I I I I I I I I I I I 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 ------- I I I I I I I I 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 I ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I 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 I I I I I ------- I I I I I I I 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 I I I I 113 Public Protection Levels for the Example Site, in and ppb '..... 82 I 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 I I I I 87 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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. ------- I I I I I I I I I I I I I I I I I I I 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. ------- I I I I I I I I I I I I I I I I I I I C-01 Meteorological Station C-12 Figure 1. Air monitoring stations at Castlewood Site. ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- 1 1 1 1 3.50 1 3.00 ™ QC uioe Io^ 2.50 QU. 00 IODUJ rCC 2.00 »o I^m oS 1.50 I3K «« O£0 SS 1.00 I-tn ^ - 0.50 | 0.0^0 — — — _ — < ^ 1 1 1 < o\ < ^ < | ^ i < < a i i i / A£ s\ .UOJL.LfW | ^ < | *>\ 1 i , 1 1" 1 1 i V 0, ^1 ^>\ ^>\ Sj\ - ':- 1 1 • i i ^ o MN-oomiw x pomiu ' DATES 1 Figure 1 1 1 2. Fourteen data point running Site/Station C-02. 8 - average, Castlewood ------- I I I I I 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. ------- I I I I I I I I I I I I I I I I I I I 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 ------- 1 1 • CRESKUTZS SITE m 450 LOPUS ROAD BEACON FALLS, CT 1 M ATE: 7/13)1 o 7 i / tOMTTORS / ' t^ar-eu'CU fr/OH STATION/LOCATION (Reading ppm) __„ — ,____ ^^1 • | S/ | ','/.7«l/ */ <^£T II 1 7^l/ //.7«v I/'.7«f^ 1 1 1 1 TIME 'a1& &bo \&° r I33>£ /— '^ 1505 \ \ \ \ \ 1 1 1 1 1 WD 01_ (\ljv£ o ^5 «/*,& o fj/fi>£. A/JlJ'C. / N/tf£ £c O O .01 .01 o 0 0 O O 0 .oS _03_ 0 t> £> ^ ^ ." .ol _04_ o ^^ d O D .01 rtl .°' O i * w ' 0 0 0 0 _05_ ^ ^ O .O/ .0' 0 £> "o- ^5 * o • .01 0) 0 _07— _OB— _! . r - 10 1 1 1 1 — t>»f-*+'* 0 ^*) 0 > **/ (O O i Figure 4. Air monitoring log photoionization detector. 11 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I 1 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 ------- 91 t/i n> •a a> -s en 0> o o a* O> a. a> -a o> 2 S* 8. $3 5' * I II LJL ' 3 ' ouotoS 3. i JL_—- I I I I i I I I I I I I I I I I I I I ------- I I I I I I I I I I I I I I I I I I 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 ------- 1 1 1 •^•f 1 1 1 I 1 1 1 1 1 1 1 1 1 1 1 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 ------- 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) ------- 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) ------- 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 ro o ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I f I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I 1 I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I 1 I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I 1 I I 1 I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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. 42 ------- I I I I I I I I I I I I I I I I I I I 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 43 ------- I I I I I I I I I I I I I I I I I I I 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, 44 ------- I I I I I I I I I I I I I I I I I I I e OLD • OUALIZATION BASIN NEA4OH HILL ' • ••00 • •000 • ••00 • •000 E1BOO • 1000 C «00 Figure 10. Ambient air sampler locations at VERTAC Chemical Corporation. 45 ------- I I I I I I I I I I I I I I I I I I I 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 46 ------- 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 47 ------- I I I I I I I I I I I I I I I I I I I Figure 11. Soil sample locations at Weatherford residence. 48 ------- 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 ------- 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 50 ------- 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. 51 ------- 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 ------- 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. ' 53 ------- 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. 54 ------- 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. 55 ------- 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. 56 ------- I I I I I I I I I I I I I I I I I I I 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 58 ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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. 60 ------- 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. 61 ------- I I I I I I I I I I I I I I I I I I I 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. 62 ------- I I I I I I I I I I I I I I I I I I I 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. 63 ------- 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 64 ------- 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. 65 ------- I I I I I I I I I I I I I I I I I I I 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. 66 ------- I I I I I I I I I I I I I I I I I I I 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. 67 ------- I I I I I I I I I I I I I I I I I I I 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: 68 ------- I I I I I I I I I I I I I I I I I I I 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 69 ------- I I I I I I I I I I I I I I I I I I I 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. 70 ------- 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 71 ------- I I I I I I I I I I I I I I I I I I I 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 72 ------- I I I I I I I I I I I I I I I I I I I 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). 73 ------- 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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 ------- 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. ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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 ------- 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- 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. ------- I I I I I I I I I I 1 I I I I I I I I 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. ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I |(*) 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 94 ------- 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 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. ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I I I I I I I I I 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 ------- I I I I I I I I I I I 1 I I I I I I I 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 ------- 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 ------- ^ Protean fcency u>s tnvucr^ _UJ) r ^lon ?'i?v[son Boulevard, 12W 77 West {fKs6°0n604-3590 Chicago, \L ------- |