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xvEPA
                United States
                Environmental Protection
                Agency
                      Office of Air Quality
                      Planning and Standards
                      Research Triangle Park, NC 27711
EPA-450/1-90-005
September 1990
          Air/Superfund
          AIR/SUPERFUND
          NATIONAL TECHNICAL
          GUIDANCE STUDY SERIES
          Contingency Plans At Superfund Sites
          Using Air Monitoring

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CONTINGENCY PLANS AT SUPERFUND
  SITES USING AIR MONITORING
                                              Prepared by
                                         IPEI  Associates,  Inc.
                                  South  Square  Corporate Centre One
                                  3710 University Drive, Suite 201
•                                  Durham,  North Carolina  27707




I                                     Contract No.  68-02-4394
                                       Work  Assignment No. 39
•                                            PN 3759-39




|                               Norm Huey,  Work Assignment Manager



•                              U.S. ENVIRONMENTAL PROTECTION AGENCY
                                  AIR PROGRAMS  BRANCH, REGION VIII
                                     1999 18TH STREET,  SUITE 500
                                           ONE DENVER PLACE
                                    DENVER,  COLORADO  80202-2405


I

•                                           September 1990     U.S. Environmental Protection Agency
                                                               Region 5, Library (PL-12J)
                                                               77 Vv'est  Jackson Boulevard, 12th Floor
                                                               Chicago,  IL  60604-3590





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                                 DISCLAIMER


     This report was prepared for the U.S. Environmental Protection Agency by
PEI Associates, Inc., Cincinnati, Ohio, under Contract No. 68-02-4394, Work
Assignment No. 39.  The contents are reproduced herein as received from the
contractor.  The mention of product names or trademarks are not intended as
endorsements of the products or their use.  The opinions, findings, and
conclusions expressed are those of the authors and not necessarily those of
the U.S. Environmental Protection Agency.
                                      ii

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                                  CONTENTS


Figures	     iv
Tables 	      V
Acknowledgement	     vi

     1.   Introduction 	      1

     2.   Past Examples of Contingency Plans Using Air Monitoring. .  .      3

            Castlewood Site	      3
            Chesnutis Site	      9
            Hooker-Hyde Park Site	     14
            Kane and Lombard Site	     21
            Sand, Gravel, and Stone Site	     24
            McKin Site	     28
            Nyanza Vault Site	     32
            Quail Run Site	     39
            VERTAC Site	     44
            Weatherford Residence	     46

     3.   Development of the Air Monitoring Portion of a Site
            Contingency Plan	     50

            Typical contents of a site contingency plan	     50
            Determining a need for contingency air monitoring	     56
            Designing a contingency air monitoring network 	     64
            Case example using reverse risk assessment 	     71

     4.   References	     91

Appendix A - Characteristics of the HNU Photoionizer and Organic
             Vapor Analyzer	     94
                                     iii

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                                              FIGURES
I         Number                                                           '        ££fle
—            1      Air monitoring stations at Castlewood Site..........    4
•            2      Fourteen data point running average, Castlewood Site/
                       Station C-02........................    8
I            3      TAT perimeter HNU-PID monitoring stations at Chesnutis. ...   10
              4      Air monitoring log photoionization detector .........   11
I            5      Site perimeter sampling locations at Hyde Park........   15
•            6      McKin pilot study treatment process .............   30
•            7      Sampling locations and meteorological tower .........   35
•            8      Diagram of the Quail Run Site................   40
              9      Results of monitoring versus action level at Quail Run. ...   40
I            10      Ambient air sampler locations  at VERTAC Chemical Corporation.   45
              11      Soil sample locations at Weatherford residence........   48
J            12      Site work zones.......................   52
              13      Sample standing  orders....................   54
I            14      An example of emergency response operations .........   57
.            15      Factors influencing the Health Assessment Process  ......   62
*            16      Development of a (Contingency) Air Monitoring Plan......   65
•            17      Example site configuration..................   72

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                                              TABLES

           Number                                                                    Paae

              1      Dates of Monitoring Station Operation	      7

              2      Compounds of  Interest  (Using TENAX) at Chesnutis  	     13

              3      Air Grab Sample Target Compounds at Chesnutis	     14

              4      Monitoring Program Summary for Hooker-Hyde Park	     17

              5      Monitoring Schedule, Action Level, and Required
                       Action Summary  	     18

g            6      Monitoring Levels for  Semivolatile Organic Parameters.  ...     21

              7      Action Levels for Kane and Lombard	     23
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             113      Public Protection Levels for the Example Site,  in
                       and ppb	'.....    82
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              8      Major Safety Threats  From Compounds at the  Nyanza
                       Vault Site ........................     33

              9      Air Sampling Results  From Nyanza Vault ...........     37

             10      Health Effects Summary Table A:  Subchronic and  Chronic
                       Toxicity Via Inhalation ..................     76

             11      Health Effects Summary Table B:  Carcinogenicity Via
                       Inhalation ........................     77

             12      Summary of Recommended Exposure Limits ...........     81
             14      Allowable Emissions at the  Example Site  in g/s  .......     85

             15      Summary of Average Air Emissions During  Remediation .....     87
             16      Comparison of Daily Average  Emissions With Allowable
I             ID      L.uiii(jctr liun ui udM
                       Emissions in g/s


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                                                                                      87

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                               ACKNOWLEDGMENT


     The concept of a report on contingency plans at Superfund sites that use
air monitoring originated with Mr. Norm Huey, Air/Superfund Coordinator in
EPA Region VIII.  Mr. Huey served as technical representative for this task.
The author was Mr. Roy Paul, PEI Associates, Inc., Durham, North Carolina.
Mr. Gary Saunders of PEI Associates carried out example calculations of alert
levels at a site.  Ms. Alicia Ferdo was the PEI Work Assignment Manager and
Mr. David Dunbar was the PEI Project Director.
     Material for this report was contributed by many individuals.  Peter
Kahn, EPA Region I, provided on overview of air monitoring at a number of
Superfund sites and provided documentation for the Nyanza Vault Site.  Mr.
David Webster, Chief of Maine and Vermont Superfund Section, provided
information on the McKin Site.  Mr. Dean Tagliaferro, On-Scene Coordinator,
provided documentation on the Chesnutis Site.  Peter Ludzia, Remedial Program
Manager, provided material on both the Sand, Gravel, and Stone Site and the
Kane and Lombard Site in Baltimore.
     Mr. Tony Babb, IT Corporation-Knoxville, provided information on air
contingency monitoring at the Quail Run Trailer Park.  Ms. Gloria Sosa,
Remedial Program Manager, arranged for documents to be provided for the
Hooker-Hyde Park Site and Ms. Nancy Aungst, Ecology and Environment Inc.,
provided the documents.  Mr. Glen Schwartz, IT Corporation-Pittsburgh,
provided information on monitoring at the VERTAC Site.  Mr. David Gray, EPA
Region VI, provided documents concerning the Weatherford Residence.  Dr.
Michael Allred, Agency for Toxic Substances and Disease Registry, provided
documentation on how health assessments are carried out.
     This document would not have been possible without the voluntary
assistance of these professionals.
                                      vi

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                                  SECTION 1
                                INTRODUCTION

     Air emissions from remedial or removal activities at Superfund sites can
potentially have a significant impact on the health and safety of the
individuals living and working around the site.  As a result, potential
offsite impacts should be considered by the Remedial Project Manager (RPM) or
Enforcement Project Manager (EPM).  He should decide whether to develop and
implement a contingency plan.  The contingency plan may require air
monitoring during site disturbance operations (i.e., exploration, removal,
and remediation).  Contingency air monitoring is an extension of the onsite
health and safety plan for the protection of workers.  It enables the early
detection of releases such that operations can be modified or controlled and
the public adequately warned in the case of an emergency.
     Contingency planning, as defined in this document, encompasses the air
program established to protect offsite populations.  Monitors for this
purpose are usually located at the site perimeter or within the community.
Monitors located within the site for the safety and protection of workers are
not included in this definition, unless onsite monitors serve the dual
purpose of protecting both the workers and offsite population.
     One reason that offsite contingency planning is sometimes overlooked is
that remediation, when carried out according to plan, should not cause
excessive emissions.  Remediation plans, however, are only as good as the
data used to characterize the site, which is usually based on soil and air
sampling.  Even the best sampling program can have limitations on the
accuracy of data concerning the locations and concentrations of chemicals.
Even a small amount of error regarding these matters can lead to unexpected
emissions and unexpected concentrations offsite, a situation that is
addressed in a contingency plan.
     A contingency plan using air monitoring establishes alert levels in
advance of actually collecting monitoring data.   Alert levels address the

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offsite population exposure concentrations that trigger an emergency response
or a change in remedial activities.  These alert levels are in addition to

alert levels for onsite personnel.
     One role of a contingency plan using air monitoring at a Superfund site

is to support a United States Environmental protection Agency (EPA) community
relations program.  This is especially appropriate for sites which are

perceived by the local community to have potentially unacceptable air

impacts.  Air monitoring provides an early warning of actual releases and the
results of air studies provide a factual basis for communicating the
potential for exposure (and nonexposure) to the public.  Contingency planning
demonstrates responsiveness to the community's concern on the part of the

responsible party.
     David Roe, Senior Attorney with the Environmental Defense Fund, defined
the public's perception of its need for information in the EPA Journal.

     "The public emphatically does not need to be deluged with "the data" on
     health risks from chemical exposures, general or specific, and told to
     make its own mind.  This, in effect is too often what happens now by
     default, particularly in controversial cases.  The public is not
     interested in government's abandoning the responsibility for deciding
     where chemical...limits lie."

     "What the public does want and need is a system that delivers a clear
     signal where chemical exposure crosses a boundary from the trivial to
     the significant, like the red light above a hockey net that flashes when
     the puck entered the goal.  The public also needs assurance that the
     system is hooked up and operating, so that the light goes on when the
     line is crossed, no matter which teams are on the ice.  And people need
     to know that the line itself is not being curved back into the net, or
     even erased, just before the playoffs."

     The purpose of this document is to:  1) illustrate contingency air

monitoring with examples from past projects, and 2) describe how a
contingency air monitoring program may be established.  This document is
illustrative in nature because the application of this type of monitoring is

not consistently prescribed in rules and regulations, but is based on
professional judgment applied in an analysis of individual sites and
particular circumstances.

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                                   SECTION 2

            PAST EXAMPLES OF CONTINGENCY PLANS USING AIR MONITORING


      Although contingency air monitoring to  protect offsite  populations  has
 not been conducted at every Superfund remediation  or removal  site, there are

 a number of cases where it has been employed.  This section  documents a
 sample of such sites, covering varying terrain and different types and

 concentrations of chemicals.  These examples exhibit wide  variations in  the

 type of monitoring program to be employed.   This variation reflects different

 site conditions, different phases in the Superfund program,  and different

 judgements of professionals who manage the sites.


 2.1  CASTLEWOOD SITE

      Castlewood is a residential neighborhood on the outskirts  of St. Louis,
 Missouri.  It is located 2.7 miles north of  the Merrimac River, a tributary
 of the Missouri River.  Figure 1 shows the configuration of  the roads in this
                                         2
 neighborhood and some of the residences.

      Soil samples were collected and analyzed from the Castlewood area from

 February 1983 to 1987, in an attempt to define the limits  of the areas
 contaminated with dioxin.  As of 1987, the known areas of  contamination
 covered nearly 450,000 square feet, with approximately 50,000 square feet
 having dioxin concentrations in excess of 10 ppb.   The highest  levels of
 contamination were found in the parking area for Mel's Tavern located at the
 intersection of Sontag and New Ballwin Roads; these concentations exceeded
 500 ppb.  In 1985 this area was paved by EPA as an interim mitigation

 measure.
      Most of the contaminated areas were located adjacent  to roadways,

 extending from the roadway for a few feet in some  areas to as much as 25 feet
"in other areas.  Many contaminated road shoulders  were located  next to

 residences while others were near heavily wooded or brush-covered lots.   In
 addition to soil contamination, dioxin contamination was found  inside nine

 residences and one business (Mel's Tavern).   Some  decontamination efforts
 were taken within these structures to reduce the potential for  exposure.

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                 C-01
Meteorological  Station
                                       C-12
              Figure 1.  Air monitoring stations at Castlewood Site.

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      In  1987 the planned remedial  actions  involved  the  excavation,
 containerization,  and onsite  consolidation of contaminated materials  in
 specially designed storage buildings.   Excavation was performed while
 maintaining  air contamination levels  specified by State and  Federal health
 officials.
      An  issue of concern to the  EPA was whether and to  what  extent offsite
 migration of dioxin in the air would  occur while these  activities were in
 progress, an issue of particular concern at the Castlewood Site due to the
 close proximity of areas of contamination  to human  populations.  Because of
 this  concern, EPA conducted air  monitoring around the site while remediation
 was  in progress.   The objectives of the air monitoring  operation were:  1) to
 evaluate the potential  for dioxin  exposure to general populations and to
 populations  at greatest risk,  2) to compare measured dioxin  air
 concentrations to an established criteria  which served  as a  trigger for
 abatement actions,  and 3)  to  assess the adequacy of onsite dust suppression
 techniques.   Specific abatement  actions to be taken were decided by the On
 Scene Coordinator (OSC).   If  soils were dry,  they would be sprayed with water
 to reduce dust and volatilization.  If  soils  were already wet, operations
 were  to  cease.   Investigations would  be initiated to determine why the alert
 level  was exceeded.
      Removal  operations were  planned  for five different sections of
 Castlewood to be  excavated in  series.   Each  excavation  section could  be
 treated  as an area source  or  multiple small  sources.
      The air monitoring network  was comprised of twelve (12) dioxin samplers
 and one  (1)  meteorological  station.  The samplers and the met station were
 located  as shown  in  Figure 1.  One  of the  samplers  served the dual purpose of
 being  both a perimeter  and sensitive receptor monitor.
      Because potential  dioxin  emissions  were  expected only where active
 removal  operations were in progress, air samples were collected only  at
 sampling locations  in those sections undergoing  active  remediation.
 Consequently,  the  schedule for sampler  operation was dependent on the
excavation schedule.  One  exception to  this rule was that one dual purpose
 (perimeter/sensitive  receptor) sampler was operated  throughout the duration
 of the project.
     All   samplers within each  section were operated concurrently on the same
 schedule.  Sampler startup times coincided with periods of minimal removal
 activity, such as early in the morning or late  in the afternoon.   Once

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started, samplers were allowed to operate continuously for 72 hours with no
more than +/-10 percent time variation.  After samples were collected at the
conclusion of the 72-hour sampling period, the samplers were immediately
restarted unless no removal activities were scheduled for that day, in which
case samplers were restarted the next day for which removal activities were
planned.  Table 1 shows the dates of start-up and decommission for each
monitor.
     Each air monitoring station consisted of a Model PS-1 PUF sampler
(manufactured by General Metal Works, Inc.) mounted on an elevated platform.
Samples were collected using a dual sample collection media comprised of a
glass fiber filter (6FF) and polyurethane foam (PUF) sorbent.  The volume of
air sampled was accurately measured, ranging from approximately 900 to 1300
M3 over the life of the project.  Samples were analyzed using
rapid-turnaround GC/MS and GC/MS/MS facilities provided by the Contract
Laboratory Program (CLP).
     The air monitoring project's performance was evaluated based upon onsite
quality assurance (QA) audit results and on QA summary statistics.  Project
performance documentation consisted of approved QA project plans, written
standard operating procedures, QA system audit reports, quality control (QC)
sample results, and QA audit results.
     All sample data generated during this project were subjected to a
rigorous data review/validation process to ensure that reported data met all
criteria for acceptability.  Initial data validation was performed by the
field sampling personnel.  Collected samples not meeting the sample
collection criteria were voided and not submitted to the CLP for analysis.
Samples that were analyzed had to pass an analytical data validation process
conducted by EPA project QA personnel.  Sample data meeting all criteria were
considered valid.
     An onsite QA audit was performed at the Castlewood Site during July
1987.  The audit results showed that with the exception of minor
deficiencies, the project was conducted in compliance with the specified
procedures.
     The resulting air monitoring data showed that average ambient
concentrations of airborne 2,3,7,8-TCDD remained below the 3.0 pg/M  action
limit throughout the project.  The tabulated data contained in the Analysis
Request Report for this project showed that of the total 392 valid individual

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               TABLE 1.  DATES OF MONITORING STATION OPERATION

Monitoring station
C-01
C-02
C-03
C-04
C-05
C-06
C-07
C-08
C-09
C-10
c-n
C-12
Date of Startup
04/27/87
04/27/87
05/03/87
05/03/87
04/27/87
05/15/87
04/27/87
05/06/87
05/12/87
05/09/87
05/09/87
05/09/87
Date decommissioned
06/20/87
06/25/87
t)6/25/87
07/24/87
10/20/87
10/20/87
10/20/87
10/20/87
10/20/87
07/21/87
10/08/87
07/20/87

air sample measurements performed over the course of the project, only three

samples (Nos. 284, 315, and 327) yielded mesasurements of 2,3,7,8-TCDD at
detectable levels.
     For the purpose of evaluating maximum population exposures over the
duration of the project, the data were grouped separately for each air
monitoring station and reduced to 14 running averages that were graphically
plotted over time.  One of these graphs is shown in Figure 2.  When computing
these running averages, all nondetect data points were treated as though they

were positive measurements.  Conservative treatment of nondetect data points
in this manner provided an upper bound result.  In addition to showing 14
running average concentrations, the graphs also showed the upper and lower 95
percent confidence limits around the averages.  For the most part, the 14
data point running average concentrations remained around the 0.8 pg/M
level.

     Based on the data generated from the air monitoring project and
presented in this report, it can be concluded that emissions caused by
removal operations were effectively controlled and that human populations
residing in the vicinity of the Castlewood site were not exposed to average

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           airborne concentrations in excess of the health based action limit

           concentration of 3.0 pg/M3 over the course of the removal project.


           2.2  CHESNUTIS SITE

                The Chesnutis Site consists of approximately 0.5 acres of land located

           o'n Lopus Road in the town of Beacon Falls, Connecticut.  The site- is bounded

           on the north by an antique auto restoration shop, on the east by Lopus Road,

           on the south by an auto body shop, and on the west by a partly paved road

           leading to Mr. Posick's home.  The Beacon Falls Municipal Waste Water

           Treatment Plant is located east of the site, on the other side of Lopus

           Road.   Figure 3 is a sketch map of the site.
                Site assessment reports for this site identified buried drums and soil

           contaminated with volatile organic compounds (VOCs).  Therefore, a strong

           potential existed for VOCs to be emitted into the atmosphere during drum and

           soil removal.  EPA's OSC, Dean Tagliaferro, was concerned that VOCs could

           volatilize into the air and be carried offsite to local receptors during soil

           and drum removal activities.
                The following three types of air monitoring were carried out:

                1.   The hot zone was monitored to determine if personnel protection
                     levels were adequate or could be downgraded.  Air monitoring was
                     done with either an HNU or OVA on a minimum of an hourly basis.  An
                     action level of 5 ppm sustained readings above background required
                     evacuation of personnel not in protective respirators.  From 0 to 5
                     ppm, benzene draeger tubes were to be used as benzene's threshold
                     limit value (TLV) is below 5 ppm, while all other identified
                     compounds TLVs were above 5 ppm.

                2.   Air monitoring at the perimeter was also conducted with an HNU or
                     OVA by the Technical Assistance Team (TAT).  This was to determine
                     if air contamination was migrating offsite and if offsite personnel
                     had to be evacuated.  Once each day, when remediation activities
3.   Pollutant-specific air monitoring was carried out with carbon tenax
     samplers during the excavation.  Results were used to identify and
     quantify the concentrations of compounds in the air in the hot zone
     and at the perimeter.

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        TO FOSICK RESIDENCE
TO ABTO
BODY SHOP
                                                              ANTIQUE
                                                              AUTO
                                                              RESTORATION
                                                              BUILDING
                                                                              •FILL
                                                          NOT TO SCALE
     Figure 3.  TAT perimeter HNU-PID monitoring stations  at Chesnutis.
                                         10

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BEACON FALLS, CT
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Figure 4.  Air monitoring log photoionization detector.
                           11

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     The air monitoring program was conducted on July 11 and 12, 1989, during
onsite soil and drum removal activities.  Time-weighted average ambient air
samples were collected on and offsite using TENAX air samples, techniques and
analytical methodologies designed to identify and quantitate the compounds
listed on Table 2.  In addition to TENAX samples, grab air samples were
Collected and analyzed onsite using a Photovac portable GC.  Grab, air
sampling and analysis techniques identified and semiquantitated the compounds

listed on Table 3.
     The air grab sampling results and continuous integrated sampling results
both identified similar compounds above background, on and off the site,
namely:  Toluene, Tetrachloroethylene, and Dichlorobenzene isomers.  These

compounds were detected at levels between 2 and 100 ppb onsite.  Total
hydrocarbon readings taken with an HNU at several locations along the
perimeter of the site, however, showed nothing above 1 ppm.  These results
indicated that several VOC targeted compounds were emitted at very low levels
(below 1 ppm) into the atmosphere and transported offsite, as a direct result
of excavation and drum removal  activities.  The HNU total  hydrocarbon
analyzer used to routinely monitor the air around the perimeter of the site
during site work was judged to provide adequate air monitoring to determine
if VOCs were migrating offsite.4
                                      12

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        TABLE 2.  COMPOUNDS OF  INTEREST (USING TENAX) AT CHESNUTIS
   1,1,1-Trichloroethane

   Carbon Tetrachloride

 '  Benzene

   1,2-Dichloroethane

   Trichloroethylene

   1,2-Dichloropropane

   Bromodichloromethane

   2-Chloroethy1vinyl ether

   cis-1,3-dichloropropene

   Methyl Isobutyl Ketone

   Dibromomethane

   Toluene

   trans 1,3-Dichloropropene

   1,1,2-Trichloroethane

   Tetrachloroethylene

   1,3-Dichloropropane

   Dibromochloromethane

   1,2-Dibromoethane

   Chlorobenzene

   Ethylbenzene

   Brorooform

   1,2-Dichlorobenzene
NOTE:  Compounds that are underlined
      samples or in soil samples.
     Xylenes  (total)

     Styrene

     Isopropropylbenzene

     1,1,2,2-Tetrachloroethane

     Bromobenzene

     1,2,3-Trichloropropane

     n-PropyIbenzene

     2-Chlorotoluene

     1,3,5-TrimethyIbenzene

     4-Chlorotoluene

     t-Butylbenzene

     1,2,4-TrimethyIbenzene

     s-Butylbenzene

     p-Isopropyltoluene

     1,3-Dichlorobenzene

     1,4-Pichlorobenzene

     n-ButyIbenzene

     1,2-Dibromo-3-chloropropane

     1,2,4-Trichlorobenzene

     Hexachlorobutadiene

     Naphthalene

     1,2,3-Trichlorobenzene

     Nitrobenzene

have been  identified in either soil  gas
                                13

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           TABLE 3.  AIR GRAB SAMPLE TARGET COMPOUNDS AT CHESNUTIS


Dichloroethylene isomers

Benzene

Toluene

Tetrachloroethvlene

Chlorobenzene

o-Xvlene

m-Xvlene

Tricloroethvlene

Ethyl Benzene


Note:  The compounds that are underlined had been identified in either soil
       gas samples or in soil samples previously taken from the site.
2.3  HOOKER-HYDE PARK SITE

     The Hyde Park Landfill, approximately 15 acres in area, is an NPL site
located in the northwest corner of the town of Niagara Falls, New York.  It
is immediately surrounded by several industrial facilities and property owned
by the power authority for the State of New York (Figure 5).  The Niagara
River, an international waterbody, is located 2000 feet to the northwest.
Between 1954 and 1975, Occidental Chemical Corporation (OCC) disposed of
approximately 80,000 tons of chemical wastes at the landfill and 0.6 to 1.6
tons of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) contaminated material.
Between 1975 and 1979, OCC implemented a number of remedial actions.  These
actions included capping the site, installing a shallow tile drain, and

initiating a ground water monitoring program.  Soil and ground water are
.contaminated with VOCs, organics, toluene, phenol, polychlorinated byphenyls
(PCBs), and dioxin.5

     The selected remedy for this site included installation of a prototype
purge well system to extract nonaqueous phase liquids (NAPL) for destruction
by incineration, installation of an overburden tile drain system,
                                      14

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1
 Implementation  of engineering  controls to  protect nearby workers,
 installation  of ground  water wells  as part of a community monitoring program,
 installation  of the  first  stage  of  a bedrock NAPL plume contaminant system,
 installation  of purge wells as an aqueous  phase liquid plume containment
 system,  implementation  of  a lower formation and deep formation study,
 implementation  of a  Niagara gorge seep program, treatment of ground water
 with  activated  carbon,  and implementation  of a monitoring program.
      As  a  result of  negotiations with EPA  and the State, an extensive air
 monitoring program was  developed for OCC by ERT, an engineering firm.  This
 air monitoring  program  has five  categories:
      1.    Personal monitoring  -  occupational health protection
      2.    Working site  monitoring - occupational health protection
      3.    Downwind of the  site - offsite community protection
      4.    Site  perimeter monitoring - offsite community protection
      5.    Community  monitoring - offsite community protection
      Table 4  summarizes the monitoring program, including the parameters to
 be monitored, the measurement  method, and  the recommended instrumentation.
 Table 5  summarizes the  monitoring parameters, frequencies, action levels, and
 required actions  for each  of the five types of monitoring.
      Site  perimeter  monitoring is the type most commonly used to protect the
 community.  Monitoring  station locations for site perimeter monitoring are
 depicted in Figure 5 (sites P-l  through P-13).  For work at Sites A and B,
 monitoring locations P-l through P-9 were  used.  For work at Site C,
 monitoring locations P-8 through P-13 were used.
      At each  of  the  monitoring locations, two monitors were used, one to
 measure total suspended particulates and one to measure semi volatile
 organics.  Total  suspended particulates were measured using a high-volume
 particulate sampler  (Hi-Vol).  The Hi-Vols were operated for 8 hours during
 remedial activity.   Semivolatile organic compounds were monitored using
 sorbent samplers  operated  for  the same period each day as the Hi-Vol
monitors.
      Semivolatile organic compounds were collected using the General Metals
Works Model PS-1  sorbent sampler.  These units were operated at a flow rate
resulting  in a total  sample volume of approximately 120 m3.   Each PS-1 was
calibrated monthly and the flow rate checked daily.
     Semivolatile organic compounds collected on quartz fiber
filter/polyurethane foam (PUF)/XAD-2 sorbent "sandwich" cartridges (PS-1
                                      16

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TABLE 4.
pArameter(s)

Meteorology
Wind Speed
Wind Direction
teal-Time
Participates
Particulates
TSP
Semi-Volatile
Organlcs
Specific Volatile
Organlcs
Total Volatile
Organlcs
Plammablllty

Semi-Volatile
Organics
H2S




-
"--.




MONITORING
Units
MPH
DEO
>9/"3
vg/m3
iig/m3
vg/m3

•g/m3
PPM
%LBL

ng/m3
PPM










PROGRAM SUMMARY FOR
Measurement Method
Meteorological
Station

Real-time
Aerosol Monitor
NIOSH 0500
Hlvol Samplers
NIOSH P and CAM 343

NIOSH PfcCAM 127
PID
Combustible
Oas analyzer
PS-1. PUF/XAD
Color-Detector Tubes







17


HOOKER-HYDE PARK
Recommended Instrumentation

Cllmatronlcs
BUS
.
MDA PCD-1
OCA HINIRAM
DuPont Alpha-1
OMU1-2000
DuPont Alpha-1

DuPont Alpha-1
HHU-PI-lOl
MSA- 100

OMW-PS-1
Draeger-47s










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                                    TABLE  5.   MONITORING  SCHEDULE,  ACTION  LEVEL,  AND REQUIRED  ACTION SUMMARY
              Location

              Personal
              Worksite
oo
Parameter

1) Participates
   (TWA)

2) Specific volatile
   organic*
   (NIOSH P and
   CAM 127)
frequencies

Twice weekly Cor first
30 days of Special
Construction activities,
Thereafter, monthly
                                 3) HCB. g
              HCCH
1) Planaablllty
                                 2) Total Volatile
                                   Organic* (PID)
1) Continuous
                        2) Continuous
Action Levels
1) M/A
                                                                                 2) TWA exceeds ACOIH
                                                                                    guidelines
3) HCB > 0.1 ppm
   gamma HCCH
   > 0.04ppa

1) 25% LEL
                          2)  (a)  5 pp* above
                                 background
                                                                                 2)  (b) 10 ppm above
                                                                                        background
                                 3) Specific Volatile
                                    organlcs
                                    (NIOSH P and CAM
                                    127)
                                 4) Real-time
                                    Partlculates
                                 5) Hydrogen Sulflde
                                    (H2S)
3) Twice per week per
   working site location
                        4) Continuous
                        5) Hourly If odor  Is
                           detected while
                           Installing extraction
                           wells
                                                 3) TWA exceeds
                                                    ACOHI gu Id lines
                          4) a) 150 ug/m3
                             b) 150 ug/m3 and
                                > 2.5 tines
                                background

                          5) 10 ppm
    Required Action

Review by Safety Officer and EPA/State
on-slte Representative  to determine what
action, tf any,  shall be taken.  Report
data and results of  corrective action If any.
to BPA/State within  7 days after receipt of
the data.
1) (1) Suspend construction/notify  BPA/State
   (11) Proceed per Vapor Emission  Response
        Plan

2) a) (1) Modify activities to reduce emissions
      (11) All working site personnel must upgrade
           to full face air purifying respirators

2) b) (1) Proceed per Vapor Emissions Response Plan
      (11) Conduct Specific Volatile Organic
           Analysis, but not more frequently  than
           once every two weeks. Complete analysis
           within one working day.   Proceed per
           Action Level, Required Action  shown In
           (3)

3) Review by Safety officer and EPA/State on-slte
   representative to determine what corrective
   action If any shall be taken.  Report  data and
   results of corrective action. If any,  to
   BPA/State within 7 days after receipt  of  the
   data.

4) a) Initiate hourly upwind monitoring,  modify
      activities to reduce emissions
                                 i  i
   b) Suspend Const. Activity, notify BPA/State
                         5)  a) Notify Site Safety Officer and KPA/State,
                              modify activities, and upgrade respiratory
                              protect Ion


                            b) Proceed per Vapor Emlslon Response Plan
             (Continued)

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 TABLE 5 (Continued)
 location
Parameter
 Downwind of the    VOC  (PID)
 Working Site
frequencies

1) Every 2 hours or
   as required
                    2) integrated (real-
                       tin*)  continuous
                       parttculates
                        2) Continuous
                           (Integrated)
 Site Perimeter     1) TSP
                    2) HCB
                    3) HCCH
                        Dally during all Special
                        Construction Activities
                    4) Perchloro-
                       pen t acyclodecane
                    5) TCP
Action Levels

1) a) 2.5 ppM (above
      background

   b) 5.0 ppM (above
      background Cor
      2 consecutive
      readings)

   c) 5.0 ppM (above
      background Cor
      3 consecutive
      readings)

2) a) Significantly >
      background Cor
      any IS Minute
      Interval

   b) Significantly >
      background Cor
      2 consecutive
      hourly averages
      or any 3 hourly
      averages during
      one work day

 1) Significantly >
   background

 2) 20 Mg/M3
                                                  3) 20 ng/M3
                                                  4) 20 ng/M3
                                                  5) 20 ng/M3
    Inquired Action

1) a) Increase Monitoring  frequency to hourly


   b) Hodlfy activities to reduce emissions
                                                                                                c) Suspend activity  until readings are less
                                                                                                   than 2.5 ppM above background, notify
                                                                                                   HPJk/Stata
                                                  2) a) 1 uspet - Modify const.-  activity to reduce
                                                        eMlsslons. 2 upsets In 1 hour  » Increase data
                                                        collection frequency to  every  1/2 hour
                                                                                                b) Suspend const, activity,  notify EPA/State
                                                  1) Analyze collocated PS-1 sample for seml-
                                                     volatlles

                                                  2) Compare with background levels (Section a.2.3)
                                                     and notify EPA/State, proceed per RUT Section
                                                     12.10.4

                                                  3) CoMpare with background levels (Section 8.2.3)
                                                     and notify BPA/8tate, proceed per RRT Section
                                                     12.10.4

                                                  4) Coapara with background levels (Sections 8.2.3)
                                                     and notify BPA/State, proceed per RRT Section
                                                     12.10.4

                                                  5) Compare with background levels (Sections 8.2.3)
                                                     and notify EPA/State, proceed per RRT Section
                                                     12.10.4
(Continued)

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         TABLE  5 (Continued)
       Location           Parameter

       Beyond the site    1) TSP



                          2) HCB


                          3) HCCH
frequencies
                          4) Perchloro-
                             pentacyclodecane

                          5) TCP
Action Levels
Dally during «11 Special  1)  Significantly >
Construction Activities      background at two
                             •jacent  sites

                          2)  20 ngAri
                          3) 20 ng/m3


                          4) 20 ng/«3


                          5) 20 ng/s£
Action
                        1) Analyze collocated PS-1 samples for se*l-
                           vola tiles
                        2) Notify EPA/State,  proceed per off-site
                           Contlgency Plan

                        3) Notify EPA/State,  proceed per off-site
                           Contlgency Plan

                        4) Notify EPA/State,  proceed per off-site
                           Contlgency Plan

                        5) Notify EPA/State,  proceed per off-site
                           Contlgency Plan
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       TABLE 6.  MONITORING LEVELS FOR SEMIVOLATILE ORGANIC PARAMETERS


       Semi volatile
     organic parameter	Monitoring Level
Hexachlorobenzene (HCB)                                     20 ng/m3

2,3,4-Trichlorophenol (TCP)                                 20 ng/m3

Perchloropentacyclodecane                                   20 ng/m3
  (C10ci12)

Hexachlorocyclohexane                                       20 ng//m3
  (HCCH) [for each alpha, beta,
  gamma, and delta isomer]
samples).  Samples were analyzed using gas chromatography/mass spectrometry
(GC/MS) or gas chromatography/electron capture detection (GC/ECD) using a
modification of EPA Method T-04.  Either GC/ECD or GC/MS was used for

identification and quantitation of the designated target compounds i.e., HCB,

2,4,5-trichlorophenol (TCP), Perchloropentacyclodecane (Cjoch2^' anc* HCCH
isomers.

     During construction activity, perimeter TSP levels were checked to

determine if they exceeded a predetermined upper level action level  (ULAL).
If a ULAL was exceeded, the PS-1 sample from the same site location  was sent
to the laboratory to be analyzed.  If any of the four target chemicals
exceeded a specified monitoring level, then that chemical was considered to

have migrated beyond the site perimeter.  If this occurred 3 times in 30

days, then construction had to be stopped.  Table 6 lists the monitoring

levels that were established for semivolatile organic compounds for  this

site, based on studies of background ambient air monitoring performed
earlier.


2.4  KANE AND LOMBARD SITE

     The Kane and Lombard Site is an 8.4 acre parcel  of undeveloped  land in
Baltimore, Maryland.- Dumping and burning of construction debris, and

disposal of domestic trash and drums occurred at the  site from 1962  until

1967 when the city passed an ordinance prohibiting the open burning  of

refuse.  Illegal  dumping continued from 1967 until approximately 1984,  during
                                      21

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 which time many citations were issued for illegal burning on the property.
 In 1980 Maryland state inspectors observed between 400 and 500 drums, the
 majority of which were rusted, damaged, and punctured.  Following an onsite
 property assessment, EPA authorized the immediate removal of 1,163 drums in
 1984.  Of those, 822 drums were classified as empty and 341 drums, contained
 contaminants which included benzene, toluene, xylene,  polyaromatir
 hydrocarbons (PAHs), PCBs, and heavy metals.   Approximately six inches of
 soil  below the drums were removed and disposed offsite.  The site was
 stabilized by regrading,  capping, and revegetation.  Currently, soil and
 ground water are contaminated with prior drum contaminants.
      The selected remedial action for this site includes removal  of drums,
 hot spots, and contaminated soil  (approximately 67,000 cubic yards), site
 cleaning and removal of vegetation to facilitate the construction of
 subsurface containment and diversion structures,  construction of a multilayer
 soil  cap,  construction of a drainage system,  clearing  of the drainage ditch
 along the  east site of the site,  development  of necessary surface water
 runoff management facilities,  and ground water monitoring.
      An air monitoring program was established to 1) determine appropriate
 safety and personnel  protective measures to be implemented  during cleanup,  2)
 document onsite employee  exposures,  and 3) assess offsite migration of
 contaminants released during remedial  activities  so that appropriate control
 measures and/or contingency plans could be implemented.   Two principal
 approaches were used to identify  and  quantify airborne  contaminants:
      o    Real-time air monitoring by  use of  direct-reading  instruments
      o    Time-weighted averages  by use  of sampling techniques  that capture
           samples over periods  of time  for later  identification and
           quantification  of specific contaminants
      Real-time  air  monitoring was  conducted for VOC's,  particulates,
 explosive  atmospheres  and  oxygen  levels.  Total organic  vapors, given  in
 parts  per  million (ppm), were detected with photoionization detector  (PID),
 manufactured by H-NU,  Inc.   Real-time readings for combustible gas  levels
tgiven  in  percent of the LEL) and oxygen levels (given  in percent 02) were  '
taken with an Industrial Scientific Combustible Gas/Oxygen Monitor, Model MX
241.  Particulate concentrations  in milligrams per cubic meters (mg/m3) were
determined by use of a direct-reading dust monitor, a Miniram PDM-3 model,
                                      22

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                TABLE 7.  ACTION LEVELS FOR KANE AND LOMBARD
Instrument
  Location
  Concentration
  Action to be taken
H-Nu monitor
H-NU PID
MX 241
oxygen meter
MX 241
LEL monitor
PDM-3 dust
monitor

PDM-3 dust
monitor
PDM-3 dust
monitor
Active work area  4 ppm above back-
                   ground
Perimeter
Active work area
10 ppm above back-
 ground

Two readings
 greater than 5 min
 apart 4 ppm or
 more above back-
 ground, or one
 reading of 10 ppm
 above background

Below 20.9% for 2
 readings 5 min
 apart within
 perimeter
Active work area  10% of LEL



                  20% of LEL

                                «•
Active work area  Up to 0.5 mg/nT


Active work area  >0.5 mg/m





Active work area  15 mg/m
                                      23
Upgrade to Level C
 protection

Alert CO of situation

Alert CO of situation
Stop activities until
 levels at perimeter
 drop below 4 ppm
Stop all work until
 source of oxygen
 deficiency is found
 and corrected

Stop all potential
 spark-producing
 activities

Evacuate work areas,
 isolate problem area

Level C protection
                      Upgrade to Level B
                       protection

                      Notify the CO

                      Evacuate all work
                       areas

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made by MIE, Inc.  Action levels for workers as well as perimeter monitoring

are listed in Table 7.
     Perimeter monitoring took place at four locations, designated according
to wind direction.  Initially, real time monitoring was performed practically
continuously during the first hour or two of each workday during-active
remediation operations, followed by periodic monitoring (at least every two

hours) for the remainder of the workday.
     Air sampling was conducted throughout complete shifts to determine
time-weighted average (TWA) concentrations of selected chemical agents.
These data were used in interpreting real-time monitoring results on a
day-to-day basis, documenting employee exposures, and for determining whether
or not significant contamination extended beyond the site.  Selection of air
contaminants for TWA monitoring was based on previous site characterization
and sampling data and included the following:

     Organic Vapors:                    Toluene, xylene, isophorone

     Nuisance (inert) dusts:            Total dust with subsequent analysis
                                          for heavy metals:  arsenic,
                                          chromium, and lead

     An action level was established for perimeter monitoring, based on the
H-Nu PID.  If one reading of 10 ppm above background was taken or if two
readings greater than 5 ppm above background were taken at least 5 minutes
apart, then all activities had to stop until perimeter levels dropped below 4
ppm.
     If monitoring results at the perimeter exceeded action levels,
subsequent readings were taken 100 feet and 200 feet downwind of the
perimeter on a perpendicular traverse approximately 200 to 250 feet in

length.  If readings at these locations exceeded action levels in the
direction of nearby schools, the Site Safety and Health Officer was required
to inform the administration of the local school.


2.5  SAND, GRAVEL, AND STONE SITE

     The Sand,  Gravel, and Stone Site covers approximately 200 acres, and is
located in Elkton (Cecil County), Maryland.  The site was previously operated
as a sand and gravel quarry under the name Maryland Sand and Gravel stone
Company.   Currently, the site is occupied by the Sand, Gravel, and Stone
                                      24

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 company.   Between 1969 and 1974,  three acres were used to dispose of waste
 processing water, sludge,  still  bottoms,  and approximately 90 drums of solid
 and semisolid waste.   On July 16, 1974,  1,300 gallons of flammable products
 in drums  were reportedly received and dumped.  On August 5,  1974, 5,000
 gallons of nonflammable materials were received at the site.   Onsjte pits
 were used as surface  impoundments, where approximately 700,000 gallons of
                   o
 waste were dumped.
      Remedial measures at the site will  be implemented in two phases.
 Selected  remedial actions approved at this time include excavation and
 offsite disposal of buried materials (drums and trucks) at an approved RCRA
 facility, installation of shallow ground water interceptors downgradient from
 waste sources, collection and treatment of contaminated ground water,
 recirculating the treated effluent to ponds, and discharging treated waste to
 Mill Creek.  A decision on remedial measures for contaminated soils, lower
 sand and  bedrock aquifers, final  site closure requirements,  and post closure
 operations and maintenance has been deferred.
      Remediation for  this site had not begun at the time of this report, but
 the air monitoring plan includes  contingencies for the protection of the
 public.  As in most remediation  plans, the site has been subdivided into an
 exclusion zone (EZ) with potentially high air concentrations, a clean zone
 (where the EZ may be  entered and  where decontamination takes place), and a
 support area.
      Air  monitoring will be conducted during excavation in the exclusion
 zone.  If work levels measured with the HNU (intrinsically safe IS101)
 monitor (or levels of benzene or  chloroform measured with detector tubes) are
 in a range from 10 to 50 ppm and  remain constant for a period of 10 minutes,
 the site  will be put  on alert. Air concentrations are expected to fluctuate
 and increase while waste is uncovered, however, the levels will also be
 reduced due to dispersion.  The  Health and Safety Officer will keep the
 Project Manager appraised of the  levels in the exclusion zone.  The Project
 Manager will designate an individual in the clean zone to check the levels in
 -this zone as well as  obtain perimeter readings.  This information will be
"reported  back via radio to the Project Manager.
      Work will halt in the exclusion zone if levels reach 100 ppm and are
 sustained for 10 minutes.   Evacuation will take place and evacuations will
 depend on wind direction.   All clean zone employees will  exit through the
                                       25

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primary gate.  The work party will exit a gate determined by wind direction.
They will, however, all exit the site at the same location. During
evacuation, the exclusion zone evacuating personnel and clean zone evacuating
personnel will remain  in constant communication via radios.  A head count
will be obtained to ensure complete evacuation.
     A second situation, involving excessive levels in the clean zone, would
also warrant evacuation.  If levels in this zone exceed 10 ppm, the Project
Managers will notify the employee's in the exclusion zone and work will halt.
The site will be evacuated in an orderly manner (abbreviated decon and use of
full facepiece respirator).  Evacuation is necessary at this point due to
respirator cartridge limitations.  It is possible, but not probable, that
concentrations in this zone could reach 10 ppm without the exclusion zone
reaching the 100 ppm evacuation point.  Again, a head count will be obtained.
     Reentry to the site will be made by a two-employee investigation team
(Health and Safety Officer and a member of the project management team).
Detector tubes, an HNU monitor, and a combustible/02 monitor will be used
during the investigation.  Information on hot spots, suspect containers, and
air levels will be relayed via intrinsically safe two way radio
communication.  At this time, the downwind perimeter monitor will be checked
and levels reported.  The Project Manager will notify the EPA and the Local
Emergency Planning Commission (LEPC).  A decision to evacuate the surrounding
areas will depend on the situation, airborne levels reported, and guidelines
contained in the Clean Air Act.
     Any time that PID or OVA levels exceed 20 ppm in the work area, an
individual with an HNU meter will repeatedly walk 100 meters downwind of the
work area.  He will repeatedly walk a 100 meter traverse with a center point
100 meters downwind of the work area.  Wind direction will  be continually
monitored during traversing,  and the locations of the traverse endpoints
adjusted as necessary.   If the fence line is nearer than 100 meters to the
work area, traverses will  be done along the fence line.
     During each traverse,  the highest 10-minute average HNU reading will  be
recorded.   If fence line readings within the plume reach 10 ppm volatile
organic chemicals,  as measured by the HNU meter,  and are sustained at that
level  for 30 minutes despite onsite control  measures,  monitoring will  move to
the nearest downwind residence.   At this location,  10-minute average HNU
readings will  be taken  continually traversing the property.
                                      26

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      If offsite monitoring  detects  an  average  concentration  of  2  ppm volatile
 organic chemicals  above background  for 10 minutes,  then  the  remediation
 contractor,  Clean  Sites Inc.  (CSI)  will  notify the  Local  Emergency  Assistance
 Agency  as  well  as  the  Cecil County  Fire  Dispatch  so that preparation for
 evacuation may  be  initiated.   The Director  of  Emergency  Management  will make
 the decision to actually evacuate residents and will  coordinate the
 evacuation with the  Cecil County Fire  Department.   CSI will  also  notify the
 EPA RPM.
      If at any  time, specific  circumstances indicate  that there is  an
 imminent threat to the public  health and safety,  CSI  will override  the above
 procedures and  notify  via telephone the  Local  Emergency  Assistance  Agency  as
 well  as the  Cecil  County Fire  Dispatch so that preparation for  potential
 evacuation may  be  initiated.
      An interesting  issue arose during negotiations  between  EPA and the
 principal  responsible  parties  (PRP's)  regarding the  types of instruments that
 should  be  used  and the community alert levels  that  should be established.9
 In EPA's original  proposal, evacuation would be triggered by residential HNU
 readings of  2 ppm  above background.  The PRPs  objected to this  proposed
 criteria,  arguing  that no adverse effects would result from  exposure  to much
 higher  concentrations  of some  of the compounds  found  at  this site.  To take
 this  factor  into account, however,  the monitoring system  used during
 excavation would have  to distinguish among  the  various compounds.
      EPA and the PRPs  tried to develop a mutually acceptable monitoring and
 evacuation strategy.   At one point, the  PRPs suggested using Draeger  tubes to
 determine  concentrations of individual compounds, but EPA rejected  this
 method  due to the  interference that might be caused by the other compounds
 found at this site.  The PRPs then  agreed to use a portable  gas chromatograph
 (GC)  to measure concentrations of individual compounds, but  did not agree
 with  the concentration  limits proposed by EPA for those chemicals, which they
 considered too conservative.  They  also  became concerned about the ability of
 the portable GC to measure concentrations for the wide variety of compounds
 found at this site at the alert levels identified by EPA.  In light of these
 limitations and the inability to reach a consensus,  the PRPs agreed to accept
 EPA's original evacuation criteria  (i.e., 2 ppm above background as measured
with an HNU meter).9
                                      27

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2.6  MCKIN SITE
     Gray, Maine, is the location of a former waste collection, transfer, and
disposal facility operated by the McKin Company from 1965 to 1978.  Onsite
waste handling procedures included discharge to the ground, storage in tanks,
incineration, and onsite burial.  The site is approximately seven acres in
size.  Neighboring lands include residential areas, wooded areas, and rural
farmland with the nearest home located approximately 200 ft from the site.
By 1983, all surface drums and tanks had been removed from the site in a
series of removal actions.  Afterward two major contamination problems were
associated with the site.  The first was onsite soil contamination which
served as a source for offsite ground water contamination.  The second was
ground water contamination of the surficial and bedrock aquifers affected by
the site.  Primary contaminants of concern in soils and ground water were
VOC's, particularly trichloroethylene (TCE), and 1,1,1-trichloroethane.
     In July 1985, the selected remedial action was onsite aeration of soils
to remove volatile contaminants from soils, extraction and treatment of
ground water from offsite contaminated areas, and certain site removal and
closure activities.  EPA established soil performance standards to protect
human health and the environment.  For VOC contaminants, TCE was selected as
the indicator compound based on its prevalence, mobility, and toxicity.  The
TCE performance standard established by EPA to evaluate soil treatment at the
McKin site was a maximum of 0.1 ppm averaged over a treatment volume of soil.
     A soil aeration pilot study was conducted with continuous air monitoring
to evaluate methods of aerating soils for removal of TCE while controlling
air emissions to maintain acceptable air quality.  Two private companies that
had potential liabilities, Fairchild Camera and Instrument Corporation and
Sanders Associates, agreed to perform a soil aeration pilot study for the
removal of TCE.  The objectives of the pilot study were to determine the
effectiveness of a full scale soil aeration process, to determine optimum
operating conditions, and to assess the impacts of the process on ambient air
quality.  The pilot study involved a series of conventional construction and
pollution control technologies used together with an innovative approach:  to
aerate soils in an enclosed, heated environment and to capture the organics
vaporized from the soil.  Several key pieces of equipment used in this
                                      28

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project were components of a portable asphalt batch plant.  The major

components of the process used to excavate, transport, aerate, solidify, and

redeposit soils, and to treat contaminated air are presented in Figure 6.

     A comprehensive air monitoring system   was designed for the pilot

study, including the following components:

     o    Continuous monitoring of excavation, soil transfer, and aeration
          for organic vapors using portable flame ionization detectors.

     o    Continuous monitoring for organic vapors at five permanent site
          perimeter stations using five flame ionization detectors with
          real-time data acquisition at 15-second intervals.

     o    Daily monitoring at ten local residences for organic vapors using a
          portable flame ionization detector.

     o    Regular collection and analysis of air pollutants by 8-h charcoal
          and Tenax tube adsorption and laboratory extraction.  Samples were
          taken at upwind and downwind site perimeter locations.

     o    Daily 24-h sampling for total suspended particulates at three
          permanent site perimeter locations, using hi-vol samplers.

     o    Continuous monitoring for particulates at two permanent site
          perimeter stations using real-time particulate analyzers and data
          storage in an onsite computer system.

     o    Continuous monitoring and data storage of wind speed, wind
          director, temperature, barometric pressure, humidity and solar
          radiation during working hours as measured on an onsite
          meteorological tower.
                                      29

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Three passes
through
^circulating
conveyor
system



Excavation
by caisson
digging bucket
within steel
caissons

_L

p

Materials
dryer
300°F
1
\

^ Cerr

i

•\
tent
er

Redeposition
in excavation
caissons




Exhausted
air

Baghouse
fines
Heated
screw
conveyer






Bag house


1
r
Scrubber
!
r
Vapor phase
carbon
adsorption
bed
Exhaust '
r
Figure 6.  McKin pilot study treatment process.
                       30

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      Contingency plans for corrective measures,  volatilization abatement,  and
 public protective responses were based on site-specific guidance from the
 Center for Disease Control [now called Agency for Toxic Substances and
 Disease Registry (ATSDR)].  Among the recommendations were 1)  continuous
 monitoring for organic vapors near site activities and 2)  public notification
 if continuous downwind organic vapors at the site perimeter were more than 2
 ppm above background.  For the purposes of this  monitoring and contingency
 plan, the background level was assumed to be the reading of the most upwind
 of the five perimeter flame ionization detectors.  Remediation and monitoring
 were performed by Canonie Environmental Services Corporation of Porter,
 Indiana, with oversight provided by the EPA.
      Results of air monitoring for organic vapors during the pilot study
 indicated that onsite activities had negligible  effects on air quality at  the
 perimeter of the 7-acre site.  As monitored with portable  onsite flame
 ionization detectors calibrated to methane, excavation activities created  the
 most significant source of airborne VOC's.  Total organic  vapor
 concentrations within 2 ft of a full caisson bucket or front-end loader  were
 as high as 1000 ppm.  At a distance of 20 ft downwind of excavation
 activities, however, 5-minute time-weighted average readings did not exceed 5
 ppm above background during the pilot study.
      Continuous monitoring for organic vapors at the site  perimeter
 demonstrated little evidence of onsite emissions of volatile organic soil
 contaminants.  Organic vapor levels of 2 ppm above background  did not occur
 at the site perimeter.  Area background levels as measured upwind of the site
 and at surrounding residences with flame ionization detectors  varied from
 about 1 ppm to 5 ppm during the study.  Continuous background  levels above
 3.5 ppm occurred only during the early portion of the pilot study.   During
 the spring, background total  organic vapor levels typically were 1  to 2  ppm
 as measured on portable flame ionization detectors calibrated  to methane.
      Air monitoring results from 8-h sorbent tube sampling at  the site
 perimeter indicated that TCE concentrations in the ambient air ranged from
 l«ss than 0.002 ppm to 0.01 ppm.   Trichlorofluoromethane (Freon 11) was
'measured at slightly higher concentrations ranging from less than 0.010  ppm
 to 0.018 ppm.  Other compounds including 1,2-dichloroethylene,  toluene,
 ethyl benzene, and xylene were detected at levels of 0.01 ppm or less on
 isolated occasions.
                                      31

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     Elevated ambient levels of suspended participates during a brief portion
of the pilot study represented the most significant air quality impact.  On
several days during the latter portion of the pilot study, total suspended
particulate levels exceeded 110 /jg/m3 as measured during 24-hour sampling
periods at high volume samplers at the site perimeter.  After dust control
measures were implemented visual dust emissions and high volume particulate
concentrations noticeably decreased, with the maximum 24-hour high volume
concentration less than 50

2.7  NYANZA VAULT SITE
     The Nyanza site is located in Ashland, Massachusetts, approximately 25
miles west of Boston.  The site is a privately owned active industrial
complex comprising approximately 35 acres.  Between 1917 and 1978, numerous
companies that manufactured textile dyes and intermediates occupied the land.
The last of these dye manufacturing companies was Nyanza, Inc., which
operated from 1965 to 1978.  Industrial wastes generated by these companies
were partially treated and the resulting chemical sludges were disposed
onsite in unlined lagoons and in an underground vault.  In 1978, Nyanza, Inc.
                                             12
ceased its operation at the Ashland facility.
     In 1986, a State of Massachusetts DEQE site investigation team
discovered that an underground vault or settling basin, which is located in
the lower industrial area of the site, contained high levels of chlorinated
organic compounds and other constituents.
     In 1987, a sampling team from the Massachusetts DEQE and an OSC from
EPA's Oil and Hazardous Materials Section took soil samples from the area
immediately downgradient of the vault.  High concentrations of nitrobenzene
(1200 to 9100 ppm), chlorobenzene, aniline, dichlorobenzene and other
chemicals were found just below the ground surface (Table 8).  Groundwater
was also heavily contaminated.  Chemical Brook is located 60 to 70 feet
downgradient of the vault and runs directly by a residential area
approximately 250 to 300 yards from the site.  Chemical Brook runs into the
Sudbury River, which empties into the Framingham Reservoir which is currently
used for recreational purposes, however, it may be considered for use as a
supplemental source of drinking water for the City of Boston.
                                      32

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   TABLE 8.  MAJOR SAFETY THREATS FROM COMPOUNDS AT THE NYANZA VAULT SITE


Nitrobenzene                       Low permissible exposure limit  (PEL),
                                   toxic combustion products, inhalation
                                   hazards

Chlorobenzene                      High flammability, reaction wiih caustic
                                   agents, toxic combustion produ'cts

Aniline                            Low PEL, toxic combustion products,
                                   inhalation hazards

Trichloroethylene                  Reaction with strong caustic agents

1,2-dichloroethylene               Reaction with strong caustic agents

1,2,4-trichlorobenzene             Reaction with strong oxidizers

Mercury
     On April 23, 1987 a removal action was authorized.  This site is now on
the NPL.
     At the time of removal operations, MCL Development Corporation leased
part of the original property to Nyacol Products Incorporated.  Nyacol's
plant directly abutted the property, which was the subject of the removal
action.12

     In a 1987 memorandum to the OSC, a representative of the ATSDR concluded
that the VOCs detected in the soil downgradient from the underground vault
presented a potential threat to public health.  Recommendations included air
monitoring at the site, especially when the soil in the area began to dry
out.13
     Removal actions took place under an air supported dome.  The purpose of
this building was to control or eliminate the release of volatile chemicals.
The dome was equipped with a carbon adsorption system that allowed for air

exchange within the building without contaminating the ambient air.
     Excavated chemical sludges and soils were shredded within the building
and were transported .on a conveyor to a rotary kiln thermal destruction unit
located just outside the building.  Excavation and shredding of materials
were conducted in such a manner as to reduce volatilization of chemicals
                                      33

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 within the building structure.   The conveyor to the outside was  enclosed  to

 contain the volatilization of chemicals.
      A small  surface area was excavated and then covered.   The material was
 delivered to a shredder hopper which was  kept covered.   After shredding,  the
 materials were covered for final delivery to the thermal destruction
 operation.  Vapor control foam was kept on hand inside  the building for use
 on exposed chemical sludge areas to reduce chemical volatilization.
      The first phase of EPA's operations  covered excavation and  destruction
 of the materials within the vault.  Then  the building was moved  to an area of
 contaminated soil directly downgradient from the vault.  Throughout both
 phases, air monitoring was conducted within the building and at  the site
           14
 perimeter.
      The purpose of the air sampling program was to collect sufficient data
 on volatile emissions from removal activities taking place inside the air
 structure and from the incineration process conducted outside in the ambient
 air.  Samplers were located at 5 sites, both inside and outside  the air
 structure, as shown in Figure 7.  Sampling and analytical  methodologies were
 designed to identify and quantify the release of six target compounds:
 nitrobenzene, chlorobenzene, aniline, trichloroethylene, 1,2-dichlorobenzene,
 and 1,2,4-trichlorobenzene.  Data were interpreted and  compared  to worker
 exposure limits [8-hour permissible exposure limits (PEL)] for determining
 the impact that onsite activities were having on both the workers and the
                                                                          14
 extent to which emissions were migrating  offsite and impacting residents.
      Calibrated Dupont Alpha 1 and P125A personal constant flow  air sampling
 pumps were used to collect eight-hour samples on conditioned 1.5 grams TENAX
 GC adsorbant, packed in 12.7 mm OD x 100 mm stainless steel tubes, which  were
 inserted into stainless steel sampling cartridges.  Two eight-hour sampling
 events were conducted during the operational phase of the removal and
 incineration process.  For each event, three samples were collected inside
 the air structure collocated with real time instrumentation:  one sample
 (approximately 5 liters) was collected over an eight hour period; the other
 -two samples (approximately 1 liter each)  were run consecutively  for four
"hours.  All samples were collected in the breathing zone,  three  to five feet
 above ground level.
                                       34

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xSite 5
             D
              Sitel*
               fHlMllt
               »CllWHt
               • IHI 	
1,	^i      ^•••SI  •  a
\_  cooos 3      At   I  I








>»     HW»U      ___ S     >»
                                         coritnotiioc.
                                         -4060CALHC1.

                                              , M.ON CAU
                   Figure  7.  Sampling  locations and meteorological tower.
                                                         35

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     One 20 liter sample was collected for eight hours outside the air
structure adjacent to the conveyor system.  The sampler was positioned to
capture fugitive volatile emissions being emitted from this system.
     One 20 liter sample was collected at a distance of 300 feet upwind of
the site conveyor system.  This location provided background data for
comparing data generated from other sampling locations.          ;
     Two 20 liter samples per event were collected at a distance greater than
300 feet downwind of the site center.  These locations provided data for
evaluating the extent that volatile emissions were migrating offsite.
     The following instrumentation was used:
     o    HP 5970 Mass Selective Detector
     o    HP 5890 Gas Chromatograph equipped with a 60 meter VOCOL capillary
          column
     o    HP 1000 computer using the RTE and Aquarius software
     o    Tekmar 5000 Thermal Desorber.
     Results of the air sampling study are presented in Table 9.  The trip
blank and lab blank both had levels below the lower limits of detection for
nitrobenzene (<4ng), chlorobenzene (<2ng), aniline (<30ng), trichloroethylene
(<2ng), 1,2-dichlorobenzene (<2ng), 1,3-dichlorobenzene (<2ng),
1,4-dichlorobenzene (<2ng), 1,2,4-trichlorobenzene (<2ng), and a
trichlorobenzene isomer (<2ng).  The results of background sampling (Site 4)
and the downwind sampling (Site 5) showed that very little, if any,
contaminants migrated offsite.  Levels were significantly higher, however,
inside the air structure (Site 1) and near the incinerator (Site 2), as
expected.  Much lower concentrations were detected just outside the air
structure between the two Nyacol buildings (Site 3), with nitrobenzene being
the highest contaminant measured at 34.3 ppb.  Inside the air structure and
next to the incinerator (where levels for certain compounds could not be
quantitative above their upper limits of detection), estimated concentrations
were calculated.  For sample 3 (inside the air structure) nitrobenzene was
estimated to be approximately 660 ppb.  Sample 2 (inside the air structure)
nitrobenzene, 1,2,4-trichlorobenzene, and trichloroethylene were estimated to
be approximately 1600 ppb, 445 ppb, and 550 ppb, respectively.  Sample 4
(next to incinerator) nitrobenzene and 1,2,4-trichlorobenzene were estimated
to be approximately 270 and 70 ppb, respectively.  These estimated values are
                                      36

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             TABLE 9.  AIR SAMPLING RESULTS FROM NYANZA VAULT
SITE LOCATION

1
inside air
structure

m




1
inside air
structure






2
3 ft fron
incinerators
feed system
and hopper




3
outside air
structure
between the
two Nyacol
buildings



4
background,
140 feet
North of
Nyacol' s
office and
lab building


5
downwind,
300 feet
VBW of air
structure
along rail-
road tracks


SAMPLE

3








2








4








6








7








8








FLOW RATE
std( ml/fain)
6.6








5.6








19.4








38.2








43.4








37.7








SJWPLE TIME
(hours)
0910 - 1259








1259 - 1649








0910 - 1710








0910 - 1710








0900 - 1700








0910 - 1706








SAMPLE VOL.
(liters)
1.5








1








9








18








21








16








COMPOUND

nitrobenzene
chlorobenzene
aniline
trichloroethylene
1,2 dichlorobenzene
1,3 dichlorobenzene
1,4 dichlorobenzene
1,2,4 trichlorobepzene
trichlorobenzene
nitrobenzene
chlorobenzene
aniline
trichloroethylene
1,2 dichlorobenzene
1,3 dichlorobenzene
1,4 dichlorobenzene
1,2,4 trichlorobenzene
trichlorobenzene
nitrobenzene
chlorobenzene
aniline
trichloroethylene
1,2 dichlorobenzene
1,3 dichlorobenzene
1,4 dichlorobenzene
1,2,4 trichlorobenzene
trichlorobenzene
nitrobenzene
chlorobenzene
aniline
trichloroethylene
1,2 dichlorobenzene
1,3 dichlorobenzene
1,4 dichlorobenzene
1,2,4 trichlorobenzene
trichlorbenzene
nitrobenzene
chlorobenzene
aniline
trichloroethylene
1,2 dichlorobenzene
1,3 dichlorobenzene
1,4 dichlorobenzene
1,2,4 trichlorobenzene
trichlorobenzene
nitrobenzene
chlorobenzene
aniline
trichloroethylene
1,2 dichlorobenzene
1,3 dichlorobenzene
1,4 dichlorobenzene
1,2,4 trichlorobenzene
trichlorobenzene
AMOUNT
(nq)
>3297
26.5
ND <30
397
447 -
19.3'
115
1929
21.7
>3297
113
ND <30
>2009
1188
58
340
>2009
55.4
>3297
60
2225
826
1963
79.2
519
>2009
129
3104
28.69
ND <30
369.55
209.18
9.83
81.97
1801
13.3
4.4
ND <2
ND <30
ND <2
ND <2
ND <2
2.86
2.64
ND <2
7.78
ND <2
ND <30
ND <2
ND <2
ND <2
1.97
6.44
ND <2
CONCENTRATION
(DDb V/v)
>440 «
3.9
ND <5.3 t
49.1
49.6
2.1
12.8
174
2.0
>656 *
24.7
ND <7.9 t
>372 *
198
9.7
56.7
>272 *
7.5
>73 *
1.5
65.0
17.0
36.3
1.4
9.6
>30 *
1.9
34.3
0.3
ND <0.4 t
3.8
1.9
0.1
0.8
13.5
0.1
0.04
ND <0.02 t
ND <0.38 t
ND <0.02 t
ND <0.02 t
ND <0.02 t
0.02
0.02
ND <0.02 t
0.09
ND <0.02 t
ND <0.4 t
ND <0.2 t
ND <0.2 t
ND <0.2 t
0.02
0.05
ND <0.02 t
(Continued)
                                      37

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TABLE  9 (Continued)
SITE LOCATION

trip blank



"




lab blank








SAMPLE

9








5








FLOW RATE
std(ml/Wn)
HA








NA








SAMPLE TIME
(hours)
NA








NA








SAMPLE TOL.
(liters)
(A








NA








COMPOUND

nitrobenzene
ohlorobenzene
aniline
trichloroethylene
1,2 dichlorobenzene
1,3 dichlorobenzene
1,4 dichlorobenzene
1,2,4 trichlorobenzene
trichlorobenzene
nitrobenzene
chlorobenzene
aniline
trichloroethylene
1,2 dichlorobenzene
1,3 dichlorobenzene
1,4 dichlorobenzene
1,2,4 trichlorobenzene
trichlorobenzene
AMOUNT
(ng)
NIX4 t
MX2 t
Nixaot
MX2 t
NIX2:t
NX2 t
NIX2 t
NIX2 t
NIX2 t
NIX4 t
NIX2 t
NDOOt
NIX2 t
NIX2 t
NIX2 t
NIX2 t
NIX2 t
WX2 t
OONCFNTRATION
(ppb v/v)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
* - upper limits of detection
t - lower limits of detection
ND - nondetectable
NA - not Applicable
ng - nanograms
ppb v/v - parts  per billion volume per voltme
                                               38

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 above  the  highest  standard  used  for quantitation; therefore, they should not
 be  compared  to  any air  quality standard.  They are only reported to  indicate
 the range  at which these  concentrations might exist.   '

 2.8 QUAIL RUN  SITE
     In  the  early  1970's, hexachlorophene and Agent Orange were produced in a
 small  industrial facility in  southwest Missouri and 2,3,7,8-tetrachlorodi-
 benzo-p-dioxin  (TCDD) was formed as a byproduct.  Waste materials containing
 this dioxin  byproduct were  mixed with used oil and applied to roads  and other
 surfaces for dust  control.  Quail  Run trailer park near St. Louis, Missouri,
 was one  of the  places where this waste material was applied.  The site
 covered  an area of approximately 11 acres and had an  irregular shape as shown
 by  the site  map (Figure 8).
     Surface and subsurface soils at Quail Run were tested and were  found to
 contain  2,3,7,8-TCDD at concentrations above 1.0 ppb  at most locations within
 the site.  A mitigation plan  was prepared to control  exposure to the
 contaminated soil.  This  plan called for the removal  of the contaminated soil
 from the surface and for  storage of the removed material  in a safe location
 onsite until  detoxification procedures were available.  An air monitoring
 plan was developed to protect the general public in the immediate vicinity of
 the cleanup  operation.
     A report from the  Center for Disease Control (presently called  ATSDR)
 recommended  5.5 picograms per cubic meter (pg/m3) as  an estimated no observed
 effect level  (NOEL).  This  level  was based on chronic health effects.  EPA
 and CDC  agreed  to  setting a "warning" or action level  at  3.0 pg/m3.   The
 design of  the monitoring  network incorporated a measurement detection limit
 in  the range of 0.1 to  1.0  p/m3  to obtain reliable measurements at the 5 p/m3
 level.   Initially,  14 samples were collected at each  monitoring site.  With
 the 14 data  values at each  of the six locations shown in  Figure 9, a
 definitive conclusion would then be reached if the data were 14 percent
 either above or below the action level.
^'   In  order to obtain sufficient data to assess the effects of onsite
 activities on the  offsite ambient air under variable  wind conditions, the
 monitoring network was  designed  to provide long-term  monitoring of the air at
 or  near  the  property boundaries  of the site.  On the  basis of the physical
                                      39

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        M -  E MONITORS
SAMPLE
LOCATION
— CONTAMINATED
  •  AREA
              Figure  8.   Diagram of the Quail Run Site.
             700
             6.00
        gfe   500
        '
             4.00
        feg   30°
        ig
        53   200
             1.00



             0.00
t:a OBSERVED EFFECT LEVEL
—
—
—4 » o • $
• i i • i

i


. ACTION LEVEL
i i
O a l (
4 4 •

                           O NON-
                             DO WHVIND

                           Q DOWNWIND

                           • NON-
                             SAMPUNC
Figure 9.  Results  of monitoring versus action  level  at Quail Run,
                                  40

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  configuration  of  the  site, which  is long relative to its width, a minimum of
  six  fixed  monitoring  locations were needed to ensure consistency throughout
  the  study  and  to  have one upwind  and one downwind sample for most days.  This
  would minimize the  probability that contaminated air would pass between the
  monitors without  being detected.  The three largest variables affecting this
"probability were  the  size of the  area within the site that was re3easing
  dioxin, local  variation  in the wind direction during a sample collection time
  period, and the duration of the study.  An onsite meteorological monitoring
  station was incorporated into the network design for the purpose of obtaining
  adequate wind  speed and direction data.
      Prior to  finalizing the network design, a site visit was made to obtain
  detailed information  on the topography and to choose the specific sampling
  locations  relative to  anticipated activities at the site.  Air sampler
  locations  were  selected so that they would be near, but just inside the
  perimeter  fence (for  security purposes), would be consistent with the
  accepted siting guidance for criteria pollutant monitoring, would provide
  permanent  placement throughout the life of the project (i.e., the samplers
  would not  have  to be  relocated during the course of the excavation activities
  at the site),  and would provide adequate coverage for most wind directions.
  Sampling locations that were selected are shown in Figure 8.
      Because of the high cost of sampling and analysis of dioxins,  a
  statistical analysis was carried out to determine the minimum number of
  samples that could be collected to have a good probability (95% confidence
  level) of  showing an exceedance of the action level, if one occurred,  and of
  showing that no exceedance occurred if one did not occur.  The number  of
  samples needed  at each location was calculated as a function  of the
  difference between the action level  (true mean)  and the mean  of a given
  number of measured values.
      To collect representative samples,  commercially available modified
 high-volume air samplers were used that  employed both a filter for  collecting
 particulate matter and a solid adsorbent for collecting vapors.   A  known
 -volume of air (calculated from the flow  rate and time of sampling)  was drawn
"through a sampling module and exhausted  to  the air via  a 10-ft exhaust duct.
 The upper portion  of the sampling  module holds a 4 in.  diameter glass  fiber
 filter,  which  collects the  particulate matter,  and the  lower  portion consists
 of a  cylindrical glass cartridge  (65 mm  x 125  mm)  containing  a solid
                                       41

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 adsorbent,  which entraps selected  vapor-phase  compounds.   Polyether-type
 polyurethane foam (PUF)  plugs  were use  as  the  solid  adsorbent material.
      To measure the very low concentrations  of dioxin  required  in  this
 project, a  large sample  volume of  air was  required.  Because the air samplers
 were only capable of providing a flow rate of  approximately 0.280. m3/mi n,  it
'was determined that the  samples should  be  collected  on a  24-h basris  (+15%).
 This time and flow gave  sampled air volume of  300  to 400  m3 of  air.
      Samplers were placed on platforms  to  obtain samples  of the ambient air
 in the breathing zone.   Initially, wind direction  could not be  predicted  for
 any 24-h sampling period.  Therefore, all  samplers were operated each day.
 During the  first 14 days of sampling, all  of the samples  were analyzed  for
 both particulate matter  and 2,3,7,8-TCDD to  obtain baseline data for the
 site.  Subsequent to this initial  sampling period, only one upwind and  one
 downwind sample were submitted for 2,3,7,8-TCDD analysis  each day.  The
 selection was based on the prevailing wind direction and  the  amount  of
 particulate matter collected on each filter  for the  sampling  period.
      Monitoring data were used for a daily risk estimation.  The maximum
 amount of dioxin a person located  just  offsite would experience during  the
 time of the cleanup activities was calculated. Data values from each monitor
 were averaged separately because the levels  from a single monitor  are
 representative of exposure for a person living near  that  monitor.   An average
 concentration was used  because it  is more  consistent with an  action  level
 based on chronic effects than  is a single  measured value. Because pollution
 abatement actions had to be taken  as quickly as possible  after  data  were
 available,  a 14-day running average (average concentration of the  most  recent
 14 days), was calculated daily. The detection limit of the instrument  was
 used as a measured value when  calculating  the  running  averages  for samples
 that did not contain a measurable  concentration of 2,3,7,8-TCDD.   Because
 none of the nondownwind  samples showed  any measurable  2,3,7,8-TCDD,  an
 average of  these numbers was used  for those  days when  data were not
 available.   A daily data point might be missed for a monitor  if that monitor
 was neither upwind nor downwind of the  site  or if  no work was occurring at
"the site.  All samples were analyzed by an EPA contractor in  accordance with
 a Region VII standard method entitled Determination  of 2,3,7,8-TCDD in  Air
 Samples Using Gas Chromatography-Mass Spectrometry.
      Both system and performance audits were included  in  the  air monitoring
 plan to ensure that the  established procedures were  actually  being followed.
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  The  audit  process  provided  a means  for continually evaluating the quality of
  the  data being generated, identifying apparent problems quickly, and making
  changes to correct apparent problems.
      During the  course of the project, tests were conducted to-assess the
  quality of data  from the monitoring network.  On the basis of the. results of
"field and  laboratory audits, the procedures described in the monitoring plan
  were being followed as written and with the exception of two data points, all
  data were  of acceptable quality.
      During the  course of the project, two experiments were conducted to
  determine  what fraction of  the 2,3,7,8-TCDD and 2,3,7,8-TCDF
  (2,3,7,8-tetrachloro-p-dibenzofuran) would pass through the filter and what
  fraction would remain on the filter under the sampling procedures that were
  established.
      These experiments indicated that dioxin was very slowly migrating from
  the  filter to the  PUF.  Therefore, analyses of only the particulate matter or
  only the vapor phase in the sample would give erroneous results.  It also
  appeared that the  furans were more easily transferred from the filter to the
  PUF  than were the  dioxins.
      An analysis of monitoring data shown that the volume of air sampled was
  just large enough  to give adequate data precision (the maximum RSD at the
  monitor showing  highest concentrations of 2,3,7,8-TCDD was approximately 22%)
  in the 3 to  5 pg/m3 concentration range.
      Figure  9 is a graph showing the 14-day running averages and the
  associated 95 percent confidence levels of those averages for the monitoring
  site with  the highest concentrations.   Data points are representative
  averages of measured or estimated concentrations for the most recent 14 days.
 A downwind sample  (labeled 0 in Figure 9)  is one in which the monitor was
 downwind of the cleanup activity during the last day of the 14-day averaging
 period.   A nonsampling value is shown  for those days when the concentrations
 at site  0 were estimated rather than measured on the last day of the
 averaging period.  The average of all  measured (or estimated)  concentrations
 -for 14 consecutive days is plotted on  the  y axis against the last day of the
'14-day averaging  period on the x axis  for  monitor 0.   Detection  limits were
 taken as measured concentrations.   If  a measurement was  not taken for a given
 day because the monitor was  not downwind or upwind  on  that  day,  an  estimate
 of the concentration was  made  by averaging all  of the  nondownwind values  to
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 date.   Because  concentrations  above the detection limit  (usually  in the range
 0.4  to  0.8  pg/m3)  were  obtained  only when  a monitor was  downwind  of the site,
 all  estimated values were  averages of detection limits.  The data are
 presented in this  manner to  illustrate the best estimate of the maximum
 exposure of any offsite population that might have resulted from .this cleanup
 activity.                                                         :
     Note that  all  of the  14-day averages  were well below the warning level
 and  the NOEL at all times.   Therefore, concentrations of 2,3,7,8-TCDD that
 cause an insignificant  risk  to the public  can be measured in ambient air
 using the procedures of this project.  During this study the public was not
 exposed to  a significant concentration (5.5 pg/m3 for a  "few months11) of
 2,3,7,8-TCDD at any time.17

 2.9  VERTAC SITE
     The VERTAC Site is a  Superfund site located in Jacksonville, Arkansas.
 It was  a World  War II army ammunition plant that was converted to the
 production  of pesticides in  1948.  The plant was converted to the production
 of 2,4,5-T  and  "agent orange"  during the 1960s and 1970s by the VERTAC
 Chemical Corporation.   Many  parts of the property and its equipment became
 contaminated with  2,3,7,8-TCDD.   In 1982 the VERTAC Site was listed on the
 NPL.
     In 1985, VERTAC Corporation was under an order [based on Resource
 Conservation and Recovery  Act  (RCRA)] to carry out site  remediation.  French
 drains  were constructed to capture storm water and tanks were built to settle
 solids  contaminated by  dioxins.  Solids were to be stored in above-ground
 vaults.  Construction activities stirred up dust that was potentially
 contaminated with  2,3,7,8-TCDD.
     During the  period  June  27,  1985 to October 25,  1985, an air monitoring
 program was conducted by IT  Corporation and EMI Consultants to determine
 airborne concentrations of 2,3,7,8-TCDD in the vicinity of the remedial
         18
 activity. ° The sampling network consisted of four sampler locations that
Included three perimeter sites to evaluate the potential for airborne
migration of_TCDD beyond the boundaries of the work site and one internal
 site to evaluate potential  work exposure (Figure 10).   A total  of 236 ambient
 air samples were collected of which 174 were perimeter samples.   All  samples
were analyzed for suspended particulate matter (PM).   Thirteen  of these,
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                                                       e
    OLD
• OUALIZATION
   BASIN
    NEA4OH
      HILL  '
                                                                                  • ••00
                                                                                  • •000
                                                                                  • ••00
                                                                                  • •000
                                                                                  E1BOO
                                                                                  • 1000
                                                                                  C «00
     Figure 10.  Ambient air sampler locations  at VERTAC Chemical Corporation.
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 which exhibited the highest potential for measurable levels,  were analyzed
 for 2,3,7,8-TCDD.  Two samples were analyzed for 2,4,5-T and  2,4-D.
      Sampling for airborne levels of PM and TCDD was performed using a PUF
 equipped high volume air sampler manufactured by General Metal-Works, Inc.
 This system used a dual chambered, aluminum sampling module,  which contained
'both particulate and vapor phase collection media.   The upper chamber
 supports a 4" diameter airborne particulate GFF.  The lower chamber
 encapsulates a glass cartridge, which contains the PUF for vapor entrapment.
 A "Method Validation" study was performed to evaluate the effectiveness of
 the PUF for collecting TCDD.
      Above background PM concentrations were calculated by assuming the
 lowest measured PM concentration during a sampling period was background and
 subtracting this value from all measured PM concentrations during that time
 period.  Samples with the highest suspended particulate matter concentrations
 were analyzed for TCDD.
      Above background PM concentrations in the work area (No. 1) averaged 3.9
 to 7.8 times higher than those measured at the perimeter samplers (Nos. 2, 3,
 and 4).  The average above background PM concentration in the work area was
 34.9 A»9/m3 and the range was from 0.0 to 154.4  /*g/m3.  The North perimeter
 sampler ranged from 0.0 to 78.5 ^g/m3 and the average above background
 concentration was 7.5 pg/m3.  Above background PM concentrations at the South
 perimeter sampler ranged from 0.0 to 6.1 pg/m3 and the average above
 background concentration was 8.9 pg/m3.  Above background PM  concentrations
 at the West perimeter sampler ranged from 0.0 to 107.6 ng/ma  and the average
 above background concentration was 4.5 /*g/m3.
      Measurable levels of TCDD onsite ranged from nondetected to 14.9 pg/m3.
 No measurable levels of TCDD were found at any of the perimeter sampler
 locations.18

 2.10  WEATHERFORD RESIDENCE
      The Weatherford Residence is located at 25 Cordelia Drive in
"Jacksonville, Arkansas.  Mr. Robert Weatherford is  an ex-employee of VERTAC
 Chemical Corporation at their herbicide production  plant in Jacksonville.
      Mr. Weatherford purchased three trucks and several  clothes  washers and
 dryers from VERTAC.   One of the trucks contained two railroad ties and about
 60 gallons of debris,  possibly dirt contaminated by still  bottoms.  He
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apparently used debris to fill in a 10 foot by 10 foot area adjacent to his
earthen driveway.  The two railroad ties were used to support a shed located
in his backyard.19'20
     On December 7, 1988, samples were collected from the International lift
truck, the Dodge flatbed truck, and the railroad ties.  These samples showed
evidence of 2,3,7,8-TCDD, as follows:                            :
     International lift truck:
          scraped material from truck bed = >180 ppb        2,3,7,8-TCDD
          exterior wipe                   - >340 pg/cm2     2,3,7,8-TCDD
          interior cab wipe               -   20 pg/cm2     2,3,7,8-TCDD
     Dodge flatbed truck:
          exterior wipe    = >290 pg/cm2     2,3,7,8-TCDD
          interior cab wipe «   20 pg/cm2    2,3,7,8-TCDD
     Railroad tie:
          bulk sample = >420 ppb 2,3,7,8-TCDD
     During April 10 to 12, 1989, the TAT conducted extensive sampling of
surface and subsurface soil at Mr. Weatherford's residence.  Two locations,
an area around the railroad ties and an area around the suspected soil burial
site, were determined to have 2,3,7,8-TCDD above the Agency's action level of
<1 ppb at the 95 percent UCL (Figure 11).
     Remedial action involved removal of dioxin contaminated soil from Mr.
Weatherford's residence and transporting it to the VERTAC Superfund site.
Contaminated trucks and the railroad ties were to be transported to the
VERTAC site and decontaminated with steam and solvent.  Removal activities
were performed by ERCs.
     TAT conducted ambient air monitoring during the removal activities.  The
objectives of air monitoring were to:  1) evaluate the potential for airborne
migration of dioxin contamination offsite (general population exposure)
during removal activities, 2) evaluate the potential for exposure of
populations at highest risk during the removal actions, and 3) assess the
adequacy of dust suppression methods being used on site as a function of the
'site-specific meteorological conditions.
     Five ambient air monitors (General Metals PS-1 PUF sampler) were
permanently placed along the perimeter of Mr. Weatherford's property so that
the network would contain an upwind and a downwind perimeter monitor for any
given wind direction.  A sixth monitor was located at an occupied residence
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Figure 11.  Soil sample locations at Weatherford residence.
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judged to be at greatest risk of exposure (sensitive receptor).  Air monitor
locations were selected with consideration for wind direction, excavation
areas, obstructions caused by buildings and trees, and probable access.  Air
monitors were placed at a distance greater than 30 feet from the excavation
areas and monitor probes were at least twice the height of obstructions.
Monitors were securely positioned atop elevated platforms, placing the
                                                               21
sampler intake at a height of 2 to 4 meters above ground level.
                                      49

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                                   SECTION 3
                   DEVELOPMENT OF THE AIR MONITORING PORTION   .   *
                          OF A SITE CONTINGENCY PLAN

      All Superfund remediation or.removal projects are required  to have a
 health and safety plan to protect workers.  A contingency plan may be an
 extension of the health and safety plan.  Contingency plans for  a site begin
 with basic site control procedures.  Then the plan covers emergency
 situations to protect, as a minimum, onsite workers.   In some cases the
 offsite population will be addressed in the plan.   Whether or not a
 contingency air monitoring program is required is  determined by  analyzing the
 site.  If required, a monitoring program plan must be developed  with the
 objective of protecting offsite populations.  A special  analysis will be
 required to determine the alert levels in the contingency plan and the
 appropriate actions to take.
      Note that this document is intended for use in the Superfund remediation
 program.  Although examples from the removal program are used to illustrate
 the types of air monitoring that have been used in support of Superfund
 cleanups, the guidelines are not directly applicable to removal  cleanups.
 When time permits and sufficient site date are available, however,  many of
 the procedures contained in this document could be used in developing an air
 monitoring plan for a cleanup operation.

 3.1  TYPICAL CONTENTS OF A SITE CONTINGENCY PLAN
      To understand the context of a contingency air monitoring plan, the
 nature of a contingency plan must be understood.  Based on existing EPA
 documents, the following subsections describe the  types of information that
 are usually provided.
-3.1.1   Site Control
      To maintain a safe environment, activities at a  Superfund remediation or
 removal site must be  controlled.   A site control program should  be  instituted
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                                                                        22  23
 prior  to  site  characterization  and  continue  throughout  site  activities.   '

 Site control serves  several  purposes:   it minimizes the potential  for worker

 contamination  or injury,  protects the  public from the site's hazards,
 facilities  work activities,  and prevents vandalism.  Site  control  1s

 especially  important in emergency situations.  Site control  procedures  may

 include:                                                          :

     o   Compiling  a site map  showing topographic features,  prevailing wind
          direction,  drainage,  and  the locations of pits,  ponds,  and tanks.
          The  map should  be  updated throughout the course  of site  operations
          to reflect changes in site conditions and activities.   The map may
          be used to plan site  activities; to assign personnel; to identify
          access routes,  evacuation routes,  and problem areas; and to
          identify areas  of  the site that require the use  of personal
          protective equipment.

     o   Preparing  the site for cleanup activities.  Preparation  includes
          constructing roads, removing physical hazards, installing antiskid
          devices, constructing operation pads, constructing docks, and
          installing electrical  wiring.  Preparation can be  as hazardous as
          cleanup.   For this reason, extreme care for worker safety must be
          taken.

     o   Establishing work  zones.   To reduce the accidental  spread of
          hazardous  substances  by workers from the contaminated area of the
          site to the clean  area, hazardous  waste sites  should be  divided
          into as many different zones as necessary to  meet  operational and
          safety objectives.  Three frequently used zones  are (Figure 12):

                The Exclusion Zone,  i.e., the contaminated  area of  a site
                The Contamination Reduction Zone (CRZ) where  decontamination
                takes  place

                The Support Zone, i.e.,  the uncontaminated  area within which
                hazardous  conditions  should not exist.

     o   Defining separate  zones and  tracking entry and exit from  these
          zones  helps  ensure that personnel  are protected  against  hazards,
          that work  activities  and  contamination are confined to the
          appropriate  areas,  and that  personnel can be  located and  evacuated
          in the  event of an  emergency.

     o    Using  the  buddy system when  necessary.  Most  activities  in
          contaminated or otherwise  hazardous areas should be conducted with
          a "buddy" who is able to  provide assistance, observe for  signs of
-""        chemical or  heat exposure, periodically check the  integrity of his
          or her  partner's protective  clothing, and notify others  if
          emergency help  is  needed.   The buddy system alone may not be
          sufficient to ensure that  help will be provided  in an emergency.
          At all  times, workers in the  Exclusion Zone should be in
          line-of-site contact or communications contact with a person  in the
          Support Zone.
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                                         Hotline forming the
                                         boundary between
                                         the CRZ and the
                                         Exclusion Zone.
                  Estimated boundary
                  of area with highest
                                                            Contamination
                                                            Control Line
                                                      Support Zone
                                                Command Post
                                                (Upwind of Exclusion Zone)
D
Access Control Points which control the flow of personnel and
equipment into and out of the Exclusion Zone

Decontamination Reduction Corridor where decontamination takes place.

Contamination Reduction Zone (CRZ).
Exclusion Zone. Buffer zone between CRZ and area of highest
contamination.
                   Figure  12.   Site work  zones.
                                    52

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     o    Establishing and strictly enforcing decontamination procedures for
          both personnel and equipment.

     o    Establishing site security measures to prevent the exposure of
          unauthorized, unprotected people to site hazards; to prevent theft;
          to avoid increased hazards from people seeking to abandon other
          wastes on the site; and to minimize interference with safe working
          procedures.  Security measures may include establishing"an ID
          system, erecting a fence, posting signs, hiring security guards,
          and enlisting public law enforcement agencies.

     o    Setting up communication networks.  An internal communications
          network is required to alert workers to emergencies, pass along
          safety information, communicate changes in the work to be
          accomplished, and maintain site control.  An external communication
          system between onsite and offsite personnel is necessary to
          coordinate emergency response, report to management, and maintain
          contact with essential offsite personnel.

     o    Enforcing safe work practices, including a list of standing orders
          stating practices that must always be followed and those that must
          never occur in the contaminated areas of the site (Figure 13).

     The degree of site control needed depends on site size and

characteristics, and on the proximity of the surrounding community.  The site

control program should be established in the planning stages of a project and

should be modified as necessary based on new information and site
            22 23
assessments.  '
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FOR PERSONNEL ENTERING THE CONTAMINATION REDUCTION ZONE:
     No smoking, eating, drinking, or application or cosmetics in this zone.
     No Batches or lighters in this zone.
     Check in at the entrance Access Control  Point before you enter this
     zone.
     Check out at the exit Access Control Point before you leave this zone.
FOR PERSONNEL ENTERING THE EXCLUSION ZONE:
     No smoking, eating, drinking, or application or cosmetics in this zone.
     No matches or lighters in this zone.
     Check in at the entrance Access Control  Point before you enter this
     zone.
     Check out at the exit Access Control Point before you leave this zone.
     Always have your buddy with you in this  zone.
     Wear an SCBA in this zone.
     If you discover any signs of radioactivity,  explosivity, or unusual
     conditions such as dead animals at the site, exit immediately and report
     this finding to your supervisor.
                     Figure 13.   Sample standing  orders.
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 3.1.2    Site  Emergencies
     Unforeseen  circumstances  may  suddenly  create unexpected  emergencies  at
 Superfund  remediation  or  removal sites.  An emergency may  be  as  limited as a
 worker  experiencing  heat  stress, or  as vast as  an explosion that spreads
 toxic fumes throughout a  community.   Some common causes of emergencies
 include fire  or  explosion,  chemical  leaks,  chemical  reactions, container
 collapse,  release  of toxic  vapors, heat  stress, personal protection  equipment
 (PPE) failure, and physical  injury.
     Site  emergencies  are potentially complex because uncontrolled toxic
 chemicals  may be numerous and  unidentified,  and their effects may be
 synergistic.  Advance  planning,  including anticipation of  emergency  scenarios
 and  through preparation for contingencies,  is therefore essential to protect
 worker  and community health and  safety.  Emergency response delays of minutes
 can  create life-threatening situations;  the rapidity of response can mean the
 difference between life and death.   Therefore,  it is essential that  personnel
 be able to immediately respond or  rescue, and that equipment  be  on hand and
 in good working  order.
     A  Contingency Plan that sets  forth  policies and procedures  for
                                                            93 p« pC pe
 responding to emergencies should be  developed for each site.  '   '   '     A
 Contingency Plan is  a  written  document (generally a  separate  section within
 the  Site Safety  Plan)  that  usually incorporates the  following:
     o     All individuals and  teams  who  will participate in emergency
           response,  and their  roles,  responsibilities, and lines  of
           authority.
     o     A detailed site map  showing the locations  and types of hazards,
           site terrain, evacuation routes,  refuges,  decontamination  stations,
           and offsite  populations  at risk.
     o     Procedures for  communicating onsite (e.g., bullhorns,  sirens, hand
           signals) and offsite (e.g., key phone numbers, contact  names,
           two-way  radio).
     o     Equipment  necessary  to rescue  and  treat victims, to protect
           response personnel,  and  to mitigate hazardous conditions on the
_.         site.
     o     Medical  treatment/first  aid techniques.
     o     Emergency  response procedures  that encompass all phases of response
           operations,  from  initial notification through preparation  of
           equipment  and personnel  for the next emergency.
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     o    Procedures for emergency decontamination, including decontaminating
          the victim(s), protecting medical personnel, and disposing of
          contaminated PPE and decontamination solutions.
     Figure 14 outlines a possible flow of operations during an actual
emergency.  Operations can be divided into three categories:
     o    Preparation, which involves assessing the situation, allocating
          personnel and equipment for response, and requesting aid from
          outside sources.
     o    Response, which involves rescuing, decontaminating, and treating
          victims; evacuating personnel and/or the public as necessary; and
          controlling the hazard.
     o    Followup, which involves replacing equipment, documenting the
          incident, and reviewing and revising the Site Safety and
          Contingency Plans.
3.2  DETERMINING A NEED FOR CONTINGENCY AIR MONITORING
     The need for contingency air monitoring is established by analyzing the
site and the remediation or removal to be carried out.  The two methods of
analysis are the air pathway analysis (APA), conducted under the supervision
of EPA, and the health assessment, conducted by the ATSDR.  These assessment
methods are briefly described in the following subsections.

3.2.1  Using Air Pathway Analysis
     One method for determining the need for contingency air monitoring is
        26
the APA.    As indicated in the Air/Superfund National Technical Guidance
Study (NTGS) Series, APA is applicable to every activity in the Superfund
process.
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Potential offsite impacts are an integral component of the Superfund risk
assessment process and should be considered in remedial
investigations/feasibility studies (RI/FS), remedial designs, and planned

removal actions.
     According to the NTGS, Volume 1, an APA conducted for a RI/FS should

involve the following steps:                                     :

     Step 1 - Identify and evaluate potential applicable relevant and
              appropriate requirements (ARARs) governing the air pathway
              for remediation/removal sources.

     Step 2 - Perform routine air monitoring during the remedial and removal
              operations.

     Step 3 - Implement a combination of modeling and monitoring techniques
              to characterize nonroutine air releases.

     When carrying out an APA for remediation planning, a combination of
monitoring and modeling techniques should be used to characterize unplanned
releases.  Dispersion modeling can be used to extrapolate monitoring data
from the source to the downwind receptor locations of interest.
     An APA for remediation planning consists of the following five steps

Step 1 - Review Existing Site Information

     First, information and data relevant to a site's potential air impacts
are reviewed, and data inputs for a modeling exercise or monitoring program
are developed.  This information consists of source and pollutant data,
receptor data, and environmental data.

Source and Pollutant Data

     Numbers and types of potential air sources located at the site should be
identified and contaminants listed.  The potential for each contaminant to be
released to the atmosphere should also be listed.  Characteristics of air
pollutants should be identified (i.e., gaseous or particulate, or a toxic
constituent adsorbed onto dust particles).  For a modeling exercise, source
dimensions for area and volume sources and stack parameters for elevated
sources, need to be listed.

Environmental Data   -

     Environmental data encompasses climatology, topography, land use
classification, and meteorology.  Climatological data are usually in the form
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  of wind roses that identify the frequency of occurrences of all wind
  directions.  Local topography, such as shown on a topographic map, can
  influence pollutant transport.  Topographic features can channel and divert
  large-scale regional wind flow such that wind direction onsite-may be much
  different from measurements taken offsite.  Land-use classificatipn affects
 '"whether the area should be modeled as "urban" or "rural," a choice that must

  be made in most dispersion models.
       Meteorological data are important to dispersion models.  A procedure for
  developing an onsite meteorological data base is included in Volume IV of the

  NTGS.
       Emission rates from potential onsite sources can be determined according

  to the procedures outlined in Volumes II and III of the NTGS.  Short-term
  maximum emission rates and long-term averages should be developed.  Due to
  the complexity of emissions mechanisms for some Superfund sources, the
  process of specifying an emission rate may involve a fairly complex protocol,

  including field measurements of emissions or monitoring and
  "back-calculating" an emission rate based on an assumed concentration

  distribution.
       When developing information in preparation for monitoring, the critical
  concentrations of each pollutant should be identified, i.e., what are the
  ARARs, concentrations, and risk levels that will determine whether or not a
  concentration is acceptable.  Risk assessments for carcinogens and systemic
  toxicants for which reference doses have been established are frequently
  bases upon long-term averages.  Nonetheless, contingency plan action limit
  air concentrations will typically be based upon exposures occurring only
  during the time period of the cleanup operations.  For a few very toxic
  chemicals which can have an immediate adverse health effects, the action
  limits can be based upon very short term average concentrations (time of
  exposure ranging from 15 minutes up to 8 hours) or an instantaneous
  concentration.

  Receptor Data

       A dispersion model can calculate concentrations at any location.
----- Usually, a gridded receptor field is mapped in the model to identify
  concentration gradients and maximum concentrations.  Population in the
  general vicinity of the site and the location of individual residences near
                                         59

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 the site should be determined.   Sensitive receptors  (e.g.,  hospitals,
 schools) should also be identified.   This information  can  be used to design  a
 receptor grid to interpret modeling  results in terms of exposure to maximum
 concentrations, and to design a monitoring network focusing on  areas of
 greatest concern.
 'Step 2 - Select APA Sophistication Level                          :
      Next,  the level of sophistication to be employed  in the analysis is
 decided.  Modeling procedures will usually begin with  a screening model.
 Steps to refine the analysis are taken only if screening results indicate
 unacceptable concentrations.  For most Superfund sources,  the Industrial
 Source Complex (ISC) model, in its short-term (ISCST)  or long-term (ISCLT)
 version, is directly applicable.  This model  can be  run in  a screening mode
 for short-term predictions.  An updated version of EPA's screening procedures
 for point sources  contains a computerized SCREEN model  that can also be
 applied to Superfund sources.  The choice of APA model  sophistication level
 depends on what levels of detection  will  provide the site  manager with
 meaningful  information, and what lead time is acceptable.
 Step 3 - Develop an APA Protocol
      A APA employing modeling should be documented in  a protocol  that
 describes how the  analysis will be carried out.   The protocol  should show
 what sources will  be modeled and how emissions will  be calculated.   Source
 characterization,  including sizes and initial  dispersion for area sources,
 and stack parameters for point sources, should be specified.   Other important
 topics for the protocol are selection of meteorological  data,  specification
 of a receptor grid, choice of model, a detailed list of model  options, and
 background concentrations.
 Step 4 - Conduct the APA
      This step involves carrying out the selected APA  through modeling or
 monitoring or a combination of the two.  Qualified personnel  must conduct the
 APA to ensure that all  QA/QC elements of the monitoring plan are followed and
.that APA results are reported and displayed.   Modeling  results  can be used to
 generate isopleths of concentrations around a site.  Superimposing isopleths
 on a site map is a useful  way to display results.
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 Step  5  -  Summarize  and  Evaluate  Results
      Monitored  and  modeled  concentrations need to be evaluated to determine
 1f  critical  concentrations  might be exceeded during remediation.  If an
 emergency condition could cause  offsite populations to be jeopardized or to
 experience undesirable  exposures, a contingency contingency monitoring
'program is justified.                                            :
 3.2.2  Using Health Assessments
      A  second method for determining  a need for contingency monitoring is a
 health  assessment.    The ATSDR  was originated to implement the
 health-related  sections of  CERCLA 1980, as amended.  The primary vehicle for
 meeting this mandate is the health assessment.  When a health assessment is
 carried out concurrent  with an RI/FS, it may help to establish the need for a
 contingency plan  and air monitoring program to protect offsite populations.
 Nature  of a Health  Assessment--
      An ATSDR Health Assessment  is an analysis and statement of the public
 health  implications of  the  facility or release under consideration.  ATSDR
 Health  Assessments  are  based on  factors such as the nature, concentration,
 toxicity,  and extent of contamination at a site, the existence of potential
 pathways  for human  exposure, the size and nature of the community likely to
 be  exposed,  and any other information available to ATSDR that is relevant to
 a determination of  potential risks to public health.  This analysis and
 attendant health  recommendations are  based on professional judgments and the
 weight  of evidence.  In this respect, Health Assessments are similar to the
 Hazard  Identification step  of risk assessment.
      Basically, every Health Assessment includes the following six steps
 (Figure 15):
      1.    Evaluate  information on the site's physical, geographical,
           historical and operational  setting, and identify health concerns of
           the affected  community(ies).
      2.    Determine  contaminants  of concern associated with the site.
^     3.    Identify  environmental  pathways.
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                                   Evaluation of
                                  Site Infonrwtfon
                                  Determination of
                              Contaminants of Concam
                                 Identification and
                                   Evaluation of
                               Environmental Pathways
                                       1
                                 Identification and
                                   Evaluation of
                              Human Exposure Pathways
       CHmate
      Sol Types
Hydrogeotogic Information
     Surface Cover
      Land Use
      Water Use
    StteAccesslMity
                                  Determination of
                              Public Health Implications
                               Recommendations and
                                   Conclusions
Figure 15.   Factors influencing  the Health Assessment  Process.
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      4.    Identify human exposure pathways.

      5.    Determine public health implications  based  on  available  medical  and
           toxicological  information.

      6.    Determine conclusions and  recommendations concerning "the health
           threat posed by the site.

      A Health Assessment is written  for the  "informed community  associated
 with the site",  which would include  citizen  groups, local  leaders, health
 professionals, and other government  agencies (e.g., EPA,  State health
 agencies,  and environmental agencies).   As more complete information is
 collected and evaluated, the conclusions and recommendations  of  the health
 assessment may be modified or altered to reflect the  public health
 implications of additional information.  Note that  an RPM or  OSC may request
 a health assessment from ATSDR.
      Both Comprehensive Environmental Response, Compensation, and  Liability
 Act (CERCLA), as amended by Superfund Amendments and  Reauthorization Act
 (SARA),  and the RCRA, as amended by  the Hazardous Solid  Waste Amendments of
 1984, permit concerned parties to petition ATSDR to conduct a Health
 Assessment.  ATSDR has promulgated regulations  on the petitioned health
 assessment process (42 CFR Part 90).   These  regulations  were  published for
 comment in 53 Federal Register 32259-32263,  24  August 1988.

 Difference Between Health Assessments and Risk  Assessment--
      Deliberate differences exist between ATSDR's Health Assessments and
 EPA's Risk Assessments.   The two agencies have  distinct  purposes that
 necessitate different goals for their assessments.  Risk Assessments include
 one or more of the following components:  hazardous  identification,
 dose-response assessment, exposure assessment,  and  risk  characterization.
 Statistical and biological models are used in quantitative and
 compound-oriented risk assessments to calculate numerical  estimates of risk
 to health using data from human epidemiologic investigations  (when available)
 and animal toxicology studies.  The  product  of  quantitative risk assessment
 is a numerical estimate of the public health consequences of  exposure to an
_agent.  EPA Risk Assessments are used in risk management decisions to
 establish cleanup levels; set permit levels  for discharge, storage, or
 transport or hazardous waste;and determine allowable  levels of contamination.
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     Health Assessments conducted by ATSDR use the components of risk
assessment that stress the hazard identification component.  Although Health
Assessments may use quantitative data, they are usually qualitative in
nature, focus on medical and public health perspectives associated with a
site, and discuss sensitive populations, toxic mechanisms, possible disease
outcomes, and especially community health concerns.  Based on the Health
Assessment findings, health advisories or additional health studies may be
initiated.27
     Thus, while a Risk Assessment conducted under EPA's RI/FS process might
lead to the selection of a particular remediation measure at a site, an ATSDR
Health Assessment may be used by local health professionals and residents to
understand the potential health threats posed by a specific waste site and
may lead to further health actions or studies.  One example of an action in
response to a health assessment could be a contingency plan and air
monitoring program.

3.3  DESIGNING A CONTINGENCY AIR MONITORING NETWORK
     The objective of a contingency air monitoring plan is to document the
                                                             pC
design specifications for a site-specific monitoring program.    The plan
should be submitted for agency technical review and RPM/EPM approval.
According to NTGS, Volume 4, developing a site monitoring plan involves the
following major elements as illustrated in Figure 16.
     o    Select the air monitoring constituents
     o    Specify the time frame for decisions
     o    Specify the meteorological monitoring constituents
     o    Design the air monitoring network
     o    Document the air monitoring plan.
     Contingency air monitoring is likely to be one component of a
comprehensive air monitoring plan at a site.  Thus many principles of a broad
program also apply to contingency monitoring.  This section, however, will
emphasize the part of the plan that is to protect offsite populations.
3.3.1  Select Air Monitoring Constituents
     The selection of compounds to be addressed in a monitoring program is a
challenging task because of the extensive number of potential contaminants at
Superfund sites.  Technical  limitations and budget limitations generally
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       Input Data
      EPA Guidance
                              Select
                           Air Monitoring
                            Constituents
                               i
                             Specify
                          Meteorological
                       Monitoring Parameters
  Monitoring
 Constituents
  Target List  -
Other Technical
   Guidance
                           Design Air
                        Monitoring Network
                          Document Air
                         Monitoring Plan
                               T
                      CONDUCT MONITORING
Figure 16.  Development of a  (Contingency) Air Monitoring  Plan.
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 necessitate the selection of a limited subset of target compounds.   Selection

 of target contaminants involves the following factors:

      o    Physical and chemical properties of chemicals (e.g.,  physical
           phase, volatibility, and water solubility)

      o    Potential health effects of the chemicals (usually based  on risk
           assessment)                                            :

      o    Estimated air concentration of a contaminant  relative to  other
           source constituents

      o    Availability and performance of standard sampling and analysis
           methods

      o    Project objectives

      o    Resource constraints.

      Compounds included in the Hazardous Substances List (HSL)  developed by
 EPA for the Superfund program are listed in the NTGS, Volume IV.  This list
 is a composite of the Target Compound List (TCL) for  organics and the Target
 Analyte List (TAL) for inorganics.  Thus the HSL represents a comprehensive
 list of compounds from which target air toxics compounds can be selected for
 a particular site.

      Emission rate measurements,  air modeling results,  air monitoring data
 from the site, and ARARs identified during previous studies should  be used to

 identify target compounds for air monitoring.  In order to rank the relative

 importance of compounds, a hazard index (HI) should be  calculated.   HI is the

 ratio of the estimated (expected) concentration divided by the  appropriate
 health-based action level.  HI values should be ranked  from highest to lowest
 to develop a priority list of candidate target compounds.   Compounds selected

 for air monitoring should be a function of the estimated HI,  and  the
 technical  feasibility of collecting and analyzing the various compounds.

      The target compound list should be periodically  reevaluated, and revised
 if warranted,  as monitoring results become available.   This is  particularly

 useful  for air monitoring programs conducted during remedial  actions.
 Periodically (e.g., monthly), a more comprehensive list of compounds may be

•sampled and analyzed to confirm the representativeness  of the routine target
 compound list.
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 3.3.2  Specify Meteorological  Constituents

      A meteorological  monitoring program should  be  an  integral  part of a
 contingency air monitoring program.   A meteorological  survey can be used to

 design the air monitoring network based on  local  wind  patterns.-
 Meteorological data can be used for  the interpretation of downwind air

"concentration data and exposure conditions  offsite.
      The required number and location of meteorological  stations depends on

 local terrain.  One meteorological station  is generally sufficient for
 flat-terrain sites.  For complex-terrain sites,  multiple stations may be
 necessary to represent major onsite/offsite air  flow paths.   Generally, one
 to three stations will be sufficient.  Meteorological  stations  should be

 located away from any nearby obstruction at a distance equal to at least 10

 times the height of the obstruction.
      Meteorological monitoring parameters can be classified  as  follows:

      o    Primary parameters
                Wind direction
                Wind speed
                Sigma theta (horizontal wind direction  standard  deviation,
                which is an indicator of atmospheric stability)

      o    Secondary parameters
                Temperature
                Precipitation
                Humidity
                Atmospheric pressure

      Primary parameters are representative of site dispersion conditions and

 should be included in all meteorological monitoring programs.  Secondary

 parameters are representative of emission conditions and are generally only

 recommended for refined air monitoring activities.
      Recommended meteorological monitoring system accuracies/resolutions and

 sensor response characteristics are summarized in the  NT6S,  Volume IV.  A
 meteorological survey may be conducted to support air  monitoring network

 design.  It may be necessary, however, to use historical offsite data to
 -estimate seasonal effects for planning purposes  if the air monitoring program

'is scheduled to last for more than a few months.
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 3.3.3  Design the Monitoring Network

      Design of a contingency air monitoring network will  be affected by

 site-specific factors such as source characteristics,  receptor locations,  and

 environmental characteristics, and thus must be decided on a case-by-case

 basis.  Components of the monitoring network design include:    -
,»

      o    Number and location of monitoring station
      o    Probe siting criteria
      o    Program duration and measurement frequency
      o    Sampling and analysis methods
      o    Air monitoring equipment

      The number and location of monitoring stations for an air monitoring

 network depend on the following site characteristics:

      o    Results of APA air dispersion modeling and monitoring

      o    Environmental  characteristics (e.g.,  meteorology, topography, soil
           characteristics)

      o    Receptor characteristics (e.g.,  population centers,  sensitive
           populations, residence locations, and estimated locations of high
           concentrations of air contaminants)

      o    Source characteristics (e.g., type and extent of contamination,
           locations of hot spots)

      o    Siting constraints

      o    Duration of the monitoring program.

      Contingency air monitoring programs that last for 2  weeks or  less

 require some judgment about the placement of monitoring stations and their

 numbers.  Historical meteorological  data would  generally  not provide accurate

 information on the meteorological conditions for the few  days  of sampling  and

 analysis.   A meteorological survey conducted just prior to air monitoring,

 however, can help to identify expected wind patterns and  downwind  sampling

 locations,  and help to characterize  wind direction variability.

 Meteorological forecasts can also be used to deploy air sampling equipment.

      Air monitoring station numbers  and locations are  highly site-specific,

 tiowever, a single downwind stationary monitor is not adequate  to monitor for"

 maximum concentrations.   Placement of air monitoring and  meteorological

 stations must conform to a consistent set  of criteria  and guidance  to ensure

 data comparability and compatibility.   Factors  to be considered  in  the

 placement  of air quality monitoring  stations are:
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      o    Vertical placement above ground
      o    Horizontal spacing from obstructions and obstacles
      o    Unrestricted air flow
      o    Spacing from roads.

      Monitoring duration and frequency depends on the specific "project
 objectives and resources.  A representative number of air samples-should be

 collected during the project to ensure a reasonable data base.  The number of

 representative samples depends on many factors and guidelines for estimating

 the required number are given in NTGS, Volume IV.  The recommendations

 specified in NTGS are based on the following factors:

      o    Augmentation of integrated sampling with continuous monitoring for
           steps that require more detailed data to enhance the data base

      o    The resource requirements for laboratory analysis for organic and
           inorganic compounds

      o    QA/QC requirements such as collocated field and trip blank samples
           and spike samples.

      Selection of air monitoring methods and equipment should be based on a

 number of factors, including the following:

      o    Physical and chemical properties of compounds
      o    Relative and absolute concentrations of compounds
      o    Relative importance of various compounds in program objective
      o    Method performance characteristics
      o    Potential interferences present at site
      o    Time resolution requirements
      o    Cost restraints.

      Various classes of contaminants must be monitored by different methods,

 depending on the compounds and their physical/chemical properties.   One

 factor that affects the choice of monitoring technique is whether the

 compound is a gas, an aerosol, or is adsorbed to solid particles.
      Screening for the presence of highly toxic air constituents involves

 techniques that are rapid, portable, and provide real-time monitoring data.

 Air contamination screening will generally be used to confirm the presence of

 an onsite release.  Quantification of individual compounds is not as
 .-important during screening, however, the technique must have sufficient

"specificity to differentiate hazardous constituents of concern from potential

 interferences, even when the latter are present in higher concentrations.

 Detection limits are usually much higher for screening devices than for
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 quantitative methods,  and  unfortunately, may  be  higher  than  alert  levels

 that are desirable to  employ.   Appendix A contains  the characteristics  of  the

 HNU photoionizer and the organic vapor analyzer for future  reference.   These

 two instruments are commonly used to obtain  real-time rapid monitoring  data.

 This material  was derived from the EPA Standard Operating Safety .Guides,

'Appendix I,  published  in July 1988.                              ;
      Laboratory analytical  techniques provide  identification  of components

 and accurate measurement of concentrations.  Preconcentration and  storage  of

 air samples  will usually be required.  Therefore, refined monitoring

 techniques usually involve a longer analytical time period, more
 sophisticated equipment, and more rigorous  QA  procedures.   Turnaround  time

 for data is  a key factor to evaluate when considering offsite analyses.

 3.3.4  Document the Air Monitoring Plan

      A site-specific air monitoring plan,  including contingency monitoring,

 should be documented to facilitate implementation.   In  addition, EPA requires

 that any project involving environmental measurement must  have a QAPP.   The

 QAPP, which is distinct from any general project  plan,  describes the

 organization of the project and the assignment of responsibility for those

 specific QA/QC activities required to meet  the project  data quality

 objectives (DQOs).  The following is a list of subjects  addressed  in a

 typical QAPP:

      o    Project description
      o    Project organization and responsibility
      o    Facilities,  services, equipment,  and supplies
      o    DQOs for measurements
      o    Sample collection
      o    Sample custody
      o    Calibration procedures
      o    Laboratory analysis procedures
      o    Data management
      o    Recordkeeping and documentation
      o    Internal QC checks
      o    External QA audits
      o    Preventive maintenance
      o    Procedures to assess data quality
.^-   o    Feedback and corrective actions
      o    Quality assurance reports
      o    Review and.approval of QAPP

 Authority for final approval of the contingency  air monitoring plan is with

 the RPM/EPM.
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3.4  CASE EXAMPLE USING REVERSE RISK ASSESSMENT
       This case example uses a hypothetical Superfund site that is a
composite of several real sites.  This example illustrates a procedure that
may be used to determine whether contingency monitoring is needed, and to
determine action levels for a contingency monitoring plan.
     The usual process of risk assessment may be likened to looking down a
gun barrel from the source of emmissions to the receptor.  In this example
the barrel was turned around to look down the barrel from the receptor to the
source of emissions.  To determine whether or not monitoring would be needed
at a remediation site, the following steps were taken:
     1.   At the location of the maximum exposed individual (MEI),  determine
          the maximum concentration of chemicals to which the MEI may safely
          be exposed.
     2.   Conduct dispersion modeling to determine the dilution ratio from
          source to receptor.
     3.   From the dilution ratio, determine the maximum emission rate that
          will allow the MEI to be protected.
     4.   Estimate the average and highest possible emission rates to
          determine whether the maximum emission rate could possibly be
          exceeded.
     If these steps lead to the conclusion that contingency monitoring will
be needed, then alert levels were required as part of the monitoring plan.
These levels were derived from the levels of public protection established in
step 1.
3.4.1  Site Description
     The site was a ten acre square (201.2 by 201.2 meters) that contained
       o
5000 yd  of contaminated soil.  The contaminated zone was an area 91.4 meters
wide and 22.9 meters long located in the middle of the site.  Five volatile
compounds were present in the soil.   These chemicals were benzene,
1-butanol, methylene chloride (MC), methyl ethyl ketone (MEK), and o-xylene.
According to the soil samples taken from the site, these chemicals were
tibmogeneously distributed, with no major hotspots.  The site plan is shown in
Figure 17.  _       _
     The site was bounded on the north by single family residences, bounded
on the east by an apartment complex, and bounded on the west by undeveloped
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                             201.2 m
  Horth
                       <	91.4 m
Contaminated soil   22.9 m
                         100.6 m
           Haul
           road
                                                          201.2 m
            Figure  17.  Example site configuration.


property (a vacant lot and a drainage easement).  A paved public road

bounded the property on the south side.  Across the road from the site was

a partly developed industrial property which was unoccupied.

     This site once contained drums of chemicals.  In a previous removal

action, several hundred drums were removed and the site was capped with a

layer of relatively impervious soil.  Since that time the cap had become
partly contaminated from below. Contaminated soil was the subject of the
remediation action under consideration.  An interesting note from the

previous removal action was that the drums were removed in various stages

of disintegration.  Some were empty.  While the soil sampling procedure did
not reveal any hot spots, there were incomplete records of the disposition

of chemicals from the drums.

     The selected remedial option was excavation and offsite thermal

treatment.  The remediation period was expected to last for two months and
would be carried out during the summer.  On each day of remediation,
removal activities would take place during an 8-hour period.  The sequence
of remediation steps was excavation (and exposure of contaminated soil),
dumping soil onto trucks, and transport down the haul road to exit from the
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site.  Excavation would remove a portion of the soil cap and a portion of
the contaminated soil.  The haul road was 100.6 meters long.  Emissions
from offsite activities were not taken into account in this example because
they did not affect persons next to the site.
3.4.2  Health Protection Levels
                                                                  :
     In an EPA risk assessment procedure  , health protection levels are
determined for the MEI.  The MEI may be a person more or less sensitive to
toxic pollutants than the general public and may or may not live at the
fenceline of the site.  This approach does not address the problem of
meeting ARARs and other standards to be considered (TBCs). The level of
protection is based solely on protecting health.
     In this example, the MEI was assumed to be an adult sensitive to the
effects of pollutants who lived at the fenceline directly north of the
contaminated soils and in the path of prevailing winds.  Selection of this
worst-case MEI assumed that other members of the public would automatically
be protected to a greater degree than the MEI.
     The RPM, or other responsible party, may consult with a toxicologist
to determine the appropriate levels of protection for the MEI.  These
levels are based on potential hazards associated with the chemicals known
to be on the site and the activity patterns and pollutant sensitivity of
the MEI.  These protection levels may be expressed as maximum allowable
concentrations at the location of the MEI.
     In this example, the RPM consulted an EPA toxicologist to determine
health protection levels for the MEI.  The toxicologist used data from the
                                                 28
Health Effects Assessment Summary Tables (HEAST),   as shown in Tables 10
and 11, in his evaluation.  These tables have been abbreviated to show data
for the inhalation route of exposure only, because the oral route does not
apply in evaluating air exposures to volatile organic chemicals.  The HEAST
tables summarize reference doses (RfD) for toxicity due to subchronic and
chronic inhalation exposure, and provide unit risk factors and unit risk
slope values for carcinogenicity due to lifetime exposure.  Chemicals
included in the tables are the subjects of draft documents from various
tjroups within~EPA and may or may not be verified as inputs to the
Integrated Risk Information System (IRIS).
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                  TABLE 10.   HEALTH  EFFECTS SUMMARY TABLE A:
                SUBCHRONIC AND CHRONIC TOXICITY VIA INHALATION
s«
Compound
Benzene
1-Butanol
Methyl ene
chloride
chronic
(RfD)
Methyl
ethyl
ketone
subchronic
(RfD.)
s
Chronic
(RfD)


o-Xylene
subchronic
(RfD )
s

Chronic
(RfD)


Exposure Species
Not listed
Not listed
695 mg/m3 Rat
6 h/day,
5 days/wk
for 2 yrs

o
693 mg/nr Rat
7 h/day,
5 days/wk
for 12 wks
693 mg/m3 Rat
7 h/day,
5 days/wk
for 12 wks
150 mg/m3 Rat
continuous
on days
7-14 of
gestation
4750 mg/m3 Rat
8 h/day,
7 days/wk
for 1 yr
Efects
of
concern


NA




CNS



CNS



Feto-
toxicity



Hepato-
megaly


Reference
dose*
mg/m
(mg/kg-day)


3 (NA)
(9E-l)a




3E-0
(9E-1)


3E-1
(9E-2)


3E+0
(1E+0)



7E-1
(2E-1)


Uncer-
- tainty
factor


100




100



1000



100




100



Calculated using a standard body weight of 70 kg,  a  standard  ventilation  rate

 of 20 m3 /day, and the RfD in M9/m3.
                                       76

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   TABLE 11.  HEALTH EFFECTS SUMMARY TABLE B:  CARCINOGENICITY  VIA  INHALATION
Compound
Benzene
1-Butanol
Methyl ene
chloride
Methyl ethyl
ketone
o-Xylene
Inhalation
exposure
Occupational
Not listed
2000 or
4000ppm
Not listed
Not listed
Tumor Unit risk,
Species site (/ig/m3)"
Human Leukemia A/8.3E-6

Lung/
Mouse liver B2/4.7E-7


Slope
factor, 1
- (mg.kg-day)"1
- 2.9E-2
*
(1.65E-3)a


Calculated using conversion formula from HEAST and unit risk per /*g/m .
     The RfD in HEAST is an estimate of the daily exposure of the human
population that is likely to be without an appreciable risk  of deleterious
effect during a lifetime.  In the case of subchronic RfD (RfDs), it is the
daily exposure during a portion of a lifetime that is without appreciable risk.
The chronic RfD is appropriate for exposures from seven to seventy years in

duration.  The subchonic RfDs is applicable to exposures from two weeks to
seven years.  In this example, both RfD and unit risk factors were prorated

to the actual exposure of the MEI over the period of remediation.
     The unit risk factors in Table 11 are each preceded by a letter code, A,

B, C, or D.  These codes indicate the strength of evidence for

carcinogenicity, as follows:
     Group A -  Human carcinogen
     Group B -  Probable human carcinogen
     Group C -  Possible human carcinogen
     Group D -  Not classifiable
     Group E -  Evidence of noncarcinogenicity

     HEAST suggests that quantitative risk assessments be conducted only for

chemicals in groups A-and B.  The unit risk factor for benzene is coded "A"
                                       77

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and the unit risk factor for methylene chloride is coded "B".  Both these

chemicals are addressed in this reverse risk estimate.
     In general, toxicity is the principal concern in short-term exposure and
carcinogenicity is the principal concern in long-term exposure. . In this
example the time period of concern for both toxicity and carcinogenicity was
*Ke two-month period of remediation; therefore, there was no distinction

between long-term and short-term exposures.
     Note that benzene is not listed on the toxicity table, but is listed on the
carcinogenicity table.  For this reason, the level of protection for benzene

was based on carcinogenicity.  MEK and o-xylene are listed on the toxicity
table, but not on the carcinogenicity table; therefore, the health protection

level was based on toxicity.  MC is listed on both tables; therefore the health
protection level was based on either systemic toxicity or carcinogenicity,
whichever was the more stringent level of protection.  1-butanol does not
occur on either table; therefore, it was not considered for toxicity or

carcinogenicity based protection levels.
     In this example, subchronic reference doses from HEAST were considered

as public protection levels when adjusted to the time of exposure of the MEL
An equation from EPA risk assessment guidance  , page 6-44, applies to
residential exposure of airborne organic vapors via inhalation, as follows:

                    CA = [(IN)(BW)(AT)]/[(IR)(ET)(EF)(ED)]            (1)

where     CA = concentration in air (mg/m )
          IN = intake (mg/kg-day)
          BW = body weight  (kg)
          AT = averaging time  (davs)
          IR = inhalation rate  (m/h)
          ET = exposure time (h/day)
          EF = exposure frequency (days/yr)
          ED = exposure duration (yrs)

     For each chemical (x), the exposure equation was solved for the MEI as

fol1ows:

     CAX - [(INX mg/kg-day)(70  kg)(60 days)]/
                [(0.8 m3/h)(8 h/day)(43 days/yr)(l/6 yr)]

     The value of IN for each  chemical was taken from the HEAST table for
RfD  (Table 10).  Other factors were taken from the Exposure Factors
                                       78

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 Handbook32'  An  inhalation  rate of 0.8 m3/h was used for an adult with an
 average  ventilation  rate  of 20 m3 per day.  Exposure time was eight hours
 per day; this  assumed  that the MEI was located outdoors at the same time
 that  remediation was in progress.  The exposure frequency was 4a days per
 year,  based  on a 60-day remediation period comprised of 43 weekdays (when

-remediation  takes place)  and 17 weekends  (no excavation activity).. The
 exposure duration was 1/6 years (the two-month period of remediation).  The
 body  weight  of an average adult is approximately 70 kg, a standard weight
 used  in  many risk calculations.  The averaging time was 60 days, the planned
 period of  remediation.  Using these data, the resulting health protection

 levels for subchronic exposures to toxic  chemicals were:

      AC(MEK)  -  82.4  mg/m3  (28 ppm)
      AC(o-xylene)   =  91.6 mg/m    (21 ppm)

      Next, protection levels were estimated for carcinogenic chemicals based
 on unit  risk factors.  The  National Contingency Plan allows a maximum
 individual lifetime  risk  (MILR) in the range 10"4 to 10"6 for Superfund sites,
 The point  of departure  is 10"6.   In this  example, a simple and conservative
 guideline  was chosen: 10    risk for each  individual chemical.  Because there
 were  only  two carcinogens,  the risk for all chemicals combined (assuming

 additive effects) was 2xlO"6.
      The following formula  was used for calculating the air concentration
 corresponding to a given  upper-bound  increased lifetime risk:

      CA  =  [(MILR)(BW)(AT)(CON)]/
           [(IR)(ET)(EF)(ED)(SLI)]                                          (2)

 where     CA  = concentration in air  Ug/m )
           MILR = maximum  individual lifetime risk (dimensionless)
           BW  = body weight (kg)
           AT  - averaging  time  (days)
           CON  = conversion factor i^g/mg)
           IR  = inhalation rate  (m /h)
           ET  - exposure time (h/day)
           EF  = exposure frequency  (days/yr)
           ED  = exposure duration  (yrs)                  ,
           SLI  «= slope  factor for inhalation (mg/kg-days)

      For each chemical  (x), the risk equation was solved for the MEI as

 follows:
                                        79

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     CAX - [(10'6)(70 kg)(25,550 days)(103 /*g/mg)]/
     {(0.8 m3)(8 h/day)(43 days/yr)(l/6 yr)[SLIx (mg/kg-days)"1]}

     The value for each SLIX was taken from the respective slope factor in
Table 11. The value of 10"6 for MILR was previously selected for this
example.  The number of days (25,550) represents the number of days in an
entire lifetime.  Other parameter values are the same as used in equation 1.
Using these data, the carcinogens in this example have the following
protection levels:
     CA(Benzene)    - 1345 /*g/m3  (0.4 ppm)
     AC(MC)         - 23,600 Mg/m3  (6.7 ppm)
     The EPA toxicologist was not entirely satisfied with the calculated
protection levels because they only provided average air concentrations over a
two-month period.  The EPA procedures did not address an emission event
that could occur during a single working day.  For this reason, the EPA
toxicologist requested a review of this site by ATSDR, with special attention
to be given to the issue of a short-term health protection level.  An ATSDR
toxicolgist reviewed the data concerning this site provided to him by EPA.
     In addressing the short-term protection level, the ATSDR toxicologist
used data from the NIOSH Pocket Guide to Chemical Hazards.  These data are
reproduced in Table 12 for the chemicals present at the example site.  From
this table he selected the most conservative recommended standard for each
chemical.  Because these values were for a healthy adult male, he then
divided these values by 10 to allow for a sensitive individual.  Using this
procedure, the following 8-h average protection levels were selected:
     CA(benzene)    = 0.01 ppm
     CA(MC)         - 10 ppm
     CA(MEK)        = 20 ppm
     CA(o-xylene)   * 10 ppm
     The following health protection levels for less than one-hour average
exposures were taken from Table 12 and adjusted in the same manner:
     CA(benzene)    = 0.1 ppm, 15 min
~r   CA(MC)         - 100 ppm, 5 min
     CA(MEK) -      --None
     CA(o-xylene)   = 20 ppm, 10 min
                                       80

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                        TABLE 12.  SUMMARY OF RECOMMENDED EXPOSURE LIMITS

1
Chemical name
Benzene
Methyl ene
chloride
MEK (2-butanone)
o-Xylene
1-Butanol

PEL,
ppm
10
500
200
200
Not
listed
OSHAa
PEL ceil-
ling, ppm
50 (10 min)
1000, 2000
(5 min/2 h
peak)
NA
NA
Not listed
NIOSHb
REL,
ppm
0.1 (8 h TWA)
Lowest feas-
ible limit
200 (10 h TWA)
100 (10 h TWA)
Not listed
ACGIHC
REL ceil-
ing, ppm
1.0 (15 min)
NA
NA
200 (10 min)
Not listed
TLV,
ppm
10
100
NA
NA
Not
listed
TLV ceil-
ing, ppm
NA
NA
NA
NA
Not
listed

 Occupation Health and Safety Administration (OSHA) Permissable Exposure Limits (PEL) published in CFR
 1910, Subpart Z. as 8-hour time-weighted averages, unless otherwise noted.  Ceiling values are not to be
 exceeded at any time.

 National Institute of Occupational Health and Safety (NIOSH) recommended exposure limit (REL), listed
 when it is less than the corresponding PEL.
cAmerican Conference of Governmental Industrial Hygienists (ACGIH) threshold limit value (TLV), listed
 when it is less than the corresponding PEL.

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     Table 13 summarizes the public protection levels based on subchronic
toxicity levels, carcinogenicity, and ATSDR recommendations.  Note that the
theoretical ATSDR-recommended protection levels appear to be more conservative
than calculated concentrations based on subchronic toxicity or
carcinogenicity. In addition, they used shorter averaging times of less than a
full day.  Because the ATSDR levels are less than one-day averages",  they could
be used to control day-to-day remedial activities at the site.  Note that if
these levels were always met, the longer-term protection levels would always
be met.

3.4.3  Dilution Ratios

     Two different models were employed to determine three different dilution
ratios for three different averaging times.  The first model, SCREEN, was used
for determining short-term (one-hour and eight-hour) concentrations.  This
model estimated one-hour average air concentrations at various distances from
          29
the source  .  These one-hour estimates were used to approximate 10  or 15
minute peak concentrations because (1) there was no standard procedure for
estimating concentrations less than one-hour average concentrations, and (2)
the health protection levels for averaging times of 15 minutes or less were
already set one order of magnitude less than the lowest recommended  level.
           TABLE 13.  PUBLIC PROTECTION LEVELS FOR THE EXAMPLE SITE,
                               IN ^g/mj AND ppb

Rick assessment,
two-month average
Chemical
Benzene
Methyl ene
chloride
MEK
o-Xylene
Molecular
weight
78
85
72
106
Subchronic
toxicity
None
None
82,400 (28)
91,600 (21)
Carcino-
genicity,
1,300 (0.4)
23,600 (6.7)
None
None
ATSDR
recommendatons
8-hour
30 (0.01)
35,000 (10)
59,000 (20)
43,000 (10)
< 15
minutes
300 (0.1)
350,000 (100)
None
87,000 (20)
                                       82

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 Another conservative estimate,  e.g.,  estimating  a  15-minute  average  higher
 than  a one-hour average,  did not  appear  to  be  in order.
      Unlike most dispersion models, the  SCREEN model does not use
 meteorological  data, but  gives  a  series  of  estimates under different possible
 meteorological  conditions.   The worst meteorological case was used^to show  the
-worst impact that could occur at  this example  site.             "   -
      To determine a dilution ratio for eight-hour  and  less average protection
 levels, a nominal emission  rate of 1  gm/sec was  used in  an extremely simple
 emission scenario.   In this simplified scenario, all emissions  were  assumed to
 be derived from excavation  operations.   (A  more  complicated  and more accurate
 emissions calculation was carried out in a  later step.)  Excavations were
 planned to be carried out at different locations across  the  contaminated zone
 from  day to day, but the  worst  case excavation would occur along the outer
 boundary of the contaminated zone on  the same  day  that worst-case  meteorology
 took  place.   The distance  between the outer edge  of the contaminated area  and
 the closest fenceline (54.9 m), was used for this  worst  case estimate.
 Accurately estimated emission rates from the site  were not needed  at this
 point, because only a normalized  emission scenario (1.0  gm/s) was  required  to
 produce the necessary dilution  ratio.
      A worst-case meteorological  day  consisted of  24 hours at stability class
 D, including the eight hours when remediation  took place.  For  stablity class
 D at  the closest distance (54.9 m) from  source to  MEI, and with a  nominal
 emission rate of 1  g/s, the SCREEN model gave  a  predicted one-hour average
 concentration of 3031 pq/m  . An  estimated  concentration of  3031 /ig/m  divided
 by a nominal  emission of 1.0 gm/s yielded  a  dilution  ratio  of 3031  »g/m  per
 gm/s of emissions.   This dilution ratio was  used  with public  protection levels
 of less than  one hour.
                                    OQ
      According to the SCREEN manual   ,  a ratio  of 0.7 may be  multiplied times
 the one-hour  average to approximate  the average concentration over  a
 eight-hour period.   Thus,  for an  estimated 3031 /^g/m   one-hour concentration,
                                                        3
 the corresponding eight-hour concentration is 2122 »g/m    A concentration of
 2122 A^g/m  divided by a nominal emission of  1.0 gm/s  yielded  a dilution ratio
 of 2122 A»g/m  per gm/s  of emissions.   This  dilution  ratio  was  used  with
 eight-hour average public protection  levels.
                                        83

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      The second model,  ISCLT,  was  used  to  estimate long-term  average
 concentrations.  This model  estimated one-year  average concentrations  based on
 one year of hourly meteorological  data.   In  this example, meteorological data
 from a nearby meteorological  station was used.  A nominal 1 g/s "emission rate
 was used to simulate the  same simplified emissions scenario used  i-n the
'eight-hour case.   A series  of receptors were defined  in the model, -
 corresponding to the points  where  radial lines  from the center of the  site
 crossed the site fenceline.   These radial  lines were  22.5 degrees apart, the
 standard radii used in  the  ISCLT model.  The center of the site was considered
 to  be the location of emissions because it is the average location of
 excavation activities over  the remediation period.
      One year of meteorological values  is  usually used with ISCLT to obtain
 one-year average concentrations at receptors.   In this example, remediation
 was not planned to take place during the whole  year,  but only during June and
 July (summertime).   Thus  the objective was to estimate average concentrations
 over a particular two-month  period.  To obtain  these  estimates, a special
 meteorlogical  year was  constructed to consist of 12 months of summer data
 only.   Because the input  meteorological data were for summer  months only, the
 one-year averages produced  by the  model were considered reasonable estimates
 of  a two-month average  concentration for the June and July period of
 remediation.
      Note that unlike SCREEN,  worst case meteorology  canot be defined  in
 ISCLT.   The worst case  is simply the location of the  receptor providing the
 highest average concentration In  this example, the highest concentration was
 145 ng/m  and it occurred at the 0 degree  radial line (due north) at a
 distance  of 100.6  meters  from  the  center of the  site.  An estimated
 concentration  of 145 /*g/m  divided by  a nominal  emission of  1.0 gm/s yielded  a
                           o
 dilution  ratio of  145 pg/m  per gm/s of emissions.  This dilution ratio was
 used with public protection levels based on long-term  (two-month) carcinogenic
 risks  or  long  term chronic exposure levels.
 3.4.4  Allowable Emissions
     Using the dilution ratios calculated for short-term (15-minute and
 eight-hour)  and long-term (two-month)  protection levels, the maximum
 15-minute,  eight-hour, and two-month average emission  rates were calculated
 for each  chemical.  These calculations were simply the following:
                                       84

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where
           :ha
           'ha
                emission rate allowed for health concern h and
                averaging time a, in g/s

                public protection level for health concern h and  ..
                averaging time a, in
                                                              per
          D,  - dilution ratio for averaging time a, in /*g/m
           a    9/s
     A summary of allowable emissions, as calculated, is shown in Table 14.
Note that the chemical that is most stringently controlled was benzene.  The
most stringent protection level for benzene was a recommendation of National

Institute of Occupational Safety and Health (NIOSH) which was recommended to
the RPM by the ATSDR toxicologist.  This stringent protection level then was
translated into a stringent allowable emission rate.  This was the key
protection level, which determined what contingency plan was required.
           TABLE 14.  ALLOWABLE EMISSIONS AT THE EXAMPLE SITE IN g/s
                         Risk assessment,
                         two-month period
                                                             ATSDR
                                                         recommendations
Chemical
                  Subchronic
                   toxicity
Carcino-
genicity
8-hour
 < 15
minutes
Benzene

Methylene
chloride

MEK

o-Xylene
                    None

                    568


                    568

                    632
    9

  163


  None

  None
0.014

 17


 28

 21
 0.010

  115


  None

  29
                                       85

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3.4.5  Estimated Emissions Versus Allowable Emissions
     A more detailed analysis of emissons showed that the example site
consisted of a number of emission sources, not just one.  Emissions were
generated from digging with a backhoe, dumping dirt into a truck, and
driving the truck down the haul road.  One of the major emissions xame from
the moving truck.  The objective was to estimate emissions from each of these
actvities as accurately as possible and to sum these emissions for the site.
     Emissions were estimated by a complex procedure that is only outlined
here, but is detailed in a separate report  .  In these emission calculations,
area sources are represented as squares.  If a site is rectangular or
irregular in outline, it is represented in the model as a series of squares
having the same area (in square meters) as the actual site.  Thus, for any
one remediation day the area of excavation was represented as a 4x4 meter
square area.  The area of dumping dirt into the truck was represented as
another 4x4 meter square area.  The truck passing down the haul road was
represented as a series of ten squares, each of which was 22 meters on a
side.
     In this example, the rate of emissions of VOCs depended not only on
their concentration in the soil, but  also on characteristics of the soil and
characteristics of the chemicals, especially volatility.  Because MC is
quite volatile and was present in the highest concentration in the soil, it
was found in highest concentration in air emissions.  For the overall
remediation, MC comprised 81.9 percent of VOC emissions, and benzene
comprised 4.9 percent.  The other three compounds comprised the remaining
13.2 percent.  The relative contribution of the five compounds did not
change appreciably during each step  in the remediation.
     A summary of the estimated site  emissions for each chemical species is
shown in Table 15. These estimates are based on an overall VOC emission of
0.299 g/s for an average remediation  day during the two-month remediation
period.  Table 16 lists the highest  estimate of the average emission for each
chemical over the two-month period (from Table 15) and the most stringent
public protection level over the two-month remediation period  (from Table 14).
-Table 16 then-lists the estimated eight-hour average emissions and the
eight-hour allowable emission  (based  on the recommended eight-hour
                                        86

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                             TABLE  15.  SUMMARY OF AVERAGE AIR EMISSIONS DURING REMEDIATION
00
-vj

Soil cap
Chemical ,
Benzene
1-Butanol
i
Methyl ene chloride
Methyl ethyl ketone
o-Xylene
Emission
fraction
0.1737
0.0049
0.5815
0.0218
0.2181
Emission,
g/s
0.052
0.001
0.174
0.007
0.065
Contaminated soil
Emission
fraction
0.0407
0.0052
0.8374
0.0911
0.0256
Emission,
g/s
0.012
0.002
0.250
0.027
0.008
All excavations
Emission
fraction
0.0495
0.0052
0.8191
0.0857
0.0404
Emission,
g/s
0.015
0.002
0.245
0.026
0.012

TABLE 16.
COMPARISON OF DAILY AVERAGE
EMISSIONS WITH ALLOWABLE
EMISSIONS IN
g/s

Chemical
Benzene
Methyl ene chloride
Methyl ethyl ketone
o-Xylene
Two-month
Estimated
0.052
0.250
0.027
0.065
average
Allowable
risk
9
163
None
None
Eight-hour
Estimated
0.156
0.750
0.081
0.195
average
Allowable
risk
0.014
17
28
21
< 15
minutes
A1 1 owabl e
Estimated3 risk
(0.156)
(0.750)
(0.081)
(0.195)
0.35
6.17
0.87 ,
i. '
2,030 '

      Estimated 15-minute emissions are  the  same  as  8-hour emissions  because  of constraints  of methodology.

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 protection  level).   It  also  lists the estimated 15-minute estimated emissions
 and  allowable  emissions.  The  15-minute emissions are the same as eight-hour

 emissions because the estimation methodology did not allow for a time
 discrimination of less  than  eight hours.  According to the data_in Table  16,
 each emission  is well below  its respective public protection level, except  in
;the  case of the eight-hour benzene  emission.   Based on these data, a
 contingency plan for this remediation would be needed and control measures

 carried out during  the  remediation  process.
      While  an  analysis  based on the available  data showed that remediation
 could proceed  (with control  measures), the site manager  questioned whether
 the  available  information was  suffient.   Soil  sampling showed no hot  spots,
 but  he questioned whether the  number of  samples was sufficient to discover  a
 hot  spot  in a  unexpected location.   In this example, the site manager opted to
 analyze  a worst-case scenario  in which an unknown hot spot might exist.
 Such a hot  spot could  be caused by  someone dumping benzene and other
 chemicals  into a temporary pit and  then  covering  it so that no evidence  of

 this pit was visible on the  surface of the ground.
      Benzene has  been  found  in concentrations  above 30,000 ppm in  soil.
 Using the  same emission estimation  methodology used for  the average
 remediation day,  emissions due to  excavation,  dumping, and hauling of soil
 with 30,000 ppm benzene were estimated.   According to this procedure,  this
 worst-case  scenario would  result  in an  air emission of 0.186  g/s of  benzene

 averaged over a eight-hour  period.
      The worst case excavation due to  an unknown  hot  spot would produce
 benzene emissions  in considerable  excess of the allowable emisssion  rates for
 public protection.   The site manager judged  that  this possible, even  if  it  was
 not a high  probability, which further  justified a contingency plan  using air
 monitoring  to protect offsite populations.   Because the  surrounding  community
 was very sensitive to operations  at the  site,  the contingency plan was
 intended to provide a margin of  safety and reassurance  to the community.
 The site manager proceeded  to prepare  a  simple plan to  address daily
 operations  and the worst-case contingency.

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3.4.6  Contingency Plan Alert Levels
     One principal in setting contingency plan alert levels is that the
averaging time of an alert level must match the averaging time used in
real-time monitoring.  In this example, estimated ambient concentrations that
corresponded to a 10   risk of cancer had been adopted as the level of
protection for the public over the two-month period of remediation*.  An
eight-hour recommended standard was also adopted to control daily
remediation operations.  This meant that when an eight-hour instrument
reading at the fenceline (near the MEI) implied an excursion of the allowable
emission rate, the remedial process was to be stopped or slowed down until
the instrument reading dropped below the alert level.  Thus, while there
could be one-hour excursions above the alert level, it is unlikely that a
eight-hour protection level would be exceeded or that a 10   risk level would
be exceeded over a two-month period.
     The key public protection level is 30 ug/m  (0.01 ppm) benzene, based
on recommendations from NIOSH.  This is below the 2.0 ppm level of detection
for a total organics monitor, the instrument frequently used for real-time
detection of ambient VOCs in the field.  As a matter of practicality, the alert
level must be set to 2 ppm of VOC at the fenceline.  An argument could be
made that a lower alert level would be justified in case the VOC were
comprised solely of benzene, however, the chosen alert level is the lowest
level that can be implemented due to the limits of technology.
     One approach is to back-calculate from the emissions rate and dilution
ratios to determine the exact downwind distance from the source that will
register 2 ppm on a monitor when the fenceline concentration is 0.01 ppm.
The monitor can then be placed at this location rather than at the fenceline.
A procedure for doing this has not yet been specified.
     Note that the standrd 10.2 eV photoionization detector (PID) lamp on
commonly used instruments will not detect methylene chloride, a compound
that is likely to be emitted from this example site.  Either and 11.7 eV PID or
a flame ionization detector (FID) could be used to solve this problem.
     Emission control measures at the site consisted of spraying foam onto the
.soil being excavated and using foam and a tight-fitting tarpaulin over the soil
being carried down the haul road.  These measures were estimated to reduced
emissions well below the eight-hour allowable emissions.
                                       89

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      The  contingency plan to protect  the  public  consisted  of  the  following

 rules:

      1.    A wind direction instrument is  to  be  installed just outside  the hot
           zone.

      2.    At the beginning of each day of remediation,  a portable "HNU  will  be
^' •        placed at the fence!ine downwind from  the  area to be excavated that
           day.   This procedure was an added  protective  measure, to  ascertain
           the highest impact regardless of whether it actually affected the
           MEI.

      3.    At two-hour intervals,  wind direction  will  be checked and the
           location of the HNU adjusted as necessary  to  be  downwind  of
           excavation.

      4.    At hourly intervals,  the HNU will  be  checked  for the latest
           one-hour average reading.

      5.    If an  exceedance is detected, it will  be reported to the  site manager
           for action under item 6 below.

      6.    When a reading above 2 ppm  occurs,  excavation of soil and truck
           hauling must stop.  Continuous  HNU readings will be taken at the
           fenceline until three continuous readings  at  10-minute  intervals
           indicate ambient concentrations below  the  alert  level.  At this point,
           excavation may proceed at a rate of one-half  the previous rate of
           excavation.  If the  alert  level is not exceeded during a 30-minute
           period, the original  rate of excavation may be resumed.
                                        90

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                                SECTION 4
                               REFERENCES


 1.   Roe,  David.   What Kind of Data Does the Public Need:  A Forum.  EPA
     Journal, Volume 5, Number 3, May/June 1989.

 2.   U.S.  Environmental Protection Agency Region VII.  Castlewood
     Site-Specific Air Monitoring Plan.  March 17, 1987.

 3.   Hudson, Jody L.  Castlewood Site 2,3,7,8-TCDD Air Monitoring Summary
     Report.  1987.

 4.   Kahn, Peter R.  Ambient Air Sampling Results During a CERCLA Removal
     Action, Chesnutis Superfund Removal Site, Beacon Falls, CT.  Memorandum
     to Dean Tagliaferro, July 27, 1989.

 5.   Aungst, Nancy, Ecology and Environment, Inc.  Background Information on
     Hyde Park Landfill.  (FAX) February 22, 1990.

 6.   Hyde Park, R02-86/038, Abstract of the Record of Decision, November 26,
     1985.  Listed from the EPA RODs data base, February 16, 1990.

 7.   ERT,  Special Construction Activities - Part II Air Monitoring Plan for
     Hyde Park Landfill, Niagara Falls, New York.  Prepared for Occidental
     Chemical Company, May 1988.

 8.   Work Plan for Buried Drum Removal, Maryland Sand, Gravel and Stone Site,
     Elkton, Maryland.  Prepared for Clean Sites Inc. by GSX Services Inc.,
     July 7, 1989.

 9.   Ludzia, Peter J.  Maryland Sand, Gravel, and Stone Excavation Criteria,
     Memorandum to File, February 6, 1990.

10.   McKin Site ROD.  Memorandum from Superfund Implementation Group,
     Department of Health and Human Services, ATSDR to John Figler, EPA
     Region I, August 1, 1985.

11.   Webster, David W.  Pilot Study of Enclosed Thermal Soil Aeration for
     Removal of Volatile Organic Contamination at the McKin Superfund Site,
     Journal of the Air Pollution Control Association, Vol. 36, No. 10,
     October 1986, pp. 1156-1163.

JL2.   U.S.  Environmental Protection Agency, Site Safety Plan Nyanza Vault
     Site.  (Revised)  September 28, 1987.
                                      91

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13.  DiSirio, Marilyn R.  Agency for Toxic Substances and Disease Registry,
     Memorandum to Frank W. Lilly, On-Scene Coordinator, U.S. Environmental
     Protection Agency, Region I, Re:  Nyanza Hazardous Waste Site Soil Data:
     Vault, April 10, 1987.

14.  U.S. Environmental Protection Agency, Region I Environmental Services
     Division, Ambient and Health and Safety Air Sampling Plan."  -Nyanza Vault
     Site Ashland, Massachusetts.  October 1987.

15.  Kahn, Peter R.  Results of Ambient and Health and Safety Air Sampling
     Study Nyanza Vault Site Ashland, Massachusetts, U.S. Environmental
     Protection Agency, Region I, Environmental Services Division.

16.  Kahn, Peter R.  Results of Ambient and Health and Safety Air Sampling
     Study Second Round Nyanza Vault Site Ashland, Massachusetts, U.S.
     Environmental Protection Agency, Region I, Environmental Services
     Division.

17.  Firless, B. J., D. I. Bates, J. Hudson, R. D. Kleopfer, T. T. Holloway,
     D. A. Morey, and T. Babb.  Procedures used to measure the Amount of
     2,3,7,8-TCDD in the Ambient Air Near a Superfund Site Cleanup Operation.
     Environmental Science and Technology, Vol. 21, p. 550, June 1987.

18.  Ambient Air Monitoring Program During Remedial Action, Vertac Chemical
     Corporation Plant Site, Jacksonville, Arkansas.  Prepared for IT
     Corporation by EMI Consultants, March 19, 1986.

19.  Site Assessment Report for Weatherford Residence.  Prepared for EPA
     Region VI Emergency Response Branch by Ecology and Environment, Inc.,
     June 20, 1989.

20.  Health Consultation:  Mr. Robert Weatherford Residence, Jacksonville,
     AR.  Memorandum from Senior Public Health Advisor - ATSDR/EPA-6 to Mr.
     David Gray, OSC, Emergency Response Branch, EPA Region VI, April 18,
     1989.

21.  Quality Assurance Project Plan for Air Monitoring at Weatherford
     Residence and Jacksonville Crane Site.  Prepared for U.S. Environmental
     Protection Agency, Region VI, by Ecology and Environment, Inc., April
     19, 1989.

22.  29 Code of Federal Regulations Chapter 17, Section 1910.120, Hazardous
     Waste Operations and Emergency Response, July 1, 1989.

23.  Protecting Health and Safety at Hazardous Waste Sites:  An Overview.
     EPA 625/9-85-006, U.S. Environmental Protection Agency, September 1985.

24.  Field Standard Operating Procedures (FSOP) #9 Site Safety Plan.  U.S.
     Environmental Protection Agency Office of Emergency and Remedial
     Response, Washington, D.C., April 1985.

25.  A Compendium of Superfund Field Operations Methods.  EPA/540/P-87/001,
     Office of Emergency and Remedial Response, U.S. Environmental Protection
     Agency, Washington, D.C., December, 1987.
                                      92

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26.  Procedures for Conducting Air Pathway Analyses for Superfund
     Applications, Volumes I through IV EPA-450/1-89-001 through
     EPA-450/1-89-004, July 1989.
27.  Health Assessment GUIdance--Information transmitted by Dr. Mike Allred,
     ATSDR, to Roy Paul, PEI Associates, Inc., February 1990.

28.  U.S. Environmental Protection Agency, Health Effects Assessment Sumamry
     Tables Third Quarter 1989.  OERR 9200.6-303(89-3), July 1989;

29.  Brode, Roger W.  Screening Procedures for Estimating the Air Quality
     Impact of Stationary Sources.  EPA 450/4-88-010 Technical Support
     Division, OAQPS, U.S. Environmental Protection Agency.  August 1988.

30.  U.S. Environmental Protection Agency, Risk Assessment Guidance for
     Superfund Volume I Human Health Evaluation Mnual (Part A).
     EPA/540/1-89/002, Office of Emergency and Remedial Response, Washington,
     D.C., December 1989.

31.  U.S. Department of Human and Health Services.  NIOSH Pocket Guide to
     Chemical Hazards.  National Institute of Occupational Health and Safety.
     September 1985.

32.  U.S. Environmental Protection Agency.  Exposure Factors Handbook.
     EPA/600/8-89/043.  Office of Health and Environmentla Assessment.  July
     1989.

33.  U.S. Department of Health and Human Services.  NIOSH Pocket Guide to
     Chemical Hazards.  NIOSH Pub. No. 85-114.  National Institute for
     Occupational Safety and Health.  September 1985.

34.  PEI Associates, Inc.  Development of Example Procedures for Evaluating
     the Air  Impacts of Soil Excavation Associated with Superfund Remedial
     Actions.  Prepared under Contract No. 68-02-4394, Work Assignment 38.
     July 1990.
                                      93

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               |(*) The use of any trade names does  not imply their
                  endorsement by the U.S. Environmental Protection Agency.
I
                            APPENDIX A

             CHARACTERISTICS OF THE HNU PHOTOIONIZER

                               AND

                      ORGANIC VAPOR ANALYZER
I.   INTRODUCTION

     The HNU Photoionizer* and the Foxboro Organic Vapor Analyzer*
     (OVA) are used in the field to detect a variety of compounds
     in  air.   The  two  instruments differ  in  their modes  of
     operation and in the number and types of compounds  they detect
     (Table 1-1).  Both instruments can be used to detect leaks of
     volatile  substances  from drums  and  tanks,  determine  the
     presence of volatile compounds in soil and water, make ambient
     air surveys, and collect continuous air monitoring data.  If
     personnel are thoroughly  trained  to operate the  instruments
     and to interpret the data, these instruments can  be valuable
     tools for helping  to decide  the levels  of  protection to be
     worn,  assist in  determining other  safety  procedures,  and
     determine subsequent monitoring or sampling locations.


II.  OVA

     The OVA operates in two different  modes.  In the survey
     mode, it can determine approximate total'concentration of all
     detectable  species  in air.   With the gas chromatograph (GC)
     option, individual  components can be  detected  and measured
     independently,  with some detection  limits  as low as  a few
     parts per million (ppm).

     In the GC mode,  a small sample of ambient air is injected into
     a chromatographic column and  carried through the  column by a
     stream of hydrogen gas.  Contaminants with different chemical
     structures  are  retained on the column for different lengths
     of  time (known as  retention times) and hence  are detected
     separately  by the  flame ionization detector.  A  strip chart
     recorder can be used to record the retention times, which are
^    then compared to the retention times of a standard with known
~C    chemical constituents.  The sample can either be injected into
     the  column  from the  air  sampling  hose or injected directly
     with a  gas-tight syringe.
I
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ACTION
Response
x-'" .
Application

Detector
Limitations
Calibration gas .
Ease of
operation
Detection limits
Response time
Maintenance
Useful range
Service life




TABLE 1-1
COMPARISON OF THE OVA AND
OVA
Responds to many organic gases
and vapors.
In survey mode, measures total
concentration of detectable
gases and vapors. In GC mode,
identifies and measures
specific compounds.
Flame ionization detector (FID)
Does not respond to inorganic
gases and vapors. Kit available
for temperature control.
Methane
Requires experience to inter-
pret correctly, especially
in GC mode.
0.1 ppm (methane)
2-3 seconds (survey mode)
for CH4
Periodically clean and inspect
particle filters, valve rings,
and burner chamber. Check
calibration and pumping
system for leaks. Recharge
batteries after each use.
0-1000 ppm
8 hours; 3 hours with strip
chart recorder.


95

HNU
HNU
Responds to many organic
and some inorganic gases
and vapors.
In survey mode, measures
total concentration of
detectable gases and
vapors .
Photoionization detector
(PID)
Does not respond to
methane. Does not detect
a compound if probe has a
lower energy than
compound's ionization
potential.
Isobutylene
Fairly easy to use and
interpret .
0.1 ppm (benzene)
3 seconds for 90% of
total concentration of
benzene .
Clean UV lamp frequently.
Check calibration
regularly. Recharge
batteries after each
use.
0-2000 ppm
10 hours; 5 hours with
strip chart recorder.




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     In the survey mode,  the OVA is internally calibrated to
     methane by the manufacturer.  When the instrument is adjusted
     to  manufacturer's  instructions   it  indicates  the  true
     concentration of methane  in air.  In  response  to all other
     detectable compounds,  however,  the instrument reading may be
     higher or  lower  than  the true  concentration. * Relative
     response  ratios  for   substances   other   than   methane  are
     available.

     To correctly  interpret the readout, it is necessary to either
     make calibration charts relating the  instrument readings to
     the true  concentration or to adjust the instrument so that it
     reads correctly. This  is  done  by  turning the ten-turn gas-
     select knob,  which  adjusts the response of the instrument.
     The knob  is normally set at 3.00 when calibrated to methane.
     Calibration   to  another gas  is done by  measuring a known
     concentration of a gas and adjusting the gas select knob until
     the instrument reading equals  that concentration.

     The OVA has an inherent limitation in that it can detect only
     organic  molecules.     Also,  it  should  not   be  used  at
     temperatures  lower than about  40  degrees  Fahrenheit because
     gases condense  in the pump and  column.    It  has  no column
     temperature  control,  (although temperature control kits are
     available)  and  since  retention  times  vary  with ambient
     temperatures  for a  given column,  determinations of contam-
     inants are difficult.   Despite these limitations, the GC mode
     can often provide tentative information on the identity of
     contaminants  in  air  without relying on costly,  time-consuming
     laboratory analysis.
III. HNU
     The HNU portable  photoionizer detects the  concentration of
     organic gases as  well  as a few inorganic gases.   The basis
     for detection is  the ionization of gaseous species.   Every
     molecule has  a characteristic  ionization potential  (I.P.)
     which is the energy  required  to remove an electron from the
     molecule,  yielding  a  positively  charged ion  and  the  free
     electron.    The   incoming  gas  molecules are  subjected  to
     ultraviolet  (UV)  radiation,  which is energetic  enough  to
     ionize many gaseous compounds.  Each molecule is transformed
     into  charged ion pairs,  creating  a current  between  two
     electrodes.

     Three probes, each  containing a different UV  light source,
     are available for use with the HNU.  Ionizing energies of the
     probe are 9.5,  10.2,  and 11.7  electron volts (eV).  All three
     detect many  aromatic and large molecule  hydrocarbons.   The
                              96

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     10.2  eV and 11.7  eV probes,  in addition, detect some  smaller
     organic molecules and some halogenated hydrocarbons. The 10.2
     eV probe is the most useful  for environmental  response  work,
     as the lamp's service life is longer than the 11.-7 eV  probe
     and it detects more compounds than the  9.5 eV  probe^

     The  HNU  factory  calibration  gas  is  benzene.    The  span
     potentiometer (calibration)  knob is turned to 9.8 for  benzene
     calibration.  A knob setting of zero increases the response
     to benzene  approximately tenfold.   As  with the  OVA,  the
     instrument's response can be adjusted to give more accurate
     readings for specific gases and eliminate the necessity for
     calibration charts.

     While  the  primary  use  of  the  HNU is  as  a quantitative
     instrument,  it  can  also  be   used   to  detect   certain
     contaminants,  or   at   least   to  narrow  the   range   of
     possibilities.  Noting instrument response to a  contaminant
     source with different probes can eliminate some  contaminants
     from  consideration.   For instance, a  compound's  ionization
     potential may be  such  that the  9.5  eV probe  produces  no
     response, but  the  10.2  eV  and 11.7 eV probes  do elicit  a
     response.   The  HNU does  not detect  methane or  inorganic
     compounds.

     The HNU is easier to use than  the OVA.  Its lower detection
     limit is also in the low ppm  range.   The response  time is
     rapid;  the  meter  needle  reaches  90%  of   the  indicated
     concentration in 3 seconds for benzene.  It can  be zeroed in
     a contaminated atmosphere and does not  detect  methane.
IV.  GENERAL CONSIDERATIONS

     Both of these instruments can monitor only certain vapors and
     gases  in air.    Many  nonvolatile liquids,  toxic  solids,
     particulates, and  other toxic  gases and  vapors cannot  be
     detected.  Because  the  types  of compounds that  the  HNU and
     OVA  can potentially  detect  are  only  a  fraction  of  the
     chemicals possibly present at an incident,  a zero reading on
     either instrument does not necessarily signify the absence of
     air contaminants.

  ^  The  instruments are  non-specific,  and their   response  to
     different compounds is  relative  to the  calibration setting.
     Instrument  rea.dings may be  higher or  lower  than the  true
     concentration.  This can be an especially serious problem when
     monitoring for  total  contaminant  concentrations  if  several
     different compounds are  being detected at once.  In addition,
     the  response  of these  instruments is  not linear over the
                               97

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entire detection range.   Care must therefore be  taken when
interpreting the data.  All identifications should be reported
as tentative  until they  can be  confirmed  by more  precise
analysis. Concentrations should be reported  in terms of the
calibration gas and span  potentiometer  or  gas-select-knob
setting.

Since the OVA and  HNU  are  small,  portable instruments, they
cannot be expected to yield results as accurate as laboratory
instruments.  They  were originally  designed  for  specific
industrial applications. They are relatively easy to use and
interpret when detecting total concentrations of individually
known  contaminants  in air,  but  interpretation  becomes
extremely difficult when trying  to quantify the components of
a mixture.  Neither instrument can be used as an indicator for
combustible gases or oxygen deficiency.

The OVA (Model 128) is  certified by Factory Mutual to be used
in Class I,  Division 1,  Groups A,B,C, and D environments.  The
HNU  is certified  by  Factory Mutual  for use  in Class  I,
Division 2, Groups, A, B,  C,  and D.
                           98

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                                        TECHNICAL REPORT DATA
                                 (Pleat nod Instructions on the reverse before completing)
    1. REPORT NO.
        EPA-450/1-90-005
                                                                  3. RECIPIENT'S ACCESSION NO.
    4. TITLE AND SUBTITLE
            Contingency  Plans  at Superfund Sites Using
            Air Monitoring
                                                                  5. REPORT DATE
                                                                        September  1990
                                                             6. PERFORMING ORGANIZATION CODE
    7. AUTHOH(S)
               • Roy  Paul
                                                             8. PERFORMING ORGANIZATION REPORT NO

                                                                 DCN 90-203-080-61-02
                                                                  10. PROGRAM ELEMENT NO.
                                                                           61
9. PERFORMING ORGANIZATION NAME AND ADDRESS

        PEI Associates,  Inc.
        11499 Chester  Road
        Cincinnati, Ohio   45246
                                                                  11. CONTRACT/GRANT NO.


                                                                          68-02-4394
    12. SPONSORING AGENCY NAME AND ADDRESS
            U.S. Environmental  Protection Agency
            Region VIII
            999 18th Street,  Suite 500, One Denver Place
            Denver, Colorado   80202
                                                              13. TYPE OF REPORT AND PERIOD COVERED
                                                                      Final
                                                              14. SPONSORING AGENCY CODE
    16. SUPPLEMENTARY NOTES
     6. ABSTRACT
                 Contingency  planning,  as defined in this document,  encompasses the air
            program established  to  protect offsite populations.   Monitors for this
            purpose are usually  located at the site perimeter or  within the community.
            Monitors located  within the site for the safety and protection of workers are
            not included in this  definition, unless onsite monitors  serve the dual purpose
            of protecting both the  workers and offsite population.
                 A contingency plan using air monitoring establishes alert levels in
            advance of actually  collecting monitoring data.  Alert levels address the
            offsite population exposure concentrations that trigger  an  emergency response
            or a change in remedial  activities.   These alert levels  are in addition to
            alert levels for  onsite personnel.
                 The purpose  of  this document is to:   1) illustrate  contingency air
            monitoring with examples from past projects, and 2) describe how a contingency
            air monitoring program  may  be established.   This document is illustrative in
            nature because the application of this type of monitoring is not consistently
            prescribed in rules and  regulations, but is based on  professional  judgment
            applied in an analysis of individual  sites  and particular circumstances.
                                    KEY WORDS AND DOCUMENT ANALYSIS
                      DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                                                                               c.  COSATI Field/Group
           Air  Pollution
           Superfund
           Monitoring
           Contingency Plans
                                                 Contingency Monitoring
    8. DISTRIBUTION STATEMENT
                                                   IB. SECURITY CLASS (This Report)
                                                                           21. NO. OF PAGES
                                                   20. SECURITY CLASS (Thispage)
                                                                           22. PRICE
I
   EPA Far* 2220-1 (R»». 4-77)   PREVIOUS COITION is OBSOLETE

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            ^ Protean fcency
u>s tnvucr^   _UJ)           r

^lon ?'i?v[son Boulevard, 12W
77 West {fKs6°0n604-3590
Chicago, \L

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