food and water supplies were adopted.  Orchards
were destroyed, and all edible animals were taken away or killed after reim-
bursement.  Cultivation and animal breeding, as well as new construction,
were prohibited or severely restricted.  Because inhabitants of Zones B and R
were assumed to be chronically exposed to low levels of TCDD, they were
placed under medical and epidemiological surveillance along with the former
inhabitants of Zone A.
DECONTAMINATION STRATEGY

     Reclamation of the contaminated area was particularly urgent for Sub-
zones A6 and A7, areas in which approximately two-thirds of the evacuees had
been living before the accident.  The average and peak TCDD levels in Sub-
zones A6 and A7 were lower than those in other parts of Zone A.2
  Lombardy Regional Law No. 2 of January 17, 1977 established 50 yg TCDD/m2
  of soil as the limit above which the area was to be barred to human inhabi
  tants.9
                                    184

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                                                   Appendix D:   Seveso3  Italy
Target Levels

     Target levels for TCDD in soil and on building surfaces were established
by the Lombardy Regional Authority as follows:7

     0    Soil, top 7 cm:  j<5 yg/m2
     0    Exterior building surfaces:  <0.7b yg/m2
     0    Interior building surfaces:  j<0.01 yg/m2

Decontamination Methods

     To a large extent, decontamination of the Seveso homes, schools, and
other buildings was dependent on reducing the TCDD concentration in the
sorrounding soil; thus decontamination of both the soil  and buildings are
discussed.

Soil-
     Following the Seveso incident, a search of the literature revealed that
TCDD degrades rapidly in ultraviolet light, given the presence of a hydrogen
donor.  Experiments carried out by Givaudan and controlled by the Istituto
Superiore di Sanita (ISS), in which an oil emulsion was  sprayed on contamin-
ated vegetation, indicated that the TCDD level could be  reduced by 50 percent
in 24 h.6  Heavy fall rains, however, washed the TCDD from the vegetation
into the soil before widespread decontamination efforts  could be attempted.

     Penetration of TCDD into the soil occurred very slowly.  Most of the
contamination was found to be concentrated in the top 15-cm soil layer.
Available data indicate that a statistically significant reduction of TCDD
levels in the unworked soil of Zone A occurred in the first 5 mo.  After this
period, no further decrease in TCDD levels was detected.5  The initial  reduc-
tion of TCDD observed in Zone A has been attributed to photodegradation in
the topmost soil layer and to volatilization through different channels, the
extent of which have decreased with time.  In situ treatment of TCDD-contami-
nated soil by microbial action was considered, but the ISS was unsuccessful
in its attempts to find microorganisms capable of degrading TCDD in soil or
organic substances that could stimulate the growth of naturally occurring
microbial flora.6

     Among the several alternative strategies for disposing of the dioxin-
contaminated soil considered in the first months following the accident were
incineration at sea, direct ocean dumping, and deep disposal in a salt  pit.
International conventions governing the use of the seas  and public opposition
to the latter made these strategies impractical.  The most practical  solu-
tion, and the one subsequently approved by the regional  authorities,  was
high-temperature incineration of the soil in a rotary kiln constructed  in the
more heavily contaminated area of Zone A.  Strong public opposition based on
the fear that some dioxin might escape from the incinerator stack and that
Seveso would become a dumping ground for all of Italy eventually forced
abandonment of these plans, however.
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Appendix D:  Seveso,  Italy
     Reclamation of the highly contaminated soil  (>5 ug/mz)  of  Zone  A has
largely been accomplished by surface stripping and replacement with clean
soil.  The contaminated soil  has been trucked to  Subzone  A5  for disposal  in
huge concrete-lined bunkers.   In the less-contaminated areas,  deep ploughing
of the top 30 cm of soil has resulted in a 40 percent decrease in TCDD con-
centration over 3 yr (1976/77 to 1979/80).5

Houses--
     No single decontamination technique was found to be  universally  appli-
cable to the variety of building materials used for domestic dwellings;
therefore, an integrated approach was used to reclaim the Seveso homes con-
taminated with TCDD.  This approach involved 1) removal of contaminated
items, 2) cleaning of surfaces to an acceptable level, and 3)  sealing in  of
residual contamination.

     Thirty-six houses in the area of highest soil contamination, which were
considered too polluted to be cleaned, had to be  demolished; new replacement
homes were constructed nearby.  One hundred and twelve houses  in the  less
contaminated areas (Subzones A6 and A7) were extensively decontaminated.
Roof tiles were replaced, and both interior and exterior walls were  vacuumed.
Smooth, nonabsorbing surfaces were washed with surfactants and common sol-
vents, whereas wall plaster and wooden floors were subjected to various
degrees of scraping.  Linoleum floors, wallpaper, furniture, and loose ob-
jects that could not be cleaned were removed and  placed in concrete-lined
pits in Subzone A5, along with the contaminated roof tiles.   Many interior
surfaces were subsequently coated with paint or varnish.   Toxic waste that
had been washed from the interior walls was collected in concrete-lined tanks
placed outside the houses being cleaned.  The tanks then were taken  by truck
to be emptied elsewhere, or the waste in them was pumped to a field  lying
just within Subzone A5.

     The top layer of soil in orchards, gardens,  and the immediate external
surroundings was normally scarified to a depth of at least 20 cm.  The con-
taminated soil was trucked to Subzone A5 and replaced with an equivalent
amount of clean soil.

Schools--
     Regional authorities made a concerted effort to decontaminate the
schools so that the children  could return to them.  Remedial measures were
similar to those taken  for houses.  In September  1976, after the walls has
been vacuumed and washed with detergents, all schools were declared free of
traces of dioxin.10   In  February 1977, however, a number of children in six
schools in Zone R developed suspected cases of chloracne.  Epidemiologists
suspected that children  had tracked dioxin into classrooms on the soles of
their shoes.  The schools that were found to be contaminated were closed so
they could be cleaned.

     During the summer  of 1977,  regional  authorities did not conduct any type
of systematic measurement of  dioxin levels in schools  in Zone B.  Decontami-
nation  operations were  carried  out only sporadically.  As the beginning of


                                     186

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                                                   Appendix D:  Seveso, Italy
the new school year approached, a considerable number of schools were discov-
ered to be contaminated with significant traces of dioxin (this included some
that had been pronounced dioxin-free earlier in the year).10  Of 139 schools
tested, 124 had to be closed until decontamination procedures could be car-
ried out.

Trichlorophenol Plant—
     One week following the explosion, the mayor of Meda issued an ordinance
to close down the production sections of the ICMESA plant, which had contin-
ued to operate.  In addition, the Givaudan company was ordered to begin
decommissioning Building B of the plant.  At that time, Reactor A101 was
estimated still to contain 250 to 300 g of TCDD.1

     In 1978, Givaudan retained the Hazardous Materials Service (HMS) of the
Harwell Laboratory, U.K., to prepare a feasibility study on remedial mea-
sures.1  Three methods were proposed by HMS for the decontamination, dismant-
ling, and disposal of the TCP plant within the ICMESA factory:

     1.   Construction of a giant monolith to entomb the entire plant.

     2.   Comprehensive decontamination of the plant, followed by dismantling
          and disposal of the clean equipment and disposal  of the contami-
          nated wastes.

     3.   Dismantling of the plant in such a way that highly contaminated
          materials would be contained within the vessels and pipes, followed
          by direct disposal of the contaminated equipment.

Each of these methods was considered in turn, and each is explained briefly.

     Monolith--Construction of a monolith involves casting  the building and
equipment in concrete.  The principal advantage of this approach is that
virtually all  worker contact with contaminated equipment or surfaces is
eliminated once the loose debris has been cleared and the surfaces  have been
coated with lacquer (to prevent migration of contamination  during the ef-
fort).   Disadvantages are numerous, however.   Technically,  it may be diffi-
cult to ensure that pipes are not broken while the concrete is being poured
and is setting.  The effects of weathering and/or flooding  might lead to
fissuring of the concrete and water ingress.   Environmentally, the  monolith
would be aesthetically unattractive and would afford only a temporary solu-
tion.

     Comprehensive decontamination—Various  techniques are  available for the
decontamination of external  surfaces, but they are either difficult to  apply
to complex  equipment and inaccessible surfaces  (e.g.,  mechanical  methods,
vacuuming), or they pose a  high risk of worker exposure to  toxic chemicals
(e.g.,  solvent or steam cleaning).   Decontamination  of the  interior of  the
reactor and its associated  vessels  and pipes  poses an  even  greater  problem.
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Appendix D:  Seveso,  Italy
The contents of the reactor have set solid, and it is unlikely that water or
solvent cleaning would be effective; some form of mechanical  removal  would be
necessary, and this would be difficult to achieve safely.   Similarly, some of
the pipes contain tarry deposits that would be difficult to remove.  Even if
the contents could be safely removed, the internal surfaces would still  have
to be decontaminated.  Because the success of such an operation would be
difficult to monitor, it would still be necessary to dispose of the equipment
as if it contained some residual contamination.  Comprehensive decontamina-
tion generates large quantities of highly contaminated liquid wastes for
disposal and maximizes worker exposure to contamination.

     Dismantling—In this method, no attempt is made to remove contaminated
solids from the vessels and pipes.  Rather, the plant is dismantled and
disposed of directly.  The main advantage of this approach is that handling
of contaminated materials is minimized.  Furthermore, liquid wastes are  not
generated; considering the unavailability of incinerators  capable of destroy-
ing such wastes, this presents an additional advantage over the comprehensive
decontamination option.

     The feasibility study identified dismantling as the most practical
remedial alternative.  Stepwise instructions outlined by HMS for the con-
trolled dismantling of the TCP plant are as follows:1

     1.   Removal of lagging.  Dust control techniques similar to those  for
          removal of asbestos should be employed.

     2.   Vacuuming of loose dust.  All surfaces should be sealed with a coat
          of paint or lacquer to minimize dust and contamination problems.

     3.   Removal of the plant and ancillary equipment.  The services and
          relatively uncontaminated pipework should be removed first and the
          heaviest and most highly contaminated items left to the end.
          Vessels known to contain liquids will need to be drained into
          drums.  Because of the presence of flammable solvents, special
          techniques and precautions will be needed when any items have  to be
          cut open or into pieces.

     4.   Decontamination or demolition of the building shell.

     The Givaudan Corporation is proceeding with the dismantling and disposal
of contaminated equipment.  The distillation plant has already been removed
from Building B.  As equipment is removed, it is to be encapsulated in spe-
cially designed containers for disposal in a remote, geologically secure site
(which has not yet been chosen).

Worker Protection

     Most of the decontamination work force has been supplied by a contractor
in Milan.  All workers are required to enter the fenced-off area of Zone A
                                     188

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                                                   Appendix D:  Seveso3  Italy
through a filter station, where they change into impermeable suits, boots,
and hoods and don face masks with filters.  At the end of the work shift,
workers must shower before changing back into street clothes.  Discarded
decontamination suits are placed in plastic containers for removal (by the
next work shift) to contaminated material  dumps in Subzone A5.

     All workers operating in the contaminated zones were given preemployment
physical examinations to ascertain their fitness.   Based on the same selec-
tion criteria, a control group was chosen  from employees of the same firm.
Medical examinations and laboratory tests  were performed on both the exposed
and nonexposed groups 9 and 6 months, respectively, after their first ex-
aminations.  No differences between these  groups were found.11

     Plans for decommissioning Building B  require that workers wear fully
encapsulating suits fitted with a two-way  communication system and supplied
with air by a trailing hose.  The affected rooms will be maintained under
negative pressure, and the extracted air will be passed through efficient
dust filters.

Costs

     Hoffman-LaRoche has assumed financial responsibility for all  aspects of
the cleanup and for victim compensation.  Approximate figures for the decon-
tamination of houses in Subzones A6 and A7 and for the TCP plant are $2.5
million and $3.0 million, respectively (personal communication from G. U.
Fortunati, Regione Lombardie, Seveso, Italy, July 3, 1984).  The total bill
is expected to exceed $130 million.12


EVALUATION OF DECONTAMINATION EFFECTIVENESS

     The buildings in Subzones A6 and A7 were extensively monitored through-
out the course of decontamination.  Figure D-2 shows the distribution of TCDD
levels detected on interior surfaces following the first level of decontami-
nation effort.7

     The uneven distribution of TCDD on building surfaces made assessment of
the effectiveness of decontamination operations a  difficult task.   Conse-
quently, Subzones A6 and A7 were further subdivided into clusters  of build-
ings with more homogeneous TCDD levels and distribution patterns.   Three
building clusters were identified (Figure  D-3) on  the basis of the following
criteria:

     0    Building location with respect to the path of the  TCDD-containing
          cloud

     0    Topographical  features

     0    TCDD levels detected on interior and exterior building surfaces
                                    189

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Appendix D:  Seveso, Italy
     After the decontamination treatments were completed, a minimum of  113
random samples were taken from interior building surfaces in each cluster and
analyzed for TCDD.  All values were within the maximum permissible level of
TCDD (0.01 yg/m2).  Similar results were obtained on samples taken from ex-
terior building surfaces.7

     Decontamination operations were reiterated until target levels for TCDD
on building surfaces and in soil were achieved (up to four cycles for agri-
cultural soil in Zone A).  Subzones Al through A5 remain sealed off, but
residents of Subzones A6 and A7 were permitted to return to their homes in
the fall of 1977, 17 mo after the ICMESA factory explosion.
                         100
                         80
                         60
                    S   40
                         20
                                 0.01 0.05 0.10 0.15

                                 LEVEL OF TCDD,
     Figure D-2.   TCDD concentrations found on internal building surfaces
            of Subzones A6 and A7 following completion of the first
                           level of decontamination.
                                    190

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Appendix D:  Seveso, Italy
                          REFERENCES FOR APPENDIX D
 1.  Bromley, J., D. C. Wilson, and E. T. Smith.  Remedial Measures Following
     Accidental Release of  Dioxin. Chemosphere, 12(4/5):687-703, 1983.

 2.  Silano, V.  Case Study:  Accidental Release of 2,3,7,8-Tetrachlorodiben-
     zo-p-dioxin (TCDD) at Seveso, Italy.  In:  Planning Emergency Response
     Systems for Chemical  Accidents.   World Health Organization Regional
     Office for Europe, Copenhagen, 1981.

 3.  Di Domenico, A., et al.  Accidental Release of 2,3,7,8-Tetrachlorodi-
     benzo-p-dioxin (TCDD) at Seveso:   Assessment of Environmental Contamina-
     tion and of Effectiveness of Decontamination Treatments.   CODATA Bulle-
     tin, 29:53-59, 1978.

 4.  Di Domenico, A., et al.  Accidental Release of 2,3,7,8-Tetrachlorodiben-
     zo-p-dioxin (TCDD) at Seveso, Italy.  I.   Sensitivity and Specificity of
     Analytical Procedures Adopted for TCDD Analysis.   Ecotoxicology and
     Environmental  Safety, 4:283-297,  1980.

 5.  Pocchiari, F., et al.   Environmental  Impact of the Accidental  Release
     of Tetrachlorodibenzo-p-dioxin (TCDD)  at  Seveso (Italy).   In:  Acciden-
     tal Exposure to Dioxins.  Human  Health Aspects.  Academic Press, Inc.,
     New York, 1983.

 6.  Pocchiari, F.   2,3,7,8-Tetrachlorodibenzo-p-dioxin Decontamination.  In:
     Chlorinated Phenoxy Acids and Their Dioxins.  Mode of Action, Health
     Risks and Environmental Effects.   Ecological Bulletin, 27:67-70, 1978.

 7.  Di Domenico, A., et al.  Accidental Release of 2,3,7,8-Tetrachlorodiben-
     zo-p-dioxin (TCDD) at Seveso, Italy:  III.   Monitoring of Residual TCDD
     Levels in Reclaimed Buildings.  Ecotoxicology and Environmental  Safety,
     4:321-326, 1980.

 8.  Sax, Newton, I.  Dangerous Properties  of  Industrial Materials.   5th ed.
     Van Nostrand Reinhold Company, New York,  1979.   p. 1012.

 9.  Noe, L.  Reclamation  of the TCDD-Contaminated Seveso Area.   In:   Acci-
     dental Exposure to Dioxins.  Human Health Aspects.  Academic Press,
     Inc., New York, 1983.

10.  Whiteside, T.   The Pendulum and  the Toxic Cloud.   Yale University Press,
     London, 1979.
                                     192

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                                                   Appendix D:   Sevesos  Italy
11.   Ghezzi,  I.   Potential  2,3,7,8-Tetrachlorodibenzo-p-dioxin Exposure of
     Seveso  Decontamination Workers.   Scandanavian Journal  of Work Environ-
     ment and Health, 8(Suppl.  1):176-179, 1982.

12.   Revzin,  P.   Chemical  Cloud Still  Casts Long  Shadow Over Seveso, Italy.
     The Wall Street Journal, July 10, 1979.
                                    193

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                                 APPENDIX E

                CASE STUDY:   BINGHAMTON STATE OFFICE BUILDING
BACKGROUND

     On February 5, 1981, an electrical  fire occurred in the basement of the
18-story Binghamton State Office Building (BSOB)  in Binghamton,  New York.
The excessive heat caused an electrical  transformer to fail  and  release an
estimated 680 to 760 liters of fluid containing 65 percent polychlorinated
biphenyls (PCB's) and 35 percent chlorinated benzenes (Arochlor  1254).
Pyrolitic conversion of these substances resulted in the formation of tetra-
chlorodibenzodioxin (dioxin) and tetrachlorodibenzofuran (furan).   Although
the fire itself was contained in the basement,  black soot containing PCB's,
dioxin, and furan was distributed throughout the  entire building via the
ventilation system.  The soot was deposited on  all surfaces  of the building
interior and its furnishings.

     Because firefighters and investigators suspected contamination when they
detected an acrid odor upon entering the basement, they immediately evacuated
the building and donned respiratory equipment before reentering.  The build-
ing was closed to employees and the public on that day and was still closed
as of February 1984.

     The building is owned by the State  of New  York; therefore,  the New York
State Office of General Services (OGS) has been responsible  for  any decontam-
ination activities and costs.  The selected cleanup contractors  were respons-
ible for planning and management of the  program and for providing the physi-
cal labor for cleanup activities.  This  site is not on the Superfund National
Priorities List.

     The decision to decontaminate the BSOB was made because the costs for
dismantling this recently constructed building  and disposing of  the debris in
a secure site were prohibitive.


NATURE AND EXTENT OF CONTAMINATION

     The nature and extent of contamination were  determined by sampling
various media for the suspected contaminants.

Contaminants Present

     The contamination consisted of polychlorinated biphenyls (PCB's), tetra-
chlorodibenzodioxin (dioxin), and tetrachlorodibenzofuran (furan).  The

                                     194

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                                Appendix E:   Binghamton State Office Building
contaminants were present in a black soot that was distributed throughout the
building.   The soot covered all  interior surfaces and furnishings and was
present in most seams, cracks, crevices, and other small  openings.1

Sampling and Analysis

     Variations of both dry-wipe and wet-wipe sampling methods were used for
different locations and surface types.   For example, the  wet-wipe method used
for sampling cleaned vinyl flooring involved soaking a sterilized cotton wipe
with hexane.  A specially designed apparatus was used to  hold the wipe in a
manner that would minimize cross-contamination and interference by other sub-
stances (personal communication from R. Westin, Versar, Inc., Springfield,
Virginia, February 27, 1984).

Initial Sampling--
     Initial sampling of the building air and soot began  the day after the
fire and continued for 3 weeks.  The samples were collected and analyzed by
the New York State Department of Health (DON).  Early test results revealed
that the air contained 6 to 62 yg PCB/m3, and all soot samples contained 10
to 20 percent RGB's.1  The air levels were below the Occupational Safety and
Health Administration (OSHA) allowable standards.  Personnel inside the
building continued to wear respirators.

     The samples that the New York State Department of Environmental Conser-
vation (DEC) took of air outside the building showed no PCB contamination.
Water samples from the nearby Susquehanna River were also collected by DEC.

     Approximately 3 weeks after the fire, DOH informed OGS that the soot
samples they had taken contained dioxins and furans, as well as PCB's.

Ongoing Sampling--
     Ongoing testing includes:

     0    Sampling of air released from air pollution control system (APCS)
          filters.

     0    Sampling of treated wastewater prior to discharge into the Bingham-
          ton sanitary sewer system.

     0    Visual inspection of all previously soot-covered surfaces.

     0    Wipe-test sampling of some cleaned areas.

     0    Soot sampling from above ceiling panels and other remote areas.

     As of January 1983, DOH had collected and analyzed 265 small bottles and
30 large containers of soot.1
                                     195

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Appendix E:  Binghamton State Office Building
Health Hazard Evaluation

     The U.S. Environmental Protection Agency (EPA) has listed polychlorin-
ated biphenyls and tetrachlorodibenzodioxins as carcinogens.   Tetrachlorodi-
benzofurans have narcotic vapors that can be absorbed through the skin.


DECONTAMINATION STRATEGY

     Because of the nature of the contamination at the BSOB,  many of the
cleanup activities were unprecedented.  The decontamination program evolved
as various problems were solved by application of the best techniques and
materials available at the time.

Target Levels

     The current major setback to the release of the BSOB for public use is
the lack of a target level for a combination of PCB, dioxin,  and furan con-
tamination.  The Commissioner of the DOH, who is responsible  for establishing
the target level, is faced with two major obstacles—no precedent and no
predetermined OSHA levels for the contaminants.

     The State of California Department of Health Services issued a draft
policy on exposure to carcinogens.  The guidelines provided therein allow up
to a one-in-a-million risk.  This policy was used in establishing a target
level for the PCB-contaminated One Market Plaza office complex in San Fran-
cisco.

     In another office building, PCB contamination was cleaned up and the
building was released for public use shortly thereafter.  In  this case,
however, wipe sampling showed that PCB's were the only contaminants present;
thus, synergistic effects were not a consideration.  Also, less contamination
was present in that it had only been tracked on the floor as  opposed to being
distributed via the ventilation system.  In this building, achievement of
ambient PCB levels was sufficient to warrant release of the building (person-
al communication from R. Westin, Versar, Inc., Springfield, Virginia, Febru-
ary 27, 1984).

Methods

     At the BSOB, the following media had to be decontaminated:  inside air;
building wastewater; and buildings, structures, and equipment.

Inside Air—
     An air pollution control system (APCS) was installed on  the BSOB roof in
September 1981.  The system was designed to remove particulate and vapor
phase PCB's and dioxins by drawing air through a series of filters.  The air
was tested to confirm that the system was operating properly.1
                                    196

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                                Appendix E:  Binghamton State Office Building
Building Wastewater--
     The BSOB cleanup activities generated large amounts of wastewater.
Disposing of used cleaning rags rather than rinsing them reduced the amount
of contaminated wastewater generated.  A water treatment system established
in the subbasement of the building consisted of three above-ground swimming
pools, each with a capacity of about 50 m3.  Water from the cleanup opera-
tions was routed to the first pool, pumped at a high rate through sand fil-
ters to remove large particulates, allowed to flow into the second pool, and
then channeled through a series of activated-charcoal filters to remove
smaller particles.  Filtered water flowed by gravity to another pool, where
it was tested for composition.  Water with a level of contamination within
the permit conditions was then released to the Binghamton sanitary sewer
system.1

Buildings, Structures, and Equipment--
     Surfaces of buildings, structures, and equipment at the BSOB were decon-
taminated by scrubbing with rags wetted with an industrial nonionic deter-
gent.  The product was chosen because it has been well characterized by
bioassay methods and does not cause interference in sample analysis.  When
this and other commerically available cleaning products proved to be ineffec-
tive for cleaning vinyl floor tiles, the flooring was removed and taken to a
secure RCRA landfill.

     Used cleaning/scrubbing rags were placed directly in drums, which were
delivered to a secure landfill.  Rinsing and reusing these rags would have
created large quantities of contaminated wastewater and could have spread the
contamination from one area to another.

     The following items associated with the BSOB had to be decontaminated:

     0    Structural appurtenances
     0    Porous materials
     0    Furniture
     0    Office equipment

     Methods used for decontaminating each of these items are discussed in
the following subsections.

     Structural  appurtenances—These are items that are structurally associ-
ated with the building and essential  to its operation.

     The thousands of customized ceiling pieces that had to be decontaminated
were removed, identified by code number, cleaned by scrubbing with detergent,
and reinstalled.   Blown insulation above the ceiling panels was vacuumed to
remove contaminated soot before the panels were reinstalled.

     Over 1000 heating/cooling terminal  boxes  had to be decontaminated.   This
entailed opening  the boxes, removing  the insulation, scrubbing with deter-
gent, and then closing them.   This task required many hours because of the
limitations in manual  dexterity posed by protective equipment.


                                    197

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Appendix E:  Binghamton State Office Building
     Decontamination of 5000 ceiling light fixtures was another time-consum-
ing task that was also limited by lack of dexterity imposed by the protective
equipment.  The fixtures were removed from the ceiling and opened.  After the
lighting element was removed, the fixture and its ceiling tracks were thor-
oughly cleaned.  Approximately 4 h were required for removal, cleaning,  and
reinstallation of each fixture.1

     Porous materials--The porous materials involved at the BSOB included
documents, carpeting, draperies, and floor tiles.  All documents on desk tops
and in files were shredded, baled, and disposed of in a secure landfill.  The
carpeting and draperies also were removed and disposed of at the landfill.
Originally it was felt that the floor tiles could be decontaminated with
detergent, but testing revealed that commercial products could not render the
tiles "clean" so they also were disposed of by landfilling.1

     Furniture—When the BSOB cleanup began, all furniture was vacuumed  and
moved to the basement.  Consideration of potential personnel attitudes toward
this furniture then prompted the decision to dispose of it.  The items in-
volved included:

           1950 chairs             190 stools
            930 desks              120 racks
            850 file cabinets      110 map files
            522 tables             100 lockers
            325 bookcases           52 benches
            310 storage cabinets    50 couches

In addition to ,the furniture, 400 miscellaneous items and all personal desk-
top items were disposed of at a landfill.1

     Office equipment--Decontamination of office equipment and machines  would
require dismantling, scrubbing, and reassembly.  Because of the costs re-
quired for such activities, disposal of the following items has been consi-
dered:
            200 typewriters
             90 recorders
             40 adding machines
             20 postage scales
15 postage machines
15 computer terminals
15 copiers
 5 microfiche readers
The cleanup contractor is currently investigating whether cleaning or dispo
sal of the office equipment is more appropriate.*
Worker  Protection
      Decontamination of the 18-story BSOB became a large, complex operation.
Although OGS represented the building owner (the State of New York), contrac-
tors  managed the project, provided onsite supervision, and performed daily
decontamination activities.
                                     198

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                                Appendix E:   Binghamton State Office Building
Personnel Training and Supervision--
     Before working in the BSOB, decontamination workers must:

     0    Attend a lecture on the health effects of PCB's, dioxin, and furan.

     0    Successfully complete OSHA respirator training and fit test.

     0    Be aware of standard operating procedures.

     0    Complete a walk-through training of procedures.

     0    Undergo a complete physical  examination.

Full-time supervision at three levels  is provided for employees working in
the building.

Safety and Security Considerations—
     Because of the large amount of space and the number of people involved
in this operation, safety and security had to be top  priorities.  Although
OGS was ultimately responsible for site activities, contractors were respon-
sible for implementing plans and procedures to produce the desired outcome.

     Female workers and female visitors are not permitted at this site be-
cause of the mutagenic and teratogenic nature of some of the contaminants.

     The DOH prepared a safety plan based on the requirements of the Occupa-
tional Safety and Health Act (29 CFR).  This plan,  which addressed security,
personal protective equipment, showers, change areas, and sampling schemes,
was approved by OGS and the National Institute for  Occupational Safety and
Health (NIOSH).1

     Medical surveillance program—A medical surveillance program for all
employees was instituted 3 yr ago and  was still in  effect as of February
1984.  Bimonthly exams are given to those who still enter the building, and
followup exams are provided for those  who have completed their assignments
within the BSOB.1

     Personal protective equipment—Workers inside  the BSOB are required to
wear Level C protection, which includes air-purifying respirators with par-
ticulate filters, Tyvek suits, gloves, and rubber shoe covers.

     Filter cartridges on the respirators originally  chosen for use at the
site tended to fall out, which caused  workers to breathe unfiltered air.
These respirators were replaced with another more reliable brand.1

     High temperatures inside the building caused workers to perspire to the
point of sometimes breaking their respirator seals.  Some employees reported-
ly lifted their masks to wipe perspiration from their faces.2
                                     199

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Appendix E:  Binghamton State Office Building
     Controlled entry—An entry module was installed at the basement level
loading dock in September 1981.  The specially designed trailer provided an
area between the contaminated building and the "clean" community where the
following took place:

     0    Contaminated equipment and other items removed from the building
          were decontaminated.

     0    Contaminated disposable clothing was placed in receptacles for
          later disposal.

     0    Contaminated reusable clothing was laundered.

     0    Employees showered before returning to their homes and communities.

     The entry module provided an additional level  of protection to prevent
contamination from leaving the BSOB.

     For prevention of unauthorized entry into the  building, round-the-clock
security is maintained.  A central  security office  is responsible for moni-
toring and testing all alarm systems.1

Costs

     As of January 1984, approximately $10 million  had been spent for the
cleanup activities.  The total effort is expected to cost $20 to $21 million
(personal communication from R. Westin, Versar, Inc., Springfield, Virginia,
February 14, 1984, and February 27, 1984).


EVALUATION OF DECONTAMINATION EFFECTIVENESS

     As of February 1984, the effectiveness of the  decontamination effort was
determined by physical removal of contaminated soot and random sampling of
various media.   Because target levels have not yet  been established, no
further determination of the cleanup effectiveness  can be made.
                                    200

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                                Appendix E:  Binghamton State Office Building
                          REFERENCES FOR APPENDIX E
1.   New York State .Office of General Services.  The Binghamton State Office
     Building Clean-up:  A Progress Report Update.  Albany, New York.  Janu-
     ary 1983.

2.   Third Anniversary Special Report.  The Sunday Press, Binghamton, New
     York, February 5, 1984.
                                    201

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                                 APPENDIX F

                        CASE STUDY:  SONTAG ROAD AREA
BACKGROUND
     In 1971-72, portions of a major county roadway and adjacent privately
owned access areas in a small community in southwestern St. Louis County,
Missouri, were sprayed with dioxin-contaminated waste oil  for dust control.
Vehicular and pedestrian traffic in combination with natural  transport pro-
cesses spread the material over a county road intersection, over approxi-
mately 1500 m of roadway, and into yards and residences of nearby homeowners,
businesses, and public buildings.  The Sontag Road area includes site loca-
tions known as Castlewood Pool, Waterman Road, Mel's Tavern,  Horsefalls
Residence, and Vespy Residence.


NATURE AND EXTENT OF CONTAMINATION

     The Sontag Road area is one of more than 35 confirmed dioxin-contaminat-
ed sites in central and eastern Missouri.   The Bliss Salvage  Oil Company
sprayed these areas for dust control, primarily in 1971 and 1972.  A poison-
ing episode at three riding stables in the summer of 1971, which killed more
than 60 horses and hundreds of birds, cats, and dogs, led  investigators from
the Missouri Department of Health and the Centers for Disease Control (CDC)
in Atlanta to believe that the waste oil had been contaminated with a toxic
substance.  More than 3 yr elapsed, however, before the toxic agent was
identified.

Contaminant Present

     Contamination of the salvage oil resulted from the improper disposal of
an industrial waste residue.  The source of the contamination was traced to a
trichlorophenol (TCP) production plant in Verona, Missouri, which was being
leased by the Northeast Pharmaceutical and Chemical Corporation (NEPACCO).
The production of TCP generated a distillation residue containing the highly
toxic contaminant 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), an unwanted
byproduct of the chemical manufacturing process.

     The still residues were routinely stored in a tank on the Verona site,
where they were allowed to accumulate until the tank was full and disposal of
some of the material became necessary.  Between February and  October 1971,
the Bliss Salvage Oil Company, which collected, stored, and resold waste oil
from a large variety of sources, hauled six truckloads of  still residues,
                                    202

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                                                Appendix F:   Sontag Eoad Area
totaling 60,500 liters, from the Verona plant.1  Most of the still  residues
were hauled to St. Louis, where they were mixed in a large tank with waste
oil from other sources.  Oil sold for re-refining or for use as a fuel  oil or
dust suppressant was drawn off the top of the tank and sludge collected at
the bottom.

     The Sontag Road area was identified by a former Bliss employee as  having
been sprayed with oil drawn from this tank.  It appears likely that at  least-
two loads of waste oil (22,700 liters total) containing an estimated 5  to 10
g of TCDD were applied to sites in the Sontag Road area at one time or
another.2

Sampling and Analysis

     In 1983, EPA Region VII personnel and their contractors collected  sever-
al hundred soil and dust samples from the Sontag Road area.  Soil samples
were taken from the road shoulders, adjacent yards, and stream beds in  ac-
cordance with well-documented methodologies.2  Dust samples from building
interiors were collected from household vacuum cleaners and portable Dust-
busters.  The highest levels of TCDD  (588 ppb) were found in the parking lot
of Mel's Tavern.  Dust collected from the interior of the tavern contained
36 ppb  (personal communication from G. E. Kepko, U.S. Environmental Protec-
tion Agency, Region VII, Kansas City, Kansas, January 20, 1984).

Health  Hazard Evaluation

     One of the most toxic  substances known to man, TCDD has been linked to
birth defects and is suspected of causing soft tissue sarcoma.  The primary
route of human exposure to  dioxin is  absorption through the skin; however, it
may also be inhaled or ingested.

     Approximately 60 persons reside  within the contaminated Sontag Road
area.   When fire  service personnel and patrons of Mel's Tavern  (who were sub-
jected  to periodic exposure) are added, the total number of exposed persons
reaches more than 300.  Children were considered particularly susceptible
because they had  been observed walking barefoot on the contaminated road
shoulders during  the summer.

     From the health effects evaluations by the CDC and others  developed
specifically for  the numerous problem areas in central and eastern Missouri,
it has  been concluded that  the general population's continuous  exposure to
TCDD levels in excess of 1  ppb in soil represents an unreasonable health
hazard  and provides adequate justification for mitigation actions to protect
the public health.  Dioxin  concentrations  in the soil at numerous locations
around  the Sontag Road area ranged from 60 to more than 500 times this action
level.2
                                     203

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Appendix F:  Sontag Road Area
DECONTAMINATION STRATEGY

     Sampling results in the Sontag Road area demonstrated the presence of
widespread TCDD contamination.  The EPA deemed it unreasonable to expect that
residents of the area could voluntarily restrict access and exposure to
dioxin-contaminated soil over the long term.  Therefore, in July 1983, EPA
requested funds under the Comprehensive Environmental  Response, Compensation,
and Liability Act (CERCLA) to remove the immediate public health hazard and
to prevent further spread of the contaminant.  The request for funds was
approved, and decontamination was initiated on August 1, 1983.  The EPA's
decontamination strategy was designed with the hope of eliminating the need
to relocate residents and close area businesses for extended periods of time.

Target Levels

     As cited previously, the CDC established an action level of 1 ppb for
TCDD in dust and soil.  Mitigative measures were required for all areas where
TCDD concentrations exceeded this level.

Methods

     Phase One operations, which were implemented within 48 h of the an-
nouncement of contamination levels to the public, included the following:

     1.   Vacuuming respirable dust from all paved surfaces in the site area
          that are contaminated (or suspected of being contaminated) by use
          of industrial-quality, air-powered vacuums equipped with high-effi-
          ciency particulate air (HEPA) filters for particulate removal.

     2.   Applying a nontoxic chemical spray dust suppressant to road shoul-
          ders and contaminated yards to prevent additional spread of contam-
          ination and to reduce exposures.

     3.   Paving the parking lot of Mel's Tavern and several private drive-
          ways with a temporary surface of minimum volume to permit continued
          use of these  areas.

     4.   Vacuuming residences and businesses known or suspected of being
          contaminated, including 608 Sontag Road, Mel's Tavern, the fire
          station, and  Horsefalls Residence.

     The methods used to decontaminate both Mel's Tavern and the equipment
used for collecting soil samples in the Sontag Road area are described here
in greater detail.

Mel's Tavern--
     Mel 's Tavern, a single-story wooden building with a crawl space under-
neath and an attic, was built in the  1920's.  The total floor area is approx-
imately 420 m2.  The wood is deteriorating, and numerous cracks and holes are
                                     204

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                                                Appendix F:  Sontag Road Area
evident in the walls and floors.  Dust blows into the tavern through vents in
the attic and through open windows in the summer.  It is also tracked in from
the parking lot on the soles of people's shoes.  Inside the building the dust
collects in the cracks and crevices.

     The aim of the decontamination efforts was to remove dioxin-contaminated
dust from the tavern.  The entire structure and all of its furnishings were
first vacuumed with high-powered vacuums equipped with HEPA filters.  The
walls, floor, ceiling, ductwork, furniture, knickknacks, etc., were then
scrubbed down with soap and water and rinsed with plain water.  Insulation in
the attic, which had trapped contaminated dust over the years, was replaced
with new insulation.  The entire effort took six to nine workers 9 days to
complete.  Throughout this period, the tavern remained open for business, and
the decontamination work had to be scheduled around the owner's operating
hours.

     The contaminated dust and insulation that were removed from the tavern
were sealed in 55-gal drums and ultimately disposed of in a secure landfill.
The wash and rinse waters were run through two filters (two 55-gal drums, one
filled with sand and the other with activated carbon) and tested with a
turbidity meter before being discharged to the ground on site.  The discharge
water was subsequently analyzed in the laboratory and found to contain no
TCDD above the detection limit of 0.001 ppb.  The drums containing the filter
media were also disposed of in a secure landfill.

Equipment--
     Soil samples taken in the Sontag Road area were collected with hand-
picks.  Cross-contamination between samples was avoided by decontaminating
the picks after each sample collection.

     The decontamination station consisted of two large metal tubs and one
aluminum foil pan placed on a sheet of plastic spread over the ground.  In
the first tub, the picks were scrubbed with soap and water until visibly
clean.  This was followed by a series of four rinses using different agents
(water, alcohol, 1,1,1-trichloroethane, and water).  In each case, the rins-
ing agent was placed in a plastic squeeze bottle and squirted over the pick.
The rinsate from the water and alcohol rinses was collected in the second
large tub.  The 1,1,1-trichloroethane rinsate was collected in the aluminum
pan, poured into a glass sample jar, labeled, and returned to the lab for
TCDD analysis.  The wash and rinse waters and the foil pan were treated as
contaminated wastes and disposed of appropriately.

Worker Protection

     The cleanup contractor took several  measures to ensure the health and
safety of their employees while on site.   As a standard practice, all  employ-
ees receive yearly baseline physicals.  In addition, the successful comple-
tion of a hazardous waste training course was required of all decontamination
workers prior to commencing site operations.  While on site, workers were
                                    205

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Appendix F:  Sontag Eoad Area
required to wear Level C protective clothing and equipment to provide skin
and respiratory protection from exposure to dioxin-contaminated particulates.
Level C protective equipment consists of disposable Tyvek suits, gloves,
boots, and air-purifying respirators equipped with particulate filters.   Dur-
ing the hot months, each worker's pulse and blood pressure were monitored for
signs of heat stress.  The quickest route to the hospital had been planned,
and the buddy system was in effect at all times.  As of January 1984, no
accidents or incidents of toxic exposure had been reported.

Costs

     The costs for sampling and analysis of approximately 400 soil and dust
samples taken in the Sontag Road area totaled $730,000.  Phase One decontami-
nation operations cost an additional $341,000.  Of this,  $11,000 was spent
cleaning Mel's Tavern.  The value of the tavern has been estimated at
$150,000; thus the Phase One costs of decontaminating the building appear to
have been justified (personal communication from G. E. Kepko, U.S. Environ-
mental Protectin Agency Region VII, Kansas City, Kansas,  January 20, 1984).


EVALUATION OF DECONTAMINATION EFFECTIVENESS

     Six weeks following the Phase One decontamination efforts, the cleanup
contractor returned to Mel's Tavern to collect a dust sample for determining
the effectiveness of decontamination.  The TCDD concentration in this sample
was measured at 22 ppb, considerably higher than the 1 ppb action level.
Apparently, the deteriorated condition of the building made complete removal
of the contaminated dust impossible.  Also it was suspected that tainted soil
from the crawl space underneath the tavern was blowing up through the cracks
in the floorboards.

     The EPA regional office recommended that the entire tavern be vacuumed
and scrubbed again and that the walls be sealed with paint and shellac.   They
further recommended that the old wooden floor be replaced with new plywood
subflooring and linoleum.  The EPA headquarters, however, would not approve
the plan, as these actions would have, in effect, constituted capital im-
provements to the site.  Thus, further decontamination was limited to repeat-
ed vacuuming and scrubbing until the 1 ppb action level could be achieved.
                                    206

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                                                Appendix F:  Sontag Road Area
                         REFERENCES FOR APPENDIX F
1.    Shea, K. P., and B.  Lindler.   Pandora and the Storage Tank.   Environ-
     ment, 17(6):12-15, 1975.

2.    U.S.  Environmental Protection Agency, Region VII.   CERCLA Fund Request
     for Immediate Removal:   Sontag Road Area Superfund Site (Draft).  July
     22, 1983.
                                   207

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                                 APPENDIX G

                CASE STUDY:   ONE MARKET PLAZA OFFICE COMPLEX*
BACKGROUND

     On May 15, 1983, a fire occurred in a Pacific Gas  & Electric (PG&E)
transformer vault serving the Steuart Tower of the privately owned One  Market
Plaza (OMP) office complex in San Francisco, California.  Flames  and  smoke
from this fire contaminated parts of the OMP building with several  types  of
toxic chlorinated organic substances.

     Interim guidelines established during the week following the fire  served
as operational goals for decontamination efforts  where  toxic substances were
found as a result of the fire.   During the decontamination process, only
cleanup personnel wearing protective equipment were allowed to enter  the
contaminated areas.   Final target levels and analytical  procedures were de-
veloped by the San Francisco Health Department with the  help of many  experts
(both individuals and organizations).

     Major decontamination efforts focused on vault surfaces; interior  and
exterior surfaces of air handling systems; walls, ceilings, and floors; and
equipment such as coils, switch gear, distribution panels, motor  control
centers, and computer control panels.

     The wide variety of decontamination methodologies  used included  grit-
blasting, dismantling, pneumatic chipping and jackhammering, insulation
removal, solvent washing, physical scraping, vacuuming/dusting, hydroblast-
ing/waterwashing, strippable coatings, and K-20 sealant.

     Contractor personnel provided management and planning support during the
cleanup operation and were responsible for actual decontamination activities.

     The closed portions of the OMP complex were  reopened by the  San  Francis-
co Health Department on March 22, 1984, and completely  reoccupied shortly
thereafter.
  Source of information:   Personal  communication from V.  G.  Rose,  Pacific Gas
  and Electric Company, San Francisco, California,  April  17, 1984.
                                    208

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                                 Appendix G:  One Market Plaza Office Complex
NATURE AND EXTENT OF CONTAMINATION

     The nature and extent of contamination were determined by collecting
samples of various media and analyzing them for the suspected contaminants.

Contaminants Present

     Various parts of the building were contaminated with polychlorinated
biphenyls (PCB's), polychlorinated dibenzodioxins (PCDD's), and polychlori-
nated dibenzofurans (PCDF's) as a result of the flames and smoke generated
during the fire.

Sampling and Analysis

     Routine air, liquid, wipe, and bulk samples were taken from the vault
and inside the building over a period of time from May through November 1983.
Final sampling was conducted in December 1983 and March 1984.  The samples
were analyzed for PCB's, PCDD, and PCDF.  Results of the PCB analyses show
that levels dropped over time as decontamination efforts progressed.  Data
from the PCDD and PCDF analyses were not available.  Methodologies for sample
collection were also not available.
DECONTAMINATION STRATEGY

     The decontamination strategy required the establishment of target con-
taminant levels and the determination of appropriate decontamination methods
for specific media.  Decisions were made weighing decontamination costs
versus equipment replacement costs.  Equipment procurement lead times, proba-
bility of success in decontamination, etc., were also considered.

Target Levels

     Initial interim guidelines were developed in the week following the
fire.  Final guidelines for contaminant levels allowing re-entry and quan-
titation procedures were developed as cleanup efforts progressed and a number
of experts were consulted.

Interim Target Levels—
     Interim guidelines developed by the San Francisco Health Department with
input from all parties involved were established as follows:

          1.0 pg PCB's/m3 (air)
          1.0 yg PCB's/100 cm2 (surfaces)
          0.5 ng total PCDD-PCDF/100 cm2 (surfaces)
                                    209

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Appendix G:  One Market Plaza Office Complex
Final Re-entry Target Levels--
     Final re-entry guidelines were developed by the San Francisco Health
Department in consultation with the California State Department of Health
Services, the New York State Health Department, the Centers for Disease
Control, the National Institute for Occupational Safety and Health, private
consultants, and academic scientists.

     The established guidelines for safe airborne and surface levels for
re-entry into the decontaminated areas at OMP were as follows:

          1.0 yg PCB's/m3 (air)
          100 yg PCB's/m2 (surfaces)
          10 pg total PCDD-PCDF/m3 (air)
          3 ng total PCDD-PCDF/m2 (surfaces)

     In the establishment of these guidelines, background levels of PCDD-PCDF
were assumed to be zero.

     Guidelines for safe airborne and surface levels for re-entry into the
PG&E vault were established as follows:

          1.0 yg PCB's/m3 (air)
          1 mg PCB's/m2 (surfaces)
          80 pg total PCDD-PCDF/m3 (air)
          24 ng total PCDD-PCDF/m2 (surfaces)

     At exposure levels at or below the above guidelines, it is believed that
anyone entering the OMP building and working in the complex 8 h/day and 5
day/week for 40'yr would experience no additional risk of cancer, reproduc-
tive, embryotoxic, or other acute or chronic health effects beyond those of a
similar nonexposed population (personal communication from V. G. Rose, Paci-
fic Gas & Electric Company, San Francisco, California, April 17, 1984, and
May 22, 1984.)

     All samples were collected according to written protocols approved by
the San Francisco Health Department.  These levels are based on a sampling
and analytical uncertainty of at least 20 percent for PCDF-PCDD analysis and
15 percent for PCB's.  Based on these figures and the large safety margins
built into the risk assessment, any deviations in actual contaminant readings
were assumed not to result in an increased risk to exposed populations.

Methods

     Four specific components of the building complex were targeted for
decontamination procedures, and procedures consisted of many state-of-the-art
methodologies.  The simultaneous cleanup of the building components required
the use of different and multiple decontamination procedures.  In all in-
stances, the objective was to remove 100 percent of the PCB and PCDF-PCDD
contamination from the OMP complex.
                                    210

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                                 Appendix G:   One Market Plaza Office Complex
Vault Surfaces--
     Decontamination procedures used on the transformer vault surfaces con-
sisted of physical removal of portions of the concrete surfaces by gritblast-
ing, dismantling, and pneumatic chipping and jackhammering.

     The initial step in the process was to grit-blast all  contaminated
surfaces to remove gross contaminants from the concrete.   A glass-like "black
sand" material was used as the gritblasting material.   All  concrete block
walls were then dismantled and removed by sawing the structures into remov-
able sections, lowering them to the vault floor, and removing leftover mate-
rials.  Pneumatic chippers, also known as scarifiers,  were  then used to chip
away 1.5 cm of concrete from the ceiling and remaining walls.  Lastly, jack-
hammers were used to remove 15 cm of concrete from the vault floor.  This
resulted in exposure of the structural building slab.

Air Handling Systems--
     More than 35 air handling systems, including such components as insulat-
ed fan housing and blower units and ductwork, had been contaminated by perme-
ating smoke.  Cleanup of these surfaces consisted of removing insulation,
solvent washing, physical scraping, vacuuming/dusting, waterwashing, and
dismantling.

     Initially, all interior insulation in the air handling systems was
removed.  The remaining surfaces were solvent-washed and physically scraped
to remove stubborn glue residue.  Exterior insulation  on ductwork was vacu-
umed and wiped.  The fan housings, other metal exterior surfaces of fan
systems, and blower units were then vacuumed and detergent-washed.

     Access to the interior of metal ducts was through holes cut in the duct-
work.  To minimize the number of holes to be cut, cleanup personnel entered
the duct system whenever possible.  Surfaces were then vacuumed to remove
ambient dust particles and washed with a detergent solution.

     Because of their adsorptive nature, rubber and synthetic components of
the fan systems could not be cleaned.  Therefore, they were physically dis-
mantled and disposed of.

     High contamination levels prompted the removal and disposal of all the
components of two air handling systems and portions of two  additional
systems.

     When accessibility problems prevented the manual  cleaning of portions of
two ventilating systems located in sealed concrete shafts,  decontamination
procedures consisted of placing a large suction at the base of each vertical
duct and,using pressurized air to loosen and dislodge  particulate matter
adhering to the interior surfaces.

Walls, Ceilings, and Floors--
     All sheet rock and concrete walls, ceilings, and  floors in contaminated
rooms were first vacuumed and detergent-washed.  Strippable coatings were


                                    211

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Appendix G:  One Market Plaza Office Complex
applied to some concrete surfaces, allowed to react for 24 to 48 h, and then
peeled off.  Concrete surfaces close to the vault were also coated with K-20.

Equipment--
     An innovative procedure was developed for decontaminantion of expensive
equipment at the OMP complex that could not be manually cleaned.  This equip-
ment included fan system heating and cooling coils, electrical  switch gear,
distribution panels and motor control centers, and computer control panels
for building life support systems.  The decontamination technique consisted
of first building a containment structure around the item to be decontami-
nated and then washing the item with a high-pressure solvent spray.  The
solvent was collected at the bottom of the containment area, and the liquid
was returned to a holding tank, where it was filtered and distilled to remove
the contaminants.

Worker Protection

     During decontamination procedures, only persons wearing standard person-
al protective equipment were allowed in the contaminated areas.  When cleanup
efforts had brought contaminant levels down to those stated in the interim
guidelines, restricted access was permitted for further decontamination
efforts.

Costs

     As of March 1984, total costs for the cleanup of the OMP complex were
estimated to range from $15 to $20 million.*


EVALUATION OF DECONTAMINATION EFFECTIVENESS

     The closed portions of the OMP complex were judged to be successfully
decontaminated as measured by the final sampling results.  The OMP complex
was reopened by the San Francisco Health Department on March 22, 1984, and
completely reoccupied shortly thereafter.
  U.S. Environmental Protection Agency.  Polychlorinated Biphenyls (PCB's);
  Manufacture, Processing, Distribution in Commerce and Use Prohibitions;
  Use in Electrical Transformers.  Advance Notice of Proposed Rulemaking.
  49 FR 11073, 1984.
                                    212

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                                 APPENDIX H

                       CASE STUDY:   FRANKFORD ARSENAL
BACKGROUND

     From its inception in 1816 until  its closure in 1977, the Frankford
Arsenal in Philadelphia, Pennsylvania, was the sight of various military
activities and accomplishments.  Major operations at the 45-ha arsenal  in-
cluded munitions manufacture, materials and research development programs,
development of propellant- and cartridge-actuated devices, and procurement
missions.  Its closure was part of the Army's worldwide realignment program
to improve management, to exploit available technology to the fullest,  and to
reduce costs.

     In June 1977, the office of the project manager for Chemical  Demilitari-
zation and Installation Restoration (now the U.S. Army Toxic and Hazardous
Materials Agency, USATHAMA) assumed responsibility for the decontamination
and cleanup of the Frankford Arsenal.   Several processes were involved  in the
development and implementation of the  decontamination program.  The time
frame and scale of these processes are presented in this case study.

     Following a records search to identify possible contaminants, USATHAMA
awarded a sampling contract in March 1978. The contractor completed the
sampling survey in November 1978.

     Procurement activities were initiated in February 1979, and a contract
calling for a multiphase, onsite decontamination and cleanup program was
awarded in September 1979.

     The decontamination and cleanup program was organized into three phases:

     0    Phase I—Demonstration of the effectiveness of various decontamina-
          tion and cleanup methods.

     0    Phase II--Generation of standard operating procedures for control
          and direction of the decontamination operations.

     0    Phase Ill—Actual decontamination and cleanup of the Arsenal.

     This case study is concerned mainly with Phase III.   Persons  having a
strong interest in the initial phases  can obtain information from  USATHAMA,
Aberdeen Proving Ground, Maryland.
                                   213

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Appendix H:  Frankford Arsenal
NATURE AND EXTENT OF CONTAMINATION

     The nature and extent of contamination of the Frankford Arsenal  were
determined by sampling various media for the suspected contaminants identi-
fied in the literature search.  These included low-level  radiological wastes,
explosive/pyrotechnic residues, organic chemicals, and inorganic chemicals
(heavy metals).

Contaminants Present

     A detailed sampling survey of the Arsenal revealed the following contam-
inants:  explosives, asbestos, radiological wastes, and heavy metals.  Sev-
eral specific wastes within the explosive, radiological,  and heavy metal
categories were identified.1

     Explosive contaminants were the greatest in number.   Major residues
included pentaerythritol (PETN), styphnic acid, trinitroresorcinol (TNR),
nitrocellulose (NC), nitroglycerine (NG), trinitrotoluene (TNT), dinitrotolu-
ene  (DNT), N-tetranitro-N-methylaniline (tetryl), and cyclotrimethylenetri-
nitramine  (RDX).  Although tests covered many specific radiological contami-
nants, only depleted uranium and radium were found in significant quantities
at the Arsenal.  The heavy nutal residues present consisted of lead,  cadmium,
chromium,  and mercury.

     Specific structures contaminated at Frankford were buildings, sumps,
vents, and sewers.  Eight buildings were contaminanted with explosives, 12
with radiological residues, and 135 with heavy metals.  The vent of one
building was contaminanted with explosives, and radiological contaminants
were found in the vents of four buildings.  The sumps associated with six
buildings  were contaminated with explosives, and sumps in 23 buildings were
contaminated with heavy metals.

Sampling and Analysis

     Samples of various media were collected and analyzed for explosive,
asbestos,  radiological, and heavy metal contamination.

Explosives--
     In buildings where explosives were historically used,  samples were
collected  and  analyzed  for RDX, TNT, 2,4-DNT, 2,6-DNT, tetryl, NG, PETN,  and
NC.  Samples were collected with acetone-saturated cotton swabs.  The acetone
was  contained  in a  2-dram vial, and wooden-stem Q-tips were used  for applica-
tion.   Five  5-cm-diameter circles distributed at the four corners and center
of  a 1-m2  area were swabbed for building surfaces, as was one 5-cm-diameter
circle  for vents.   The  Q-tip was dipped in  acetone before and after  each
circle  was swabbed.1
                                    214

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                                               Appendix H:   Frankford Arsenal
     Sump samples for explosives were collected with a vacuum pump.   A length
of Tygon tubing sufficient to reach the bottom of the sumps  was  used to pump
the samples out.  Clean tubing was used for sampling each sump.   Samples were
stored in glass containers.

     Analysis of the swab and sump samples was performed with a  high-pressure
liquid chromatograph (HPLC).   Eight buildings, one vent, and six sumps were
determined to be contaminated with explosives at levels above the detection
limit of the instrument.  When surface areas were confirmed  to be contami-
nated with explosives, a match test was performed to determine ignitibility.

     In buildings suspected of being contaminanted with both heavy metals and
explosives, air samples were  taken to determine levels of airborne heavy
metals prior to the explosive samples.

Radiological Residues--
     Building and vent surfaces suspected of radiological contamination were
sampled through surface smears.  A filter paper disc with a  2.4-cm diameter
was passed over a representative (usually approximately 100  cm2) portion of
the surface in question by the tip of a thumb.  Because the  pressure-bearing
portion of the filter paper disc was approximately 2 cm wide, the smear was
about 50 cm long.  The smear  was applied in a Z or S pattern, and care was
taken to avoid excess surface dirt.  Duplicate smears were taken at one out
of five locations.2

     After the smears were taken, appropriate instruments were used to test
the samples for radiological  contamination.  Areas that tested positive for
contamination were identified by painting a yellow border around them.

     Sludge and water from sumps were simultaneously sampled for radiological
contamination by filling a 1-liter plastic bottle.  Approximately one-half to
three-fourths of the bottle's volume was composed of sludge.  A lid was
placed on the bottle and secured with" tape.  The container was then labeled.
When dry sludge samples were  taken, the bottles were no more than three-
fourths full of sludge material.  Any suspected presence of  explosive contam-
ination was noted on the container and data sheet.

     This same methodology was used for water samples except that samples
were taken in half-gallon plastic bottles, and care was taken not to collect
solid residues such as surface scum or sludge.  Concentrations in effluent
released to surface waters were averaged on a monthly basis.

     Areas suspected of airborne radiological contamination  were sampled by
passing air through a filter  paper.  Lapel sampling pumps, air sampling pumps
with glass fiber filters, and high-volume air samplers were  used for this
purpose.  The sampler used, its flow rate, and the sampling  time were record-
ed on a data sheet.  The filter paper was placed in an envelope  on which the
serial number was marked.
                                   215

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Appendix H:  Frankford Arsenal
     In buildings where heavy metal  and radiological  contamination was sus-
pected, airborne sampling for heavy  metals and radiological  air survey were
performed simultaneously.

Heavy Metals--
     Testing of heavy metal contamination of building surfaces and vents
consisted of measuring airborne concentrations of mercury (Hg), cadmium (Cd),
chromium (Cr), and lead (Pb).  The concentrations of Cd, Cr, and Pb were
determined by atomic absorption analysis of three filter samples.   Samples
were collected by use of cellulose ester (CE) air filters with 0.8-ym pore
size and an air-moving pump that operated 8 h at a flow rate of approximately
1500 cm3/min.  The mercury concentration was measured by use of a  mercury
sniffer that operated with an air flow rate of approximately 750 cm3/min.

     Sump samples were collected and analyzed for heavy metals in  a manner
similar to that used for explosive sump samples.  Briefly, samples containing
both water and sludges were collected by means of a vacuum pump.  Enough
Tygon tubing to reach the bottom of the sump was used for pumping  the samples
out.  Clean tubing was used in each sump.  Samples were stored in  precleaned
polyethylene containers.

Health Hazard Evaluation

     Health hazards presented by the four categories of contaminants (explo-
sives, asbestos, radiation, and heavy metals) are many and varied, and dis-
cussion of each is beyond the scope of this case study.


DECONTAMINATION STRATEGY

     The strategy for decontamination activities first required that target
contaminant levels be established first and that the appropriate methods for
decontamination of specific media be determined.  Worker protection and
project costs were also considered.

Target Levels

     A basis for declaring the Arsenal "decontaminated" and releasing it for
unrestricted use was established by setting target levels for all  specific
contaminants.  These target levels are presented in Tables H-l  (Explosives),
H-2  (Heavy Metals), and H-3 and H-4 (Radiological Contaminants).  Asbestos
target levels are not included because the relatively small amounts of this
contaminant found were  in buildings that were ultimately burned to the
ground.
                                    216

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          TABLE H-l.  SUMMARY OF TARGET LEVELS FOR EXPLOSIVES
                                                             a,b
Explosive








NG
PETN
RDX
TNT
2,4-DNT
2,6-DNT
Tetryl
NC
Surface,
g/ml of extract
40
50
1.0
1.0
1.0
1.0
1.0

a. Reference 1.
         TABLE H-2.  SUMMARY OF TARGET LEVELS FOR HEAVY METALS'
Heavy metal
Mercury
Cadmium
Chromium
Lead
Surfaces,
yg/m3
1.6
1.6
1.6
1.5
Sewers ,
mg/ liter
0.005
0.1
3 (total)
1
Surface runoff,
ppm
0.01
0.02
0.1 (hexavalent)
0.1
Reference 1.
                                  217

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              TABLE  H-3.   SUMMARY  OF  TARGET  LEVELS  FOR  RADIOLOGICAL CONTAMINANTS  ON  SURFACES
ro

CO
Nuclidesb
U-nat, U-235, U-238, and
associated decay products
Transuranics, Ra-226, Ra-228,
Th-230, Th-228, Pa-231,
Ac-227, 1-125, 1-129
Th-nat, Th-232, Sr-90, Ra-223,
Ra-224, U-232, 1-126, 1-131,
1-133
Beta-gamma emitters (nuclides
with decay modes other than
alpha emission or spontaneous
fission) except Sr-90 and
others noted above
Surfaces
Averagec'd>e
5,000 dpm a/100 .cm2
100 dpm/100 cm2
1,000 dpm/100 cm2
5,000 dpm Ba/100 cm2
Maximumc>e'f
15,000 dpm a.1 100 cm2
300 dpm/100 cm2
3,000 dpm/100 cm2
15,000 dpm go/ 100 cm2
Removable0 'e'9
1,000 dpm a/100 cm2
20 dpm/100 cm2
200 dpm/100 cm2
1,000 dpm Ba/100 cm2
               Source:   Reference 1.
             b  Where  surface contamination by both  alpha- and beta-gamma-emitting nuclides  exists, the limits established
               for alpha- and beta-gamma-emitting nuclides should apply independently.
             c  As used  in this table, dpm (disintegrations per minute) means the rate of  emission by radioactive material
               as determined by correcting the counts per minute observed by an appropriate detector for background,
               efficiency, and geometric factors associated with the instrumentation.
             d  Measurements of average concentration should not be averaged over more than  1m.  For objects of less surface
               area,  the average should be derived  from each such subject.
             e  The average and maximum radiation levels associated with surface contamination resulting from beta-gamma
               emitters should not exceed 0.2 mrad/h at 1 cm and 1.0 mrad/h at 1 cm, respectively, measured through not
               more than 7 mg/cm2 of total absorber.
             f  The maximum contamination level  applies to an area of not more than  100  cm2.
             9  The amount of removable radioactive  material per 100 cm2 of surface  area should be determined by wiping
               that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount
               of radioactive material on the wipe  with an appropriate instrument of known  efficiency.  When removable
               contamination on objects of less surface area is determined, the pertinent levels should be reduced pro-
               portionally, and the entire surface  should be wiped.

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                TABLE H-4.  SUMMARY OF TARGET LEVELS FOR
        RADIOLOGICAL CONTAMINANTS IN WATER AND AIRBORNE SAMPLES0
Nuclide
H-3
CO-60
Zn-65
Kr-85 (gaseous)
Ag-llOm
Pm-147
Po-210
Ra-226
Th-230
Th-nat
U-nat
U-238
Sewers ,
y Ci/ml
0.1
0.001
0.003
—
0.0009
0.006
0.00002
0.0000004
0.00005
0.00006
0.003
0.003
Surface runoff,
y Ci/ml
0.003
0.00003
0.0001
—
0.00003
0.0002
0.0000007
0.00000003
0.000002
0.000002
0.00003
0.00004
Airborne samples,
y Ci/ml
2 x 10"7
3 x 10"7
2 x 10"9
3 x 10"7
3 x 10"9
2 x 10"9
7 x Kf12
2 x 10"12
8 x 10" 14
2 x 1012
5 x 10"12
3 x 10"12
Source:   Reference 1.
                                 219

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Appendix H:  Frankford Arsenal
     There was some concern that unneutralized explosive material  could be
released in water, either to the surface or as runoff to the sewers.   There-
fore, target levels for explosives were based on the lowest available instru-
mentation detection limits, which were established by use of a signal-to-
noise ratio equal to 3.  After detailed testing, limits were agreed upon and
specified in the contract.3

     All established target levels for radiological  contaminants were based
on ANSI standards and CRC guidelines.3

     Levels of surface heavy metal contamination were established by measur-
ing airborne concentrations and determining that samples were below the
maximum allowable concentrations of heavy metals set by the Surgeon General's
Office.  Water target levels as related to heavy metals were developed in
accordance with Philadelphia's Wastewater Control Regulations (sewers) and
the Delaware River Basin Guidelines (surface runoff).3

Methods

     Meeting the goal of releasing the facility for unrestricted use required
the implementation of several effective state-of-the-art decontamination
methods.  Cleanup techniques used were both contaminant- and structure-speci-
fic.  Methods were developed from current state-of-the-art techniques; modi-
fications and/or additions were made during Phases I and II of the cleanup
program.

     Explosives were decontaminated through flaming.  Various types of flam-
ing devices (e.g., floor flamers, wall flamers, and hand flamers) were used.
Mass flaming (complete burndown) was performed in one area of the Arsenal.

     Asbestos decontamination took the form of simple removal.  The friable
asbestos was removed and packaged for delivery to suitable burial  grounds.

     Decontamination methods for radioactive materials consisted of localized
cleanup (hand wash and scrub), dry vacuuming and sweeping, high-pressure
water treatment, detergent foam application and removal, physical  removal,
and sand blasting.

     The heavy metal decontamination technique consisted of removing loose
and flaked paint, preparing surfaces for painting, and subsequent painting
with low-lead paint.

     Priorities were established for decontamination efforts to maximize
personnel protection.  Explosives were removed first, followed by radiologi-
cal residues and heavy metals.  In areas that were mass-burned (because of
explosive contamination), asbestos was removed before the burn-down was
begun.
                                    220

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                                               Appendix H:  Frarikford Arsenal
     When structures were contaminated with a combination of wastes, the
decontamination activities proceeded in the priority order.  Except where
noted, decontamination methods for multi-contaminant structures did not
differ from the normal procedures described.

Explosives--
     The buildings, vent, and sumps contaminated with explosives were decon-
taminated by use of a variation of the flaming process.  This was possible
because most buildings at the Arsenal were constructed of brick, concrete,
metal-based, and clay-tile materials.  Before the actual cleanup process
began, safety considerations and requirements were developed, and all combus-
tible materials were removed from the buildings.

     Removal of combustible materials--Preparation of the buildings for
flaming involved the removal of all combustible materials and obstructions
that would hinder the process.  The operation was performed with nonsparking
tools and under wet conditions.  The specific equipment required included
nonsparking tools (including wrecking bars), water and a water sprayer,
safety glasses, coveralls and gloves, hard hats with face polycarbonate
shields, an air compressor, containers for the removed material, an air-
powered circular saw, spare saw blades, penetrating oil, a fire extinguisher,
plastic hats, and dust masks.

     When the equipment was assembled, the removal process began.  Penetrat-
ing oils were applied to all joints, screws, and nuts to be removed.  Wooden
surfaces were wetted and then removed with spark-proof tools.  Metallic
materials were removed and hand-flamed.  Caution was used not to allow any
friction-producing tools to reduce the size of removable materials until the
debris was flamed in the area to be cut.  After removal, materials were
packaged in boxes and marked according to building location and debris type.

     Remote f1 aming--Remote flaming (through the use of a floor flamer and
wall flamer) was used in the larger buildings.  Equipment and materials
required included a flame torch drive system, assorted hand tools, a measur-
ing tape, a 5-kVA or larger generator, hard hats with shields, a fire extin-
guisher, dust masks, and NIOSH-approved respirators.

     When the equipment and materials were assembled at the building sites,
areas were roped off and signs were posted to prevent entry.   Flamers were
then set up to cover as large an area as possible, and torch  heads were
positioned approximately 10 cm from the building surface.  Operators then
retreated to a safe area and notified the fire department of  the operation so
that a standby fire truck could be secured.  Torches were ignited and tra-
versed at 300 cm/min.  Cracks were flamed for 60 s.   If residue flowed from
the cracks, the flamers were set to traverse the crack at 300 cm/min.  Ten
min were then allotted for cooling purposes.   Upon reentering the area,
decontamination personnel repositioned the torches to cover the next building
surface. The above steps were then repeated until  all walls,  floors, and
exposed ceilings had been flamed.1*
                                    221

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Appendix E:  Frankford Arsenal
     Remote flaming was used at a few buildings that were contaminated with
both radiological and explosive residues.   When it appeared the flaming
process would spread the radioactive contamination, local enclosures were
used to control the airborne radioactivity.

     Hand flaming--Hand-flaming techniques supplemented the remote flamers
when areas were inaccessible to the floor and wall units and also in the
smaller buildings.  Equipment used for hand flaming was the same as that for
remote flaming with a few modifications.  The remote flaming torch drive
system was replaced by a flame torch (1.8-m-long handle) with a 75-degree
offset and brush tip; and the assorted hand tools, measuring tape, and gener-
ator required for remote flaming were replaced by safety glasses, flame-
retardant coveralls, and protective aprons.

     After the equipment and materials were assembled and the fire department
had been notified, the hand-flaming process began.  Torch heads were posi-
tioned approximately 10 cm from the surface and were moved at the rate of
3 m/min.  Workers concentrated on cracks for 1 min; if residue flows were
produced, the cracks were traversed at 3 m/min.  Hand flamers were used on
any areas contaminated with explosives that had not been flamed with the
remote flamers.

     The single  set of ductwork contaminated with explosives was hand-flamed
and subsequently removed and shipped to a  suitable waste burial site.

     Sump decontamination with charcoal briquets—The technique used to flame
the six contaminated sumps was based on obtaining a temperature that would
result in either decomposition or ignition of the residues in the sump.
First, aerator 'lines using compressed air  were  installed, and the sumps were
partially filled with charcoal.  Igniter units made from a combination of
explosives were  then placed in the  sump.   A layer of kerosene-soaked charcoal
was placed on  top of the igniter units, and the sumps were filled to capacity
with charcoal.   The charcoal bed was then  ignited and allowed to burn  for  an
extended period  of time.

     Mass burning of the 400 area—The  400 area at  the  Frankford Arsenal was
a  3.6-ha tract consisting of 32  small buildings,  sumps,  and  sewer systems.
Because these  buildings  had a  low value and a  history of explosives manufac-
turing, this  area was  cleared  of any free  structures or  other contaminants
 (asbestos)  and then  demolished and  leveled to  grade.

     The approach  to this effort consisted of  removing  all friable  asbestos
and ceiling  panels.  In  a manner similar  to that  used for  sump  cleanup,  the
buildings  and sumps  were loaded  with charcoal,  soaked with  kerosene,  and
remotely  ignited.  Two  detonations  occurred during  the  burn, and  observers
reported  "feeling  the  ground  shake."
                                    222

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                                               Appendix H:   Frankford Arsenal
     When the burning was completed, footing, sumps, and sewers were excavat-
ed and the buildings were demolished according to traditional  industrial
demolition procedures.5

     Secondary waste impacts—Waste forms generated by the flaming methods
consisted of combustible (wood) and noncombustible materials (metallic struc-
tures) possibly contaminated with explosive residues.   These wastes were
surface-treated through flaming or flashing and disposed of as scrap or in a
landfill.

Asbestos—
     Because asbestos contamination was present only in the 400 area, the
magnitude of the cleanup effort was insignificant compared with the decontam-
ination procedures for explosives, radiological residues, and heavy metals.
Therefore, only a brief description of asbestos cleanup is presented in this
case study.

     Asbestos shingles and pipes insulated with asbestos were on the outside
of the buildings in the 400 area.  Steam and air pipes insulated with approx-
imately 5 cm of asbestos generated 44 m3 of removable  material.  Twenty-seven
m3 of asbestos shingles were removed from the roofs of the buildings and
covered walkways in the 400 area.  The pipe insulation and shingles were
treated separately.5  A notice of asbestos removal was submitted to appropri-
ate local, state, and Federal agencies prior to starting the cleanup process.

     Elevated pipes were lowered to the ground before  any asbestos removal
took place.  The pipes were wetted, and the asbestos remained wetted through-
out the entire handling process.  Pipes on which the insulation was intact
were then cut into sections, and the sections containing asbestos insulation
were wrapped in 6-mil or thicker plastic sheeting.  The sheeting was secured,
and the wrapped pipe was placed in a roll-off container.  When the container
was filled, it was covered with a tarpaulin and transported to an approved
landfill.

     During removal of the shingles from the roofs, precautions were taken to
prevent unnecessary breakage during the operation.  The shingles were placed
in a covered roll-off container (separate from the piping) and sent to an
approved landfill for disposal.  All OSHA, EPA, and associated state and
local regulations and requirements were adhered to during all  asbestos-remo-
val operations.5

Radiological Residues—
     Twelve buildings and four vents contaminated with radiological residues
were decontaminated by cleaning, removal of surface material,  and removal of
other structures (drains, overhead facilities).  Safety considerations were
addressed and preparation plans were developed before  the decontamination
process began.
                                    223

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Appendix H:  Frankford Arsenal
     Preparation for decontamination—Initially, controlled areas  around  the
buildings were established to prevent the possible spread of contamination
during cleanup operations.  These areas were sealed and isolated from the
rest of the Arsenal.  Any items that were to be decontaminated were wrapped
in plastic and moved into one of the controlled areas.   Loose debris was
sprayed lightly with water and then boxed for disposal.  Any structures
(drains, light fixtures, conduits) interfering with access to ceiling, wall,
and floor surfaces were dismantled and packaged.  Main  water and steam lines
were capped, and electrical conduit circuits were disconnected at  the source
when these items were removed.  When significant amounts of dirt or dust
remained on the floor, the floor was vacuumed or swept  to minimize particu-
late activity during cleanup procedures.6

     Bui!dings--Radiological decontamination of buildings was organized  into
sections.  In most cases, cleanup procedures started with the initial stage
and proceeded onward.  Surveys were taken at the end of each stage; if the
contaminant levels of particular areas or rooms were below the target levels
described in Table H-3, the cleanup equipment was decontaminated as necessary
and the areas were sealed off to prevent recontamination.  If the  survey
showed higher contamination levels than allowable, the  next cleaning stage
was begun.  For some ceilings, walls, and floors (depending on the type  and
condition of the surface and contamination activity), decontamination proce-
dures were begun at one of the higher stages.6

     Equipment needed for all cleanup stages included a wet/dry vacuum clean-
er, high-pressure water equipment with variable pressure controls, assorted
janitorial supplies, detergents, caustic, chipping devices, (chipping ham-
mers, scabblers, grinders), brushes, NIOSH-approved respirator equipment,
work clothes and other protective equipment, radiological instrumentation,
ladders and approved platforms, an air compressor, a fire extinguisher,  and
containers for the disposal of contaminated materials.

     Initial Stage—Localized Cleanup, Hand-Hash, and Scrub.  For small
     isolated spots of contamination, detergent and brushes were used to
     clean up the residues.

     Stage I--Dry Vacuuming and Sweeping.  When all equipment required for
     this stage was assembled and checked over, workers donned the protective
     respiratory gear and clothing and started vacuuming at the ceilings and
     tops of the walls and worked their way down to the floors.  Extra atten-
     tion was given to cracks, crevices, and hard-to-reach areas.

     Stage II--High-Pressure Water.  First, all drains, cracks, and doorways
     were sealed off to prevent flow of effluent into outer areas.  All
     needed tools and equipment were then assembled and checked for opera-
     tional efficiency.  After donning their protective clothing and face
     shields, workers began the spray operation at the ceilings and tops of
     walls and proceeded downward to the floors, giving extra attention  to
                                    224

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                                               Appendix H:  Frankford Arsenal
     cracks and crevices.  Afterwards, water rinse effluents were vacuumed or
     collected, and surfaces were allowed to dry.  If surface surveys met the
     target levels established in Table H-3, effluent samples were sent for
     contamination analysis.

     Stage Ill—Detergent Foam Application and Removal.  Foaming was not used
     on  radiological contamination of the fixed variety because it requires
     removal of the surface material.

     Physical Removal.  Chipping hammers, scabblers, grinders, and brushes
     were used to remove contaminated surfaces.  This was the primary method
     used at this installation.

     Vents—In one building, two vents encased in concrete presented a remo-
val and  disposal problem.  Therefore, they were cleaned in place by a sand-
blasting technique, and the sand residue was shipped to a disposal site as a
radiological waste.6

     Secondary waste impacts—Secondary wastes generated by the radiological
decontamination procedures consisted of contaminated wash and rinse waters,
dry solid waste, and contaminated fixtures, conduits, drains, piping, and
other structural materials.

     Excess wash and rinse waters were collected in 55-gal  drums, neutralized
(if necessary), decanted, filtered, and analyzed.  Water that met Federal  and
local requirements for wastewater was released to the sanitary sewer system.
Water that failed to meet these criteria and contained above-limit concen-
trations of radioactivity was solidified by hydraulic (cement/fixation)
procedures.  If radioactivity levels were acceptable but other contaminants
were present in above-limit concentrations, the water was trucked to a site
licensed to handle the contaminant present.

     Dry solid material and all contaminated fixtures were  packaged in ap-
proved containers and disposed of in approved burial  grounds.  Uranium-con-
taminated waste was shipped to Barnwell, South Carolina, for burial; and
radium-contaminated waste was sent to a  Beatty, Nevada,  disposal  facility.

Heavy Metals —
     The major source of heavy metal  contamination in 135 buildings at the
Arsenal  was the lead-based paint that had been on the interior surfaces.   A
few of the buildings also were contaminated with mercury as the result of
laboratory spills.

     Buildings—Based on work done during Phase I of the cleanup  program,
airborne heavy metal  residues in the  buildings were found to be below target
levels.   Therefore,  the only decontamination work required  was the removal  of
loose and flaking paint, preparation  of  surfaces for painting, and subsequent
painting to meet bioavailability requirements set forth  by  the Surgeon  Gen-
eral.   Approval  granted to USATHAMA by the Surgeon General's Office to  paint
                                   225

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Appendix H:  Frankford Arsenal
to a height of only 1.8 m limited bioavailability of the new paint to people
who might occupy the buildings after their release by the Army.

     Cleanup and painting of the buildings were contracted to a  small local
business firm.  Their work consisted of removing loose and flaking paint from
the walls, sweeping the floors, vacuuming building rafters, and  applying a
paint containing no more than 0.06 weight percent lead.   The entire process
took approximately 7 mo.

     Sumps—The cleanup of 23 sumps contaminated with heavy metals was divid-
ed into water and sump sludge decontamination activities.  The water layer in
the sumps was analyzed and then discharged into the city sanitary sewer
system following approval by local officials.  Sludges remaining in the sumps
were then removed and disposed of in an approved landfill.  Empty sumps were
thoroughly rinsed with high-pressure water and then sampled.  Nine sumps in
which the target levels for heavy metal contamination were still exceeded
were backfilled with concrete to prevent further usage.7

Worker Protection

     Safety requirements were based on Federal, local, and industrial prac-
tices.  Workers went through a training program (overseen by the decontamina-
tion manager) in which all procedures were reviewed in detail.  Periodic
audits by quality assurance personnel ensured adherence to the specific
procedures.

     Prior to actual flaming for explosives decontamination, USATHAMA and the
local fire department were notified.  Fire extinguishers or hoses were made
available to all' operating personnel, and specific procedures were developed
in case of ignition.  Worker protection was provided by fire-retardant cover-
alls, safety glasses, face shields, protective aprons, and nonsparking tools.

     Until air samples were analyzed and it was determined that  airborne lead
levels were not being exceeded, workers wore appropriate respiratory protec-
tion.

     Vacuuming equipment used for radiological decontamination was equipped
with special exhaust high-efficiency particulate air  (HEPA) filters to reduce
the discharge of particulates to the atmosphere.  Workers wore specially de-
signed breathing apparatus during the vacuuming operation and safety glasses
during the vacuuming, washing, and surface-removal operations.  A fire extin-
guisher was present at all decontamination sites.

      In addition to complying with OSHA requirements and local building codes
for electrical equipment, all workers underwent a specialized training pro-
gram, in which they had  to review and understand all procedures before clean-
up began.  Quality assurance ensured adherence to specified procedures
through periodic audits.
                                    226

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                                               Appendix H:   Frankford Arsenal
Costs

     The cost of the decontamination and cleanup efforts at Frankford Arsenal
totaled $8 million.
EVALUATION OF DECONTAMINATION EFFECTIVENESS

     After decontamination, all  surfaces and sumps had explosive concentra-
tions below the levels established in Table H-l.   Asbestos-contaminated
materials were removed and disposed of in an approved landfill.   The 12
buildings contaminated with radiological wastes were certified as decontami-
nated when radiological surveys  indicated surface and airborne radioactivity
levels below the target values in Tables H-3 and  H-4.  Water was also cleared
of radiological contamination; test results yielded values lower than those
in Table H-4.

     Frankford Arsenal was assessed as acceptably decontaminated for radio-
logical contamination when appropriate tests had  been performed for each
1-m2 area and each effluent source or release pathway.  Because many of the
buildings were too large to be sampled in 1-m2 areas, a partial  inspection
was performed, and the results were interpreted statistically to assure
acceptability of these sites.  Following all cleanup activities, the NRC
toured the 12 buildings and verified their decontamination.

     Cleanliness of surfaces after decontamination activities was determined
through procedures similar to those used during initial sampling.  As expec-
ted, airborne samples taken after the cleanup yielded heavy  metal levels
below the target levels; actually, airborne heavy metals concentrations were
below these levels before any painting was done.'

     Water from the sumps discharged in the city  sewer also  met the criteria
in Tables H-2 and H-4.  The 14 sumps not filled with concrete were thoroughly
rinsed with high-pressure water.   The water was sampled and  found to meet
Philadelphia's requirements for  effluents in sewers.
                                   227

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Appendix H:  Frankford Arsenal
                          REFERENCES FOR APPENDIX H


1.   Rockwell International.  Final Report for the Frankford Arsenal Decon-
     tamination/Cleanup Program.  DRXTH-FE-CR-800, December 1980.

2.   Tuttle, R. J.  Frankford Arsenal Decontamination/Cleanup Operation -
     Radiological Inspection for Release for Unrestricted Use..   Rockwell
     International.  Pub. No. N505SRR000004, December 1980.

3.   Tuttle, R. J.  Frankford Arsenal Decontamination/Cleanup Operation -
     Cleanness Criteria for Release for Unrestricted Use.  Rockwell  Interna-
     tional.  Pub. No. N505SRR000002, October 1980.

4.   Strahl, H.  Frankford Arsenal Decontamination/Cleanup Operation - Stand-
     ing Operating Procedures for Cleanup of Explosive Residues  From Build-
     ings at Frankford Arsenal.  Rockwell International.  Pub. No.
     N505P000018, October 1980.

5.   Haines, R. V., and W. W. Kelley.  Frankford Arsenal Decontamination/
     Cleanup Operation - Cleanup and Demolition of the 400 Area.   Rockwell
     International.  Pub. No. N505TI000054, November 1980.

6.   Johnson, W. R.  Frankford  Arsenal Decontamination/Cleanup Operation  -
     Standing Operating Procedures for Cleanup of Heavy Metals and Explosive
     Residues and Radiological  Contamination of Buildings at  Frankford Ar-
     senal.  Rockwell International.  Pub. No. N5050P000009,  April  1980.

7.   Johnson, W. R.  Frankford  Arsenal Decontamination/Cleanup Operation  -
     Standing Operating Procedures for Cleanup of Heavy Metals and Explosive
     Residues From Buildings at Frankford Arsenal.  Rockwell  International.
     Pub. No. N5050P000014, August 1980.
                                    228

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                                  APPENDIX I

                   CASE STUDY:  NEW ENGLAND OFFICE BUILDING*
BACKGROUND

     In 1978 and 1979, a research program was undertaken at an office build-
ing in New England to 1) determine what commercial products could be used as
encapsulants to contain, prevent, or restrict the release of asbestos fibers
from friable asbestos-containing materials; 2) determine methods of evaluat-
ing commercial products for their efficiency as encapsulants; 3) determine
the effectiveness of the evaluation methods by evaluating a group of commer-
cial products; and 4) evaluate fiber release during field trials.

     During the course of the research program, asbestos was applied to
structures within the building, which were subsequently decontaminated
through encapsulation.  During these procedures, strict methodologies and
regulations were followed.


NATURE AND EXTENT OF CONTAMINATION

Contaminants Present

     Friable asbestos-containing material was spray applied to precast con-
crete slabs, steel support girders, and steel ductwork in a number of rooms.
These areas were concealed by drop ceilings, which were attached 0.75 m below
the precast concrete slabs.

Sampling and Analysis

     As part of the test program, air sampling was conducted at field sites
during encapsulant applications to determine the levels of worker exposure to
airborne asbestos during different periods of the operation and to determine
the settling rate of the asbestos fibers.  Airborne asbestos was collected
for subsequent microscopic analysis before, during, and after periods of room
preparation, encapsulant application, and cleanup.  Air samples were taken
*
  Source of Information:   Battelle Columbus Laboratories.   Final  Report on
  Evaluation of Encapsulants for Sprayed-On Asbestos-Containing Materials in
  Buildings.  U.S.  Environmental Protection Agency, Industrial  Environmental
  Research Laboratory, Cincinnati, Ohio.   1979.
                                   229

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Appendix I:  New England Office Building
both in the encapsulant spray test room and in adjacent rooms.   Outdoor ambi-
ent background samples were also taken.  Each of four rooms  evaluated inde-
pendently showed similar results.

     The indoor sampling procedure involved the use of a vacuum pump to draw
the asbestos-laden air through high-efficiency membrane filters.  A 47-mm-
diameter, 0.4-ym pore size polycarbonate membrane (Nuclepore)  filter sup-
ported by a 5.0-ym pore size cellulose acetate membrane (Millipore) filter
was used to collect the fibers.  Filters were placed at breathing height
around the rooms in open-faced filter holders covered with a hood to prevent
collection of unwanted debris, extremely large particles, or excess encapsu-
lant mist.  The sampling flow rate was set at 4.7 x 10~4 m3/s  (1 ft3/min) and
monitored with a rotometer throughout the sampling period.  Sampling times
were varied according to expected levels of airborne asbestos  and observable
loading of the filters.

     Outdoor asbestos samples were taken with an RAC Model GMWL high-volume
air sampler equipped with 0.45-ym pore size cellulose acetate  membrane (Mil-
lipore) filters at flow rates of 4.7 x 10"3 to 8.5 x 10"3 m3/s (10 to 18
ft3/min).  These samples were subsequently analyzed to determine the ambient
background level of airborne asbestos.

     The collections of airborne fibers on Nuclepore filters (along with the
Mi Hi pore backup filters) were stored and transported in 48 x  8.5 mm Mini-
pore plastic petri dishes.  Because it was not feasible to carbon-coat the
Nuclepore filters at the collection site, extreme care had to  be taken during
transport to avoid dislodging the particles on the filter surface.

     Upon its return to the lab, the collected sample was to be carbon-
coated, the Nuclepore filter material dissolved away, and the  fibers counted
and measured in the configuration in which they had been collected by trans-
mission electron microscopy (TEM).  Both light and electron microscopic
examination, however, revealed that the asbestos was unevenly distributed
(often in clumps).  This greatly reduced the chances for analysis of a repre-
sentative area by TEM.  In addition, the particulate concentration in some
samples was too high to penetrate with the electron beam.  These factors led
to the conclusion that the particulate should be redistributed before at-
tempting TEM analysis.

     Not enough extraneous organic particulate material was present to war-
rant sample preparation by low-temperature ashing.  Therefore, the particu-
late was removed from the Nuclepore filter by ultrasonic treatment in water
containing a surfactant (sodium dioctylsulfosuccinate).  The resuspended
particulate was divided into 10-, 20-, and 70-ml aliquots, each of which was
filtered, and the collected particulate was redeposited on separate 25-mm-
diameter, 0.2-ym pore size Nuclepore filters.  This made it possible to
select a particulate distribution suitable for analysis by TEM.  The result-
ing data were subjected to computer analysis, and the results were expressed
                                     230

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                                     Appendix I:   New England Office Building
in asbestos mass and numbers of fibers per m3  of sampled air.   The computer
also plotted fiber length, width, and length/width  ratios versus  cumulative
number percent and calculated mean fiber lengths, widths, and  length/width
ratios.

Hazard Evaluation

     Since the early 1970's, there has been an increasing awareness of the
carcinogenic properties of asbestos fibers.  One source of asbestos contami-
nation to the general  public is the deterioration of friable,  sprayed-on
asbestos-containing materials.  These materials were used in the  construction
industry until the EPA banned them in 1978.  Such asbestos fiber  hazards are
present in schools, apartments, night clubs, hotels, office complexes, and
industrial plants where asbestos was used for  thermal  insulation, fireproof-
ing, acoustical insulation, and decorative finishes.  Microscopic, needle-
like asbestos fibers are easily inhaled by inhabitants of these asbestos-con-
taining buildings.  Inhaled, asbestos fibers flow through the  respiratory
system and lodge in the lungs.  Lung and other forms of cancer have been
attributed to asbestos exposure.


DECONTAMINATION STRATEGY

     Four encapsulants were evaluated in the field  under conditions that
would be found in public buildings containing  friable asbestos contamination.
The encapsulants were classified as "bridging" or "penetrating" encapsulants;
one of the encapsulants was included in the former  category and three in the
latter.  Bridging encapsulants are defined as  those that form  a continuous
surface membrane over the asbestos-containing  test  matrix; penetrating encap-
sulants are defined as those that penetrate into the test matrix  (from 0.6  to
3.2 cm) and thereby improve the strength of the encapsulating  barrier.

Target Levels

     Because the primary objective of the research  operation was  to evaluate
potential encapsulants, no decontamination target levels were  set.  A second-
ary objective, however, was to detect any significant differences in concen-
tration of airborne asbestos before, during, and after applying encapsulants.

Methods

     The four encapsulants used for field evaluation were identified as fol-
lows:

     A—Bridging acrylic-based material
     B--Penetrating polyvinyl acetate copolymer-based material
     C—Penetrating acrylic-vinyl acetate copolymer
     D--Penetrating acrylic-modified polyester
                                     231

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Appendix I:  New England Office Building
     First, the four encapsulants were evaluated for fire resistance by a
modification of ASTM Test Method E 162 (Surface Flammability of Materials
Using a Radiant Heat Energy Source).   The encapsulants were applied to three
test panels:  1) asbestos board, 2) the test matrix, and 3) plywood.  The
asbestos board substrate was used as  a control.  Bridging encapsulant A was
rated as having a Class "C" flame spread on the test matrix (Department of
Housing and Urban Development Minimum Property Standards).  Class "C" materi-
als have limited application.  Penetrating encapsulants B, C, and D were each
rated as having a Class "A" flame spread on the same substrate.

     Field trials were conducted during two different time periods; however,
both trials were conducted on the same asbestos-containing substrate in dif-
ferent rooms.  The test matrix was a  friable asbestos-containing material (30
to 35 percent chrysotile) applied approximately 5.1 cm thick over a precast
cement roofing and also on steel support I-beams.   Although highly friable
(released visible fibers when brushed), the material was in good condition
(no loose material hanging down).

     Bridging encapsulant A and penetrating encapsulant B were applied to the
asbestos-containing material with an  airless spray gun.  The pump pressure
was kept as low as possible to ensure a uniform spray pattern and minimum
asbestos fiber release.  The pump pressure resulted in a nozzle pressure of
7210 to 8270 kPa (1050 to 1200 lb/in2).

     Bridging encapsulant A was applied in two coats.  The first coat was
applied as a mist coat with the encapsulant reduced approximately 10 percent
with water.  The second coat was applied without this reduction approximately
4 h after the first coat.  The combination of the two coats formed a very
tough elastic film about 0.3 cm thick over the surface of the asbestos.
Penetration of the two coats was approximately 1.0 cm deep.

     Penetrating encapsulant B was also applied in two coats.  The first
coat, however, was actually a "double coat."  Because the encapsulant pene-
trated into the asbestos-coating material very quickly, after coating approx-
imately a 1.1-m2 area, the same area  was recoated immediately.  The second
coat was then applied (in one pass) after the first "double" coat had been
allowed to cure for a minimum of 12 h.  The encapsulant penetrated up to 1.9
cm into the 9.1-cm asbestos-containing material.

     In the second field trial, penetrating encapsulants C and D were applied
to the test matrix by the same procedure used for the penetrating encapsulant
in the first trial.  With an airless  spray nozzle and pump, the first coat
was applied as a "double coat" and the second as a single coat.

     Penetrating encapsulant C penetrated approximately 0.6 cm.  Examination
of a core sample indicated that the resin binder in the encapsulant material
did not penetrate as deeply into the  asbestos material as the water did.
This resulted in a resin-rich top layer that sealed the surface and prevented
the release of asbestos fibers.  The  surface, however, did not exhibit the
desired impact-resistance.


                                     232

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                                     Appendix I:  New England Office Building
     Encapsulant D foamed during the airless spray application of the first
coat.  Therefore, the encapsulant was reduced with water for the second
application.  The foaming apparently restricted the penetration of the encap-
sulant.  A core sample indicated that the maximum penetration achieved was
only 1.0 cm.  Although the foaming was overcome during the application of the
second coat, no further penetration was achieved, possibly because the sur-
face of the asbestos material was partially sealed by the first coat.  Even
though the encapsulant did not penetrate as desired, it did form a sealed
surface over the asbestos material that could restrict asbestos fiber
release.

Worker Protection

     All personnel in the coating area and the control room were required to
wear disposable protective clothing and a respirator.  The protective cloth-
ing consisted of plastic disposal coveralls, polyethylene booties, a hood,
and rubber gloves.  Two types of respirators were used.  The first type was a
half-mask respirator with two Ultra Filters (cartridge type "H").  This res-
pirator is approved by the National Institute for Occupational Safety and
Health (NIOSH) and the Mine Safety and Health Administration (MSHA) for pro-
tection against dust and mist.  The second respirator type was a 3M 09910
dust and mist respirator, which has NIOSH and MSHA approval for asbestos use.
This disposable-type respirator proved to be ineffective in keeping a good
seal around the face when stretching the neck to look overhead.

Costs

     The cost for the encapsulation research study is not available.


EVALUATION OF DECONTAMINATION EFFECTIVENESS

     The results of air sampling during spray application operations demon-
strated how strongly activity affects the airborne asbestos concentration in
a room.  In all cases, peaks in airborne concentration corresponded to peri-
ods of high activity (ceiling removal, spraying, cleanup, ceiling replace-
ment).  Without exception, the highest levels were observed during the ini-
tial sealant application in each room.  During periods of no activity, the
airborne concentration of asbestos decreased drastically.  Such a decrease
may be attributed to gravitational settling of fibers or clusters of fibers.

     The results strongly, if not conclusively, suggested that workers'
activities serve to entrain and disperse previously deposited asbestos fibers
in their work environment and thereby create a possible health problem.  Each
of the test areas evaluated had airborne concentrations below the NIOSH
standard (2.0 fibers/cm3) during background and nonactive periods, but during
each period of worker activity, the airborne concentration typically exceeded
the standard by one or two orders of magnitude.
                                     233

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Appendix I:  New England Office Building
     The airborne asbestos concentration measured in a room adjacent to the
room being sprayed varied in a manner similar to that of the sprayed room.
Though attempts were made to isolate the spray rooms, elevated concentrations
of asbestos in adjacent unsprayed rooms were undoubtedly the result of con-
tamination from the spraying activities.  This observation clearly demon-
strates the need to isolate the room in which encapsulating procedures are
taking place.
                                     234

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                                 APPENDIX J

                   CASE STUDY:  LUMINOUS PROCESSES, INC.*
BACKGROUND
     The Luminous Processes, Inc., site is a defunct manufacturing facility
near Athens, Georgia, in Clarke County.  The company, which was operational
from 1952 until 1978, utilized radioactive radium-226 and tritium to paint
watch and clock dials.  When the owners essentially abandoned the site in
1980, the levels of radioactive contamination in the soil and building ex-
ceeded the generally accepted criteria for permissible levels of radiation
and radioactive material.

     The State of Georgia made several unsuccessful attempts to get the
company to decontaminate the building and surrounding property (approximately
0.4 ha).  In March 1981, the Governor of Georgia appointed an interagency
task force to determine the extent of the problem and seek the necessary
financial assistance to decontaminate the property.  During the succeeding
months, personnel from the Georgia Department of Natural Resources (DNR) and
the Department of Human Resources (DHR) conducted a detailed site evaluation.
A decommissioning plan was prepared and later submitted to the U.S. Environ-
mental Protection Agency (EPA) as part of pre-grant negotiations for finan-
cial assistance under the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (Superfund).  In addition, the State of Georgia
initiated legal proceedings against Luminous Processes, Inc., and its associ-
ated officers and directors.  The Luminous Processes site was nominated as
Georgia's top priority site for planne'd removal  and appeared on EPA's October
1981 Interim Priority List of 115 uncontrolled hazardous waste sites.

     On April 6, 1982, EPA and the State of Georgia entered into a Coopera-
tive Agreement for remedial action at the Luminous Processes, Inc., site,
whereby the Georgia Environmental Protection Division (EPD) was established
as the lead agency.  A contractor qualified to remove the contaminated soil
was selected from among 39 interested firms.  The scope of work included in
the contract involved the excavation, packaging, shipment, and disposal of
*
  Source of Information:   State of Georgia.   Department of Natural  Resources,
  Environmental Protection Division.   Luminous Superfund Project Report:
  Remedial Action for the Removal  of Ra-226  Contamination at the Luminous
  Processes, Inc. Site in Clarke County, Georgia.   August 1982.
                                    235

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Appendix J:  Luminous Processes,  Inc.
425 m3 of soil and materials contaminated with radium-226 up to concentra-
tions of 2000 picocuries per gram (pCi/g).  The scope of work section of the
contract was later amended to include removal  of contaminated structures
inside the building and septic tank tile field areas that were found to be
more contaminated than the original site studies had indicated.


NATURE AND EXTENT OF CONTAMINATION

     As part of a comprehensive feasibility study, the State of Georgia
conducted a full-scale radiological evaluation of the Luminous Processes site
and adjacent properties during the spring of 1981.  The purpose of this
evaluation was to determine the nature and extent of contamination and to use
information gained in the evaluation process to identify decontamination
options.

Contaminants Present

     During the evaluation period, State personnel conducted direct radiation
measurements (both onsite and offsite) to determine radiation exposure rates.
In addition, soil samples were collected at established grid pattern loca-
tions and Ra-226 concentrations in picocuries per gram were measured as a
function of soil depth.

     The maximum observed onsite external radiation level was found to be
approximately 1.5 millirems per hour (mrem/h).  This means that the continu-
ous presence of an individual in such an area for a period of 1 year could
result in a theoretical dose of over 13,000 mrem.  This theoretical level is
more than 25 times the 500 mrem recommended by the National Council on Radia-
tion Protection for exposure of the general public.  Levels of Ra-226 wastes
in onsite soils were found to be in excess of ambient (background) levels by
more than a factor of 40.  Approximately 425 m3 of soil was estimated to be
contaminated.  In addition, external radiation levels in soils immediately
adjacent to and south of the site were found to be approximately two times
background levels.

     Inside the building, residual levels of removable alpha contamination
were found to be present on certain walls and surfaces.  In addition to the
removable contamination, some fixed contamination was still found to be
present in the building.  The initial internal building evaluation did not
include the extent and distribution of fixed contaminants within the building
because of measurement problems created by interferences from the higher
outside levels of radiation.  After about two-thirds of the remedial action
outside the building was completed, a detailed study was conducted inside the
building.

Sampling and Analysis

     An initial entry into the building was made to collect air samples for
determination of radium daughter products in the air.  While the highest


                                     236

-------
                                        Appendix J:  Luminous Processes3  Inc.
value of 0.003 working levels was well within permissible limits for occupa-
tion of the building during the survey, a decision was made to air out the
building overnight by opening several windows and doors.

     The next phase of the project was to lay out the building into definable
survey blocks according to a grid system (Figure J-l).  Because this had al-
ready been done by previous investigators, it was merely a matter of recheck-
ing the grid system against reference points in the building.  Next, an
appropriate survey plan had to be devised to be sure all  portions of the
building were adequately covered during a survey for Ra-226 arid its daughter
products detectable in situ or in smearable form.  Not only did interior sur-
faces such as floors, walls, ceilings, doors, and windows need to be surveyed
for evidence of contamination, but remaining fixtures (sinks, toilets, light
fixtures, heating ducts, roof structures, and subfloor/foundation) also
required radiological testing.

     The tests that were utilized in the assessment included in situ direct
alpha activity testing, wet smearable (removable) testing for tritium (where
appropriate), and special testing for activity found in paint and concrete.
The building was also surveyed for direct gamma radiation with a low-level
gamma radiation detector (Ludlum Model 19).  Testing was conducted primarily
on a regular, internal sampling basis (without biased scanning for hot spots)
to build the statistical distribution necessary for a representative assess-
ment.  More than 200 in situ alpha tests, 200 dry measurable alpha tests, and
50 wet smearable tritium tests were conducted during this phase of the
survey.

     Three survey teams conducted the in situ direct alpha testing, utilizing
either Eberline PAC-1 SATA-AC 3-7 or Ludlum 2200-PR-0190 alpha scintillation
type survey instruments with wide-area contamination monitoring probes.  The
efficiency of each instrument was determined with an NBS traceable Am-241
alpha source (No. D963), and the effective area of each probe was determined
so that the instrument readings (counts per minute) could be corrected to
alpha activity in disintegrations per minute per 100 square centimeters
(dpm/100 cm2).  This survey was conducted at approximately 200 points over
1.5-m2 subgrid block areas on the floor, walls, and ceiling of the building.

     A second type of alpha radiation testing was conducted to determine dry
smearable (removable) contamination from surfaces.  This test consisted of
wiping (smearing) the surface under test with an ash!ess-type filter paper
over approximately a 100-cm2 area.  The smear paper was then counted with an
alpha scintillation detector and a Ludlum 2200 sealer in the laboratory.  The
alpha detector-sealer system was calibrated with the Am-241 alpha source.

     Tritium smears were taken with a cotton tip swab and placed in contact
with a liquid scintillation counting solution.  An Aston 1006 Manual Liquid
Scintillation Counter was used to analyze the sample in the laboratory.
Calibration was performed with an NBS traceable H-3 solution to determine a
base efficiency.  Internal  standards testing was also performed on some
off-color samples or if quenching determinations were necessary.

                                     237

-------
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-------
                                        Appendix J:   Luminous Processes3  Inc.
     Typical data are presented by grid block location for groups of related
grid blocks in Table J-l.   For in situ direct alpha and dry smearable alpha
tests, multiple test points were often measured within the group of related
grid blocks to determine representative values.  For this reason, the number
of data points, the mean or average value of the data points,  and the maximum
observed value of the data points are given in the table.

     A review of the data  indicated that very little removable alpha activity
existed.  There were also  small areas of tritium contamination, but the main
problem was alpha contamination between the wall surface and the layer of
paint.  Contamination also existed at defined areas on the ceiling, doors,
ductwork, and electrical wall panels.

     Based on the data, it was decided that physical testing of the surfaces
would be necessary to determine how deeply the contamination was embedded in
the wall board or painted surfaces, and to determine the best way to remove
it.  In this regard, a limited number of tests were performed on paint chips,
wall board chips, and concrete chips.   The results indicated that, at the very
least, the entire coat of paint had to be removed from the walls, along with
some of the interior surface of the wall structure.  Tritium was also found
deeply imbedded in the wallboard itself.

Health Hazard Evaluation

     Radium-226 is a radioactive isotope of radium having a half-life of 1620
years.  Radium 226 emits ionizing radiation (gamma rays) that is destructive
to living tissue.  High levels of ionizing radiation cause somatic damage and
may also induce genetic damage.  Long-term effects of exposure to ionizing
radiation may include increased incidence of carcinoma and shortening of the
life span.  Tritium is a beta-emitter; its radiotoxicity is very low.  Once
inhaled, tritium enters the normal body pool and in a short period becomes
part of the body's metabolic scheme.   Maximum permissible exposure limits to
Ra-226 and tritium are discussed in the following section under the heading
"Target Levels."


DECONTAMINATION STRATEGY

     Making the site suitable for release for unrestricted use by the general
public required that actions be taken to ensure the reduction of radiation
and radioactive materials  to acceptable levels.  Of the options available to
the State, the preferred method was the removal of the radiological contami-
nants from the site and ultimately disposing of them in an authorized radio-
active burial facility.  The bulk of the contaminants were in the form of
radium-contaminated soil (425 m3) and, to a lesser extent, contaminated
building materials.  Under the decontamination and decommmissioning plan
submitted by the State, contaminated soil and building materials would be
removed from the site until the target levels could be achieved.
                                     239

-------
      TABLE J-l.  TYPICAL BUILDING SURVEY DATA FROM INTERIOR WALLS
Bldg.
area
(grid)
la
14a
6
44
71
68
60
52
43
Number of
measurements
1
1
1
5
4
10
4
12
8
In situ alpha,
dpm/100 cm2
Average
1,870
1,870
ND
898
608
823
468
1,683
95
Maximum
1,870
1,870
-
2,618
2,431
3,740
1,122
14,960
375
Smearable alpha,
dpm/100 cm2
Average
NDb
ND
ND
ND
6
ND
ND
8
3
Maximum
-
-
-
-
26
-
-
20
13
Window sill.
ND - None detected.
                                   240

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                                        Appendix J:   Luminous Processes,  Inc.
Target Levels

     The State of Georgia's position has been that decommissioning and decon-
tamination work at Luminous Processes, Inc., should be conducted in such a
manner that exposures to radiation and radioactive material  would be as low
as reasonably achievable (ALARA).  Target levels for the building and the
property and grounds were developed to serve as guidelines for attaining this
objective.

Building--
     The decontamination target levels for the building on site were based on
U.S. Nuclear Regulatory Commission (NRC) guidelines for decommissioning
nuclear facilities.  Table J-2 indicates the allowable direct radiation
levels and the allowable levels for Ra-226 (and associated daughter products)
and other contaminants.

Property and Grounds--
     The target levels for external (direct) radiation were  established at an
average of 10 microrads per hour (yR/h) above background (30 yR/h).  Levels
of 10 yR/h for persons working in, residing in, or otherwise using the "re-
leased" area would, if continuously present in such an area, receive less
than 20 percent of the National Council on Radiation Protection's recommended
exposure for members of the general public.  A level of 10 yR/h was specified
by the NRC in guidelines for decommissioning nuclear facilities.

     With respect to the Ra-226 concentration in the soil, a target level of
an average of 5 pCi/g above background (5 pCi/g) was established.  This
objective was based on draft guidance by the U.S. EPA.

     The target level for tritium in soil was established as an average of
50,000 pCi/g.  This objective could be exceeded in some instances provided
potential surface water runoff from the property did not exceed 3,000,000
pCi/liter and that the potential for surface runoff to result in contamina-
tion of drinking water above the recognized Georgia Safe Drinking Water limit
of 20,000 pCi/liter was minimal.  This objective was based on NRC rulemaking
March 11, 1981, concerning radioactive wastes.  Basically, the NRC recognized
an "exemption" for disposal of certain tritiated wastes provided the concen-
tration of tritium did not exceed 50,000 pCi/g.  The rulemaking change is
currently incorporated in 10 CFR 20.306.  The limiting value for tritium in
surface runoff (3 x 106 pCi/liter) is based on NRC limits for release of
licensed material to unrestricted areas via the waterborne pathway.  The
limiting value for tritium contamination in drinking water is based on the
maximum contaminant limit for public drinking water supplies as specified in
the Georgia Rules for Safe Drinking Water (Chapter 391-3-5,  July 1977).
                                     241

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                                   Table  J-2.  ACCEPTABLE  SURFACE  CONTAMINATION  LEVELS
           Nuclides0
                                      Average
                                                  b,c,d
     Maximum
                                                                      b,d,e
    Removable
                                      b,d,f
ro
-P»
ro
U-nat, U-235, U-238, and
associated decay products

Transuranics, Ra-226, Ra-228,
Th-230, Th-228, Pa-231,
Ac-227, 1-125, 1-129,

Th-nat, Th-232, Sr-90,
Ra-223, Ra-224, U-232, 1-126,
1-131, 1-133

Beta-gamma emitters (nuclides
with decay modes other than
alpha emissions or spontaneous
fission) except Sr-90 and
others noted above
                                         5,000 dpm a/100  cm2
                                           100 dpm/100  cm2
                                         1,000 dpm/100  cm2
                                         5,000 dpm  ey/100  cm2
15,000 dpm a/100 cm'
  300 dpm/100 cm2
 3,000 dpm/100 cm2
15,000 dpm By/100 cm2
1,000 dpm a/100 cm2
   20 dpm/100 cm2
  200 dpm/100 cm£
1,000 dpm gy/100 cm2
        Where  surface  contamination  by both alpha- and beta-gamma-emitting nuclides exists, the  limits estab-
        lished for alpha- and  beta-gamma-emitting nuclides  should apply  independently.
        As  used in this  table,  dpm  (disintegrations per minute) means the rate of emission by radioactive
        material  as determined  by correcting the counts per minute observed by an appropriate detector for back-
        ground, efficiency,  and geometric factors associated with the instrumentation.
        Measurements of  average contaminant should not be averaged over more than 1 m2.  For objects of less
        surface area,  the average should be derived for each such object.
        The average and  maximum radiation levels associated with surface contamination resulting from beta-gamma
        emitters  should  not  exceed 0.2 mrad/h at 1 cm and 1.0 mrad/h at  1 cm, respectively, measured through not
        more than 7 mg/cm2 of  total  absorber.
        The maximum contamination level applies to an area of not more than 100 cm2.
        The amount of  removable radioactive material per 100 cm2 of surface area should be determined by wiping
        that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount
        of  radioactive material  on the wipe with an appropriate instrument of known efficiency.  When removable
        contamination  on objects of  less surface area is determined, the pertinent levels should be reduced
        proportionally and the  entire surface should be wiped.

-------
                                        Appendix J:   Luminous Processes,  Inc.
Methods

     The majority of the work scope for the cleanup of the Luminous Processes
site involved excavation, packaging, shipment, and disposal  of soil contami-
nated with Ra-226.  After about two-thirds of the remedial action outside the
building was completed, a detailed assessment of the building was performed.

     The building, a single-story structure with approximately 370 m2 of
space, was divided into 18 rooms, including watch dial and hand painting
rooms, a dark room, an ultraviolet room, supplies and mechanical  rooms,
storage rooms, shipping room, restrooms, lunch/break room, offices, closet
areas, and a garage.  Prior to the State of Georgia's involvement in cleanup
of the site, contractors for Luminous Processes had partially removed Ra-226
and tritium contamination from the building.  During this decontamination
effort, most of the readily removable contents of the building were shipped
off for disposal.  These included items such as tables, chairs, cabinets,
exhaust hoods, sinks, air conditioners, assorted tools, office equipment
(including a typewriter and printing machines), some doors and light fix-
tures, hot water heater, dollies, and floor tiles.  In addition,  the walls
were washed to remove loose contamination before contaminated paint was
stripped.  Work had not progressed beyond this point since the end of 1979.

     Before the State of Georgia could proceed with further decontamination,
the overall structural integrity of the building had to be assessed.  It was
found that the center section of the ceiling and roof was in danger of col-
lapse because frequent heavy rains had caused leakage through vent penetra-
tions that had not been resealed after previous decontamination work.  Large
puddles of water and plaster chips from the ceiling covered nearly 50 percent
of the floor space, and the ceiling was sagging from the pressure of water.
Because of the obvious structural hazards, as well as the obstacles of debris
and water on the floor, the following actions were taken:  the ceiling was
braced for safety purposes, the water and debris were removed from the floor
and placed in drums for disposal, and the roof was covered with a temporary
plastic cover to prevent further entry of water.

     Following these structural modifications, the building was surveyed to
determine the nature and extent of contamination, as outlined previously
under "Sampling and Analysis."  The results of the survey indicated that con-
tamination had penetrated the paint and wallboard.  The most cost-effective
means of achieving decontamination was determined to be removal of all paint-
ed wallboard.

     Interior wallboard was removed from the building studs, broken up into
small pieces, and packaged in DOT-specification 17H drums for shipment to a
hazardous waste disposal site in Richland, Washington.  In addition, it was
determined that a small area around each door knob on the doors to the inte-
rior rooms was contaminated with alpha radioactivity.   Rather than remove the
entire door, the contaminated areas were removed from the door by sawing out
the surrounding sections, which were then placed in drums for shipment to the
                                     243

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Appendix J:  Luminous Processes,  Inc.
disposal site.  The fuse boxes and electrical  panels were found to be contam-
inated on both inside and outside surfaces.   They were removed, crushed, and
placed in barrels for shipment.  Contaminated area spots were also found on
window sills, light fixtures, and the heating ductwork.   Table J-3 presents
representative data for a number of these areas.   After several physical
removal tests were performed, it was determined that a variety of techniques
could be employed to decontaminate the area so that shipment to the disposal
site in Richland, Washington, would not be necessary.  For example, the
window sills were treated with paint remover and sandpapered to remove the
contamination.  The light fixtures and ductwork were carefully removed and
taken outside the building, where as much paint as possible was stripped by
use of a high-velocity jet washer.  The remaining areas were further sanded
and monitored to determine that target levels had been met.  These decontam-
inated fixtures were then crushed and transported for disposal in the metals
disposal area of the Clarke County Sanitary Landfill.

     Finally, other remaining areas (such as toilets and sinks) were surveyed
and found to be free of radioactive contamination.  One of the last studies
involved the complete breaching of the concrete floor pad and removal of a
sample of the underlying gravel and soil support structure.  An analysis of
the material showed that it was not contaminated with radioactivity.

Worker Protection

     One of the primary objectives during cleanup work at the Luminous Pro-
cesses site was to keep external and internal exposure to radiation and
radioactive materials as low as reasonably achievable (ALARA).  A system for
personal protection and exposure monitoring was established to meet this
objective.  This system included the following items:  whole body radiation
counting, bioassays, radiation dosimetry, breathing zone air sampling, respi-
ratory protection, and protective clothing.  As a result of the exposure
controls enforced during the cleanup, no personnel were unduly exposed to
radioactive materials.  Thus, the stated objective of keeping exposures ALARA
was achieved.

Whole Body Radiation Counting--
     All workers whose efforts could routinely put them in direct contact
with contaminated material were checked for radiation exposure by counting  in
a Nal whole body counter before, during, and after the project.  None of
these counts showed a Ra-226 level above the minimum detectable level of 2
nanocuries (nCi).

Bioassays--
     Indirect bioassays were made of the urine of persons working inside the
Luminous Processes building to be sure they had not  ingested excessive
amounts of tritium.  The highest value obtained was  11±3 pCi/ml, well within
safe limits.
                                     244

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              TABLE J-3.  TYPICAL BUILDING SURVEY DATA  FROM
                   INTERIOR STRUCTURES  (EXCLUDING WALLS)
Building
area (grid)
14
20
25
35
42
43
46
49
62
65
68
Structure
Window sill
Heating duct
Heating duct
Door (around knob)
Fuse box
Door (around knob)
Dirt under floor slab
Heating duct
Floor
Heating duct
Heating duct
Average gross alpha,
dpm/cm2
1,870
1,065
852
2,805
3,740
7,480
NDa
1,065
1,520
3,195
4,473
ND - None detected.
                                  245

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Appendix J:  Luminous Processes,  Inc.
Radiation Dosimetry—
     External exposures were monitored by use of thermoluminescent dosimeters
(TLD's) assigned to each person entering the site.   Thirty-five individuals
were assigned dosimeters.  The average exposure of  these individuals,  includ-
ing background, was 18.5 mrem; the maximum exposure was 80 mrem.

Breathing Zone Air Sampling--
     For determination of the potential inhalation  hazard due to airborne
contamination, workers in areas likely to pose an airborne hazard were moni-
tored by lapel or breathing zone samplers similar to those used in uranium
mines.  Such samplers utilize a battery-powered pump to draw a measured
amount of air through a filter that collects airborne particulates.  The
filter is later analyzed for radioactive content.  In general, workers in the
drum-loading hopper or in other dusty operations, such as demolition of the
wallboard or septic tank, were sampled.

Respiratory Protection--
     The use of respiratory protection was limited  to activities conducted
inside the building and served mainly to protect workers from dust from the
wallboard, not from airborne radioactive materials.  All workers inside the
building during the removal of building materials wore full-face, air-purify-
ing respirators.  The cartridges used in these respirators, however, also
provided protection from airborne radioactive materials.

Protective Clothing—
     The use of protective clothing by onsite personnel served a dual  func-
tion—that of preventing direct skin contact with radioactive materials
(thereby avoiding the possibility of radioactive materials on the hands being
ingested during eating, smoking, or other activities) and preventing the
spread of contamination.  All persons working on the site were required to
wear long-sleeved coveralls, gloves, and either disposable boots or heavy-
duty boots that remained on site.  For safety reasons, all persons on the
site were also required to wear a hard hat.  Persons performing a task having
a  high probability of contamination were required to wear a disposable paper
suit over the coveralls.

     Upon leaving the site, all persons were required to remove all protec-
tive clothing in the contamination reduction area.   Disposable items were
discarded in a plastic trash can liner, which eventually was placed in a drum
along with contaminated  soil.  Nondisposable items, such as coveralls, hard
hats, boots, and cloth gloves, were left on site until they could be surveyed
for release.  After removing their protective clothing, workers washed their
faces and hands in the contamination reduction area, and then checked them-
selves with  a Geiger counter.

     All items leaving the  site were surveyed for contamination before re-
lease.   A log book was maintained that  showed the type of  items, the name  of
the person performing the  survey, and whether or not the item was  released
                                     246

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                                        Appendix J:   Luminous Processes,  Inc.
from the site.  Several sets of coveralls were found to be contaminated above
release limits and were discarded along with the disposable items.   No equip-
ment was found to be contaminated above release limits.

Costs

     Under the Cooperative Agreement between the State of Georgia and the
EPA, the State agreed to pay 10 percent of the total project cost;  EPA agreed
to finance the remaining 90 percent.

     During the course of the remedial  action, the contract was amended twice
to incorporate additional scopes of work not included in the original con-
tract.  These included decontamination  of the interior of the building and
removal of contamination in areas previously unidentified.  The resulting
total project cost for the Luminous Superfund Project was $754,394, which
included the costs for building decontamination, compared with an initial
estimate of $812,921, which did not include any building decontamination
costs.
EVALUATION OF DECONTAMINATION EFFECTIVENESS

     The interior of the building has been decontaminated within the estab-
lished criteria, but a major safety hazard continues to exist because of the
rapidly deteriorating condition of the structure.   The water-logged ceiling
is expected to continue to place enough stress on  the roof to widen the
existing cracks and holes, and at some time, the entire roof will  cave into
the building.  For this reason, the building has not been released; it re-
mains locked and posted to prevent access.
                                     247

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                                  APPENDIX K

                CASE STUDY:   CHEMICAL METALS INDUSTRIES,  INC.*
BACKGROUND

     Until its bankruptcy in August 1981, Chemical  Metals  Industries,  Inc.
(CMI) occupied two pieces of property in the Westport section of Baltimore,
Maryland—one at 2001 Annapolis Road (Site 1) and one at 2103 Annapolis  Road
(Site 2).  The two sites are separated by approximately 15 to 20 private
residence row houses.  Land use in the immediate surrounding neighborhood is
a mixture of residential and commercial.

     Operations conducted by CMI included the manufacturing of copper  sulfate
and copper hydroxide, and the recovery of precious metals  from waste chemical
solutions, and the printing of circuit boards.  Site 1 was used for storage
of miscellaneous solids (in drums), large quantities of scrap metal and
acids, and other caustic and neutral waste liquids.  This  site (a former
Sinclair gasoline station) consisted of a storage garage and adjoining yard.
Site 2 comprised the office, laboratory, and manufacturing center for  CMI.
It included a building that housed company operations and  an adjoining yard
with numerous large  (19,000-liter) above-ground storage tanks.  Local  resi-
dents and former CMI employees indicated that precious metals reclaiming had
been conducted at this location since the 1950's.

     Approximately 2 weeks before CMI filed for bankruptcy in August 1981,  a
Maryland Office of Environmental Programs inspector spotted the abandoned CMI
operation.  Subsequent investigations led State and Federal officials  to
conclude that immediate site remedial action  (using Superfund monies)  was
warranted.  Conditions were such that chemical substances  abandoned on the
site might react and cause a fire or explosion in the surrounding residential
neighborhood.

     Using Superfund resources, both pieces of property were remedied and put
back into public use.  Site 1  (the former CMI chemical storage yard) is  now a
neighborhood park.   Site 2  (the former CMI manufacturing facility) is now
used by  the Maryland Department of Health as office and storage space.
*
  U.S. Environmental Protection Agency (Region III).  Federal On-Scene
  Coordinator's Report.  Chemical Metals Industries, Inc., Baltimore,
  Maryland.   Immediate Removal Project.  Philadelphia.  Undated.
                                     248

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                                 Appendix K:   Chemical Metals Industries, Inc.
 NATURE AND EXTENT OF CONTAMINATION

      Site  1 contained approximately  1500  severely deteriorated plastic and
 metal  drums piled haphazardly  on  top of one  another.   Liquids from  some of
 the  drums  were  leaking onto  the ground.   Markings on the drums indicated that
 at one time they  contained,  and may  have  still contained, corrosive  liquids,
 cyanide-bearing compounds, and ammonia-bearing compounds.  Twenty drums con-
 tained organic  solvents.   Four underground storage tanks were located on the
 site;  one  contained  suspected  waste  oil and  the other  three contained gaso-
 line and water.   Organic  vapors were detected in samples of soil and ground-
 water  from the  site.   Rainfall was carrying  a blue-green material offsite,
 and  this material  was impacting walkways  and streets and draining into storm
 sewers.  Analysis  of the  liquids  in  the drums showed no commercially signifi-
 cant levels of  precious metals.   Analysis of soils from the site indicated
 cadmium levels  above EP toxicity  values (i.e., greater than 1 mg/liter in the
 EP extract).

     Site  2 contained 15  processing, chemical, and waste storage tanks, some
 of which were open.   The  tanks were  filled with varying amounts of liquid and
 crystalline material.  Approximately 100 drums filled with acids, caustics,
 salts,  and wastes  were also  stored there.  Sampling of the drums confirmed
 the  presence of cyanide-  and ammonia-bearing materials and corrosive liquids.
 One  drum containing  acid  was reported to be  fuming.   Another 175 drums at the
 site contained  solids  and sludges of unknown composition.  A vault at the
 site contained  approximately 12 boxes and 12 bags of solid and powdered
 metals  and other miscellaneous items.  The metal  stored in the vault was
 later  confirmed to be  zirconium, which is unstable as a powder.   (In bar
 form,  the  zirconium metal is stable; however, a spontaneous chemical reaction
 may  occur  if it is dropped.)   Small quantities of numerous reagents were
 found  in the laboratory and  in laboratory storage areas.   Low concentrations
 of hydrogen  cyanide  and organic vapors were detected through air monitoring
 at the  site.

     Chemical analyses of the contaminated soil  samples taken from the site
 indicated  that the material would be acceptable for  disposal  at  a permitted
 hazardous  waste landfill.  Groundwater samples taken from monitoring wells  at
 the  site were bluish-green.

     Major concerns for both sites included  1)  imminent  threat  of fire  or
 explosion  in the residential  neighborhood, either from the actions of vandals
 or because of the chemical incompatibilities  of the  materials  in  the deteri-
 orating drums; and 2) potential hazard to the public and  the  environment
 posed by runoff that could impact  Gwynns  Falls,  a tributary of the Patapsco
 River.

     Extent-of-contamination  surveys  and  helicopter  overflights  indicated
that most of CMI's hazardous  materials  had not contributed to  any offsite
environmental degradation.
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Appendix K:  Chemical Metals Industries,  Inc.
DECONTAMINATION STRATEGY

Target Levels

     Target levels for decontaminating buildings and structures apparently
were not established.  Rather, cleanup generally focused on the analysis,
identification, and removal of chemicals in containers and the identification
of potentially incompatible wastes that could lead to fire or explosion if
allowed to contact each other.

     Soil removal at the site was guided by the RCRA EP Toxicity character-
istic defining hazardous waste (see 40 CFR 261.24).  Soils were determined to
be hazardous and were removed if levels of metals in the extract from the
test exceeded the established criteria of 100 times drinking water standards.

Methods

     At Site 1 (the CMI storage yard), more than 1500 plastic and metal drums
were removed.  Approximately 3800 liters of liquids (mostly waste oil and
mixtures of gasoline and water) were pumped from the four underground tanks
at Site 1.  After they were emptied, these tanks were filled with a concrete
slurry to prevent further use and to fill the void.  All above-grade struc-
tures on Site 1 were razed and removed, along with contaminated soil, to a
hazardous waste landfill.  One remaining wall, which was shared with an ad-
joining residence, was left standing; this wall was sandblasted to remove
contamination.  After the removal of all hazardous materials and other de-
bris, Site  1 was graded, capped, and sodded.  The site  is now used as a
playground  for neighborhood children.

     At Site 2 (the CMI main operations center), approximately 19,900 liters
of acidic solutions and 31,400 liters of basic/neutral  solutions were pumped
from the 15 above-ground storage and processing tanks.  After careful removal
of the liquids from these tanks, the tanks themselves and all chemical pro-
cessing equipment were removed.  In addition, approximately  100 drums of
acids, caustics,  salts, and other wastes and  175 drums  of solids and sludges
of unknown  composition were removed.  These materials were classified as
hazardous wastes  and removed  to  a permitted disposal  facility.

     An  unstable  structure at the rear  of  Site  2 was  removed.  Electricity
was  restored to  the  remaining building, and the front and side walls were
sandblasted.  The yard was paved after  cleanup  and  surface grading.  The
building and yard of Site  2 are  now used by the Maryland  Department  of Health
as additional office and storage space.

Worker  Protection

      Site  safety plans were written for both  sites.   These plans required
medical  examinations  and training  for  cleanup personnel,  outlined  the  site
monitoring  program,  described general  site safety  rules,  established zones  of
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                                Appendix K:   Chemical Metals Industries,  Inc.
contamination containment, and identified levels  of protective equipment and
evacuation signals.

     The monitoring  program was designed to track NH3,  HCN,  and explosive
organic levels in the air at the site.   Notably,  at air concentrations  be-
tween 2 and 10 ppm,  cyanide respirators were required.   Below 2 ppm,  normal
protective equipment was sufficient;  levels above 10 ppm signaled  an  evacua-
tion of all personnel from Zones 2 and  3 to the clear zone  (Zone 1).  The
three zones of contamination containment and levels of  protective  equipment
that were required are outlined for each site:

Site 1:   Zone 1 included those areas outside Zones 2 and 3.   It was  desig-
          nated as a Clean Zone into  which no uncontained waste or contam-
          inated equipment or personnel could be  introduced.   No respiratory
          protection or protective clothing were  required in this  area.

          Zone 2 was defined as the area bordered on the south by  the block
          wall surrounding Site 1, on the east by a line that encompasses
          the eastern end of the decon  trailer, and on  the west by a  line
          that encompasses the dumpster boxes and trucks or  trailers  being
          loaded with waste or empty  drums; it also includes the sidewalks on
          the south  side of Clare Street and Clare Street up to the north
          curb.  Respiratory protection as necessary (cartridge/canister
          respirator, airline gas mask, or self-contained breathing appara-
          tus) was worn when the task being performed warranted it.  As  a
          minimum, workers wore plastic-coated Tyvek or rain gear  and gloves
          when loading empty drums onto trucks or trailers.   Gross decontami-
          nation of  personal protective equipment and other  equipment was
          performed  in this area before that equipment  left  Zone 2.

          Zone 3 was defined as the area within the cement block wall and
          building at Site 1.  Minimum  personal protective equipment  included
          either a one-piece acid suit  or rain gear or  better, PVC boots with
          steel toe  and shank or better, PVC gloves or  better, and self-con-
          tained breathing apparatus  or airline full-face mask with 5-min
          escape bottle or better.  All openings  were taped  shut.   Personnel
          were always accompanied by  another individual  when in Zone  3.

Site 2:   Zone 1 included those areas outside Zones 2 and 3.   It was  desig-
          nated as a Clean Zone into  which no uncontained waste or contam-
          inated equipment or personnel could be  introduced.   No respiratory
          protection or protective clothing were  required in this  area.

          Zone 2 was defined as the area bordered on the south by  the south-
          ern set of Railroad tracks  bordering Site 2;  on the east by the
          outer northbound lane of Annapolis Road and the contaminated  side
          of the decon trailer on the north by the center line of  the decon
          trailer extended to the CMI building; and on  the west by the  facade
                                    251

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Avvendix K:  Chemical Metals Industries, Inc.
          of 2103 Annapolis Road.  Respiratory protection  (cartridge/canister
          respirator with acid gas cartridge/canister, airline gas mask, or
          self-contained breathing apparatus) was worn when the task being
          performed warranted it.  As a minimum, workers wore plastic-coated
          Tyvek or rain gear and gloves when loading empty drums onto trucks
          or trailers.  All personnel exiting this area were decontaminated.
          Gross decontamination of personal protective equipment and other
          equipment was performed in this area before that equipment left
          Zone 2.

          Zone 3 was defined as the area within the chain-link fence and the
          facade of 2103 Annapolis Road.  Minimum personal protective equip-
          ment included either a one-piece acid suit or a two-piece rain
          suit, PVC outer boots with steel toe and shank protection, acid-
          proof gauntlet style gloves or better, and SCBA or airline full-
          face mask with 5-min escape bottle or better.  All openings were
          taped shut.  Personnel in Zone 3 never worked alone and maintained
          radio contact with an individual in Zone 1 who was aware of emer-
          gency notification procedures.
Costs
     Initial estimates of the total cleanup effort for Sites 1 and 2 ranged
from $58,000 to $83,000 and 1 week's time.  Actual cleanup activities took
place over a 2-mo period between October 19 and December 18, 1981.  The total
cost of all cleanup and remediation activities exceeded $325,000.  More than
$200,000 of Superfund resources were committed.  In addition to these funds,
the city of Baltimore contributed $35,000 in the form of police and fire
protection during the removal of certain hazardous materials from the sites.
The State of Maryland contributed approximately $90,000 in redeveloping both
pieces of property into their current uses.


EVALUATION OF DECONTAMINATION EFFECTIVENESS

     Details on how building decontamination efforts were judged to be effec-
tive have not been reported.  It would appear that visual inspections of the
premises following sandblasting and structural removal operations were used.
Chemical analyses were used to judge the effectiveness of removal operations
involving contaminated soils.
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                                                       • US GOVERNMENT PRINTING OFFICE 1985- 559-111/10807

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