United States
                           Environmental Protection
                           Agency
Office of
Solid Waste and
Emergency Response
       4>EPA        Personal Air Sampling  and
                          Air Monitoring  Requirements
                          Under  29 CFR  1910.120
        Office of Emergency and Remedial Response
        Emergency Response Division MS-101
Publication 9360.8-17FS

August 1993
                        Quick Reference Fact Sheet
 Background and  Purpose
                 Under the authority of Section 126
                 of the Superfund Amendments and
                 Reauthorization   Act  of   1986
                 (SARA Title I), the U.S. Environ-
                 mental Protection Agency (EPA)
                 and the U.S.  Occupational Safety
                 and   Health  Administration
 (OSHA) issued identical health and safety standards to
 protect workers engaged in hazardous waste operations
 and emergency response.   The OSHA regulations,
 codified at 29 CFR 1910.120, became  effective on
 March 6,  1990 (54  FR 9294).   On  April 13, 1990,
 corrections to these regulations were published (55 FR
 14072)  to  clarify  certain  medical   surveillance
 requirements  and to identify which employers must
 comply with  29  CFR  1910.120(p).    The  EPA
 regulations, published on June 23, 1989,  at  54 FR
 26654, incorporate the OSHA standards by reference
 and are codified at 40 CFR Part 311.
    Although  the two  sets  of standards  contain
identical substantive provisions, the EPA and OSHA
standards address different audiences. In states that do
not have an OSHA-approved program, federal OSHA
standards protect all private and federal employees
engaged in hazardous waste operations and emergency
response; EPA worker protection standards protect all
state and local government employees.  In states that
do  have  an  OSHA-approved  program,  the  state
program covers all private, state, and local government
employees; OSHA covers  federal  employees.   The
OSWER Fact Sheet, Hazardous Waste Operations and
Emergency Response  (HAZWOPER):    Uncontrolled
Hazardous Waste Sites and  RCRA  Corrective Action
(OSWER Publication 9285.2-08FS, 1991), provides a
general overview of the worker protection standards as
they apply to operations conducted at uncontrolled
hazardous waste sites.

    OSHA requirements for monitoring at  uncon-
trolled hazardous waste sites are codified at 29 CFR
J910.120(h).   While the provisions outlined in this
section may be interpreted to include the collection of
samples (i.e., surface wipes in the support area on a
lead-contaminated site), the purpose of this Fact Sheet
is to summarize the HAZWOPER air monitoring and
sampling aspects of these  requirements.  The Fact
Sheet is composed of five parts:  (1) Introduction to
Air Monitoring and Air Sampling; (2) Air Monitoring
Requirements Upon Initial Entry; (3) Air Monitoring
Requirements After Initial Entry; (4) Conducting Air
Monitoring and Sampling; and (5)  Information Sources
and Contacts.

Introduction  to Air  Monitoring  and  Air
Sampling
                 The presence of hazardous mater-
                 ials at  a  site, as well  as  actions
                 taken to  address these materials,
                 can result in the release of hazar-
                 dous substances  into  the  air.
                 Chemical    fires,  transportation
                 accidents, open  or leaking  con-
                 tainers,  wind-blown dust, and site
                 cleanup   activities  all  produce
                 emissions that  can rapidly affect
                 the health and  safety of response
                 personnel  (site  workers   or
emergency response)  and  the public.   Hazardous
atmospheres may be:

•   Explosive (characterized by the presence of
    ignitable or explosive vapors, gases, aerosols, and
    dusts);

•   Toxic/hazardous (characterized by the presence
    of vapors, gases, particulates, and aerosols);

•   Oxygen-deficient (characterized by the
    consumption or displacement of oxygen in
    ambient air); or

    Radioactive (characterized by the presence of
    radioactive materials).
                                                                                id/Recyclable
                                                                                Hth Soy/Canola Ink on paper that
                                                                                at least 50% recycled fiber

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The  presence of one or more of these hazards is an
important factor  in  determining subsequent actions
that   should  be   taken   to   protect  workers,  the
community, and the environment. Their presence may
dictate operations that are necessary to mitigate the
likelihood  of an  incident,  and will  dictate  safety
considerations for response personnel.

    OSHA requirements  for air monitoring are set
forth in the  HAZWOPER  standards at  29 CFR
1910.120(h). Specifically, §1910.120(h)(l)(i) states that
monitoring must be performed "where there  may be a
question  of  employee  exposure  to  hazardous
concentrations of hazardous  substances  in  order  to
assure proper selection of engineering  controls, work
practices and personal protective equipment  [PPE] so
that employees are not exposed to levels which exceed
permissible exposure limits [PELs], or other published
exposure levels...."  The regulations also  require air
monitoring for use  in identifying health  hazards  in
order to determine appropriate level of PPE.  Once the
appropriate PPE is  selected, personal air  sampling
should be continued  in order  to ensure that personnel
exposures are not exceeding these limitations.
   «s- NOTE:  OSHA does  not define the term
   "air monitoring.'1  Rather, OSHA uses this term
   to refer to both monitoring using direct reading
   instrumentation  and  to  air sampling  using
   personal sampling pumps or other quantitative
   methods. However, in this Fact  Sheet, the term
   "air  monitoring"  refers  to the use  of  direct
   reading instruments producing instantaneous
   data, while the term "air sampling" refers to the
   use of a sampling  pump and collection  media
   that  produce samples that must be  sent to a
   laboratory for analysis.  The specific distinctive
   features of each are:

      Air monitoring:
         • Provides "real-time" results;
         • Provides rapid response;
         • Is generally not compound-specific;
         • Has limited detection levels; and
         • May  not  detect  certain  classes  of
           compounds.

      Air sampling:
         • Can be compound- or  class-specific;
         • Provides greater accuracy of detection;
         • Requires more time for results; and
         • Requires  additional  pumps,  media,
           analytical  support.
    One example of the difference between air moni-
toring and air sampling is that air monitoring can be
performed to identify the existence of a  hazardous
atmosphere during initial site entry, while air sampling
is  performed to identify and quantify  an  employee's
personal exposure to a hazardous chemical or range of
hazardous chemicals.  Further, air monitoring data are
instantaneous and are useful in comparing conservative
action guidelines to determine an appropriate level of
protection relative to  the work activity.  Air sampling
data are information  used  to compare an  employee's
exposure to OSHA 1971 time-weighted average PELs
(PEL-TWA),  PEL-ceiling (PEL-C),  the  American
Conference  of Governmental  Industrial   Hygienists
time-weighted  average   Threshold  Limit   Values
(TLV-TWA), and associated values (STEL,C).

    In   addition  to  the  requirements at  29 CFR
1910.120(h), OSHA mandates air sampling for specific
chemical contaminants under 29 CFR 1910.1000, which
lists approximately  428 substances in Tables Z-1 -A,
Z-2, and Z-3. OSHA also has comprehensive health
standards that  have  additional  PELs  and  other
requirements (see Highlight  1).   Consult  individual
standards for specifics.
   B3"  NOTE: The U.S. Court of Appeals, Eleventh
   Circuit, issued a decision on July 7, 1992, vacating the
   "Final Rule" of the Air Contaminants Standard.  A
   decision was made on March 22, 1993, not to appeal
   to  the Supreme Court, and the Eleventh  Circuit
   Court's decision stands.  Employers  and  Employees
   can find the 1971 permissible exposure limits that are
   now in effect listed in the Air Contaminants Standard,
   in the columns headed "Transitional Limits" in Table
   Z-l-A and in Tables  Z-2 and  Z-3  in 29 CFR
   1910.1000 (1989 or later).
Air Monitoring Requirements Upon Initial
Entry
                  During   the   initial  site   entry,
                  information is gathered to evaluate
                  site-specific risks and hazards. This
                  information  is used to select and
                  develop  site-specific  engineering/
 __^^_^^^^   administrative   controls,   PPE,
                  medical   monitoring,  and  air
sampling requirements.  Highlight 2 identifies some of
the  contaminant  and  hazard  risks  that  may  be
encountered during initial site entry.

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                      Highlight 1
       SUBPART Z, TOXIC AND HAZARDOUS
                    SUBSTANCES
      29 CFR 1910.1001

      29 CFR 1910.1002

      29 CFR 1910.1003
      29 CFR 1910.1004
      29 CFR 1910.1006
      29 CFR 1910.1007
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
      29 CFR
1910.1008
1910.1009
1910.1010
1910.1011
1910.1012
1910.1013
1910.1014
1910.1015
1910.1016
1910.1017
1910.1018
1910.1025
1910.1027
1910.1028
1910.1029
1910.1043
1910.1044
1910.1045
1910.1047
1910.1048
1910.1101
Asbestos, tremolite,
anthophyllite, and actinolite
Coal tar pitch volatiles
(interpretation of term)
4-Nitrobiphenyl
alpha-Naphthylamine
Methyl chloromethyl ether
3,3'-Dichlorobenzidine (and
its salts)
bis-Chloromethyl ether
beta-Naphthylamine
Benzidine
4-Aminodiphenyl
Ethyleneimine
beta-Propiolactone
2-Acetylaminofluorene
4-Dimethylaminoazobenzene
N-Nitrosodimethylamine
Vinyl chloride
Inorganic arsenic
Lead
Cadmium
Benzene
Coke oven emissions
Cotton dust
1,2-dibromo-3-chloropropane
Acrylonitrile
Ethylene oxide
Formaldehyde
Asbestos (Applies in lieu of
revised standards governing
occupational exposure to
asbestos, tremolite,
anthophyllite, and actinolite)
    Air monitoring techniques are used to assess the
risks that may be present during initial site entry.  As
specified  at 29  CFR  1910.120(h)(2), air  monitoring
must  be  conducted during  the  initial  site entry to
identify:

•   IDLH conditions;

•   Exposure  over permissible  exposure limits  or
    published exposure levels;

•   Exposure over radioactive materials dose limits; or

•   Exposure  to  other  dangerous  conditions  (e.g.
    presence of flammable  atmospheres  or oxygen-
    deficient environments).
                  Highlight 2
 CONTAMINANT AND HAZARD RISKS DURING
             INITIAL SITE ENTRY

    Exposure exceeding the OSHA PELs or other
    published exposure levels;

•   Exposure to immediately dangerous to life and
    health (IDLH) concentrations;

•   Exposure through skin absorption and irritation
    (chemical or biological);

•   Eye irritation;

•   Explosions resulting from shock-sensitive
    substances and flammable atmospheres;

•   Confined space-entry;

•   Injury from physical hazards; and

•   Exposure to radioactive (ionizing radiation)
    materials.

"3-  NOTE:  While required in 29 CFR 1910.120
(h)(2), monitoring for radioactive  materials under
initial entry conditions is not an "air" monitoring
technique.  If the main concern is to identify
exposure over radioactive material dose limits, the
contaminant of interest is gamma  radiation.  Gamma
radiation is not  air-matrix dependent.
                                                  Air sampling is not usually performed during the
                                              initial entry.  Instead, information about the potential
                                              chemical hazards is gathered during  the initial entry
                                              and used to make decisions about air sampling needs.
                                              For any contaminants  discovered  during the initial
                                              entry  that  are regulated by 29 CFR  1910.1000  or
                                              Subpart  Z (see  Highlight  1)  or  that could  be
                                              considered  hazardous, the air sampling needs must be
                                              assessed according to the requirements.

                                              Air Monitoring  Requirements After Initial
                                              Entry - Periodic Monitoring
                                                                Site  conditions and  atmospheric
                                                                chemical  conditions  may  change
                                                                following   the   initial   site
                                                                characterization.  As stated  at 29
                                                                CFR    1910.120(h)(3),   periodic
                                              ^^^^^^^^^   monitoring  must  be  conducted
                                                                when  "the possibility of an IDLH
                                             condition or flammable atmosphere has developed or
                                             when there is indication that exposures may have risen
                                             over permissible exposure limits or published exposure

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levels since prior monitoring."  Highlight 3 identifies
situations that call for periodic monitoring required at
29 CFR  1910.120(h)(3)(i-iv).
                    Highlight 3
            SITUATIONS THAT REQUIRE
              PERIODIC MONITORING

       When work begins on a different portion of the
       site;

       When contaminants other than those previously
       identified are being handled;

       When a different type of operation is initiated
       (e.g., drum opening as opposed to exploratory
       well drilling);  or

       When employees are handling leaking drums or
       containers, or working in areas with obvious
       liquid contamination (e.g., a spill or a lagoon).
    Once cleanup  activities begin  on-site,  29 CFR
 1910.120(h)(4) requires employers to  ''monitor those
 employees likely to  have the  highest exposures  to
 hazardous substances and health hazards likely to  be
 present above permissible exposure limits or published
 exposure  levels by using personal sampling frequently
 enough to  characterize employee  exposures."  Air
 sampling  for high-risk  employees  is  performed  to
 identify the  "worst-case exposure."  If the worst-case
 exposure  is above the PEL, then monitoring should  be
 conducted to identify all employees likely to  be above
 those limits.  (Note:  It  is not required to monitor
 employees engaged in site characterization operations
 covered under 29 CFR 1910.120(c).  Appropriate PPE
 based upon  the preliminary evaluation is required.)

    Post-initial entry situations that require periodic
 monitoring  also  should  be  characterized  by  air
 sampling,  as appropriate, and should be determined  by
 a  competent  health  and  safety  professional.   Air
 sampling  information  can be  compared to the  air
 monitoring data for the same period of time to:  (1)
 illustrate  trends  in the accuracy of the air monitoring
 data; (2) develop a correlation to the air monitoring
 readings; and (3) develop better air monitoring action
guidelines. Air monitoring data may also be used  to
determine when further sampling is needed (i.e., if site
conditions have changed).
    Personal  sampling  generally   is  not  used  to
characterize  overall site  air  quality.   However,  air
sampling conducted in areas of high concentration may
assist in determining whether  personal  sampling  is
necessary.  Air  sampling  may  also assist On-Scene
Coordinators  (OSCs),  Remedial  Project  Managers
(RPMs), or other site managers in determining whether
chemical  contaminants  covered   under  29   CFR
1910.1000, Subpart Z, need to be monitored.

    An   air   sampling  strategy   outlined   in  the
site-specific   health  and  safety  plan  must  address
frequency and  type  of  air  monitoring,  personal
monitoring,  and environmental sampling  (29  CFR
1910.120(b)(4)(ii)(E)). Highlight 4 identifies additional
information   that  should be  provided  in  area and
personnel air sampling strategies.
                    Highlight 4
    EXAMPLES OF ELEMENTS TO INCLUDE IN
        AM AREA AIR SAMPLING STRATEGY

       The locations where air sampling will be
       performed;

       The hazardous substances that will be sampled
       during the task;

       The duration of the sample;

       The equipment that will be used to sample  for
       the different hazardous substances; and

       Collection of meteorological data.

    EXAMPLES OF ELEMENTS TO INCLUDE IN
     A PERSONNEL AIR SAMPLING STRATEGY

       Employee sampled;

       Tasks performed;

       Duration;

       Hazardous substances; and

       Equipment to be  used.

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Conducting Air Monitoring
                  Table 1 at the end  of this Fact
                  Sheet,   "Summary   of   Direct-
                  Reading  Air Monitoring  Instru-
                  ments,"  lists  the direct-reading
                  instruments (DRIs) used during air
                  monitoring   to  characterize
                  hazardous atmospheres.  DRIs may
be  used to  rapidly detect  flammable  or explosive
atmospheres,  oxygen deficiency,  certain  gases  and
vapors, and ionizing radiation.  DRIs are the primary
tools of initial site characterization. The information
provided by DRIs can be used to:  select appropriate
protective  measures such  as  personal   protective
equipment, evacuation,  and other similar  measures;
determine the most appropriate equipment for further
monitoring; and assist in developing optimum sampling
and analytical protocols.

     DRIs have limitations.  For example, the Flame
lonization   Detector  (FID)  and  Photoionization
Detector (PID) are commonly used at hazardous waste
sites to monitor  for a  broad  range  of  organics and
some inorganics.  However, they do not detect some
particularly toxic  agents such as hydrogen cyanide and
hydrogen  sulfide.   Thus,  these  devices  must  be
supplemented with  other methods of detection (e.g.,
electrochemical   sensors or  colorometric  indicator
tubes). Many DRIs designed to detect one particular
substance  may also detect  other (cross  sensitive)
substances, thus rendering a "false positive." All DRI
information should be interpreted with a certain degree
of caution.

     To characterize personal exposure, air monitoring
should  be  performed in the breathing  zone of the
individual.   Emission sources may be characterized
through head-space monitoring (e.g. drums) or close-
range monitoring, if this can be done safely.  Emission
source  measurements  are  not   representative  of
personal exposure.

    Air  monitoring instruments  should  be field-
calibrated on  a daily basis prior to the initial  entry
and/or  any  field  activity.    Calibration  must  be
performed  according to manufacturer's  instructions.
Field calibration should take place in field atmospheric
conditions in a "clean" area, such as the command post.
Calibration  must be documented, either  in  a  site
logbook, or  a logbook designated  for instrument
calibration  records as required in the site safety plan
(29 CFR 1910.120(b)(4)(ii)(E)).

    Air monitoring data should be documented in the
individual's field  or  the site logbook.  Observations
pertaining  to the  monitoring data  (i.e., weather
conditions,  drum label information,  activity performed
during monitoring, number/names of individuals being
monitored,  etc.)  should  be  recorded  with  the
monitoring data.
Conducting Air Sampling
                  Table 2 at the end  of  this Fact
                  Sheet,  "Common  Air  Sampling
                  Methods and  Media  Used by the
                  EPA/ERT,"   summarizes   some
                  sampling methods commonly used
                  on hazardous waste sites.  Personal
 ^^^~^^~~"   air sampling is generally performed
using a personal sampling pump capable of both low-
flow  (20-750  cc/min)  and  high-flow  (1-4  L/min)
operation.  Low-flow operation with various  media-
packed tubes  is used  to  sample  volatile organic
materials and acid gas mists. High-flow operation with
various filter media or bubbler/impinger solutions is
generally used to sample particles, paniculate aerosols,
and   inorganic   gases.    Personal air  sampling  is
performed   for  the  duration   of  the workshift.
Employees with  the  highest exposure  potential wear
the sampling pumps with the sample media positioned
on their shoulders and the inlet of the filter or tube
facing down toward  the chest.  (Applying protective
"covers" often eases' decontamination of the pumps.)
Personal air sampling results are generally compared to
the 8-hour PEL-TWA.

    Sampling for comparison to the PEL-Short-Term
Exposure   (PEL-STEL) will  require   collecting  a
15-minute sample at higher flow rates.  PEL-STEL and
PEL-C sampling may be run throughout the  workshift
alongside  the PEL-TWA sampling.  PEL-STEL and
PEL-C sampling may be performed  once every hour
throughout the  workshift,  at  the times of highest
potential exposure.   Judgment should be used when
identifying  times of  highest potential exposure and
performing a PEL-STEL and/or PEL-C sampling event
simultaneously during this high-risk exposure period.

    There are a number of references that list standard
methods for performing personal air sampling.  OSHA
and the National Institute for Occupational Safety and
Health (NIOSH) publish two  sets of the most widely
used personal air sampling methods. Both NIOSH and
OSHA methods  are "recipes" for performing both air
sampling  and chemical analysis.  The methods outline
the sampling device, collection media, and flow rate at
which to set the sampling device.  OSHA and NIOSH
usually include in the methods any interferences that
may  bias  the  sampling.  The EPA/Environmental
Response Team  (EPA/ERT) has developed standard
sampling methods that incorporate existing NIOSH and
OSHA methods.  The "Information Sources" section of

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this  Fact  Sheet identifies  sources  to  obtain more
information on  these methods.

    Before a sampling method is chosen, the laboratory
should be contacted  to  determine whether it  can
perform   the  desired  analysis.    The   EPA/ERT
recommends  using  laboratories  accredited  by  the
American  Industrial Hygiene Association (AIHA) for
performing analysis on personal  air samples.  A list of
AIHA-accredited  laboratories may  be obtained  by
contacting the AIHA (see the "Contacts" section of this
Fact Sheet for AlHA's address and phone number).
                       As with DRIs, sampling pumps must be calibrated
                   prior to use.  The  goal of calibrating  the  personal
                   sampling pump is to set, and ensure that the pump can
                   maintain, a known flow rate.  Calibration requires a
                   pump,  a sampling train (including the sample media
                   and all  connecting tubing), and a primary standard-flow
                   indicator, such as a bubble meter  (Buck calibrator/
                   Gillibrator), or an inverted buret with bubble mixture.
                   A  secondary  standard flow  indicator,  such  as  a
                   rotameter, may be used to calibrate  the pump as long
                   as   the secondary  standard  has  been  previously
                   calibrated to a primary standard. Highlight 5 illustrates
                   several different methods of calibration.
                                               Highlight 5
                                EXAMPLES OF CALIBRATION METHODS
     Calibrating a Rotameter with a
            Bubble Meter
             SvnpHng
                Pump
Calibrating a Personal Sampling
  Pump with a Bubble Meter
Daaortc CdtrMor
               PWWIMI Swnpang
                   Pump
                                    Calibrating a Personal Sampling
                                       Pump with a Rotameter
Pwomi SflfflpHnQ
    Pump
                                           Calibration Apparatus
                         23k    r
                         U«V    f=t,
                                       • Noli: uxd far Sandart T«mp«rmr» Ptmmn oori«UM»
                      Souro*
                             (NOSH, 1964. Pub No. 84-100)

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               Highlight 6
EXAMPLES OF PERTINENT INFORMATION
  FOR AIR SAMPLING DOCUMENTATION

  Name of employee sampled;

  Task performed during sampling period;

  Suspected hazardous substances;

  Level of PPE;

  Type of collection media;

  Flow rate of the calibrated pump (pre- and
  post-sampling event);

  Duration of the sample;

  Date of sampling event;

  Location of sampling event;

  Environmental conditions during sampling event
  (e.g., temperature, Rh, wind speed, etc.);

  Unique sample number;

  Volume of air sampled during event;

  Any special handling requirements; and

  Analytical holding times.
    Documentation of all  aspects  of the sampling/
monitoring event is critical for both air monitoring and
air sampling.  Documentation provides information for
data interpretation and, in the case of air samples, for
tracking  the  sample from  the sample  taker  to  the
laboratory.   Air  sampling  documentation  is  more
formalized than documentation for air monitoring.
Highlight 6 identifies pertinent information that must
be documented for air sampling.

    If sampling media  (tubes or filters) are changed
throughout the day  to  prevent  overloading, sample
duration  for that media must be noted. Judgment must
be used in deciding how to document such a sampling
event.  Each tube/filter may be designated a unique
number and treated as  a single sample, or each tube/
filter may be designated the sample  number with a
different  consecutive letter  of the  alphabet attached.
The tubes or filters are unique,  but together  they
represent one complete workshift sample.  Setting up
and  performing  personal  air  sampling  generally
requires  more preparation time  than  air monitoring;
however,  in  both  cases, the correct instrument or
sampling  train  must be chosen, the instrument or
sampling train must be  calibrated, and the monitoring
or sampling event must be observed.

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                                                               TABLE 1
                         SUMMARY OF DIRECT-READING AIR MONITORING INSTRUMENTS
   Principle of
    Detection
  and Monitoring
      Need
                      Instrument
                                                         Features
                                                                                                             Limitations
Wheatstone
Bridge Filament
    Monitoring
    Need:
    Combustible
    Gas
Combustible
Gas
Indicator
*   Calibrated to pentane, hexane. or methane

*   Nonspecific detector for combustible gases
    measures gas concentrations as a percentage of
    lower explosive limit (LEL)

»   Lightweight, portable, and easy to use

*   Visual and audible alarms
    (some models)

*   Probe provides remote sensing capabilities

*   8- to 12-hour battery operating life for most
    models

*   Accuracy varies depending upon the model;
    accuracies of ± 2 to 3 percent are attainable*
    Potential interferences or filament damage from
    leaded gasoline, silicones, and silicates, which
    are more strongly adsorbed on catalyst than
    oxygen or gas in question.  Membranes are
    available to minimize these effects.

    Most models do not measure specific gases

    May not function  properly in oxygen-deficient
    atmospheres (< 10 percent)
Chemical Cell
    Monitoring
    Need:
    Oxygen
    Deficiency
                     Oxygen
                     Meter
                *  Direct readout in percent oxygen

                *  Visual and audible alarms

                4  Lightweight, portable, and easy to use

                *  Probe provides remote sensing capabilities

                *  Accuracies of + 1 percent are attainable, but
                   depend on the particular model

                *  Generally 8- to 10-hour battery life
                                                     *  High humidity may cause interference

                                                     *  Strong oxidants may cause artificially high
                                                         readout

                                                     *  Oxygen calibrations are dependent on altitude
                                                         and barometric pressure

                                                     *  CO2 "poisons" detector cell
Chemical Sensor
Wheatstone
Bridge Filament
    Monitoring
    Need:
    Combustible
    Gas/Oxygen
    Deficiency
Combination
Oxygen
Meter and
Combustible
Gas
Indicator
*   Calibrated to pentane, hexane, or methane

4   Measure percent oxygen and gas concentration as
    a percentage of LEL

*   Both visual and audible alarms (some models)
*   Remote sensing capabilities

*   Lightweight, portable, and easy to use

*   Accuracies of ± 2 percent are attainable'
*   Same limitation as oxygen meters and
    combustible gas detectors

*   In certain units, acid gases and high CO2
    concentrations shorten the life of oxygen
    sensor/cells

*   Certain units require a conversion factor for
    true specific compound response  readings

*   In certain units, oxygen calibration is altitude
    dependent
Optical, Electrical,
Piezoelectric
   Monitoring
   Need:
   Aerosol/
   Participate
Aerosol/
Paniculate
Monitor
*   Selectable ranges

»   Particle size differentiation available

*   Certain units have data logging capabilities
*   Factory recalibration required on certain units

*   Values represent total  particulales:  dust, mist,
    aerosols are all inclusive with no differentiation

*   Cold weather may have adverse effect on
    detector

4   High humidity and precipitation negatively
    affect  meler response
   Manufacturer specifications.  Actual field use may yield greater variations.

                                                                    8

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                                                          TABLE 1 (CONT'D)
                           SUMMARY OF DIRECT-READING AIR MONITORING INSTRUMENTS
     Principle of
      Detection
   and Monitoring
        Need
 Instrument
                                     Features
                                                                       Limitations
  Photoionization
  Ultraviolet Light
     Monitoring
     Need:
     Toxic Gas/
     Vapors
Photo-
ionization
Detector
(PIDf
*  Nonspecific gas and vapor detection for organics
   and some inorganics
*  Not recommended for permanent gases
*  Lightweight (4 to 9 Ibs) and portable

*  Sensitive to 0.1 ppm benzene.  Sensitivity is
   related to ionization potential of compound
•  Remote sensing capabilities

*  Response time of 90 percent in less than 3
   seconds

•  More sensitive to aromatics and unsaturated
   compounds that the flame ionization detector
   (FID)

•  8-hour battery operating life; certain units with
   external interchangeable battery packs
•  Audible alarm is available

•  Certain units have data  logging/computer interface
   capabilities
•  Certain units available with calibration libraries
•  Certain units available with interchangeable lamps
*  Does not monitor for specific gases or vapors

*  Cannot detect hydrogen cyanide or methane
*  Cannot detect some chlorinated organics

*  High humidity and precipitation negatively
   affect meter response
•  Readings relative to calibration standard
  Hydrogen Flame
   Icnization
      Monitoring
      Need:
      Toxic Gas/
      Vapors
Flame
Ionization
Detector
(FID)
    In the survey mode, it functions as a nonspecific
    total hydrocarbon analyzer; in the gas
    chromatograph mode, it provides tentative
    qualitative/quantitative identification (OVA-
    specific)
    Most sensitive to saturated hydrocarbons, alkanes,
    and unsaturated hydrocarbon alkanes

    Lightweight (12 Ibs) and portable

    Remote sensing probe is available

    Response time is 90 percent in
    2 seconds

    8-hour battery operating life
    Sounds audible alarm when predetermined levels
    are exceeded
*   Not suitable for inorganic gases (e.g., C12, HCN,
    NH3)
*   Less sensitive to aromatics and unsaturated
    compounds than PID

*   Requires skilled technicians to operate the
    equipment in the GC mode and to analyze the
    results (OVA-specific)

•   Requires changes of columns and gas supply
    when operated  in the GC (gas chromatography)
    mode in certain units (OVA-specific)

•   Because specific chemical standards  and
    calibration columns are needed, the  operator
    must have some idea of the identification of the
    gas/Vapor (OVA-specific)

*   Substances that contain substituted functional
    groups (e.g., hydroxide (OH-) or (CI-) chloride
    groups) reduce the detector's sensitivity
     LTV sources vary in strength among available units (10.2ev, 10.6ev, 11.7ev).  Each source has a range of compounds it cannot detect based upon
ionization potentials. See manufacturer's literature for specifics.

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                                                        TABLE 1 (CONTD)
                         SUMMARY OF DIRECT-READING AIR MONITORING INSTRUMENTS
   Principle of
    Detection
  and  Monitoring
      Need
                      Instrument
                                                         Features
                                                                                       Limitations
Infrared Radiation
   Monitoring
   Need:
   Toxic Gas/
   Vapors
Infrared
Analyzer
    Overcomes the limits of most infrared (IR)
    analyzers by use of a variable filler; can be used to
    scan through a portion of the spectrum to
    measure concentration of several gases or can be
    set at a particular wavelength to measure a
    specific gas

    Detects both organic and inorganic gases

    Portable but not as lightweight
    (32 Ibs.) as the PIDs or FIDs
*   Less portable than other methods of gas/vapor
    detection

*   Requires skilled technicians to operate and
    analyze results when positive identification is
    needed

*   Interference by water vapor and  carbon dioxide

*   Most require AC power source

*   Positive identification requires comparison of
    spectrum from strip chart recorder with
    published adsorption spectrum; infrared
    spectrum not available for all compounds

*   Intrinsic safety is unit dependent; see
    manufacturer's literature
Chemical
Reaction
Producing a Color
Change
    Monitoring
    Need.
    Toxic Gas/
    Vapors
Indicator
Tubes
*   Quantitative accuracies are variable

*   Simple to use, and relatively inexpensive

*   Real time/semi-real time results
*   Low accuracy

*   Subject to leakage during pumping

*   Requires previous knowledge of gases/vapors in
    order to select the appropriate detector tube

*   Some chemicals interfere with color reaction to
    read false positive

*   Temperature and humidity may affect readings
Electrochemical
Cell
   Monitoring
   Need:
   Toxic Gas/
   Vapors
   Specific
   Atmospheres
Toxic
Atmosphere
Monitor
*   Ease of operation

*   Small,  compact, lightweight

*   Audible alarm upon exceeding pre-set action level
    or Threshold Limit Value (TLV)

*   Certain units have digital readout

*   Generally compound-specific

*   Certain units interface with data logger
*   Cross sensitivity

*   Slow response/recovery after exposure to high
    contamination levels

*   Limited number of chemicals detected
Metal-Oxide
Semiconductor
   Monitoring
   Need.
   Toxic Gas/
   Vapors
Toxic
Atmosphere
Monitor
*   Ease of operation

»   Small,  compact, lightweight

*   Audible alarm upon exceeding present action level
    or TLV

*   Certain units have digital readout

*   Certain units interface with data logger

*   Nonspecific gas and vapor detection for some
    organics and inorganics
*   Cross sensitivity

*   Slow response/recovery after exposure to high
    contamination levels
                                                                   10

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                                                        TABLE 1 (CONT'D)
                          SUMMARY OF DIRECT-READING AIR MONITORING INSTRUMENTS
     Principle of
     Detection
   and Monitoring
       Need
 Instrument
                                   Features
                                                                                    Limitations
  Scintillation
  Detector
     Monitoring
     Need:
     Radiation
Radiation
Meters
Measures radiation in R/lir or fractions thereof
(gamma)
(battery operated)

Probe provides remote sensing capabilities

Accuracy and sensitivity varies considerably with
manufacturer and type of meter

A variety of meters are available. Some measure
total ionizing radiation; others are specific for
gamma, alpha, or a combination of two or more
types
   Some meters do not determine type of radiation
                                                                  NOTE:   Initial entry surveys should focus on the
                                                                           presence of gamma radiation. If alpha or
                                                                           beta are suspected, consult your health
                                                                           physicist.
  Gold Film Sensor
     Monitoring
     Need:
     Mercury
     Vapor
Mercury
Vapor
Analyzer
Compound specific; has survey and sample modes

0.001 mg/m3 detection limit

Provides sensor saturation readout; saturated
sensor cleaning capabilities

Can be used with dosimeters for on-site dosimetry

Microprocessor serves reading; automatically re-
zeros

Certain units have data logging capabilities

5-hour battery life
*  Requires yearly factory recalibration

*  Short battery life

4  Requires AC power for Heat Cleaning Cycle
Sources:  Mathamel, 1981; Spittler, 1980; McEnery, 1982; National Mine Service Company, 1980; Gas-Tech, 1980; Enmet Corporation,
1979; Foxboro Analytical, 1982; HNU Systems, 1982, 1991; Photovac International, Inc., 1989; Jerome,  1990; MIE, 1990.
                                                                  11

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                                                          TABLE 2
                      COMMON AIR SAMPLING METHODS AND MEDIA USED BY EPA/ERT1
CONTAMINANT
Hydrocarbons:
BP 36-126 Deg. C
Aromatic
Halogenated
Inorganic Acids
Alcohols
Acetic Acid
Acetaldehyde
Aliphatic Amines
Aromatic Amines
Volatile Organic
Compounds
Volatile Organic
Compounds
Polynuclear Aromatic
Hydrocarbons (PAH)
PAH
Pesticide/PCBs
Dioxin2
Metals
Formaldehyde
Formaldehyde
AIR SAMPLING
METHODS
NIOSH 1500
NIOSH 1501
NIOSH 1003
NIOSH 7903
NIOSH 1402
NIOSH 1603
NIOSH 2538
NIOSH 2010
NIOSH 2002
EPA TO1 and TO2
EPA TO14
NIOSH 5515
NIOSH 5506
Lewis and McCleod,
Modified
EPA TO4
EPA TO9
NIOSH 7300
NIOSH 3500
NIOSH 2541
FLOW RATE
1 L/m
1 L/m
1 L/m
1 L/m
0.5 L/m
1 L/m
1 L/m
1 L/m
1 L/m
20 cc/m
Grab 10-50 cc/m
2.5 L/m or 5 L/m
260 L/m
3.5 L/m
260 L/m
3 L/m
1 L/m
0.1 L/m
COLLECTION MEDIA
Charcoal
Silica Gel
Charcoal
Charcoal
2-Hydroxymethyl (2-HMP)
Pipendine on XAD-2 Resin
Silica Gel
Silica Gel
Tenax/Carbon Molecular Sieve
(CMS)
Summa Canister
Summa Canister with Critical
Orifice
XAD-2 Resin Tube with 37 mm
2 urn TeflonR Filter with
Polytetrafluoroethylene (PTFE) O-
Ring Support
2" x 1" Polyurethane Foam (PUF)
with 50 grams XAD Resin
2" x 3" PUF with Glass Fiber Filter
2" x 3" PUF and Glass Fiber Filter
0.8 um Mixed Cellulose Ester
Filter (MCEF)
1 um PTFE Filler and 2 Impmgers,
Each with 20 ml of 1 percent
Sodium Bisulfite Solution
10 percent 2-HMP on XAD-2
Resin
SAMPLE
DURATION
(HOURS)
2-8
2-8
2-8
2-8
2-8
8
8
1-2
Grab, 4-12
2-8
8-12
2-8
72
2-8
2-8
4-8
'   This table is to be considered a guideline only. NIOSH methods were developed for indoor industrial use. Most NIOSH methods cited here
   have modified now rates for use in outdoor ambient conditions.  Sample duration should reflect extent of work shift when used in personal
   monitoring.  If area sampling is being conducted for site characterization, sample durations may need to be modified to achieve desired
   detection limits.

~   For dioxm. method is for area sampling only.

      :  OSHA analytical  methods should also be evaluated for appropriate, applicable use.  Most are available on OSHA's Computerized
   Information System (OC1S)
                                                              12

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Information Sources

Federal Regulations

  The OSHA HAZWOPER regulations are codified at 29 CFR 1910.120 (54 FR 9294 and 55 FR 14072).  Subpart
  Z, Toxic and Hazardous Substances, can be found at 29 CFR 1910.1000.

  The EPA HAZWOPER regulations are codified at 40 CFR 311 (54 FR 26654).

Computer Software

  Air Methods Database (EPA/Environmental Response Team, Edison, NJ).

     Available on the Cleanup Information electronic bulletin board (CLU-IN), formerly OSWER BBS. For
     further information, call (301) 589-8366.  Communications:  No Parity, 8 Databits, I Stopbit, F Duplex.

  EPA Health and Safety Planner: Software and User's Guide (EPA, OSWER Publication 9285.8-01, 1990).

Fact Sheets

  Hazardous Waste  Operations and Emergency Response:  General Information and Comparison (EPA, OSWER
  Publication 9285.2-09FS, 1991).

     Explains the scope and purpose of the HAZWOPER standards, and distinguishes the SARA Title I standards
     from regulations and consensus standards covering the same or similar subject matter.

  Hazardous Waste  Operations and Emergency Response: Uncontrolled Hazardous Waste Sites and RCRA
  Corrective Action  (EPA, OSWER Publication 9285.2-08FS, 1991).

     Explains the principle HAZWOPER requirements as they apply to employees engaged in hazardous waste
     operations and  emergency response at uncontrolled hazardous waste sites, including employees who perform
     corrective actions at RCRA TSD facilities.

  Hazardous Waste  Operations and Emergency Response:  RCRA TSD and Emergency Response Without Regard
  to Location (EPA, OSWER Publication 9285.2-07FS, 1991).

     Describes the HAZWOPER planning, training, and medical surveillance requirements as they apply to
     emergency responders regardless of location, and employees who perform routine hazardous waste operations
     at RCRA TSD  facilities.

  Establishing Work Zones at Uncontrolled Hazardous Waste Sites (EPA,  OSWER Publication 9285.2-06FS,
  1991).

     Defines the different work zones usually found at a hazardous waste site (i.e., Exclusion, Contamination
     Reduction, and Support) and provides information on  selecting and maintaining work zones.

  Hazardous Waste  Operations and Emergency Response: Available Guidance (EPA, OSWER Publication 9285.2-
  10FS, 1993).
     Provides a list and description of computer software, fact sheets, guidance documents, and ERT training
     programs that pertain  to the worker protection standards.

General Health and Safety Guidance Documents

  Standard  Operating Safety Guides (EPA, OSWER Publication 9285.1-03, 1992).

     Provide guidelines for use by any organization in developing specific operation safety procedures.  These
     Guides should be adapted to address the safety criteria required for protection of response personnel from
     the hazards created by a specific operation or incident.
                                                  13

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  Standard Operating Procedures for Air Sampling and Monitoring at Emergency Responses (EPA, OSWER
  Publication 9285.2-03A, draft).
     Describes the types and methods of air surveillance, procedures and equipment for air monitoring, and a
     method for analyzing organic solvents by gas chromatography.

  Standard Operating Procedures for Site Safety Planning (EPA, OSWER Publication 9285.2-05, being updated).
     Describes the general requirements for a site safety plan, discusses development and implementation of a site
     safety plan, and provides sample plans and a checklist.

  Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (NIOSH/OSHA/
  USCG/EPA, NIOSH Publication 85-115, GPO No. 017-033-00419-6, 1985).

  Draft International Document on Guide to Portable Instruments for Assessing Airborne Pollutants Arising from
  Hazardous Wastes (U.S. National Working Group (NWG-4 OIML) Pilot Secretariat PS-17: "Measurement of
  Pollution."  Reporting Secretariat RS-5:  "Measurement of Hazardous Waste Pollution." ISBN: 0-936712-75-9).
     Provides guidance for using portable instruments to  assess airborne pollutants arising from hazardous waste.

  Procedures for Conducting Air Pathway Analyses for Superfund Applications addresses a variety of issues
  relevant to the air impacts at Superfund sites in four volumes entitled:
     Volume I:  Application of Air Pathway Analyses for Superfund Applications (EPA, EPA-450/1-89-001, NTIS
     PB90 113374/AS, 1989).
     Volume II: Estimation  of Baseline Air Emissions at Superfund Sites  (EPA, EPA-450/1-89-002, NTIS PB89
     18053/AS, 1989).
     Volume HI: Estimation of Air Emissions from Clean-up Activities at Superfund Sites (EPA, EPA-450/1-89-003,
     NTIS PB89 180061/AS, 1989).
     Volume IV: Procedures for Dispersion Modeling and Air Monitoring for Superfund Air Pathway Analysis (EPA,
     EPA-450/1 -89-004, NTIS PB90 113382/AS, 1989).

Standard Air Sampling Method Documentation

  OSHA Analytical Methods. The  OSHA Technical Center maintains an updated data base of analytical testing
  methods. Printouts of analytical  methods for individual chemicals are available by request.  For more
  information about the data base,  contact:
     OSHA Technical Center
     1781 South 300 West
     Salt Lake City, UT 84115
     (801) 487-0521

  Occupational Exposure Sampling Strategy Manual (Leidel, N.A., K.A. Busch, and J.R.  Lynch. U.S. Departmenl
  of Health, Education, and  Welfare, Publ.(NIOSH) pp. 77-173, 1979).

  Manual of Analytical Methods (Volumes 1-3, 3rd Ed., with supplements) (NIOSH Publication 89-127, 1989).

Recommended Exposure Limit Documentation

  1991-1992 Threshold  Limit Values for Chemical Substances and Physical Agents and Biological Exposure
  Indices (American Conference of Governmental Industrial Hygienists, 1991).

  Guide to Occupational Exposure Values-1992 (American Conference of Governmental Industrial Hygienists,
  1991).

  NIOSH Pocket Guide to Chemical Hazards (NIOSH Publication 90-117, updated annually).

                                                  14

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Contacts
The following contacts can provide additional information on air monitoring and air sampling at uncontrolled
hazardous waste sites:
American Industrial Hygiene
Association (AIHA)
Washington, D.C.
2700 Prosperity Avenue
Suite 250
Fairfax, Virginia 22031
(703) 849-8888
U.S. EPA
Environmental Response Team
2890 Woodbridge Avenue,
Building 18 (MS-101)
Edison, NJ  08837-3679
(908) 321-6740
24-Hour Hotline: (908) 321-6660
OSHA
U.S. Department of Labor
200 Constitution Avenue, NW
Room N-3647
Washington DC 20210
(202) 219-8036

OSHA Notification Service
(Complaint Hotline)  for Emergency
Situations: 1-800-321-6742
                                      EPA REGIONAL OFFICES
   EPA Region 1
   Emergency Planning and Response Branch
   60 Westview Street
   Lexington, MA 02173
   (617) 860-4367

   EPA Region 2
   Response and Prevention Branch
   2890 Woodbridge Avenue, Raritan Depot
   Building 209
   Edison, NJ  08837
   (908) 321-6656

   EPA Region 3
   Superfund Removal Branch
   841 Chestnut Street, 9th Floor
   Philadelphia, PA  19107
   (215) 597-0992

   EPA Region 4
   Emergency Response and Removal Branch
   345 Courtland Street, NE
   1st Floor
   Atlanta, GA 30365
   (404) 347-3931

   EPA Region 5
   Emergency and Enforcement Response Branch
   77 West Jackson Boulevard
   Chicago, IL 60604
   (312)353-9295
                   EPA Region 6
                   Emergency Response Branch
                   1145 Ross Avenue, 9th Floor
                   Dallas, TX 75202-2733
                   (214) 655-2270

                   EPA Region 7
                   Emergency Planning and Response Branch
                   25 Funston Road, 2nd Floor
                   Kansas City,  KS  66115
                   (913) 551-5037

                   EPA Region 8
                   Emergency Response Branch
                   999 18th Street, Suite 500
                   Denver, CO  80202-2405
                   (303) 924-7129

                   EPA Region 9
                   Field Operations Branch
                   75 Hawthorne Street
                   San Francisco, CA 94105
                   (415) 744-2353

                   EPA Region 10
                   Superfund Branch
                   1200 6th Avenue, llth  Floor
                   Seattle, WA  98101
                   (206) 553-1677
                                                  15

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