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
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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.
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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)
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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.
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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
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