Site Inspection
      Training Course
   Hazardous Site Control Division
LJ. S. Environmental Protection Agency
        Washington, D.C.

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      QUALITY ASSURANCE AND QUALITY CONTROL  IN  SITE  INSPECTIONS
1.0  INTRODUCTION

     The complex tasks confronting a project  like  the  CERCLA Site  In-
spection Program require the establishment of management  controls  to
ensure that project activities are efficiently conducted.   These con-
trols should require management to plan work methods,  verify that  re-
quired work methods are followed, develop employee  training programs,
and provide an assurance that critical activities  are  correctly
conducted.

     Decisions concerning the apparent or actual hazards  posed by  a
specific site to the surrounding environment and the HRS  ranking of
such sites must be based on valid analytical data.  Such  decisions
will be no better than the data on which they are  based.  Therefore,
it is imperative that the data be of high quality.  To obtain requis-
ite levels of precision and accuracy with minimum  expenditures of  re-
sources, it is necessary to develop a comprehensive and well-docu-
mented QA program.  Activities concerning sampling  site selection; the
frequency of sampling; the number of samples  to be  collected;  the  pro-
cedures involved in the collection, preservation,  and  transport  of
samples; the calibration and maintenance of  instruments;  and the pro-
cessing, verification, and reporting of the  data must  incorporate  a QA
program.  If careful attention is not paid to each  of  these items, it
is highly probable that invalid data will be  produced. Such data
waste resources, lead to bad management decisions,  and hinder
enforcement actions.

     The QA program developed  for this program  should  provide guidance
in the quality procedures related to project  activities.   Because  of
the heterogeneous nature of many hazardous waste materials, these
guidelines cannot cover every  possible situation that  may be encoun-
tered in the field.  Consequently, an awareness  of common mistakes and
areas where QA may be seriously jeopardized  during field  sampling  is
necessary if data items are to be considered valid.

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2.0  FIELD SITUATION

     Field sampling, whether  for  SI/HRS  or  other  purposes,  requires
the collection of numerous data elements  generated  under  less  than
ideal conditions.  This  necessitates  carrying  various  measuring  and
sampling devices into  the field to  generate  and record the  necessary
information.  The quality of  data generated  is directly related  to the
care given these devices coupled  with the experience and  expertise of
the individuals using  them.   This section will address the  required
quality control elements, some of the more  common problems  encountered
during field operations, areas of the investigation affected,  and
possible solutions to  the problems.

2.2  DATA ACQUISITION

     The collection of field  data such as pH,  conductivity,  tempera-
ture, static water level and  ambient  air  characteristics  is  critical
to SI investigations.   Static water levels  in  wells, coupled with  the
total depth of the wells, provides  the data  necessary  to  calculate the
volume of water required to be purged from  the wells prior  to samp-
ling, to assure that representative formation  water is being sampled.
Conductivity, pH and temperature  provide  the data necessary to iden-
tify contaminant plumes  as well as  physio-chemical  states of contami-
nants such as heavy metals.

     Ambient air data  from organic  vapor  analyzers, air sampling de-
vices,  combustible gas meters, oxygen meters,  etc., provide  the  data
documenting off-site air pathway  migration.  This data may  be used
later in hazard evaluations,  risk assessment,  etc.

     Common problems encountered  during  the  collection of these  data
elements include:

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2.3  FIELD EQUIPMENT

     Properly maintained and calibrated  field equipment  is  essential
to the collection of valid field data elements and  representative
samples during site inspections.  Ideally,  this  equipment will  be
maintained by a designated individual or group within  the office.
They would be responsible for maintaining  the calibration,  maintenance
and availability of the equipment.  Additionally, they should assure
that field teams are knowledgable in the proper  use, calibration and
limitations of the equipment.

2.3.1  SAMPLING EQUIPMENT

     Sampling equipment, including pumps,  bailers,  buckets,  funnels,
etc., should be made of reasonably inert materials  such  as  stainless
steel or teflon.  PVC is not recommended except  for use  as  single  site
dedicated or disposable equipment as in  soil scoops.   This  equipment
is usually decontaminated (as discussed  later) following each SI and
requires minor maintenance.

     Care must be taken in use of the right  piece of sampling equip-
ment for the particular sampling job.

2.3.2  SCIENTIFIC EQUIPMENT

     This group of equipment provides a  significant amount  of actual
field data and associated quality control  problems.  Included in  this
group are pH meters, water conductivity  meters,  thermometers, organic
vapor analyzers, air sampling equipment, geophysical equipment  and
water level indicators  (M scopes).  Since  this equipment is more
complex than the sampling equipment, the need for quality  control  to
assure valid data is much greater.  Proper care  and maintenance is
essential.  In addition, proper calibration and  operational experience
is required to assure valid  data.

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     Each  instrument  in  this  group comes  with an instruction manual
detailing  the  procedures  and  theory of  operation,  calibration proce-
dures and  frequency  and  maintenance requirements.   Quality control
measures for these instruments  include  performance of required main-
tenance, operational  checks  and established calibration schedules.
These items should be  recorded  in  a logbook for each piece of equip-
ment.

     The major problems  encountered with  this equipment are:

     o  Failure  to calibrate  equipment  prior to use.
     o  Inexperience  in  operating  the equipment.
     o  Inability  to  assure  proper functioning of  equipment.
     o  Improper cleaning and maintenance of the equipment.

     An obvious  solution  to  these  problems is to provide training to
the  individuals  using  the equipment.  Since this is not always pos-
sible, another solution  is  to maintain  a  comprehensive manual contain-
ing  the manufacturer's instruction manuals for all the equipment.
Each team  could  then  review  the appropriate equipment instructions
prior to use.

     To ensure proper  calibration, each instrument should be tagged
with a label indicating when  calibration  is required.  In the case of
simple insturments such  as pH,  conductivity, and combustible gas
meters, these  would be calibrated  before  each use.   Appropriate
calibration standards  should  be stored  with the instruments.  In this
way, the necessary calibration  materials  are taken to the field with
the  instruments.  The  calibration  data,  together with the field data
are  then recorded in  the  logbook.

     In some cases, access to the  operations manual also allows
inexperienced  individuals to  successfully operate  the instruments.  It
is recommended  that an experienced individual oversee the novice.  The
experienced individual can then assure  that compensation or  correc-
tions for  differences  in  temperature in pH and conductivity  measure-
ments are  properly addressed.

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     To insure that instruments are operating  properly,  several  solu-
tions are available.  These include:

     o  Proper calibration as above.
     o  Having a supply of appropriate batteries  for  the  units.
     o  Having properly charged batteries where replacement  is
        impractical.
     o  Using a solvent-based marker to check  organic  vapor  analyzers
        and combustible gas detectors.
     o  Breathing on an oxygen monitor to produce  a meter response.

     Additionally, some instruments use Ni-Cad or  Gel-Cell rechargable
batteries.

     The Ni-Cad units need to be cycled from fully charged to deep
discharge monthly to insure stable charging characteristics  and
maximum battery life.  The Gel-Cell batteries, however,  should  never
be deep discharged as they will never hold a full  charge  again.   This
will significantly reduce field use and can lead  to erratic  data.
Gel-Cells should be kept on charge when not in use.

2.4  SAMPLING

     The actual sample collection, preservation and tagging  provides
numerous opportunities for error and data invalidation.   This phase  of
the SI involves the greatest number of people  actually handling  the
samples.  The areas of concern within the sampling phase  include:

     o  collection of samples by the team sampling members,
     o  sample preservation,
     o  sample tagging, and
     o  decontamination.

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2.4.1  SAMPLE COLLECTION

     Quality control  requirements  in  this  area  include:  sample
containers, sample collection  and  transfer,  capping  and  number of
samples collected.

     The sample containers  used  should  be  spotlessly cleaned  or new,
unused bottles.  Cleaning methods  should be  documented  through a
bottle lot control number system or  certified  in writing,  by  the
person cleaning the sample  containers.  This quality control
information should be  recorded in  the field  logbook  and  addressed in
the sampling plan.

     Failure to use the proper type  and properly cleaned sample
containers results in  numerous quality  control  problems.  For
instance:

     o  Improperly cleaned  one liter  polyethylene bottles  for metals
        can be contaminated with metal  residues  during manufacture  or
        if not properly revised  with  decontaminated  metals-free water
        and acid (nitric) prior  to sampling.
     o  Improper drying of  organic sample  bottles at 120°C for one
        hour or more can lead  to erroneous findings  of phthalates
        which occur during  manufacturing or  cleaning solvent  residuals
        introduce during bottle  preparation.
     o  Insufficient  sample volumes will result  in less  sensitive
        detection limits or total  loss  of  the affected data element.
     o  The sampling of several  sample  points at one time  by  one team
        can result in  confusing  which metals bottle  or VOA goes with
        which sample point.  This  can occur  downrange or at the field
        command post.

     As previously mentioned,  the  use of properly cleaned  containers
will eliminate some of these problems.  A  check  with the analytical
laboratory performing  the analyses will assure  that  proper types of
containers and volumes are  established  prior to  the  actual sampling

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(see Exhibit 1).  These requirements  should  be  included  in the
sampling plan and field logbook so that  these requirements are not
forgotten.  The actual sampling should be performed  at  each location
and completed totally before moving on to the next sample  point.   If
this is not efficient, temporary pre-labelling  of  the  sample  bottles
with masking tape bearing a unique sample identification number for
each sampling point may be used.

     Finally, care must be exercised  in  the  actual sample  collection
and transfer.  Items to be aware of include:

     o  Rinse buckets, funnels, scoops,  etc. used  to collect  and
        transfer the sample with a portion of the  actual sample which
        is then discarded.
     o  Transfer samples carefully to avoid  entrainraent of air which
        strip materials, oxidize metals  or otherwise change the
        content of the sample.  This  is  especially true for Volatile
        Organics (VOA) and metals in  ground  water.
     o  Exercise extreme care with sample container  caps.   Regardless
        of how well the container has been cleaned and  prepared,
        dropping the lid, losing the  teflon  liner  or reversing the VOA
        cap septum will invalidate the sample.

2.4.2  SAMPLE PRESERVATION

     With the exception of medium and high hazard  samples, all the
samples collected during an SI will require  preservation of some  type.
These samples will also have a finite "holiday"  time prior to receipt
at the analytical lab.

     The most common quality control  problems in this  area are
mislabelling bottles, failure to add  the appropriate preservative and
exceeding the holding time.  These problems  can  be easily  avoided
through a little care and organization.  Included  are:

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     o  Verifying, with  the  lab,  the appropriate preservation and
        holding time  for  each  parameter  sampled (see Exhibit 2).
     o  Tabulate  these requirements in the sampling plan and field
        logbook.
     o  Preserve  and  tag  samples  one at  a time rather than trying to
        process them  en masse.
     o  Pre-plan  and  document  shipping times for collected samples to
        assure they arrive at  the lab within the specified holding
        times.
     o  Pre-plan  and  double  check that appropriate preservatives  in
        sufficient quantities  are conveyed to the field.

2.4.3   SAMPLE TAGGING

     Obviously, samples must be identified as to location, date and
time of collection, analytical  pararaeter(s) requested,  samplers per-
forming collection, type  of  sample and preservative added if any.  To
facilitate organized  sampling  efforts, unique site designations and
sample  types should be developed.  These might include:

     o  A two or  three letter  code designating the site.   An example
        is Anytown Landfill  being designated as AL.
     o  Types of  samples  can be identified in a similar  manner by:
        GW - Ground water — SW - Surface water — LG -  Lagoon
        SE or SED - Sediment — ST - Stream — LK - Lake
        SS - Surface  Soil — SC - Soil core sample
     o  Each sample location can  then be uniquely numbered and identi-
        fied.  For example:   AL-GW-2 might represent the  ground water
        sample from Monitoring  well B-203 at Anytown Landfill.
     o  Pre-numbered  sample  tags  providing sufficient space to record
        the data  discussed above  are essential to tracking the various
        parameters collected at each sampling location.

     The most common  QC problems  in this area include:   incomplete
sample tags; failure  to provide the coding information  in the sampling
plan and field logbook; mistagging samples,  omitting parameters for
analysis and omitting added  preservatives.   Again,  a modicum of care
and preplanning will  eliminate  many of these problems.

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     o  Failure to accurately record  the data  at  the  time  of collec-
        tion.
     o  Failure to accurately record  the location where  the readings
        were taken.
     o  Human errors such as transposed numbers,  math  errors,  mis-
        placed or omitted decimal points.

     These errors or problems can easily compound themselves during  SI
write-ups and MRS rankings.  Results  of such errors can  include
inability to reproduce sample results, resample specific problem areas
and inaccurately ranking a site either too high or  too low.

     Solutions to these problems include:

     o  Designating a team member as  the documentation coordinator.
        As such, this person will be  responsible  for  recording all
        field data in a bound logbook.  Recorded  data would  be checked
        for accuracy by the individual generating the  data by  reading
        back or reviewing the data entries and initialing  the  data.
     o  Sample locations should be staked, flagged  or  otherwise
        uniquely identified.  Measurements from permanent  features
        (center line of road, numbered utility pole,  etc.) to  the
        sample point could be made and entered into the  logbook.
        Designations on a quad map, accurate site map  or site  sketch
        with distance measurements of sampling locations is  another
        option assuring reasonable reproducibility.
     o  Human errors can be reduced by the use of calculators, written
        logbook records of mathematical formulae  used  and  quality
        control checks by a second member of the  team.

2.1  FIELD LOGBOOK

     This item is, perhaps, the single most  important  quality control
element in a site inspection.  This document is  the written record of
all field data, observations,  field equipment  calibrations, samples
and chain of custody.  The potential  for future  legal  actions based on

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this SI requires  that  the  field  logbook be  a site-specific  document
which is a bound  (not  loose  leaf)  book  such as  a  ledger,  composition
book, diary, etc.  The  pages  should be  sequentially numbered,  either
printed or hand numbered,  the  important point  being that  pages  cannot
easily be removed or  fall  out.

     The field  log should  be  maintained by  one  team member.   This may
be the Project  Officer,  team  leader or  documentation team member.
This individual should  make  relevant entries.   The entries  should be
made in waterproof ink.  Mistakes  should not be erased or scratched
out but should  be lined out  with a single line  through the  error, the
corrected material inserted  above,  below or behind the error,  and the
error should be initialed  by  the person making  the correction.

     Information  should be made  in a logical manner.  This  might be
having sections for general  observations, sample  stations with  provi-
sions for field data  and sample  locations observations,  site sketches,
chain of custody, etc.   Another  organization scheme is the  diary
approach.  This would  result  in  a  chronological recording of all the
above information by  time  and  date.  Whatever method is selected it
should be followed consistently.   Provide a table of contents  identi-
fying major information locations.   Each page or  day should be  signed
and dated by the  person making  the  entry(ies).

     The most common,  problems  associated with the field logbook are:

     o  Failure to begin the  log at the onset  of  the project.
     o  Procrastination in recording on-site observations and  data.
     o  Failure to sign and date entries.
     o  Having  numerous individuals making  entries.

     The only viable  solutions to  these problems  is to select  dedi-
cated, responsible individuals to  manage the field logbooks and
designate a second individual  to review,  from a quality control stand
point, the field  logs  to assure  completeness.

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     Having a second person check over  the  sample  tags  following
attachment to the sample bottles can eliminate  potentially  serious
data omissions.  Sample tags should be  filled out  immediately prior to
attachment to the sample bottle.  While time consuming,  it  is the  best
method to avoid sample confusion and mistagging  of  samples.   Addition-
ally, the sample coding, pairing the sample with the  sample  locations
should be tabulated in the sampling plan  for ready  reference in the
field operations.  This information, together with  the  field data
should be recorded in the field logbook.

2.4.4  DECONTAMINATION

        Once a sample location has been sampled, the  equipment  used in
the sample collection must be cleaned or  decontaminated  before  moving
to the next location.  Failure to properly  clean this equipment will
result in cross-contamination of samples  and subsequent  loss of valid
data.  The only exception to this requirement are  cases  where:

     o  sufficient equipment is available to use clean  equipment at
        each sample location,
     o  contamination is so great that  disposable  equipment  is  re-
        quired, or
     o  where equipment is dedicated to each specific sample location.

     The scope of SI work generally precludes the  last  case  due to
high costs associated with dedicated equipment.  Hence,  we  are  left
with decontamination and/or disposable  equipment which  is used  once,
then thrown away.

     Decontamination, while labor intensive, is  probably the most  cost
effective for long range planning.  Decontamination also allows the
equipment to be utilized on a number of projects.   Decontamination
entails washing the equipment with soap and water  or  a  specific decon
solution (see Exhibit 3), rinsing with  tap  water,  rinsing with
deionized (DI) water, solvent rinse (acetone or  methanol if sampling
for organics) and a final triple rinse  with deionized water.

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Decontamination does  introduce  some  quality  control  problems  based  on
the type of agents used.  The most common  problems are:

     o  Solvent carry-over,  and
     o  Inadequate removal  of previous  sample  media,  especially
        viscous oil,  tars,  wood  preservatives,  etc.

     Both of  these problems  can  be handled successfully  in the  field.
Procedures required to assure adequate  quality control include:

     o  Selection of  equipment  which is easily washed as a unit or  can
        be easily disassembled  for cleaning,
     o  Scrupulous cleaning  in  soap  and water  and/or  decon solutions
        using heavy-duty brushes,
     o  Using copious amounts of water  and DI  water  during rinses,
     o  Allowing sufficient  time for solvents  (if used)  to evaporate
        before rinsing with  DI  water.   If  the  solvent has not evapor-
        ated and becomes mixed  with  the final  DI rinses,  the  solvent
        becomes extremely difficult  to  remove  and usually contaminates
        the next sample,
     o  Preparation of a blank  sample at the end of  each day.  This
        sample should be handled exactly as  any other sample.  This
        blank will provide  a quality control check on field decon
        procedures.

2.5  RECOGNIZING LOSS OF QC

     This is the most important  factor  in  field quality  control.  Each
of the above elements must  be checked and  verified as completed.  Loss
of quality control can be identified by:

     o  Incomplete field logs,
     o  Gaps or absence of  field data elements,
     o  Incomplete sample tags,
     o  Lab results where blanks containing  contaminants,  dissolved
        metals exceed total  metals,  etc.,

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     o  Calibaration information  is  not  recorded  and
     o  Log entries are not signed.

     While the list could go on and  on,  these  are  common,  readily
apparent signs of loss of quality control.  Corrective  actions  must  be
instituted immediately upon1 discovery  to assure correction of  these
problems so that future activities will have adequate QC.   The  most
common reasons for these problems are  inadequate  pre-planning,  lack  of
attention to details,  and poor field organization.

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EXHIBIT 1

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EXHIBIT 2

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EXHIBIT 3

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                PREPARATION OF DECONTAMINATION SOLUTIONS
Decontamination solutions should be designed to react  with  and  neutralize
specific contaminants  found at  a  hazardous waste  site.   However,  since
the contaminants on a  particular site  will  be  unknown 1n the majority  of
cases, 1t  1s  necessary to use a decontamination  solution that 1s  effec-
tive  for  a variety of contaminants.    Several  of  these  general  purpose
decontamination solutions (some  Ingredients are  available at hardware  or
swimming pool supply stores) are listed below:


DECON  SOLUTION  A  -   A  solution  containing  5X  sodium   carbonate  (Na£
COj) and 5% trisodium  phosphate (Na3 P04).


DECON  SOLUTION  B  -   A  solution  containing  10X  calcium hypochlorlte
(CaC1202).


DECON  SOLUTION C  - A  solution  containing  5X trlsodlum phosphate  (Na3
PC>4).  This solution can also be used  as a  general  purpose  rinse.


DECON SOLUTION D - A dilute solution of hydrochloric acid (HC1).


See Table 1 for recommended uses of these solutions.

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                                                                  DRAFT

                   CHEMICAL AND PHYSICAL PROPERTIES
                               CONTENTS

SECTION                                                            PAGE

1.0      INTRODUCTION TO HAZARDOUS MATERIALS                      CP-1
1.1      DEFINITION OF A HAZARDOUS MATERIAL                         CP-1
1.2      CLASSIFICATION OF HAZARDOUS MATERIALS                      CP-1

2.0      PHYSICAL PROPERTIES OF HAZARDOUS MATERIALS                CP-1
2.1      PHYSICAL STATE                                             CP-1
2.2      DENSITY OF GASES AND LIQUIDS                                CP-2
2.2.1     VAPOR DENSITY                                              CP-3
2.2.2     SPECIFIC GRAVITY                                            CP-4

3.0      FLAMMABIUTY                                               CP-5
3.1      CHEMISTRY OF FIRE                                           CP-5
3.1.1     FIRE PYRAMID                                                CP-6
3.1.2     CONCENTRATION                                             CP-7
3.1.3     FLASH POINT                                                CP-7
3.1.4     FLAMMABLE SOLIDS                                           CP-8
3.2      FIREFIGHTING AND FIRE PREVENTION                             CP-8
3.2.1     CLASSES OF FIRE                                             CP-8
3.2.2     USES AND LIMITATIONS OF FIRE EXTINGUISHERS                  CP-9
3.2.3     SPONTANEOUS COMBUSTION                                   CP-10

4.0      CORROSIVITY                                                CP-11
4.1      CHARACTERISTICS OF CORROSIVITY                             CP-11
4.2      CHARACTERISTICS OF ACIDS                                   CP-11
4.3      UNIQUE HAZARDS OF SELECTED ACIDS                          CP-12
4.4      CHARACTERISTICS OF ALKALIS (METAL HYDROXIDES)               CP-16
4.5      CHARACTERISTICS OF HALOGENS                                CP-17
4.6      CHARACTERISTICS OF ACID ANHYDRIDES                         CP-17

5.0      REACTIVITY                                                  CP-17
5.1      REACTIVITY OF SOME COMMON ELEMENTS                       CP-17
5.2      WATER-REACTIVE MATERIALS                                  CP-18
5.2.1     ALKALI METALS: POTASSIUM, SODIUM, LITHIUM                    CP-19
5.2.2     OTHER WATER-REACTIVE METALS:  MAGNESIUM, ALUMINUM,        CP-19
        ZIRCONIUM, TITANIUM, ZINC
5.2.3     WATER-REACTIVE INORGANIC CHLORIDES                        CP-19
5.2.4     OTHER WATER REACTIVES                                      CP-20
5.3      OXIDIZING MATERIALS                                        CP-20

6.0      HAZARD MODIFIERS                                           CP-21

7.0      REFERENCES AND INFORMATION RESOURCES                     CP-24
                                  CP-ii

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                                                               DRAFT
                   CHEMICAL AND PHYSICAL PROPERTIES
                               EXHIBITS
NUMBER                                                         PAGE

CP-1    REPRESENTATIVE DEHYDRATION REACTIONS OF                  CP-14
        CONCENTRATED SULFURIC ACID
CP-2    HAZARDOUS REACTIONS INVOLVING CONCENTRATED              CP-15
        SULFURIC ACID
                                CP-iii

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                                                                          DRAFT
1.0   INTRODUCTION TO HAZARDOUS MATERIALS

1.1   Definition Of A Hazardous  Material

A  hazardous material is a naturally occurring  or  synthesized material that  because
of  its  physical  or  chemical   properties  can cause the  deterioration  of  other
materials or can be injurious to  living things.

1.2   Classification  Of Hazardous Materials

Hazardous materials fall into four classes:

      1.  Flammable or explosive
      2.  Corrosive
      3.  Reactive
      4.  Toxic or poisonous

2.0   PHYSICAL PROPERTIES OF  HAZARDOUS MATERIALS

2.1   Physical State

The physical state  of a material (gas, liquid, or solid) has a definite  relationship to
the potential danger  posed by that material.   A  material  that  is dangerous in  one
state  can be relatively innocuous in another.

      1.  Gas

         a.  More hazardous than liquids or solids.

         b.  Flammable gases ignite easily.

         c.  Toxic gases can easily gain access to the body by  inhalation.


                                      CP-1

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                                                                           DRAFT
         d.  Gases in the environment are more difficult to  contain than  solids or
             liquids, but they are more easily dispersed.

      2.  Liquid

         a.  More ha2ardous than solids.

         b.  Flammable  liquids ignite easily only when vaporized.

         c.  Toxic  liquids  can be absorbed by the skin if splashed or spilled; they
             can be inhaled only when vaporized.

         d.  Liquids can sink, float, or dissolve in water.

         e.  Liquids can be  very  hot (boiling  water, 212  F)  or  very  cold (boiling
             liquid  nitrogen,  230  F), and thus they can cause burning or freezing.

         f.   Liquids in  the environment  can be collected, contained, or absorbed  if
             insoluble; they can be dispersed or diluted if soluble.

      3.  Solid

         a.  Less hazardous than gases or liquids unless powdered.
         b.  Flammable  solids ignite when the ignition temperature is reached.
         c.  Toxic solids have the greatest difficulty in gaining access to the body.
         d.  Solids in the environment can be easily collected and  contained.

2.2   Density Of Gases and Liquids

The density of  a gas in  relation to the density of air  is termed the vapor density.  It
is  calculated as  follows:
                                      CP-2

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                            DRAFT
      .,      .                    	Weight of substance	
      Vapor dens,tv         .       Wejght Qf an equa| vo|ume  of ajr
The  relative  density of a liquid is termed  the  specific gravity.  It is calculated  as
follows:

      c   -f-   _   -t              	Weight  of liquid	
      bpecmc gravity       =     Weight of an equa| V0|ume of water

The  vapor density or specific gravity is  an  important piece  of  information when
dealing with  environmental pollutants.  It  will  affect the way the material travels
through the environment, the kinds  of hazards  it  poses, and the safety  precautions
that  must  be taken to afford  protection  against the  material's hazardous  effects.
Refer  to  The  Merck Index  or  similar  technical  references  for  vapor density  or
specific gravity of the material in question.

2.2.1    Vapor Density

2.2.1.1    Hazards of Materials Lighter Than Air

If the vapor density is less than 1, the material is lighter than air and will rise and
dissipate in the air if unconfined.  The material could collect  in high spots such  as
ceilings if confined.  One example  is hydrogen.

Demonstration 1: Vapor Density
To demonstrate the effects of lighter-than-air gases and vapors.
                                        CP-3

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                                                                           DRAFT
2.2.1.2   Hazards of Materials Heavier Than Air

If the vapor density is greater than  T, the material is heavier than air and will sink.
The  material will  linger  near the ground and collect  in low spots.   Examples  are
carbon  dioxide  (can  displace oxygen),  chlorine (toxic), gasoline  vapors (explosive),
and trichloroethylene (can displace air).

Demonstration 2:  Vapor  Density

Purpose:

To demonstrate the effects of heavier-than-air gases and vapors.

2.2.2    Specific Gravity

2.2.2.1   Hazards of Materials Lighter Than (but Insoluble in) Water

If specific gravity is less  than 1, the  material will float on water.

If the material enters the environment, it will sink in porous  materials such as  soil
or sand until it  encounters water (i.e., a groundwater aquifer),  where  it will then
float.

Demonstration 3: Specific Gravity

Purpose:

To  demonstrate  the  properties  of a material  that  is  lighter  than, but  insoluble in
water.
                                       CP-4

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                                                                           DRAFT
2.2.2.2   Hazards of Materials Heavier Than Water

If the  specific  gravity is  greater than  one, the  material  will  sink  in water.  This is
true   of  materials  like   carbon  disulfide,  virtually   all  chlorinated  solvents,
chlorinated pesticides and herbicides, and polychlorinated biphenyls.

If the  material  enters the environment, it will  sink  in porous material  such as soil
or sand, then sink unaffected by water  in an  aquifer until it reaches a nonporous
surface.

Demonstration  4: Specific Gravity

Purpose:

To  demonstrate the  properties of a material that is  heavier than but insoluble  in
water.

3.0   FLAMMABIUTY

3.1   Chemistry Of Fire

In order  for a fire to occur a number of well-defined  chemical and physical factors
must be present.   If any one is  missing,  combustion  cannot  take  place.  These
factors are designated as the "fire pyramid."
                                      CP-5

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                                                                           DRAFT
 3.1.1    Fire Pyramid
 The fire pyramid is illustrated below.
The symbol demonstrates that fire needs four things to maintain combustion:

      1.  Fuel (any combustible material)
      2.  An  oxidizer, which need not necessarily be oxygen
      3.  A source of ignition
      4.  Reaction intermediates

Take away one leg of the pyramid (one of the necessary factors) and the fire either
will not start or will  stop burning.
                                      CP-6

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                                                                         DRAFT
3.1.2    Concentration

Flammable gases and vapors of flammable liquids will ignite in air when exposed to
an ignition source.

However,  each  substance has a concentration above  and below  which  it will  not
burn.   The minimum concentration below which a  flammable gas or liquid vapor
will not burn, even when  exposed to an ignition source, is called the lower explosive
(or flammability) limit (LEL).

The maximum concentration above which a substance will not burn  is called  the
upper explosive (or flammability)  limit.

Continuous monitoring with LEL instrumentation is essential  in an environment of
flammable gases or liquid vapors.

3.1.3    Flash Point

Flammable liquids do not  burn  as a liquid; they  give  off vapors that only ignite
when  a combustible mixture in air has been attained.  A flammable liquid may  not
give  off  enough  vapors at  its ambient  temperature  to  ignite.   Some  liquids
volatilize  at  very low  temperatures.    Other liquids  must  be   heated  before  a
flammable  concentration of vapors can  be produced.  The  minimum temperature
that a  liquid  must reach to produce an  ignitable concentration of vapors is called
the flash point.

Liquids  having  a  flash point below 80 F are  considered  by the  US Department of
Transportation (DOT) to be flammable liquids and must be placarded as such.

Liquids  having  a  flash  point greater  than 80 F but below 200 F  are  considered by
the DOT to be combustible and must be  placarded  as such.
                                     CP-7

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                                                                          DRAFT
3.1.4    Flammable Solids

A  flammable  solid  is  one that will  ignite through  friction  or spontaneously  by
chemical reaction  with  moisture or air.  The temperature at which a solid begins to
burn is  called  the  ignition or kindling temperature.

An  example is white phosphorus, which has an ignition temperature of 86°F.  When
placed  in an  environment  in which  the temperature  exceeds 86°F (such  as  your
skin) and exposed  to air, white phosphorous will  ignite  and  continue to burn.

3.2   Firefighting and Fire Prevention

Firefighting  and   fire  prevention   are  important  considerations  in dealing  with
hazardous  chemicals.   The use of  improper methods to  extinguish a fire  could
increase the potential fire hazards.

3.2.1    Classes of Fire

The major  consideration in extinguishing any  fire  is the class of fire (i.e.,  the type
of fuel or other contributing factors).

Class  A—Wood, paper, and  cloth (Symbol: /A\  ).

Water can be  used to extinguish a Class A fire. Dry powder will also work.

Class  B—Flammable liquids and gases (Symbol: |  8  | ).

         Water CANNOT  be  used  to extinguish a Class  B fire.   Water  is  either
         ineffective or  will spread the  burning liquid and make  the fire  worse.
         Carbon dioxide, dry powder, and, in some cases, foam must be used.
                                      CP-8

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                                                                          DRAFT
Class C—- Fires  involving live electrical equipment (Symbol: (CJ ).
         Water  CANNOT  be used to extinguish a Class  C fire.  Water is either
         ineffective or  can  act as an electric conductor, making  the  live electrical
         fire  worse   or   endangering  the   life   of  the   firefighter  by  risking
         electrocution.  Carbon dioxide or dry powder must be used.

Class D—Fires involving flammable metals (Symbol:'

         Water CANNOT be  used to extinguish  a  Class  D fire.   Water is generally
         ineffective or, by reacting with the burning  metal, makes the  fire worse
         by producing  the  hydrogen  gas which ignites.  Carbon dioxide  and dry
         powder are  also generally ineffective, as they  too  react with the burning
         metal.   Dry  salt, graphite,  and dry sand are  generally  used to fight Class
         D fires.

3.2.2    Uses and Limitations of Fire Extinguishers

There are three  basic types  of fire  extinguishers in common use  today, the carbon
dioxide, the dry powder models, and halon.

3.2.2.1    Carbon Dioxide

This model employs a directed flow of carbon dioxide,  which replaces  the oxygen  in
the fire  triangle, thereby  extinguishing the  fire.   It  has  the  advantage of being
rapid  and not leaving any  residue.  However, the lack  of residue prevents a carbon
dioxide  extinguisher from exerting a long-term effect  on the hot  embers.  There  is
nothing to  prevent reignition.

3.2.2.2   Dry Powder

The dry powder also  eliminates the  oxygen supply  to the fire.  In this  case  it
eliminates  the reaction intermediates.  It does leave a messy residue.  The  residue,
                                      CP-9

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                                                                         DRAFT
however,  effectively continues to suffocate  the fuel  source, thereby lowering the
possibility of reignition.

3.2.2.3   Halon

Halon  is a chlorofluoro carbon, chemically very similar  to some freon refrigerants.
Although expensive, it combines the best properties of both  carbon dioxide and dry
powder.   It suffocates the fire, eliminates reaction  intermediates,  remaining in the
area to prevent re-ignition from smoldering embers, but  leaves no residue.

Demonstration 5: Fire Extinction

Purpose:

To  demonstrate the use and  limitations of a variety of  fire  extinguishing  materials
and techniques.

3.2.3    Spontaneous Combustion

Some combustible materials may undergo autocombustion in the presence  of strong
oxidizers.

Demonstration 6: Spontaneous Combustion

Purpose:

To  demonstrate  the  fact that some  common  oxidizing agents may cause  some
common materials to ignite without a source of ignition.
                                     CP-10

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                                                                           DRAFT
4.0   CORROSIVITY

4.1   Characteristics Of Corrosivity

A  corrosive material is one that has the ability to

      1.  Cause deterioration or alteration  of metal surfaces.

      2.  Cause  visible destruction  or alteration of  skin  tissue  at the  point  of
         contact.

Corrosive  materials  include acids,  alkalis, elemental  halogens,  and  materials that
form acids or alkalis upon  hydrolysis.

4.2   Characteristics Of Acids

Acids undergo certain common reactions:

      1.  React with metals more  chemically  active  than  hydrogen  to  form a salt
         and hydrogen gas.  Hydrogen gas is flammable.
         HCI + Zn •* ZnCL +  H   t
         (hydrochloric acid + zinc metal  •*  zinc chloride + hydrogen)

      2.  React with alkalis to form a salt and water.

         Neutralization:
         HCI + NaOH  -»  NaCI + HO
         (hydrochloric acid + sodium hydroxide  •*  sodium  chloride + water)
                                      CP-11

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                                                                          DRAFT
      3.  React with metallic oxides to form a salt and water.

         Rust remover:

         HCI + Fe203  --  FeClg + H20

         (hydrochloric acid  + ferric oxide  •*  ferric chloride + water)

      4.  React with carbonates to form a salt, water, and carbon dioxide.  This  is a
         handy technique for cleaning up an acid spill.

         HCI + Na2C03  -  NaCI + H20 + C02  t

         (hydrochloric acid  + sodium carbonate  (or sodium  bicarbonate) -*• sodium
         chloride + water + carbon dioxide)

Demonstration 8: Corrosivity

Purpose:

To illustrate the general properties of acids.

4.3   Unique Hazards Of Selected Acids

Most individuals respect an  acid's ability to produce burns, some  of which can be
severe and  result  in permanent damage.  However, acids can be dangerous even if
they don't come in direct  contact with an individual.  Some examples of this are

      1.  Sulfuric acid

         a.  Has vigorous affinity for water.
         b.  Reacts violently with chlorates, perchlorates, and permanganates.
                                     CP-12

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                                                                            DRAFT
          c.  Has an exceptionally high boiling point (640 F).
          d.  Is a strong oxidizing acid.

             (Representative  dehydration reactions and other  hazardous  reactions
             involving   sulfuric  acid   are   listed  in  Exhibits   CP-1   and  CP-2,
             respectively.)

Demonstration 9: Sulfuric Acid, Dehydrating Effect

Purpose:

To demonstrate the dehydration effects of concentrated sulfuric acid.

      2.  Nitric acid

          a.  On produces toxic oxides of nitrogen contact  with metals instead  of
             hydrogen.

          b.  Is a powerful oxidizer.

          c.  Causes skin burns on contact.

Demonstration 10:  Nitric Acid

Purpose:

To illustrate some  unique properties of nitric acid.

      3.  Hydrofluoric acid

          a.  Exhibits general properties of acids.
          b.  Dissolves glass.
                                       CP-13

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          Reagent
                                    Reaction
                                                         Comments
     Sugar



       (C12H22°11>
                      C12"22°n
                                           Reaction runs smoothly, hut very


                                           exothermic
O
-o
Cellulose


  (wood products)









Concentrated


  perchloric acid






Formic acid






Oxalic acid







Ethyl alcohol


  (C2H5OH)
     KMnO
                           (C6H10°5>x
2HCIO4 -  C\2<07 + H2O
                           HCOOH -*  HO + CO
H2C2°4 ^ H2° + C0 + C02
                                                 (T - 150C)
                           (T =  125  C)
                                                      2HMnO
                           2HMnO4 -»  Mn20? * HO


                           2Mn2O? -  4MnO2 + 3O
                                           Reaction runs smoothly, except for

                                             finely divided materials; very

                                             exothermic
                                                                     Violent explosion
                                                                     Reaction runs smoothly, but CO toxic
                                                                     Reaction runs smoothly, but CO toxic
                                          Reaction runs smoothly, but product

                                            flammable




                                          Reaction runs smoothly, but product


                                            flammable
                                                                     Violent explosion
d  2

O  -1
z  o
in  TJ

O  -
Tl

"  2
o  £5
Z  3
O  fn
m  m
Z  m






    I
D  rS
                                                                                                                tn
                                                                                                                    O
                                                                                                                    m
                                                                                                           30  O


                                                                                                           51
                                                                                                           o  o
                                                                                                           O  2
                           "2Cr2°7  k  2Cf°3 + "2°
                                                                     Reaction runs smoothly, but very

                                                                       exothermic

-------
                                                                     DRAFT
                                 EXHIBIT CP-2
                       HAZARDOUS REACTIONS INVOLVING
                         CONCENTRATED SULFURIC ACID
Reactant
                     Chemical reaction
                                                        Hazardous feature
NaBr
             2NaBr
Reaction runs relatively
  smoothly, but S0_ and
  Br2 toxic
 Nal
            2Nal
Reaction runs relatively
  smoothly, but S0_ and
  vapors of L toxic
NaCN
             2NaCN
                           2NaHS04 + CO
Reaction runs relatively
  smoothly, but CO
  toxic
 NaSCN       NaSCN + 2H S04 + H_0 * COS +

               NaHSO. + NH.HSO,
                     4      44
                                                    Violent explosion; COS
                                                      (carbonylsulfide)
                                                      extremely toxic and
                                                      flammable
NaCI03      3NaCI03 + 3H2S0

              HCI04 + 2C!02
                              *  3NaHS0
Violent explosion; CIO,
  unstable and toxic
 HI
            SHI
Reaction runs relatively
  smoothly, but H2S
  toxic
                                   CP-15

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                                                                          DRAFT
4.4   Characteristics Of Alkalis (Metal Hydroxides)

Alkalis, although  chemically  the  opposite  of  acids, produce  strikingly similar end
results  upon skin  contact.  Alkalis have the  following characteristics:

      1.  React with acids to produce salt and water.

         NaOH + H2S04 ->•  Na2$04 + H20

        (sodium hydroxide + sulfuric acid > sodium sulfate +  water)

      2.  React with metals  (principally  aluminum, zinc, and lead) to  form salt and
         hydrogen.

         KOH + Al  •*  AI(OH)3 + H2 t

         (potassium hydroxide + aluminum  •*  aluminum hydroxide  + hydrogen)

      3.  React with metal  salts to form  metallic  hydroxides

         Ca(OH)2  + CuCI2  -»  CaCI2 + Cu(OH)2   *

         (calcium   hydroxide   +   copper chloride  -»•  calcium  chloride   +   copper
         hydroxide)
                                                                     t
      4.  Destroys skin through saponification.

         Sodium hydroxide +  animal fat  (stearic acid)  •*  yellow soap  + water
                                     CP-16

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                                                                          DRAFT
4.5   Characteristics of Halogens

The  halogen family consists of fluorine, chlorine,  bromine,  iodine, and  astatine.
These elements exhibit the following properties:

      1.  Corrosive and poisonous
      2.  Emit toxic fumes when  heated
      3.  React violently with reducing  agents
      4.  Vapors  produce high eye, skin, and respiratory irritation and  burning

4.6   Characteristic of Acid Anhydrides

An acid  anhydride is an acid with one  or  more  molecules of water removed;  for
example, 863 is the anhydride of  sulfuric acid (H2S04).  Acid anhydrides have the
following characteristics:

      1.  Corrosive and poisonous
      2.  Emit toxic fumes when  heated
      3.  React with water to form  acids; reaction generates heat
      4.  Violent  reaction  usual with most good oxidizers

5.0    REACTIVITY

5.1    Reactivity Of Some Common  Elements

Many common  elements  will react  quite violently  with  other chemicals or when
exposed to certain physical conditions.

      1.  Oxygen

         a.  As a gas,

            It will greatly increase the flammable  potential  of other materials.
                                     CP-17

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                                                                          DRAFT
         b.  As a liquid,

            It  is cryogenic and  can actually freeze living tissue  to  a  point where
            the tissue  will shatter.

Demonstration 11: Reactivity of Oxygen

Purpose:

To  illustrate the reactivity of oxygen rich atmospheres.

      2.  Halogens

         a.  As a gas
         b.  As a liquid

Demonstration 12: Reactivity of Chlorine

Purpose:

To  show the ease with  which chlorine gas may be generated and to demonstrate its
reactivity.

5.2    Water-reactive Materials

Some materials can react chemically or physically with water.

Water can combine with burning  metals to create a fire of greater  magnitude.

Water, even moisture  in the air, can  cause some  metals and  other  substances to
ignite.  Substances that spontaneously ignite are called "pyrophoric."
                                     CP-18

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                                                                          DRAFT
The  most  serious  hazard is  encountered  when  water  participates  in  a  chemical
reaction.   This  reaction is   called  "hydrolysis."    Hydrolysis  products  can  be
corrosive, toxic, and flammable.

5.2.1    Alkali Metals: Potassium, Sodium, Lithium

The following demonstrative illustrative this phenomenon:

Demonstration  13: Water Reactives—Sodium

Purpose:

To illustrate the reaction of sodium metal on contact with water.

5.2.2    Other Water-Reactive  Metals: Magnesium,  Aluminum,
        Zirconium, Titanium, Zinc

Other materials such as  magnesium, aluminum,  zirconium, titanium,  and zinc are
also  quite reactive in the presence of water.

5.2.3    Water-Reactive  Inorganic Chlorides

General  characteristics  of  this class  of  compounds  include  the  formation  of
hydrochloric acid upon  hydrolysis.  This makes them quite dangerous,  since  even
perspiration on one's  hand  can create  an  acid  if  one touches these chemicals.
Additionally, if  a  sealed  drum  of the material  is  opened on a  rainy or very humid
day,  toxic  and  corrosive hydrochloric  acid  vapors  could  be  released.   The  class
includes

      1.  Aluminum chloride
      2.  Antimony  pentachloride
      3.  Boron trichloride
      4,  Phosphorus oxychloride
                                     CP-19

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                                                                           DRAFT
      5,  Phosphorus pentachloride
      6.  Phosphorus trichloride
      7.  Silicon tetrachloride
      8.  Stannic tetrachloride
      9.  Titanium tetrachloride
     10.  Thionyl chloride

Demonstration 14: Water Reactives—Inorganic Chlorides

Purpose:

To  illustrate  the vigorous generation  of hydrogen chloride  vapors and hydrochloric
acid when  inorganic chlorides  come in contact with water.

5.2.4    Other Water Reactives

A variety of  other chemicals can react with water to  produce toxic by-products  or
unstable compounds:

      1.  Acetyl chloride (and bromide)
      2.  Phosphorus pentasulfide
      3.  Chlorosulfonic acid
      4.  Acetic anhydride
      5.  Phosphoric anhydride (phosphorus pentoxide)

5.3    Oxidizing Materials

These materials can cause ignition, combustion,  or detonation of organic  materials,
powdered  metals, and  other reducing agents.   They  are used as chlorinating and
bleaching  agents,   fertilizers,  pyrotechnic  mixtures,  and  rocket fuels.    Some
common oxidizing agents are:

      1.  Hypochlorites, chlorates, and perchlorates

                                      CP-20

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                                                                            DRAFT
Demonstration 15: Oxidizers—Chlorates, Perchlorates

Purpose:

To illustrate the effects of oxidizing agents on ordinary organic materials.

      2.  Nitrates
      3.  Peroxides

Demonstration 16: Oxidizers — Peroxides

Purpose:
To illustrate the effects of peroxides with  ordinary organic materials.

6.0   HAZARD MODIFIERS

Different  site activities will  alter  the degree  of  risk of  exposure  to hazardous
materials  on a site.

Planned activities

      •  Recon. Make observations  from off site.  Minimum risk.

      •  Initial investigation.  Observations and ambient monitoring on site.

      •  Remedial   investigation.      Detailed  site  assessment   with  minimum
         disturbance of material.

      •  Removal activities. Greatest  risk due to disturbance of material.
                                      CP-21

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                                                                          DRAFT
Site information

      •  Known  hazards.   Records search, ambient monitoring,  chemical analysis
         results.

      •  Unknown  hazards.   Incomplete  information, material  inaccessable  until
         disturbed.

Ambient temperature

      •  Hot.   Contaminants  most  volatile.   Sweating  skin  more suseptable to
         dermal  permeation.    Greatest risk  of  heat induced  illness.   Chemical
         hazard tradeoff to level of protection.

      •  Cold.    Contaminants  least  volatile.    Aqueous  material  may solidify to
         form  ice.   Greatest  risk of  cold  induced injuries.   Decontamination with
         aqueous solutions most difficult.   Beware  of using  flammable liquid fires
         to  heat  equipment or areas.

Precipitation

      •  Can mobilize or cause reaction of  hazardous materials.

      •  Physical properties.  May change with temperature  and precipitation.

         -  Gas  or liquid  vapor.  Rises or  sinks depending  on vapor density.  Most
            difficult  to  contain.   Disperses readily  if contained.   Highest risk if
            contained in vessel or building.

         -  Liquid. Will sink or float on water depending  on specific gravity if  -

            Insoluble.  May dissolve in water or solvents.  May react with  water or
            other materials.
                                     CP-22

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                                                                           DRAFT
         -  Solid.   Easiest to  contain.   Least  degree of  risk for exposure.   May
            mobilize or react on exposure to liquids or gasses.

Chemical  properties

      •  Toxicity.     Consider   routes  of  exposure  (inhalation,   dermal,   oral,
         subcutaneous), relative toxicity, acute or chronic effects.

      •  Reactivity.   Ability to  produce  toxic,  corrosive,  flammable,  or  explosive
         by-products on exposure to other materials including air and water.

      •  Corrosivity.   Ability  to alter  or  destroy metal surfaces  or skin  tissue  at
         point of contact.

      •  Flammability.   Ability  to   produce  flammable  vapors   or  gasses  upon
         reaction or volatilization.

Location of Material
         Field
            Underground.   Limited risk of exposure unless disturbed or exposed by
            excavation.

            On  ground.  Can  be mobilized or volatilized.  Contact and respiratory
            exposure risk.

            Groundwater.   Greatest  risk of exposure by ingestion, or contact when
            drilling.  Material is contained but mobile.

            Surface water.  Risk of exposure  through contact.  Volatile hazards  if
            on  surface.
                                      CP-23

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                                                                         DRAFT
      •  Building (Higher risks of exposure in most cases)

         -  Condition of building. Consider structural  integrety and ventilation.

         -  Location  in  building.    Consider  means  of  access  and  egress.
            Remember hazards of confined  vapors and gasses  in  basements and
            ceilings.

Type of material containment

      •  Tank.   Consider  structural  integrety,  tank open  and  vented  or closed,
         possibly under pressure.  Tank contents; solid, liquid, gas, or vapor.

      •  Drum.   Structural  integrity.   Accessability  of contents.   Physical and
         chemical  properties of contents. Contents under pressure.

      •  Lagoon. Multiple hazards and risks.

      •  Other

7.0   REFERENCES AND INFORMATION RESOURCES

Text references

      •  Chemistry of Hazardous  Materials
      •  Merck Index
      •  NIOSH hazardous materials manual
      •  NIOSH hazardous materials pocket guide
      •  NIOSH TLV guidelines
      •  DOT Transportation emergency  manual
      •  OtherOther references and resources
                                     CP-24

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                                                            DRAFT
•  CHEMTREC
•  OHMTADS
•  NRC
«  EPA Regional Offices
•  TOXLINE Computer data base
•  HAZARDLINE Computer data base
                            CP-25

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                                                                DRAFT
                           SITE OPERATIONS
                              CONTENTS
SECTION                                                        PAGE

1.0      TRAINING                                                SO-1
1.1      INTRODUCTION                                          SO-1
1.1.1    CONTINUING TRAINING                                   SO-2
1.1.2    REFRESHER TRAINING                                    SO-2
1.1.3    SITE-SPECIFIC TRAINING                                  SO-3

2.0      HAZARD EVALUATION                                    SO-3
2.1      SITE CONDITION                                          SO-3
2.2      WASTE TOXICITY AND HAZARD                            SO-*
2.3      DERMAL PROTECTION                                    SO-6
2.1      RESPIRATORY PROTECTION                               SO-7

3.0      SITE SAFETY PLAN                                        SO-12
3.1      MINIMUM REQUIREMENTS                                 SO-12

4.0      SITE OPERATIONS                                        SO-13
4.1      TEAM SIZE                                               SO-13
4.1.1    MINIMUM PROTECTION REQUIRED                         SO-14
4.1.2    AIR-PURIFYING RESPIRATORS/CHEMICAL-
          PROTECTIVE COVERALLS                               SO-14
4.1.3    SUPPLIED-AIR RESPIRATORS/CHEMICAL-PROTECTIVE SUITS  SO-14
4.2      TEAM ORGANIZATION                                    SO-14
4.2.1    TEAM LEADER  FUNCTION                                 SO-15
4.2.2    SITE SAFETY FUNCTION                                   SO-15
4.2.3    DECONTAMINATION FUNCTION                            SO-15
4.2.4    RESCUE FUNCTION                                       SO-16
4.2.5    SAMPLERS/FIELD PERSONNEL                             SO-16
4.3      OPERATIONS                                             SO-16
4.4      DEMOBILIZATION                                         SO-17
4.5      WORK ZONES                                            SO-17
4.5.1    INTRODUCTION                                          SO-17
4.5.2    CONTROL AT THE SITE                                   SO-17
4.5.3    DELINEATION OF WORK ZONES                            SO-1S
4.5.4    MODIFICATIONS                                          SO-22
4.5.5    AREA DIMENSIONS                                        SO-22
4.5.6    MONITORING AND SAMPLING                              SO-23
4.5.7    PERSONNEL IDENTIFICATION AND MOBILITY                SO-23

5.0      WORK PRACTICES                                        SO-25
5.1      PERSONNEL PRACTICES                                   SO-25
5.2      OPERATIONAL  PRACTICES                                SO-27
                                 SO-i

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                                                                 DRAFT
                            SITE OPERATIONS
                        CONTENTS (CONTINUED)
SECTION                                                         PAGE

6.0     DECONTAMINATION                                      SO-31
6.1     INTRODUCTION                                           SO-31
6.2     PRELIMINARY CONCERNS                                 SO-32
6.2.1    INITIAL PLANNING                                        SO-32
6.2.2    CONTAMINATION REDUCTION CORRIDOR                   SO-33
6.3     EXTENT OF DECONTAMINATION REQUIRED                 SO-35
6.3.1    MODIFICATIONS OF INITIAL PLAN                          SO-35
6.3.2    EFFECTIVENESS OF DECONTAMINATION                    SO-37
6.3.3    EQUIPMENT                                              SO-37
6.3.*    DECONTAMINATION SOLUTION                            SO-38
6.3.5    ESTABLISHMENT OF PROCEDURES                         SO-38
6.4     DECONTAMINATION DURING  MEDICAL EMERGENCIES        SO-38
6.4.1    BASIC CONSIDERATIONS                                   SO-38
6.4.2    PHYSICAL IN3URY                                        SO-39
6.4.3    HEAT STRESS                                             SO-40
6.4.4    CHEMICAL EXPOSURE                                    SO-40
6.5     PROTECTION FOR DECONTAMINATION WORKERS            SO-41
6.6     DECONTAMINATION OF EQUIPMENT                        SO-41
6.6.1    BASIC CONSIDERATIONS                                   SO-41
6.6.2    DECONTAMINATION PROCEDURES                         SO-42
6.6.3    PERSONNEL PROTECTIVE EQUIPMENT                      SO-43
6.6.4    PERSISTENT CONTAMINATION                             SO-43
6.6.5    DISPOSAL OF CONTAMINATED MATERIALS                  SO-43
7.0     FIRST AID
7.1     ASSESSING THE SITUATION                                SO-44
7.2     VITAL SIGNS                                              SO-45
7.2.1    PULMONARY RESUSCITATION                              SO-45
7.2.2    CARDIAC COMPRESSION                                  SO-46
7.3     WOUND CARE                                            SO-48
7.3.1    SURFACE WOUNDS                                        SO-48
7.3.2    DEEP WOUNDS AND SERIOUS BURNS                        SO-49
7.4     BANDAGING                                              SO-49
7.5     REFERENCES                                             SO-49

8.0     EMERGENCY PLANNING                                   SO-51
ATTACHMENT A

ATTACHMENT B
                                  SO-ii

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                              EXHIBITS




NUMBER                                                       PAGE

SO-I   DIAGRAM OF SITE WORK ZONES                           SO-22
SO-2   TYPICAL PA/SI DECON LAYOUT                           SO-34
                                SO-iii

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                                                                        DRAFT

1.0       TRAINING

1.1       Introduction

Personnel training is performed to ensure employees are

     •   Aware of the hazards of their jobs and are able to perform their work in
         a  manner where risk to  personal  health  and  safety is  reduced to  the
         greatest extent feasible

     •   Aware  that  maximum  concern  for  the  health  and  safety  of  other
         workers, the public, and the environment is given

     •   Aware of and comply with all laws, rules, and regulations

     •   Knowledgeable  in the tasks they must perform so  they react responsibly
         and are able to correctly respond to emergency situations

Identifying   problems  which  signal  a  need  for  formal training  requires  careful
investigation of the problem causes.  Many  times, changes  in equipment  type or
design,  operating  procedures, or physical layout are more  appropriate  solutions.
Symptoms of training  problems can include

     •   High  accident rates
     •   High  frequency  for particular accident types
     •   High  personnel turnover
     •   Personnel complaints
     •   Productivity drop
     •   Expanded work  scope or load

Appearance  of  any of the above will trigger an investigation into  the cause and its
solution.
                                     50-1

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Personnel training necessary for personnel involved in remedial response activities
includes several areas:

      •   Introductory to explain the work  needed to fulfill  program objectives,
          describe the management and reporting system  to be used, and provide
          technical information and skills needed to perform the work.

      •   Continuing  to introduce new  ideas and  equipment and to respond  to
          unexpected situations, and for new employees.

      •   Refresher to reinforce  previous  knowledge and skills  and to correct
          undesired behavior.

      •   Site specific to cover special  problems, procedures, and equipment.

The following subsections describe  how  the need for training will be identified and
the material covered in each of the three  training areas previously described.

1.1.1     Continuing Training

Continuing  training is provided to employees through periodic meetings at each
office or specialized courses.  Meetings are coordinated and scheduled by the MHS
and  provide  an opportunity for reviewing problem areas,  new  ideas, new technol-
ogy, and case  histories.  Employees are  expected to  attend as required by  their
work needs,  they  provide an excellent forum  for soliciting and developing employee
safety awareness and promoting morale.

1.1.2     Refresher Training

Refresher training is provided to reinforce correct behavior and correct  improper
behavior.   Refresher  training will be  provided  by  periodic  refresher courses.
Periodic refresher courses  will be  scheduled  and provided by  the  MHS.  Subjects
will include  those  covered during the Introductory Training as well as other subject
needs identified during the contract period.  Refresher  training will be provided as
required to meet regulatory and operational needs.

                                     SO-2

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                                                                        DRAFT

1.1.3      Site-Specific Training

Site-specific training needs  are spelled  out in  each site safety plan.  SMs are
responsible for ensuring all site investigation personnel have received the necessary
training.  Those who have not must be trained and certified by  the MHS prior to
working on the subject site.

2.0       HAZARD EVALUATION

Once  the  hazards have  been  identified, they must be ranked in order to determine
action needed to eliminate or minimize  the dangers.   Hazard evaluation  can be
divided into two categories:

     •   Hazards due to the physical condition of the site
     •   Hazards due to the toxicity of wastes encountered

2.1       Site Condition

Hazards due to the physical condition and operations on the site will nearly always
be the easiest to discover and  eliminate.   Examples  of these  hazards  and the
solutions include:

     «   Open pits   guarding with barricades or by filling in

     •   Unstable material  stacks   overhead guarding of equipment,  protective
          clothing for spills, cribbing, or restacking

     «   Lagoons,  ponds,  streams    protective footwear  and clothes, rescue
          devices (lifeline).

     •   Cold,  snow, ice  - antislip footwear, warm  clothing, scheduling of  work
          and rest periods, extra planning and manpower, and hot  meals

     3   Heat, humidity   extra supervision to ensure  protective materials are
          worn, scheduling of  work  and  rest  periods,  and  extra  planning and
          manpower
                                     SO-3

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                                                                        DRAFT
      •   Contaminated  environment  -  site  air, soil,  and water analysis  for
          hazardous materials with use of protective gear for hazardous materials
          found

      •   Confined spaces  - air analysis for  hazardous materials, oxygen content,
          and  combustible  gas  concentrations  with  use of  protective  gear  for
          hazardous  materials  found,  and  use  of rescue  devices and  standby
          personnel

      •   Spills - planning, operation  procedures use, protective equipment,  and
          clean up.

      «   Struck by  object -  hard hats,  safety shoes, body guards, and machine
          guards

      •   Striking against object  machine guards, handrails, and proper footwear
          and walking surfaces

      *   Caught  in or between - machine guards, training in equipment use,  and
          movement alarms

Elimination  of most of  these  physical  risks  is accomplished by  appropriate
engineering controls or use of the protective equipment issued to each  employee.
Use of  powered  mechanical  equipment  is  limited to  those  people  specifically
trained and appropriately licensed and only at the direction of the SM.

2.2       Waste Toxicity and Hazard

Hazards due to wastes encountered depend upon  their toxicity and the probability
of personnel exposure.  Since  the  toxicity of the materials is uncontrollable,  the
probability  of  exposure  must  be minimized.  Categories of personnel protection
required depend on the degree  of hazard and  probability of exposure by a route of
entry into the body.

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                                                                        DRAFT
Toxicity  is related  to the amount of material needed to produce an effect on the
health or behavior  related  to  the person exposed.  Toxicity can be  scaled  using
several rating  systems  including  TLVs, PELs, and the  dose (LD50  for nquids or
solids) or concentration (LCjrj for gases) needed to kill  one-half of a group of test
animals.

The degree of hazard integrates toxicity and probability of exposure.  For example,
walking by a sealed drum of highly  toxic material several times is less hazardous
than drinking a lethal dose of a relatively harmless material.  Exposure to  toxic
materials can occur by inhalation, absorption, ingestion,  and injection.

Inhalation is the most probable method of exposure to toxic materials  at hazardous
waste  sites.   Protection  ranges  from  pressure  demand,  self-contained  breathing
apparatus (PD-SCBA) to air-purifying dust  respirators.  Skin and eye  absorption is
next most probable because of material handling or contact with contaminated
protective equipment.  Use of suitable protective garments, eye and  face protec-
tion,  and personal  hygiene is  required.  Ingestion can  occur when  sanitation and
personal  hygiene are neglected or when  food or drink  are contaminated by  toxic
materials.  Cleaning of all  equipment and personnel,  segregation   and  proper
disposal of contaminated materials,  and banishment of food and beverages from the
waste site are required  here.  Injection of toxic  materials is possible when protec-
tive  coverings  and  the body are  pierced by  a contaminated material.  Examples
include cuts from contaminated sharp metal, broken glass, and nails. Care must be
taken to  eliminate  or guard against  this exposure.  All injuries must be treated by a
person trained  in first aid and reported to  the SM to allow evaluation of possible
exposure, determination of  additional treatment, and to help reduce similar  future
exposures.

2.3       Dermal Protection

Prior to  on-site arrival, adequate personal  protective equipment must be selected
by the team leader for  conducting field inspections and operations.  For adequate
protection against  possible  exposure to hazardous materials, the team leader must
have available  protective clothing, respiratory protection, and first aid equipment.
In selecting this equipment, the following basic decision  process should be used:

                                      SO-5

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                                                                        DRAFT
      
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It should be recognized that no one type of encapuiated suit or protective clothing
will be  adequate for all possible  uses because of the permeability factors  of  the
materials used.  Several suits are available on the market today.  These different
suits are made of nitrile rubber, neoprene rubber, PVC-coated nylon, polyurethane-
coated nylon, CPE, and butyl rubber.

Both disposable  clothing and reuseable clothing are available.  Each has advantages
and disadvantages.  Presently  available disposable clothing is more  easily torn than
reuseable clothing and  disposable  shoe covers are of limited value on rough ground
or in walking through snagging objects.  Reuseable clothing is tougher but must be
decontaminated after use.

2.tt       Respiratory Protection

OSHA's General Industry Standards, 29 CFR  1910.134, state that respirators shall
be selected on the basis of the hazards to which workers are exposed and that ANSI
Z88.2 shall be  used for guidance in their selection.   OSHA  also  requires that
approved or accepted respirators  may be  used when available based upon 30 CFR
11, 14,  and 14a.  Selection of respiratory equipment for use in hazardous waste
disposal site operations must be guided by considerations of risk to life and health,
the nature of the equipment  available,  and relative  comfort and ease with which
work may be performed while protected.

Selection of the proper type of  respirators  for  use  in on-site activities shall be
based upon the following criteria:

     •    The type of respiratory hazards, including  physical properties, physiolo-
          gical effects on the body,  concentrations of toxic  material or airborne
          radioactivity level,  established permissable time-weighted average  for
          toxic materials and oxygen levels

     •    The location  of the hazardous area in relation to the nearest area having
          acceptable respirable air
                     *r

     9    The period of time for which respiratory protection  must be provided

                                     SO-7

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                                                                        DRAFT
     •   The anticipated work loads of field personnel

     •   The  physical characteristics  and  functional capabilities and limitations
          of the various types of respirators

In order  to select  the appropriate  minimum  level  of  respiratory  protection,
quantitative data  on air quality must be available.  In many instances during the
initial entry into hazardous waste sites, potential respiratory hazards have not been
quantified.  It  must then be assumed that the  unknown atmosphere is  immediately
dangerous to life  and health and oxygen deficient.  In many cases, other agencies
will  have previously entered the hazardous waste site, and  the level of respiratory
protection may be modified in light of previous experience.

OSHA, in   the  latter  situation, requires  that  positive  pressure  self-contained
breathing apparatus must be used,  per  29 CFR 1910.134 and ANSI Z-88.2 (Revised).
Therefore, when personnel enter a  hazardous waste site with unknown  air contami-
nation, they must use  PD-SCBA.  Only National  Institute of Occupational Safety
and  Health/Mine  Safety   and  Health Administration-approved,  PD-SCBA  are
acceptable.

There  are cases where the site entry team  will visit a hazardous waste site when
the  concentration  of  oxygen and contaminants are known, based upon  adequate
sampling and analysis procedures.   In  these situations, the OSHA  regulations and
ANSI  Z-88.2  (Revised) guidelines  prescribe  specifically  allowable   respiratory
protection as follows:

     •   Atmospheres which are oxygen deficient (less than  19.5 percent 62)

In these atmospheres, OSHA requires that respirators which provide an  independent
sources of respirable air must be used; i. e., PD-SCBAs.

     •  Atmospheres which  are  "Immediately Dangerous to Life  and  Health"
         (IDLH)

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                                                                        DRAFT
In  atmospheres  encountered that contain adequate oxygen  but are  immediately
dangerous to life and health as defined  in ANSI Z-88.2 because of the presence of
toxic contaminants,  only  respirators which  provide  an  independent  source of
respirable air under positive pressure may be used.  If adequate sample analyses
demonstrate that IDLH conditions exist  at a site, the entry team should withdraw
from the area and notify EPA, state and  local authorities.

     •    Atmospheres which are not immediately dangerous to life and health.

If  atmospheres  contain  adequate oxygen (above 19.5 percent)  and contain only
contaminants with  good warning  properties (taste, smell, irritation)  and  are not
immediately dangerous  to  life  and  health  because  of  the  presence  of  toxic
contaminants, air-purifying respirators can be used.

Air-purifying respirators operate by  drawing air through canister or cartridge  filter
medias  designed  to  remove  particulates,  vapors  and  gases, radionuclides or
combinations  of  particulate/gas/vapor.   Only  approved NIOSH/MSHA  cartridges
can  be  used  in  these  respirators  and  only  filters specifically  provided  for an
individual manufacturer's air-purifying  respirator.   NIOSH/MSHA  approved air-
purifying  respirators  are manufactured  in several mask models.  Advantages and
disadvantages deal primarily  with degree of  fit, comfort, and  the need  for eye
protection.

In  atmospheres  where  air-purifying respirators  are  used and the possibility of
increased concentration  of  toxic  substances  exists,  OSHA  requires that  an
emergency  escape  mask be provided  for all  field personnel.   Thus,  when air-
purifying  respirators are used for entry  into hazardous waste  sites, NIOSH/MSHA
approved emergency escape masks may also need to be carried.

OSHA also requires that each person using an air-purifying respirator undergo a fit
test using the particular device selected.  Because of the wide variety of  facial
characteristics of field personnel and the wide array of respirator manufacturers,
no mask shall be issued to field personnel until a proper fit test of the individual to
the  specific device is  made.   Field personnel must feel comfortable with  the
                                      SO-9

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                                                                         DRAFT
device. A qualitative fit test should be conducted using isoamyl acetate first and
then irritant smoke (stannic chloride) while wearing the selected model.

Only  NIOSH/MSHA approved cartridges  for  the  selected mask and model can be
used.  The canister types include particulate filters, vapor or gas removing filters,
radionuclide filters, combination particulate/gas/vapor and radionuclide filters, and
high efficiency filters.

Remember  that when the encountered contaminants  do not  possess good warning
properties, only PD-SCBAs shall be used.

      •   Phase - may be hard to handle due  to the physical state of material

      a   Vapor pressure   may be fire  hazards, explosion hazard, or suffocation
          hazard by displacing air

      *   Vapor density - may be fire hazard and suffocation hazard if  material
          displaces oxygen

      9   Solubility in various  materials    may  dissolve protective equipment or
          container

      *   Melting point -  may become in.liquid during handling, causing a spill or
          exposure

      •   Boiling  point    may  boil at ambient  temperatures releasing  toxic gas
          vapor

      •   Reactivity   may generate heat  or  toxic gases

      «   Radioactivity   may injure upon exposure

      9   Flash point  may be fire and explosive  hazard
                                     SO-10

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                                                                         DRAFT
Not all of these  properties will be important  for  each waste  encountered.  The
point  is to recognize which  properties are important for each  waste encountered
and then to control the hazards associated with those properties.  Most commonly,
concern is given to a material's  fire and explosion potential  and  its reactivity.

Flammable liquids are classified by flash point (fp).  Flash point  is the temperature
at which a sufficient amount of vapor is  produced  by a burnable  liquid so that  an
ignition source (spark or flame) will cause a fire to  start. Liquids are classified as
either flammable (fp <  37.8°C) or combustible (fp > 37.8°C).  Some materials (liquid
or solid) will  also spontaneously start burning at elevated temperatures.  These are
called auto-ignitable materials.  Fires are  controlled  and  extinguished by elimi-
nating any one of the four requirements  needed for  fire: heat, fuel, reaction, or
oxygen.  Fire extinguishers eliminate either the  heat (water) or the reaction (dry
chemical).  One  reminder is to be aware of the  reactivity of the extinguishing
material used on  fire, especially when using water to extinguish  the  fire.  Many
materials react with water causing a  more  serious  problem.   Water  may also
dissolve the hazardous material creating a toxic  effluent which is more  hazardous
than the fire  and associated air pollution.

Reactivity of  waste  materials  is  also  important  when   sampling or  handling
materials. Care  must be taken to be sure materials cannot react with  sample or
analysis gear, personnel protective equipment, air, or body tissue.

3.0       SITE SAFETY  PLAN

A  site  safety  plan  must  be prepared  by experienced personnel for  each  event
involving hazardous substances. For remedial action at abandoned hazardous  waste
sites, safety  plans can  be developed simultaneously  with general operation plans
and implemented when remedial actions begin.  Emergency situations may require
verbal safety instructions and the use of standard operating safety procedures until
specific safety protocols can be written.  For  any  incident, the plan must include
health and safety considerations for all activities required at the scene.  The safety
plan  must be periodically reviewed during extended field  operations  to keep  it
current and technically correct.
                                     SO-11

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                                                                       DRAFT
All team members should be thoroughly trained in the preparation and use of  safety
plans.  The SM will assemble the known facts concerning the site and will prepare a
preliminary plan. The preliminary plan will be reviewed by health  and  safety staff.
The final site safety plan will be generated at this review.

3.1       Minimum Requirements

As a minimum, the  site  safety plan must—

      1.   Evaluate the  risks associated  with the incident and with each operation
          conducted.

      2.   Identify key personnel and alternates responsible  for both site safety and
          response  operations.

      3.   Address  the  levels of  protective equipment to  be  worn by  personnel
          during various site operations.

      4.   Designate work areas (exclusion zone, contamination reduction zone, and
          support  zone), boundaries, size of zones,  distance between zones, and
          access control points into each zone.

      5.   Establish decontamination procedures for personnel and equipment.

      6.   Determine the number  of  personnel and equipment needed in the work
          zones during initial entries and/or subsequent operations.

     7.   Establish site emergency procedures—for example, escape routes, signals
          for evacuating work parties,  emergency  communications (internal and
          external), and procedures for fire and/or explosions.

     8.   Implement a  program and  make arrangements with the  nearest medical
          facility (and  medical  life  squad unit) for  emergency medical care for
          routine injuries and toxicological problems.
                                    50-12

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                                                                        DRAFT
     9.   Train personnel for any nonroutine site activities.

     10.   Consider  weather and other conditions which  may affect the health and
          safety of personnel during site operations.

     11.   Implement control procedures to prevent access  to the site  by unautho-
          rized personnel.

Included at the end of  Tab 9 is Attachment A "Appendix M  - Site Safety Plan Gui-
dance", which provides EPA's internal requirements for Health and Safety Plans.

4.0       SITE OPERATIONS

Operating at a hazardous waste site requires a coordinated  move of equipment and
personnel  during startup, a regular flow of supplies and supporting personnel during
operation, and demobilization of all operations after job is finished.  Preplanning
for mobilizing people and equipment is essential to rapid, trouble-free site setup.
Maintaining equipment between operating  periods  is key to preventing problems
when equipment is needed.

A  SM will be designated prior to work on any site project.  The SM is responsible
for all  aspects of work at the site and will report to the Project Manager.  Several
items which require the SMs attention during project startup include:

     9   Site assessment
     *   Work plan preparation
     •   Site personnel selection
     *   Necessary equipment to site
     «   Procuring site utilities

4.1       Team  Size

The team  size is determined by the  amount and nature of the work  required and by
the gear needed  to protect against  site hazards.  Since the amount and nature of
the work  for every project cannot  be determined here, this section will dwell on
minimum  team sizes based on hazard protection requirements.
                                     SO-13

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                                                                       DRAFT
4.1.1     Minimum Protection Required

Where no chemical hazards nor any extraordinary physical hazards exist, a team of
two people is required. All work activities are performed using the "buddy system"
and visual and verbal contract must be  maintained.  Minimal decontamination is
necessary  with water washing  of  shoes and  washing  of hands  and  face  most
common.  Each team  member helps the other remove protective gear, decontami-
nate and clean equipment. Initial PA/SI activities are often done at this team size.

4.1.2     Air-Purifying Respirator/Chemical-Protective Coveralls

Use of  air-purifying  respirators or  chemical  protective coveralls  implies  the
presence of a toxic chemical hazard.  A team  of two is still possible if the use of
this protective gear is only precaution.  But, if analysis and  TLV/PEL data shows
the definite need for this protection, a team of three  is required. The third person
serves the  safety/rescue/decontamination functions and has supplied-air respirators
(PD-SCBA) on stand-by.   This team size is common at  sites of known hazard and
during sampling of known contaminated areas.

4.1.3     Supplied-Air Respirator/Chemical-Protective Suits

Three  persons are required for a these types of operations, including  two persons
downrange and a  third person, dressed at the same level of protection as the down-
range  people,  filling  the  functions of  safety, decontamination  and  emergency
rescue.  It is  preferable  to have a fourth person in the clean area  to act as  the
safety person  while  the  third  person  serves  as the  decontamination/emergency
rescue person. A three-person team is sufficient only for  the simplest of supplied-
air  respirator operations.

4.2       Team Or Ran ization

The downrange work party always consists of a minimum of two people.  One of  the
two always functions as the team leader.  The  team  leader  may  also have other
functions.  The other team member serves as one or a  combination  of the following
                                     SO-14

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                                                                         DRAFT
functions.  When a two-person  team is used, it is important that the two peopie
chosen are of equivalent size and weight so one could evacuate the other in case of
an emergency.

*.2.1      Team Leader Function

The team leader maintains all administration responsibility for the site.  The team
leader is responsible for all decisions concerning site activities and works with the
team  safety officer to maintain safe working  conditions.

*.2.2      Site Safety Function

The site safety officer usually  remains at  the decontamination area in order to
monitor all  downrange  operations.  Downrange personnel are either in the safety
person's line of sight or other individuals are located between the safety person and
the downrange personnel in order to maintain an unbroken, person-to-person line of
sight.  The specific responsibilities of the site safety officer are as follows:

      1.   Monitors the  work time and physical condition of all personnel.

      2.   Makes all decisions concerning protective  equipment and monitors  all
          activities to remove personnel from any  unsafe work conditions or unsafe
          work acts.

If  the site safety officer goes downrange to  observe work practices,  he is replaced
at the decontamination area  by  the  site leader, who assumes the safety officer's
responsibilities and emergency action authority.

4.2.3      Decontamination Function

This individual  is responsible for organizing decontamination  stations, assisting/
supervising  all  decontamination  operators,  disassembling the  decontamination
stations, and disposing of all contaminated liquids and solids.
                                     50-15

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                                                                        DRAFT
*.2.4     Rescue Function

This person is outfitted at the highest level of protection being used by the field
team. The rescue  person  remains at the decontamination line and goes downrange
only  to  assist  with emergency evacuations.   On  small  teams, the  rescue  and
decontamination tasks can be handled by a single individual.

*f.2.5     Samplers/Field Personnel Function

These are the individuals who complete all downrange operations.  On large teams,
the field personnel who are not currently downrange can assist with decontamina-
tion or command post operations.

*.3       Operations

Site operations will be conducted  according to the approved work  plan.  SMs are
responsible for  implementation of the work plan.  Site operations  depend on the
personnel  working on  the site,  support  from  base  personnel,  and equipment
operation.

SMs are  responsible  for  procuring and  maintaining these requirements.   Base
personnel  provide   the  backup, expertise, supplies,  and funds  needed  by  site
personnel.  Base support  functions will be written  into the work  plan.  SMs  will
advise the Project  Manager regarding additional support or materials needed after
site operations commence.

The SM must ensure that all employees have received their initial and site-specific
training, know the  tasks to be performed,  and  are  medically qualified  to  perform
the tasks.  A record of personnel assigned to each site and their tasks must be kept
in the  plans for each site investigation.

SMs  must provide  adequate verbal site operation reports to  the Project Manager,
Management personnel will audit site operations,  safety, quality  assurance,  and
progress  on a periodic basis using both announced and surprise visits.
                                     SO-16

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                                                                        DRAFT
it.it       Demobilization

SMs must give as much attention to leaving a site at end of project as to arriving
at a site.  Time and effort to  properly clean equipment, perform  maintenance
necessary for  storage, and leave the site neat and clean will be rewarded  through
increased equipment reliability, extended equipment life, and community and client
or owner goodwill.   Operating  personnel  must be advised of  the importance  of
demobilizing  to counteract the  natural tendency  to slacken their enthusiasm and
productivity after the actual site work  is finished.

*f.5       Work Zones

^.5.1      Introduction

The  activities required during  responses  to environmental  incidents involving
hazardous substances may contribute to the movement of materials (contaminants)
from  the site  to unaffected  areas.   Equipment  used around the substances and
response personnel  working around these  substances, may become  contaminated
and carry the  material into clean areas.  Material may become airborne because of
its volatility, or the disturbance  of contaminated soil may cause it to become wind
blown.  To minimize the transfer of hazardous substance(s) from the  site, due to
site activities, contamination control procedures are needed. Two general methods
are used, establishing site  work  zones  and  removing contaminants from people and
equipment.

tt.5.2      Control at the Site

A  site  must  be controlled  to  reduce  the  possibility  of (1) exposure  to any
contaminants  present and (2)  their transport  by personnel  or equipment from  the
site.  The possibility of exposure or translocation of substances can be reduced or
eliminated in a number of ways,  including—

      1.   Setting up security  and physical barriers  to exclude unnecessary person-
          nel from the general area.
                                     SO-17

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                                                                        DRAFT
      2.   Minimizing the number of personnel and equipment at the site consistent
          with effective operations.

      3.   Establishing work zones within the site.

      ^.   Establishing control points to regulate access to work zones.

      5.   Conducting operations  in a manner to reduce  the exposure of personnel
          and equipment and  to eliminate the potential for airborne dispersion.

      6.   Implementing appropriate decontamination procedures.

 4.5.3     Delineation of Work Zones

 One  method  of preventing  or  reducing the  migration of contamination  is  to
 delineate zones  on the site  where  prescribed  operations  occur.   Movement  of
 personnel and equipment between zones  and  onto the site itself is then limited  by
 access control points.  By  these  means, contamination  would be expected  to  be
 contained within certain relatively small areas  on  the  site and  its potential for
 spread minimized.  Three contiguous zones (Exhibit SO-1) are often used.

 Zone 1:   Exclusion Zone
 Zone 2:   Contamination Reduction Zone
 Zone 3:   Support Zone

 4.5.3.1    Zone  1;  Exclusion Zone

The  Exclusion  Zone, the innermost of three concentric  areas,  is the  zone where
contamination does or could occur.  All  people entering  the Exclusion Zone must
wear prescribed levels  of protection gear.  An entry and exit checkpoint must  be
established at the periphery of the Exclusion Zone to regulate the flow of  personnel
and equipment into and out of the zone to /erify that the procedures established  to
enter and exit are followed.
                                     SO-13

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                                                                        DRAFT
The  outer  boundary of  Zone  1, the Hotline, is  initially  established by  visually
surveying the  immediate  environs of  the  incident  and  determining where the
hazardous substances involved are located; where any drainage, leachate, or spilled
material is; and whether any discolorations are visible.  Guidance in determining
the boundaries is also  provided by  data  from the  initial site survey indicating the
presence of organic or inorganic vapors/gases or particulates in the air, combusti-
ble gases, and radiation, or the results of water and soil sampling.

Additional  factors that should  be considered include  the  distances needed to
prevent fire or an explosion from affecting personnel outside the zone, the  physical
area necessary to conduct  site operations, and the potential for contaminants  to be
blown  from  the  area.   Once  the Hotline  has  been  determined,  it should  be
physically secured, fenced, or well-defined  by landmarks.  During  subsequent site
operations,  the boundary  may be  modified  and  adjusted  as  more  information
becomes available.

All personnel within the Exclusion Zone  must wear the required level of protective
gear.  Personnel  protective  equipment is  designated on the basis of  site-specific
conditions, including the type of work to be done and  the hazards that  might be
encountered.  Different levels of protection in the Exclusion  Zone might also be
designated  by  job  assignment.  The assignment,  when  appropriate,  of  different
levels of protection within  the Exclusion Zone generally  makes for a more  flexible,
effective, and less costly operation, while still maintaining a high degree of safety.

4.5.3.2    Zone 2:  Contamination Reduction Zone

Between the Exclusion Zone and the Support Zone  is the Contamination  Reduction
Zone, which provides a transition between contaminated and clean zones.  Zone 2
serves as a buffer  to  further  reduce the  probability of  the clean  zone becoming
contaminated or  being affected by other  existing hazards.  It provides additional
assurance  that the physical  transfer  of  contaminating  substances  on  people,
equipment,  or in  the  air  is  limited through a combination of decontamination,
distance between the  Exclusion and Support Zones, air  dilution, zone restrictions,
and work functions.
                                     SO-19

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                                                                       DRAFT
Initially, the Contamination Reduction Zone is considered to be a noncontaminated
area. At the boundary between the Exclusion and Contamination Reduction Zones,
decontamination stations are  established for personnel and for heavy equipment.
Exit from the Exclusion Zone is through a decontamination station.

As operations proceed,  the  area around the decontamination  station may  become
contaminated, but to a  much lesser degree than the Exclusion Zone. On  a  relative
basis, the amount of contaminants should decrease from the Hotline  to the  Support
Zone due to the distance involved and the decontamination procedures used.

The  boundary between  the  Support Zone and the Contamination Reduction  Zone,
called  the  Contamination Control Line, separates the possibly  low  contamination
area from  the clean Support Zone.  Access to the Contamination Reduction Zone
from the Support  Zone  is through a control point. Personnel entering there wear
the  prescribed personnel protective  equipment, if  required, for working  in  the
Contamination Reduction Zone.   Entering the  Support  Zone requires cleaning or
removal of any protective equipment worn in the Contamination  Reduction Zone.

4.5.3.3    Zone 3;  Support Zone

The  Support Zone,  the  outermost part of the site, is considered to  be a non-
contaminated  or  clean  area.   Support  equipment  (command  post, equipment,
vehicles, etc.) is located in the zone; traffic is restricted to authorized response
personnel.  Since normal work clothes are appropriate within this zone, potentially
contaminated personnel clothing, equipment, and samples are not permitted but  are
left in the Contamination Reduction Zone until they are decontaminated.
                                    SO-20

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                            EXHIBIT SO-1
                   Diagram  of Site  Work  Zones
                                                                           DRAFT
Exclusion
  Zone
                        Hoi Line

                                                   N
                                    Access Control
                                        Points
                                    Contamination
                                      Reduction
                                      Corridor
Contamination
Reduction Zone
                                                     \
                                                      \
                                                                   — Wind Direction
                                                                    Contamination
                                                                     Control Une
                                           Command
                                             Post
Support
 Zone
                                   SO-21

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                                                                        DRAFT
4.5.4      Modifications

The use of a three-zone system, access control points, and exacting decontamina-
tion  procedures  provides  a  reasonable  assurance  against  the translocation  of
contaminating  substances.   This  site  control  system is  based on a "worst-case"
situation. Less stringent site control and decontamination procedures may be used
if  more definitive information is available  on the types of substances involved and
the hazards they  present. This information  can be obtained through air monitoring,
instrument survey and  sampling, and technical data  concerning the characteristics
and behavior of the material present.

4.5.5      Area Dimensions

The distance between the Hotline, Contamination Control Line, and command post
and the size and shape of each zone have to be based on conditions specific to each
site.  Considerable judgment is needed to ensure that the distances between zone
boundaries are large enough  to allow  room for the  necessary operations, provide
adequate  distances  to  prevent  the spread  of contaminants,  and eliminate the
possibility of injury  due to  explosion or fire.  Long-term  operations would involve
developing  reasonable  methods to  determine  if  material  is being transferred
between zones  and to assist in modifying site boundaries.

The  following  criteria should be  considered  in establishing  area  dimensions and
boundary distances:

      1.   Physical and  topographical features of the  site.

      2.   Weather conditions.

      3.   Field/laboratory  measurements  of air contaminants  and environmental
          samples.

      4.   Air dispersion calculations.

      5.   Potential for  explosion and flying debris.

                                    SO-22

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                                                                         DRAFT
     6.   Physical,  chemical,  toxicological, and other  characteristics  of  the
          substances present.

     7.   Cleanup activities required.

     8.   Potential for fire.

     9.   Area needed to conduct operations.

     10.   Decontamination procedures.

     11.   Dimensions of contaminated area.

     12.   Potential for exposure.

4.5.6     Monitoring and Sampling

To verify that site control procedures are preventing the spread of contamination,
a monitoring and sampling program should be  established. The  Support Zone should
be periodically  monitored  for  air contaminants using direct-reading instruments
and/or collecting air samples for  particulate, gas, or  vapor analysis.  Analysis of
soil  samples collected in the most  heavily traveled area would indicate contami-
nants being carried from the Exclusion Zone by personnel, equipment, or  wind.
Occasional swipe tests should be taken in trailers and other areas by personnel.

These  same types  of  samples  should  be  collected  and  air  monitored in  the
Contamination Reduction Zone. Increased concentrations in air or other environ-
mental  media may indicate  a breakdown  in  control over   the  Contamination
Reduction Corridor, ineffective decontamination procedures, or failure to restrict
site  access.

4.5.7     Personnel Identification and Mobility

Identification of an individual dressed in protective clothing is difficult.  The more
protective clothing worn, the  more difficult it  is to identify individual work party

                                     50-23

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                                                                        DRAFT
members.  Positive  identification of entry party members is essential for control
and safety.  Individuals can be identified by:

      1.   Marking with colored tape.
      2.   Writing name with felt tip marker on masking tape.
      3.   Writing name on hard hat.
      
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                                                                       DRAFT
     3.   Wearing of protective equipment will require:

          a.   More time than is usually required to do a task.
          b.   More people than are usually required to do a task.

5.0  WORK PRACTICES

The work practices specified in this section must be used by all investigators.

5.1  Personnel Practices

     •    Protective Clothing - Protective clothing must be worn by all personnel
          while working an areas of suspected or  confirmed dermal hazard  unless
          sufficient data has been acquired to enable the SM to make an informed
          judgment that protective clothing is not needed.  In the absence of clear
          indications  that  work can  proceed  safely without protective clothing,
          required items include chemical-resistant pants,  jacket, boots,  gloves,
          and hardhat  or  head  cover, and  may  include  a  fully encapsulating
          chemical protective suite.  SMs must also consider the potential hazards
          of  wearing protective clothing since protective  clothing is cumbersome,
          hastens  the onset of fatigue, increases heat stress, and increases the
          time the personnel must spend in the high-risk area.

     *    Heat Stress   Employees must compensate for  the increased heat stress
          caused by wearing protective clothing in hot weather in order to prevent
          the onset of  heat-induced  illnesses.   Employees must maintain an
          appropriate work-rest regimen and water and salt balances.

     «    Eye Protection - Devices to  provide appropriate eye protection must be
          worn on any  task where  the danger  of eye injury exists and should meet
          ANSI Z87.1,  "Practice  for  Occupational and Educational Eye  and Face
          Protection."
                                     50-25

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                                                                  DRAFT
•    Forbidden Practices - The  following practices are expressly  forbidden
     during field operations:

         Eating,  drinking, chewing gum or  tobacco, smoking, or any practice
         that increases that probability of hand-to-mouth transfer and inges-
         tion of material is prohibited in any area designated contaminated.

         Ignition  of  flammable  liquids  within,  on,  or  through improvised
         heating devices (barrels, etc.) or space heaters.

         Approach or entry  into areas or spaces  where toxic or  explosive
         concentrations of gases or dust may exist without proper equipment
         available to enable safe entry.

         Medicine and alcohol can potentiate  the effects from  exposure  to
         toxic chemicals.  Prescribed drugs should not be taken by  personnel
         on response operations if there is a likelihood of such potentiation.

         Conduct of on-site operations without off-site backup personnel.
         Site Managers may exercise informed judgment regarding the need
         for  off-site  backup at active sites, or in cases where sites have been
         repeatedly entered or occupied without apparent harm.  In any case
         where doubt exists, backup personnel must be present.

•    Personal Hygiene   All personnel  must wash the affected  area immedi-
     ately after obvious contact  with a hazardous substance, report incident
     to SM, and seek appropriate  medical care or testing.

•    Personnel and equipment in  the  contaminated area should be minimized,
     consistent with effective site operations.

*    Whenever decontamination procedures  for  outer  garments  are  in effect,
     the entire body should be thoroughly washed as soon as possible after the
     protective garment is removed.
                               50-26

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                                                                        DRAFT
     •    No excessive facial hair, which interferes  with a satisfactory  fit of the
          mask-to-face seal, is allowed on personnel required to  wear respiratory
          protective equipment.

     «    Contact with contaminated  surfaces or with surfaces suspected of being
          contaminated should be avoided. Whenever possible, one should not  walk
          through puddles, mud,  and other discolored surfaces;  kneel on  ground;
          lean, sit,  or place equipment  on  drums, containers,  vehicles,  or  the
          ground.

5.2  Operational Practices

     •    Information  Review and Reconnaissance  -  The Safety Plan for  a  field
          investigation must be based  upon a thorough evaluation of existing data
          and review  of follow-up reports  from  previous  investigations.  The
          information  search  may indicate possible chemical  hazards  such as the
          presence of  incompatible  chemicals,  toxic gases, explosives, etc.  Such
          indications may  provide insight to specific  safety  precautions  needed.
          Similarly,  a  perimeter  inspection or aerial  imagery, followed  by an on-
          site reconnaissance, may reveal safety hazards requiring special atten-
          tion.

          Investigators and response personnel will normally become better able to
          specify appropriate safety precautions as  they get  progressively closer
          to, and measure, hazardous  materials in air, runoff, ground water, soil,
          spilled  material, barrels, etc.

     »    Protection Levels - Although the SM must determine the level  of protec-
          tion which is appropriate for each task,  four specific  protection levels
          have been provided as benchmarks for the SM.  The SM  must  select a
          level based on available information.
                                     SO-27

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                                                                  DRAFT
t»    Zones - Zones must be established, clearly delineated, and posted:

         Decontamination Zone  -  During operations on  a suspect or known
         HWS, a zone must be established for decontamination of equipment
         and personnel and access control just outside the area of suspected
         contamination.

         Contamination Zone(s) - The area(s) which contains, or is suspected
         of containing, hazardous  materials  must be clearly  delineated and
         posted.  The SM may establish more than one contamination zone
         for  areas of different  levels of potential personnel hazard.  Only
         persons authorized by the SM may enter a contamination zone.

•    Radioactivity and Explosivity  -  All HWSs must be  checked for  radio-
     activity  and explosivity during first entry onto the  site.   Normal back-
     ground radioactivity is  approximately 0.01 to 0.02  mR/hr.  Detecting
     levels of activity significantly greater than normal  background is cause
     for a  careful survey of the entire  site;  if levels above two  mR/hr are
     encountered, the advice of a competent  radiation health physicist should
     be sought before continuing operations on the site.  (EPA's Office of Air,
     Noise, and Radiation has radiation specialists in each EPA office as well
     as staff at HQ, EER-Montgomery, and ORD Las Vegas.

     If explosivity readings less than 10  percent Lower Explosive Limit (LED
     of methane are detected, continue surveys of the area. Ambient readings
     approaching or exceeding  10 percent LEL are cause  for immediately
     withdrawing personnel and notifying the  emergency, fire, and explosion
     units.  The SM must be consulted before continuing operations.

•    Buddy System    A minimum of two employees, in constant communica-
     tion (either visual with flags or hand signals or  voice  via radio or normal
     voice) with each other,  are  required to perform any  work in contamina-
     tion zones.  Appropriate emergency planning and  work communications
     are needed to keep site personei in touch  with each other.
                               SO-2S

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                                                                  DRAFT
•   Sampling Procedures - Sampling  procedures must minimize the risk  of
    personnel exposure to hazardous  materials  during sampling, packaging,
    shipping, and analysis; and minimize the risk  of exposure of  others  to
    spilled or residual waste  materials.  As a general rule, sampling  equip-
    ment used on an HWS should  be  disposable.  Sampling instruments and
    other  nondisposable  equipment  should  be  kept  clean with  disposable
    protective covers.  Dippers, scoops, and similar devices for solid samples
    should be placed in plastic bags for disposal or later decontamination.
    Liquid samples from barrels or tanks should be withdrawn in inert tubing,
    such as glass, and tubing should then  be broken and abandoned within the
    barrel or tank.  If incineration or recycling of contents is contemplated,
    the tubing may be diposed of  in other suitable  containers.   Whenever
    possible, equipment should  be  decontaminated prior  to  leaving the work
    area.  Equipment which cannot be decontaminated at the  scene must  be
    double-bagged  and  transported to another area for eventual decontami-
    nation.  Where possible,  verify  completeness of decontamination with
    sniffers, swipe  tests, or other appropriate tests.

•   Sample Handling -  Samples of runoff, ambient  air, or ground water may
    be  moved directly  into  laboratories and  handled with  normal  safety
    precautions,  unless the SM  determines that special handling is appropri-
    ate.   However,  samples of  liquids  or solid materials  removed from
    containers or obviously contaminated spill  areas must be  assumed to  be
    hazardous materials and handled accordingly.  Hazardous materials must
    be  packaged to withstand shocks, pressure  changes, and  any  other
    conditions which might cause  leakage  of  contents incident to ordinary
    handling during transportation.  Shipments of hazardous materials must
    be in  accordance with DOT  regulations.

•   Respirator Program  -  A respirator  use program  must be provided for
    investigators and personnel  who enter areas where a potential for  inhala-
    tion exposure to a hazardous material is present.  This program will meet
    the requirements of the OSHA General Industry Standards  for respiratory
    protection as  detailed in  29  CFR  1919.134.  The  respirators must  be
    certified in  accordance with the  requirements  of  the  National Institute
                                SO-29

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                                                              DRAFT
for Occupational Safety and Health (NIOSH) under the  provisions of 30
CFR  11.  The  selection and use of  respirators must be  approved by the
Site Safety Officer.

Cartridge or emergency escape respirators must be carried on-site when
the SM judges that, although the risk is very low, hazardous materials
may become present in  the air during operations.  The  respirators  must
be donned immediately upon experiencing any of the warning properties
described immediately above.  The user must leave the site immediately
after donning an escape  respirator  or if the warning properties persist
after donning a cartridge respirator.

Leaving the Site - Procedures for leaving the suspect contaminated area
must be planned  before entry.   Provision must be made for:   decontami-
nation and safe  packaging of protective clothing;  disposal or packaging
of disposable  gear; handling of samples and  preparation of  samples for
shipment; transfer of equipment, gear, and samples from the contami-
nated  area  to  the  clean area;  etc.   Sequences  will depend  on several
variables—such as SCBA inside or  outside  of protective clothing--but
must be worked out in advance.

Monitoring  Equipment  -  For immediate evaluation  of  potential health
hazards, use direct reading instruments such as portable combustible gas
and oxygen  meters, photoionization meters,  gas chromatographs, infra-
red spectrometers, radiation survey meters, and  colorimetric detector
tubes.  The  SM must be aware  of the  limitation  of these portable direct
reading instruments  when  characterizing  the  unknown chemicals  at
unknown concentrations at work areas.

Decontamination - Procedures, equipment, and supplies for decontamina-
tion  must be available on-site.  The equipment and supplies  must allow
employees to wash exposed areas of their bodies as well as equipment or
other items  which have been in the  contamination  zone,  and  collect the
washwater and other contaminated materials for  disposal.   The equip-
ment  must include  at least an  emergency eye wash and may include  a
personnel  shower.
                           SO-30

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                                                                       DRAFT
6.0       DECONTAMINATION

6.1       Introduction

Personnel responding to hazardous-substance incidents may become contaminated
in a number of ways:

      1.   Contacting vapors, gases, mists, or particulates in the air
      2.   Being splashed by materials while  sampling or opening containers
      3.   Walking through puddles of liquids or on contaminated soil
      >4.   Using contaminated instruments or equipment

Protective  clothing and  respirators help  prevent the  wearer  from  becoming
contaminated or inhaling contaminants, while  good work practices help reduce the
contamination of protective clothing, instruments, and equipment.

Even  with  these safeguards, contamination  may occur.  Harmful  materials can be
transferred into clean areas, exposing  unprotected personnel.  In removing con-
taminated  clothing,  personnel  may  come  into  contact  with  and/or inhale the
contaminants.  To prevent such occurrences, contamination reduction and decon-
tamination procedures must be developed and implemented.  Such procedures must
be in place before  anyone enters a site  and  they  must continue  (modified as
necessary) throughout the  period of site  operation.

Decontamination   involves physically removing  contaminants  and/or converting
them  chemically  into innocuous substances.  How extensive decontamination must
be depends on a number  of  factors,  the most  important  being the  types of
contaminants  involved.  The  more harmful the  contaminant, the more extensive
and thorough decontamination must be.  Less  harmful contaminants  may  require
less decontamination.  Combining decontamination, the correct doffing of protec-
tive equipment, and the zoning of site  work areas minimizes cross-contamination
from  protective  clothing  to  wearer, equipment to  personnel, and  one  area to
another.   Only general  guidance can  be  given on  methods  and techniques  for
decontamination.  The exact procedure  is determined by evaluating factors specific
to the incident.
                                     SO-31

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                                                                        DRAFT
6.2       Preliminary Concerns

6.2.1     Initial Planning

The initial decontamination plan  is based on the assumption that all personnel and
equipment leaving the Exclusion Zone (area of potential contamination) are grossly
contaminated.  The plan includes a system for washing and rinsing, at least once,
all the protective equipment worn.  The washing and rinsing are done in combina-
tion  with a  sequential  doffing  of equipment, starting  with  the  most heavily
contaminated article and progressing to the the least contaminated article.

The spread  of  contaminants  during  the washing and  doffing  process  is further
reduced by separating each decontamination step from the previous one.  Ideally,
contamination should decrease as a person  moves from one step to another along
the line.

While  planning site operations, methods must be developed and used to prevent the
contamination of people and  equipment.   For example,  using remote  sampling
techniques, opening  containers by  nonmanual  means, bagging  monitoring instru-
ments, using  drum grapplers,  watering down dusty  areas,  and  avoiding  areas of
obvious contamination would  reduce  the probability of contamination and  would
preclude a more elaborate decontamination procedure.

The initial  decontamination  plan  is  based on  a  worst-case situation  (if  no
information is available about the  incident).  Specific  conditions at  the  site are
then evaluated, including:

      1.   Type of contaminant
      2.   Amount of contamination
      3.   Levels of protection  required
      4.   Type of protective clothing worn

The initial plan is modified by eliminating unnecessary  stations  or  it  is otherwise
adapted to site conditions.   For instance, the plan might require a complete wash
and rinse  of protective garments.  If disposable garments are worn, the wash  and
                                     SO-32

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                                                                       DRAFT
rinse  step could  be  omitted.  Wearing  disposable boot  covers and gloves could
eliminate the washing and  rinsing of  gloves and  disposable boots and reduce the
number of stations needed.

6.2.2     Contamination Reduction Corridor

An area within the Contamination Reduction Zone (Exhibit SO-2) is designated the
Contamination Reduction Corridor (CRC).  The CRC controls access into and out
of the Exclusion Zone and confines  personnel  decontamination  activities  to  a
limited area.  The size of  the corridor  depends  on the number of stations  in the
decontamination procedure, the overall dimensions of work control zones, and the
amount of space available  at the site.  A corridor of  75 by 15 feet should be
adequate for  full decontamination.  Whenever possible, it should be a straight path.

The  CRC  boundaries  should be  conspicuously  marked,  with  entry  and  exit
restricted. The far  end  is the hotline—the  boundary between the Exclusion Zone
and the Contamination Reduction Zone.  Personnel exiting the Exclusion Zone must
go  through  the CRC.   Anyone  in the CRC  should  be  wearing  the  Level of
Protection  designated for  the decontamination  crew.   Another  corridor may be
required  for  the entrance and exit of heavy equipment needing decontamination.
Within the CRC, distinct areas are set aside for the decontamination of personnel,
portable  field equipment, removed clothing,  etc. These  areas should be  marked and
restricted to  those  personnel wearing the  appropriate Level of  Protection.  All
activities within the  corridor are confined to decontamination.

Protective  clothing, respirators,  monitoring equipment, sampling  supplies,  and
other equipment  are all  maintained outside  of  the CRC.   Personnel don  their
protective equipment away  from the CRC and enter the Exclusion Zone through a
separate  access control point at the hotline.
                                     SO-33

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                                    EXHIBIT SO-2
                         TYPICAL PA/SI DECONTAMINATION LAYOUT
                                      EXCLUSION ZONE
HOT LINE
CRC
1.   Equipment and Drop.




2.   Decontamination Solution Wash.




3.   Rinse




4.   Canister/Tank Change.




5.   Outer  Glove and Boot  Remover.




6.   Respiratory Protection  Removal.




7.   Dermal  Protection Removal.




8.   Field  Wash.
                                     SO-34

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                                                                       DRAFT
6.3       Extent of Decontamination Required

6.3.1      Modifications of Initial Plan

The original  decontamination plan  must be adapted to conditions specific to each
incident.  These conditions  may require  more or less personnel decontamination
than planned, depending on a number of factors.

6.3.1.1    Type of Contaminant

The extent of personnel  decontamination depends on the effects the contaminants
have on the  body.  Contaminants do not exhibit the  same degree of toxicity  (or
other hazard).   The more toxic a substance is, the  more extensive or thorough
decontamination must  be.  Whenever it is known or suspected  that personnel can
become contaminated with  highly toxic or skin-destructive  substances,  a full
decontamination procedure  should  be followed.  If less hazardous materials are
involved, the procedure can be downgraded.

6.3.1.2    Amount of Contamination

The amount of  contamination on protective clothing is usually determined visually.
If  the  clothing  is  badly contaminated,  a thorough decontamination  is  generally
required.   Gross material remaining on the protective  clothing for  any extended
period of time  may degrade or permeate  it.  This likelihood increases with  higher
air concentrations  and greater amounts of liquid contamination.  Gross contamina-
tion  also  increases the probability of personnel contact.  Swipe  tests  may help
determine the type and quantity  of  surface contaminants.
                                    50-35

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                                                                        DRAFT
6.3.1.3    Level of Protection

The  Level  of  Protection and  specific pieces of clothing worn  determine on  a
preliminary basis the layout of the decontamination line. Each Level of Protection
presents different problems with respect to  the decontamination and doffing of the
equipment. For example, the decontamination of the harness straps and backpack
assembly of the self-contained breathing apparatus (SCBA) is difficult.   A butyl
rubber  apron worn  over  the  harness makes decontamination  easier.   Clothing
variations and  different Levels of  Protection may require  the addition or  deletion
of stations used in the original decontamination procedure.

6.3.1.4    Work Function

The  work  that  each  person  does  determines  the  potential  for  contact  with
hazardous materials.  In turn, this dictates the layout of the  decontamination line.
Observers,  photographers, operators  of  air  samplers,  or  others in  the Exclusion
Zone performing tasks that will not bring them in contact  with contaminants may
not need, for example, to have their garments  washed and rinsed.  Others in the
Exclusion Zone with a potential for direct contact with the  hazardous material will
require  more thorough decontamination.  Different decontamination lines could be
set up for different job functions, or certain stations in  a line could be omitted for
personnel performing certain tasks.

6.3.1.5    Location of Contamination

Contamination  on the upper areas of protective clothing poses a greater risk to the
worker  because volatile compounds could make breathing  hazardous both for  the
worker  and  for the  decontamination  personnel.   There is also  an  increased
probability of contaminant contact with the skin  when the worker  is doffing  the
upper part of the clothing.
                                     50-36

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                                                                       DRAFT
6.3.1.6    Reason for Leaving Site

The reason for  leaving the Exclusion Zone also determines the need for and extent
of decontamination. A worker leaving the Exclusion Zone  to  pick up or drop off
tools or instruments and immediately  returning may not  require decontamination.
A  worker  leaving to get a new air cylinder or change a respirator or canisters,
however,  may require  some degree of decontamination.  Individuals  departing the
CRC  at  breaktime,  lunchtime, or  the end of  the day  must be  thoroughly
decontaminated.

6.3.2      Effectiveness of Decontamination

There is no method of determining immediately how effective decontamination is
in removing contaminants.   Discolorations,  stains, corrosion,  and residues  on
objects  may indicate  that  contaminants  have not been  removed.   However,
observable effects only indicate surface contamination and not permeation (absorp-
tion) into  clothing.  Many contaminants are not easily observed.

One method for determining the effectiveness of surface  decontamination is swipe
testing. Cloth or paper patches—swipes—are wiped over predetermined surfaces of
the suspect object  and later analyzed in a laboratory.   Both  the  inner and outer
surfaces of protective clothing  should be swipe tested.  Positive results for both
sets of swipes would indicate that surface contamination  has not been removed and
substances have penetrated or permeated  the garment.  Swipe tests can also be
performed on skin or inside clothing.   Laboratory analysis is required to determine
if  protective garments  have been  permeated.  Both swipe and permeation testing
provide after-the-fact  information.   Along  with  visual observations, results of
these tests can help in ascertaining the effectiveness of decontamination.

6.3.3      Equipment

Decontamination equipment, materials, and  supplies are  generally selected on  the
basis of availability.  The ease of equipment decontamination  and disposability  are
also  considered.  Most equipment and  supplies can  be easily procured.  Soft-bristle
scrub brushes or long-handle brushes are used to remove contaminants.  Buckets of
                                     SO-37

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                                                                        DRAFT
water or  garden sprayers are used for rinsing.  Large galvanized wash tubs, stock
tanks, or  children's  wading pools can also be used as  containers for wash and rinse
solutions.  Large plastic garbage cans or similar containers lined with plastic bags
are useful for the storage  of  contaminated clothing  and equipment, and metal or
plastic cans  or  drums are convenient for the temporary storage of contaminated
liquids.  Other  gear includes paper  or cloth towels for  drying protective clothing
and equipment.

6.3.4     Decontamination Solution

Protective equipment, sampling tools, and other equipment are  usually decontami-
nated by  scrubbing with detergent  water using a soft-bristle  brush, followed by
rinsing with  copious  amounts  of  water.   While this process  may not  be  fully
effective in  removing  some contaminants (in some cases, the  contaminants may
react with  water), it  is  a relatively  safe  option   compared  to  the  use of  a
decontaminating  solution.   The contaminant must be identified before  a  decon
chemical  is used, and reactions of such a chemical with unidentified substances or
mixtures  could  be especially  troublesome.  A  decontamination solution  must be
selected in consultation with an experienced chemist.

6.3.5     Establishment of Procedures

Once  decontamination procedures have been established,  all personnel requiring
decontamination must  be  given precise instructions  (and practice, if necessary).
Compliance with the procedures must be frequently checked.  The time it takes for
decontamination must be ascertained.  Personnel wearing self-contained  breathing
apparatuses (SCBAs) must leave their work areas with sufficient air to walk to the
CRC  and  go through decontamination.

6.*       Decontamination During Medical Emergencies

6.4.1      Basic  Considerations

Part  of the overall  planning for incident response is  managing medical emergen-
cies.  The plan should provide for the following?

                                     SO-38

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                                                                        DRAFT
     1.   Full training of some  response  team members in first aid and cardiopul-
          monary resuscitation.

     2.   Arrangements  with the nearest medical facility for transportation  and
          treatment of the injured, and for the treatment of  personnel suffering
          from exposure  to chemicals.

     3.   Consultation with a toxicologist.

     4.   Emergency eye washes, showers, and wash stations.

     5.   First aid kits, blankets, a stretcher, and a resuscitator.

In addition, the plan should have established methods for  decontaminating person-
nel  with medical  problems and injuries.  There is  the possibility that decontamina-
tion may aggravate a health problem or cause more serious  problems.  If prompt
life-saving first aid and/or medical treatment is  required, decontamination proce-
dures should be omitted.  Whenever possible, response personnel should accompany
contaminated  victims to the  medical  facility  to  advise  on  matters involving
decontamination.

6.4.2     Physical Injury

Physical injuries  can  range  from a sprained ankle to  a compound fracture, or from
a minor cut  to massive  bleeding.  Depending on  the  seriousness of  the injury,
treatment  may be given at  the  site by  trained response  personnel.  For more
serious  injuries, additional assistance may be required at the site or the victim may
have to be treated at a medical  facility.

Life-saving care  should be  instituted immediately without considering decontami-
nation.  The outside garments can be  removed (depending on the  weather) if  this
does not cause  delays,  interfere  with  treatment, or  aggravate  the  problem.
Respiratory masks and  backpack assemblies  must always  be  removed.  Fully
encapsulating  suits or chemical-resistant clothing can be cut  away.  If the outer
contaminated  garments cannot be safely removed, the individual should be  wrapped

                                     50-39

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                                                                        DRAFT
in plastic, rubber, or blankets to help prevent contaminating  medical personnel
and/or  the  inside  of ambulances.   Outside garments are  then  removed  at  the
medical facility.  No attempt should be made to wash or rinse the victim unless it
is known that he  has  been contaminated with an  extremely  toxic or corrosive
material that could also cause severe injury or loss of life.  For minor  medical
problems or injuries, the normal decontamination procedure should be followed.

6.4.3     Heat Stress

Heat-related illnesses range from heat fatigue to heat stroke, the latter being the
most serious. Heat stroke requires prompt treatment to prevent irreversible brain
damage or death.  Protective  clothing may have to be cut off.  Less serious forms
of heat stress require prompt attention or they may  lead to a heat stroke.  Unless
the  victim   is obviously  contaminated,  decontamination should  be  omitted  or
minimized and treatment begun immediately.

6.*.*     Chemical Exposure

Exposure to chemicals can be divided into  two categories:

      1.  Direct contact through  either touch (e.g., acid burns) or inhalation.
      2.  Indirect contact through gross contamination of  clothing or equipment.

Injuries from contaminant inhalation can only be treated by qualified physicians. If
the contaminant  is on the skin or in  the eyes, immediate measures must be taken to
counteract its effect.  First aid treatment  usually involves  flooding the affected
area  with water; however,  for a few chemicals, water  may  cause more  severe
problems.

When protective  clothing is grossly contaminated, contaminants may be transferred
to the wearer or  to  treatment personnel  and  may cause  injuries.   Unless  severe
medical problems could be created by splashing of the contaminant, the protective
clothing should be washed off as rapidly as possible and carefully removed.
                                     SO-40

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                                                                        DRAFT
6.5       Protection for Decontamination Workers

The  Level of  Protection worn by decontamination  workers is  determined  by  the
protection worn by site investigators.  Decon workers must be at least at the same
level. Evaluation criteria for selecting proper protection include:

      1.   Expected or visible contamination on workers.
      2.   Type of contaminant and associated respiratory and skin hazards.
      3.   Total vapor/gas concentrations in the CRC.
      *f.   Particulates and specific inorganic or organic vapors in  the CRC.
      5.   Results of swipe tests.
      6.   The presence (or suspected presence) of highly toxic or skin-destructive
          materials.

6.6       Decontamination of Equipment

6.6.1      Basic Considerations

All possible measures should be taken to prevent the contamination of sampling and
monitoring equipment.  Sampling devices become  contaminated, but  monitoring
instruments, unless they are splashed, usually do not. Once instruments have been
contaminated,  it  is difficult to clean them  without damaging them.  Any delicate
instrument that cannot  be decontaminated easily should be protected while  it is
being used. It should  be bagged, and the bag  should be taped and secured  around
the instrument. Openings are made  in the bag for sample intake.  Solutions picked
by chemist based on type of contamination.
                                     SO-fl

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                                                                       DRAFT
6.6.2     Decontamination Procedures

6.6.2.1    Sampling Devices

Sampling devices  require special cleaning. The Site Safety personnel can provide
information on proper decontamination methods.

6.6.2.2    Tools

Wooden  tools are  difficult to decontaminate because they absorb chemicals.  They
should be kept on the site and handled only by protected workers.  At the end of
the  response, such tools  should be disposed of as hazardous waste.  Other tools
should be decontaminated.

6.6.2.3    Respirators

Certain  parts of  contaminated respirators,  such  as  the  harness assembly and
leather or cloth components, are difficult to decontaminate.  If grossly contami-
nated, they may have to  be discarded.  Rubber components can be soaked in soap
and water and scrubbed with a brush.  Regulators must be maintained according to
the  manufacturer's  recommendations.  Persons  responsible for decontaminating
respirators should  be  thoroughly trained in  respirator maintenance.

6.6.2.4    Heavy Equipment

Bulldozers,  trucks, backhoes,  bulking chambers, and other heavy  equipment are
difficult to decontaminate. The method generally used  is to wash them with water
under  high  pressure   and/or  to  scrub accessible parts with  a detergent/water
solution  under pressure.   In some cases, shovels, scoops, and lifts  have  been
sandblasted or steam-cleaned. Particular  care must be given to tires, scoops, and
other components  in direct contact with contaminants.  Swipe tests should be used
to determine effectiveness of the decontamination process.
                                    SO-42

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                                                                        DRAFT
6.6.3      Personnel Protective Equipment

In addition to being decontaminated, all respirators, protective clothing, and other
personal articles must be sanitized before they can be used again.  The insides of
masks and clothing become  soiled from exhalation, body oils, and perspiration.  The
manufacturer's instructions  should be followed in sanitizing the respirator mask. If
practicable,  protective  clothing should be  machine  washed after  a thorough
decontamination; otherwise, it should be cleaned by hand.

6.6.*      Persistent Contamination

In  some  instances,  clothing  and  equipment will  become  contaminated  with
substances that cannot  be  removed by  normal decontamination  procedures.  A
solvent  may be used to remove such contamination from  equipment if  it does not
destroy  or  degrade  the protective  material.   If  persistent  contamination is
expected, disposable  garments should be used.  Testing for persistent  contamina-
tion of  protective clothing and  appropriate  decontamination must be done  by
qualified laboratory personnel.

6.6.5      Disposal of Contaminated  Materials

All materials  and equipment  used  for decontamination  must  be disposed  of
properly.   Clothing,  tools, buckets, brushes, and  all other  equipment  that is
contaminated must be secured  in drums or other containers and labeled.  Clothing
not completely decontaminated on the site should be secured in plastic  bags before
it is removed from  the site.

Contaminated  wash  and rinse solutions can  be  kept temporarily  in a  step-in
container (for example, child's  wading pool) or in a plastic-lined trench  about 14 in.
deep.  Such solutions  are ultimately transferred to labeled drums and  disposed of
with other substances on the site.

Attachment  A describes basic decontamination  procedures for workers  wearing
Level A, B, or C protection.
                                     SO-43

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                                                                        DRAFT
7.0       FIRST AID

Employees  are  often required to  work in locations far from  medical  aid  and
communications.  Injuries received must be treated by coworkers, passersby, or
even  the injured  employee.   It  is, therefore, important that all  employees be
knowledgeable in first-aid procedures.

7.1       Assessing the Situation

Use the  following steps to assess  what emergency problems exist and what actions
are needed:

Use the  following steps to assess  what emergency problems exist and what actions
are needed:

      1.   Don't  panic.  You will  be able to assess the situation more effectively.
          Remember, psychological support is also important.

      2.   Look  for an emergency medical identification tag on the victim's wrist,
          ankle, or neck.  Check his wallet for an identification card with further
          instructions.   Another  alerting device could be a sticker on  the wind-
          shield of the victim's car.

      3.   Remember the  ABC's of life support:

          a.  Airway open.  Open and maintain the victim's airway.

          b.  Breathing  restored.  If  the victim is not breathing,  begin rescue
              breathing techniques  immediately.

          c.  Circulation maintained.  If there is no pulse, start external cardiac
              compression immediately.

      >t.   Check for bleeding.  If  bleeding is found, apply direct pressure, elevate
          the injured limb ony if it does not cause  further pain or injury, and apply
                                     SO-W

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                                                                        DRAFT
          pressure on the blood-supplying artery.  Use a tourniquet only as a  last
          resort for severe life-threatening hemorrhage when all other measures
          fail.

     5.   Look for signs of shock and broken bones.

     6.   Get professional help  quickly.  Know emergency numbers such as 0 or
          911.  Telephone appropriate authorities (rescue squad, ambulance, police,
          poison control center, or fire department) and describe the problem.  Be
          sure to give your name and location,  as well as the number of persons
          involved.

     7.   Loosen any clothing that may  restrict  the victim's breathing or interfere
          with circulation.

     8.   Never give an unconscious person anything by mouth.

     9.   Do not  move injured  persons unless  the  situation is life  threatening.
          Keep  the victim  still,  quiet,  and  warm  (except in  cases   of  heat
          exhaustion and  sunstroke).  A victim with broken  bones should not be
          moved until a splint has been properly applied.

7.2       Vital Signs

Once  the situation  is  stabilized,  the victim's  breathing and heartbeat  must be
checked.  Pulmonary resuscitation techniques are used  to restore breathing, and
cardiac compression is used to restore the heartbeat.

7.2.1      Pulmonary Resuscitation

Symptons of breathing difficulties include shortness  of breath, dizziness, chest
pain, rapid pulse, bluish-purple skin color, dilated pupils, and  unconsciousness.  The
following procedure  should be used for persons who have stopped breathing:
                                     SO-45

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                                                                        DRAFT
      1.   Lay the victim on his back.  Place one hand under the victim's neck and
          lift, tilting the head back as far as possible with other hand to open the
          airway.   Avoid exaggerated head  tilt in infants, small  children, and
          victims with neck and back injuries.

      2.   Look, listen, and feel for respiratory  movement. If breathing is absent,
          pinch the victim's nostrils closed, take a deep breath,  and completely
          cover the victim's mouth.  Give four quick full breaths.  If the chest does
          not rise, check for airway obstruction.

      3.   Clear the airway using your fingers in a  hooked fashion to remove any
          solid or liquid obstructions.  If the victim has a  tracheostomy (permanent
          opening in neck), start rescue  breathing by placing your mouth  over the
          neck opening (stoma) rather than the mouth.

      if.   If  a  pulse is  present, continue rescue  breathing at a rate of  1 strong
          breath every 5 seconds (i.e.,  12 per minute) for adults or 1 shallow breath
          every 3 seconds (i.e., 20 per minute) for small children.

      5.   If  a  pulse is  not present, start  external  cardiopulmonary resuscitation
          (CPR).

7.2.2     Cardiac Compression

Symptons of heartbeat problems include  those for breathing difficulty.  Heartbeat
can be checked by feeling for a pulse.

The  normal  adult  heart rate is  60  to 80.   Children  are slightly  faster and
excitement, exercise, or fever may  increase the heartbeat.   Pulse  rates can be
determined as follows:

      1.   Place the  tips of your  index  and  middle  fingers  on  your side of the
          victim's neck  next to the airway  to feel for a pulse.   Do not use your
          thumb, as this will confuse the victim's pulse with your own.
                                     SO-46

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                                                                       DRAFT
     2.  Once a pulse has been  located, count the number of beats in 15 seconds
         and  multiply by 4, or, if the pulse is very slow or irregular, count for an
         entire 60 seconds.

         A pulse  rate may vary  depending on the victim's condition. The normal
         adult male pulse is 54 to 70 beats per minute; for a female it is 75 to  80.
         A young child's  pulse  ranges  between  80 to  180.  In addition to  the
         number  of  beats, be sure  to  note whether the pulse  is full,  weak,
         bounding, or irregular.

Lack of heartbeat or pulse requires starting CPR.  There are two methods of giving
CPR depending on whether two people are available or only one.

7.2.2.1   One-Rescuer CPR

Apply  80 compressions per  minute.   Every  15 compressions should be followed by
two very quick breaths.   Call  for  professional  medical help as soon as possible.
Keep  the  victim warm and still.  Signs of recovery include  a return  to normal
breathing, an improvement in skin color, and the movement of arms and legs.

For adults, once must exert enough pressure to depress the breastplate 1-1/2 to  2
inches. Every five compressions  should  be followed without pause by one rescue
breath. Children require  the heel of only one hand to depress the breastplate  3/4
to 1-1/2 inch.  Continue compressions at a rate  of  100 per minute.  Every five
compressions should be followed without a pause by one rescue breath.

7.2.2.2   Two-Person CPR

Partner A begins with first four mouth-to-mouth or mouth-to-nose rescue breaths.
Partner B kneels with shoulders  directly  over victim's breastplate and  places  the
heels of both hands one on top  of the other with fingers interlocked over the  lower
half of the  sternum.  The elbows should be straight.

Partners should trade positions if  they  become tired.  The CPR should continue
until the partners  are exhausted  or  relieved, or until a physician can evaluate  the
victim's condition.
                                     SO-47

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                                                                       DRAFT
7.3       Wound Care

When possible, wash hands thoroughly with soap and  water before administering
first aid.  Even minor  cuts and scrapes  can become contaminated and infected.
Using the following  good wound management techniques can prevent or  reduce the
possibility of infection. Prepare a clean,  uncluttered place to put articles required
to provide care.  Under emergency conditions, when this is not possible, try not to
touch the wound unnecessarily, breathe on  the wound, or cough over the wound.
Keep the wound and all first-aid materials as  clean as possible.  When operating
packages of sterile pads or dressings, handle only the edges.  Do not touch the area
that comes in contact with the wound.

7.3.1     Surface  Wounds

Cleanse  the  wound and the surrounding area gently with  mild soap and water and
rinse.  Blot the wound dry with a sterile pad or clean dressing.  Treat the wound to
protect against contamination and cover it to  soak up fluids and prevent further
contamination.  Handle only the edges  of sterile pads or dressings.

The following bandage types may be used:

      1.   Adhesive pads for large wounds,  cuts, or  scrapes.  This  is a convenient,
          one-step bandage to cushion  and protect.

      2.   Sterile pads for cuts, scrapes, or other minor wounds.

      3.   Nonstick sterile pads  for bleeding and draining wounds, burns, and infec-
          tions. These will not stick to the  wound or disrupt the healing process.

      *4.   Rolled gauze for securing sterile  pads.  This  is especially good for joints
          and hard-to-bandage wounds.

     5,   Tape bandage secured with first-aid tape to help keep out dirt and germs.
                                    SO-48

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                                                                       DRAFT

7.3.2      Deep Wounds and Serious Burns

These  types of wounds should be cleansed only by professional medical personnel.
The patient should be treated for bleeding and shock.  One must be alert for signs
of infection such as a hot, painful reddening around the wound, swelling, chills, and
fever.   Consult  a  physician  immediately, and  check for  immunization  against
tetanus within the past 5 years.

7.4       Bandaging

Emergency bandages can  be devised from clean handkerchiefs, sheets, belts, socks,
or stockings.   Bandages  should be snug but not  tight enough  to interfere with
circulation.  Always leave the victim's fingertips or  toes exposed  when a splint or
bandage  is applied  to  the  arms or  legs.    Loosen the  bandage  if swelling,
discoloration, or a cold, numb, or  tingling sensation  occurs  in the fingers or toes.
Never  apply a tight bandage to the victim's neck, as the circulation of blood to  the
brain may be restricted or stopped.

7.5       REFERENCES

Cornish,  H.H. and  1. Adefuin.    1967.  "Potentiation  of  Carbon Tetrachloride
Toxicity by Aliphatic Alcohols." Arch.  Environ. Health, Vol. 14, pp. 447-449.

Dixon, R.L. 1980. "Toxic Responses of the Reproductive System".  In Casarett  and
Doull's Toxicology, edited by 1. Doull, C.D. Klaassen, and M.O. Amdur, Macmillian,
New York, N.Y., pp. 332-356.

Goldstein,  G.M. and  3.   Doull.    1971.     "Treatment  of   Nitrite  Induced
\\ethemoglobinemia with Hypebaric Oxygen."  Proc. Soc. Exp. Biol. Med., Vol.  138,
pp.  137-139.

Gosselin,  R.E.,  H.C. Hodge, R.P.  Smith, and  M.N. Gleason.    1976.   Clinical
Toxicology of Commercial  Products;    Acute  Poisoning,  4th  ed.,  Williams  and
 \Vilkins Co., Baltimore, NAd.
                                     SO-49

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                                                                      DRAFT
Habison, R.D. and R.L. Dixon.  1978.  "Proceedings of the Symposium on Target
Organ Toxicity:   Gonads (Reproductive and  Genetic  Toxicity)."   Environ.  Hlth.
Perspect, Vol.  2
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                                                                        DRAFT

8.0       EMERGENCY PLANNING

An emergency plan must be covering the  most probable emergency situations must
be developed, personnel must be trained to perform the plan, and periodic drills
must be performed.  Typically, an emergency plan will need  to consider:

     •    Fire/explosion
     »    Injury/poisoning
     •    Chemical spill
     *    Evacuation procedures

Each emergency plan will require  a chain-of-command, development of required
response action, identifying response teams, posting of  a list of local emergency
agencies  in  all  mobile offices/trailers,  identifying site  medical personnel, and
reporting  procedures.  Reports must be made for all incidents  involving injuries  or
property damage.  Reports will be completed by the SM as  soon after the incident
as possible and forwarded to appropriate management and safety personnel. Injuries
requiring  medical  treatment beyond first aid must be reported within  24 hours  by
phone, followed by the written report.
                                     SO-51

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ATTACHMENT A

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                                                   1/11/85
                                              New Page M-l
                        APPENDIX M


                SITE SAFETY PLAN GUIDANCE


PURPOSE

    This appendix has been extracted from the Standard
Operating Safety Guidelines (SOSG),  issued by EPA's Office
of Emergency and Remedial Response (OERR).   It is provided
here to assist State Project Officers (SPOs)  and Regional
Site Project Officers (RSPOs)  in developing and reviewing
site safety plans for CERCLA remedial response projects.
Since field work at a site may not begin until an accep-
table site safety plan is approved,  State and Regional
personnel should be familiar with this appendix and the
entire SOSG.

BACKGROUND

    All CERCLA projects must have in place a site safety
plan which establishes the requirements and procedures for
protecting the health and safety of all on-site person-
nel.  It should present, in a logical format, information
about the site and instructions for preparing for and re-
sponding to potential health and safety hazards.  Further,
the site safety plan must specify the Levels of Protection
necessary for each field activity,  establish detailed in-
structions for responding to emergency situations, list
key safety personnel, and describe monitoring
requirements.

    Responsibility for developing the site safety plan
depends on whether the State or EPA is leading the reme-
dial project.  For State-lead remedial response, the State
(or its contractor) will prepare the plan and submit it to
EPA for review; for Federal-lead projects, an EPA contrac-
tor will develop the plan.

APPENDIX SUMMARY

    This appendix explains the key elements of a site
safety plan.  It is organized into five parts, as follows:

         Information on how to prepare a site safety plan

         Suggested plan for emergency operation codes

         Safety Check-off Sheet
                            M-l

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                                                   1/11/85
                                              New Page M-2

         Suggested format for a site safety plan

         Sample site safety plan  (from the Occupational
         Health and Safety Manual).

The body of this appendix is actually Part 9 of the SOSG
and should be used in conjunction with the entire
document.  The SOSG give detailed information on various
aspects of health and safety protection for personnel at a
hazardous waste site and are applicable to removal and
remedial projects.  Any questions on the content of this
appendix or the SOSG should be directed to:  EPA's Safety
and Occupational Health Officer, Hazardous Response
Support Division, Woodridge Avenue, Building 10, Edision,
New Jersey 08837.  (Phone:  (201) 321-6745 or FTS 340-6745),
                            M-2

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I SB.
                                                    1/11/85
UMTEO STATES E-'Vli-.TNMENTAL PROTECTION AGENCY     ^ p^Q  ^_^
            /; ASHiNG TON. O.C  20460


                NOV  I 9  1984
     MEMORANDUM

     SUBJECT:   Standard Operating Safety Guides,  November 1984

     FROM:      William N.  Hedeman, Jr., Director   \") ^
               Office of Emergency and Remedial Response"

     TO:        Regional Office Addressees

          The  enclosed Standard Operating Safety  Guides, November 1984
     replaces  the Interim standard Operating Guides,  Revised
     September 1982.   The Guides have been updated and revised to
     reflect additional experience EPA personnel  have gained in
     responding to environmental incidents involving  hazardous
     substances.

          The  Standard Operating Safety Guides are in accordance and
     consistent with  the procedures for employee  health and safety
     contained in EPA's Occupational Health and Safety Manual,
     Chapter 9, Hazardous Substances Responses, (1440 TN12),
     May  5,  1984.

          The  guides  are not meant to be a comprehensive safety
     manual  for incident response.  Rather, they  provide information
     on health and safety to complement professional  judgement and
     experience,  and  to supplement existing Regional  office safety
     procedures.

          If you  have any questions or comments concerning the
     guides, please contact Mr. Stephen Lingle, Director, Hazardous
     Response  Support Division or Mr. J. Stephen  Dorrler, Chief,
     Environmental Response Team.

     Enclosure

     Addressees

     Director, Ofc. o'f Emergence & Remedial Resp., Region II
     Director, Hazardous Waste Mgmt. Div., Region III
     Director, Air &  Waste Management Division,
               Regions IV, VI, VII. VIII
     Director, Waste  Mgmt. Div., Regions I & V
     Director, Toxics & Waste Mgmt. Div., Region  IX
     Director, Air &  Waste Division X

     cc:  Gene  Lucero, OWPE
         John  Skinner, OSW

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                                    PART 9

                              SITE SAFETY PLAN
 I.  INTRODUCTION
     The purpose of  the  site safety  plan  is to establish  requirements  for
     protecting the  health  and  safety  of  responders during all  activities
     conducted at  an incident.   It  contains  safety  information,  instruc-
     tions, and procedures.

     A site safety plan must be prepared and reviewed by qualified personnel
     for each hazardous substance  response.   Before operations at an incident
     commence, safety requirements must be  written,  conspicuously posted  or
     distributed to  all  response  personnel,  and  discussed with  them.   The
     safety plan must be  periodically  reviewed to keep it current and techni-
     cally correct.

     In non-emergency situations, for  example,  long-term  remedial  action  at
     abandoned hazardous waste  sites,  safety plans  are developed simultane-
     ously with the general work plan.  Workers can become familiar with  the
     plan before  site activities  begin.   Emergency  response  generally  re-
     quires verbal   safety  instructions  and  reliance  on  existing  standard
     operating procedures until,  when time permits,  a  plan can  be written.

     The plan must  contain  safety requirements for  routine  (but hazardous)
     response activities  and also  for  unexpected  site  emergencies.   The
     major distinction between  routine and  emergency  site safety  planning
     is the ability  to predict,  monitor,  and evaluate routine  activities.
     A site emergency is unpredictable and  may occur  anytime.


II.   GENERAL REQUIREMENTS

     The site safety plan must:

        Describe the  known  hazards  and evaluate  the risks associated with
        the incident and with each activity conducted.

     -  List  key  personnel  and  alternates   responsible  for  site  safety,
        response operations,  and for protection of public.

     -  Describe Lsvels  of Protection  to be worn by personnel.

     -  Delineate work areas.

     -  Establish procedures  to  control  site access.

        Describe decontamination  procedures  for   personnel  and  equipment.

     -  Establish  site emergency procedures.
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      -   Address  emergency  medical   care   for  injuries  and  toxicological
         problems.

      -   Describe  requirements  for an  environmental  surveillance program.

      -   Specify any  routine  and  special training  required for responders.

      -   Establish  procedures  for protecting workers  from weather-related
         problems.


III.   SITE  SAFETY PLAN SCOPE AND DETAIL

      The plan's scope, detail, and length  is based on:

         Information available about the incident.

      -   Time available to prepare a site-specific plan.

      -   Reason for responding.

      Three general categories  of  response exist - emergencies, character-
      izations and  remedial actions.  Although considerations for personnel
      safety are  generic  and  independent  of  the  response   category,  in
      scope, detail,  and  length  safety  requirements  and plans vary consid-
      erably.  These  variations  are  generally  due  to  the  reason  for
      responding (or category of response)  , information available, and the
      severity of the incident  with  its concomitant.dangers to the respon-
      der.

      A.   Emergencies

          1.  Situation:

             Emergencies generally  require  prompt  action  to prevent  or
             reduce undesirable affects.  Immediate  hazards of fire, explo-
             sion, and  release  of  toxic  vapors  or   gases  are  of  prime
             concern.  Emergencies  vary  greatly  in  respect  to  types  and
             quantities  of material,  numbers  of responders,  type  of work
             required, population affected, and other  factors.  Emergencies
             last  from a few hours to a few days.

                Information available:  Varies  from none  to  much.  Usually
                information about the  chemicals involved  and their associ-
                ated hazards  is quickly obtained  in transportation-related
                incidents, or incidents involving  fixed facilities.  Deter-
                mining the  substances  involved in some incidents, such as
                mysterious spills,  requires  considerable  time and effort.

             -  Time  available:  Little  time, generally requires  prompt
                action to bring the  incident under control.

             -  Reason   for  response:   To implement  prompt  and  immediate
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        actions to  control  dangerous  or  potentially dangerous  sit-
        uations.

    2.  Effects on Plan

        In emergencies, time  is  not available  to write lengthy and
        detailed safety plans.   Decisions  for  responder safety are
        based on  a  continual  evaluation   of  changing  conditions.
        Responding organizations must  rely on their  existing  written
        standard operating safety  procedures  or a generic plan, and
        verbal safety  instructions  adapted   to  meet   site-specific
        conditions.  Since heavy reliance is placed  on  verbal  safety
        instructions an  effective  system   to  keep   all   responders
        informed must be established.  Whenever  possible,  these inci-
        dent-specific instructions should be  written.

B.  Incident Characterization

    1.  Situation:

        In non-emergency  responses,for example,  preliminary  inspec-
        tions at abandoned wastes  sites or more  comprehensive waste
        site investigations the objective is  to  determine  and  charac-
        terize the  chemicals  and  hazards   involved, the  extent   of
        contamination, and risks to  people  and  the  environment.   In
        general, initial   inspections,  detailed  investigations, and
        extent of contamination surveys are  limited  in the  activities
        that are required  and  number of people  involved.   Initial  or
        preliminary inspections generally require  1-2 days.  Complete
        investigations may last over a  longer time period.

           Information available:   Much background information. Gener-
           ally limited on-site data for initial inspection.   On-site
           information more  fully  developed  through  additional  site
           visits and investigations.

        -   Time available:   In most  cases adequate time is available
           to develop written site-specific  safety plan.

        -   Reason for response:  To  gather  data to  verify or refute
           existing information,  to  gather  information  to determine
           scope of subsequent investigations, or  to  collect data for
           planning remedial  action.

    2.  Effects on Plan:

        Sufficient time is available  to write  safety  plans.   In scope
        and detail, plans  tend to be  brief containing safety  require-
        ments for specific on-site work  relevant  to  collecting data.
        As information is  developed through additional investigations,
        the safety plan, is modified and, if  necessary,  more detailed
        and specific requirements added.
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C.  Remedial  Actions

        1.   Situation:
            Remedial  actions  are  cleanups which  last  over a long period
            of time.   They commence after more  immediate problems at an
            emergency have been controlled, or they involve the mitigation
            of hazards   and   restoration  of   abandoned   hazardous  waste
            sites.  Numerous activities are required involving many people
            a  logistics  and support base, extensive equipment,  and more
            involved  work  activities.  Remedial actions may require months
            to years  to  completely accomplish.

            -   Information available:   Much  known about  on-site hazards.

            -   Time available: Ample time for  work  planning.

            -   Reason for  response:    Systematic  and  complete  control,
               cleanup,  and restoration.

        2.   Effects on Plan:

            Since ample  time  is  available  before work  commences,  site
            safety plan  tends to  be  comprehensive and  detailed.   From
            prior investigations much  detail  may  be  known about the ma-
            terials or  hazards  at  the  site and  extent of contamination.
IV.  SITE  SAFETY  PLAN DEVELOPMENT

    To develop the  plan  as much background  information as possible  should
    be obtained, time permitting, about the incident.   This  would  include,
    but not  be 1imited to:

       Incident  location and  name.

    -  Site  description.

    -  Chemicals and quantities involved.

    -  Hazards associated with each  chemical.

       Behavior  and dispersion of material  involved.
                 »
    -  Types of  containers,  storage,  or transportation methods.

    -  Physical  hazards.

    -  Prevailing weather condition  and forecast.

    -  Surrounding  populations and  land use.

    -  Ecologically sensitive areas.
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       Facility records.

       Preliminary assessment reports.

    -  Off-site surveys.

       Topographic and hydrologic information.

    The information  initially available  or  obtained through  subsequent
    characterization provides a basis  for developing a site-specific safety
    plan.  Information is needed about the chemicals and  hazards involved,
    movement of material on  and  off the site, and  potential  contact  with
    responders or the public.  This type of information is then used along
    with the reason  for  responding  (and work plan) to develop  the  safety
    plan. The plan  is  tailored  to the  conditions  imposed  by  the  incident
    and to  its  environmental  setting.  As additional  information  becomes
    available the  safety plan is modified to protect  against  the  hazards
    discerned and to provide for site emergencies that may occur.


V.  ROUTINE OPERATIONS

    Routine operations are those  activities  required in   responding  to  an
    emergency or a  remedial  action  at a hazardous waste  site.  These ac-
    tivities may involve a  high  degree of  risk,  but are  standard  opera-
    tions that all  incident responses may require.

    Safety practices for routine  operations  closely parallel  accepted in-
    dustrial hygiene and industrial  safety procedures. Whenever a  hazard-
    ous Incident progresses to the point where operations become more rou-
    tine, the associated site safety plan becomes a more  refined document.
    As a minimum, the following must be  included  as  part of the site safety
    plan for routine operations.

    -  Describe the Known Hazards and Risks

       This must include all  known or suspected  physical, biological, rad-
       iological, or chemical hazards.   It  is  important that  all  health
       related data be kept up-to-date.  As air,  water, soil,  or hazardous
       substance monitoring and  sampling  data becomes available,  it  must
       be evaluated, significant  risk or exposure to workers  noted,  poten-
       tial  impact  on public assessed, and  changes made in the plan.  These
       evaluations-need to be repeated  frequently since  much  of the plan
       is based on  this information.

    -   List Key Personnel  and Alternates

       The plan must  identify  key personnel   (and  alternates)  responsible
       for site safety.   It should also identify  key personnel  assigned  to
       various  site operations.   Telephone  numbers, addresses,  and  organi-
       zations  of these people must be  listed in  the  plan  and  pasted  in a
       conspicuous  place.
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   Designate Levels  of Protection  to  be  Worn
   The Levels of  Protection  to be  worn  at  locations  on-site or  by
   work functions  must  be designated.   This  includes  the  specific
   types of respirators and clothing  to  be worn for each  level.   No
   one shall  be  permitted in  areas  requiring personnel  protective
   equipment  unless  they have  been  trained  in its  use and are wearing
   it.

-  Delineate  Work  Areas

   Work areas  (exclusion  zone,  contamination  reduction  zone,   and
   support zone)  need to  be  designated on  the  site map and  the  map
   posted.  The size  of  zones, zone  boundaries,  and access  control
   points into  each  zone  must  be  marked and made  known to all  site
   workers.

-  List Control  Procedures

   Control procedures  must  be  implemented  to  prevent  unauthorized
   access.  Site security  procedures  - fences,  signs,   security  pa-
   trols and  check-in procedures -  must  be  established.   Procedures
   must also  be established to  control  authorized  personnel  into  work
   zones where  personnel  protection  is  required.

-  Establish  Decontamination  Procedures

   Decontamination procedures  for personnel  and equipment must be es-
   tablished.  Arrangements must also  be  made for  the proper disposal
   of contaminated material,  solutions, and equipment.

-  Address Requirements   for  an  Environmental  Surveillance  Program

   A program  to monitor  site  hazards must be implemented.  This would
   include air  monitoring  and  sampling,   and  other  kinds  of media
   sampling at   or  around  the  site that  would  indicate  chemicals
   present, their  hazards, possible migration, and  associated safety
   requirements.

-  Specify Any  Routine and Special  Training Required

   Personnel  must  be  trained not only in general safety procedures and
   use of  safety equipment, but in  any specialized work  they may be
   expected te  do.

-  Establish  Procedures  for Weather-Related Problems

   Weather conditions can affect   site work.   Temperature  extremes,
   high winds,  storms,  etc.  impact  on personnel  safety.  Work prac-
   tices must be established to protect  workers  from  the effects of
   weather and   shelters  provided,   when  necessary.   Temperature ex-
   tremes especially  heat  and  its  effect  on  people  wearing protec-
   tive clothing,  must  be considered  and   procedures  established to
   monitor for and minimize heat stress.
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VI. ON-SITE EMERGENCIES

    The plan  must  address  site  emergencies -  occurrences that  require
    immediate actions to  prevent  additional  problems  or harm to  respon-
    ders, the  public,  property,  or  the  environment.   In general,  all
    responses present a  degree of  risk  to the workers.   During  routine
    operations risk is minimized  by establishing  good work practices  and
    using personnel protective  equipment.   Unpredictable  events  such  as
    fire, chemical  exposure,  or  physical  injury  may  occur and must  be
    anticipated.  The plan must contain  contingencies for  managing them.

    -  Establish Site Emergency Procedures

       —  List the  names and  emergency  function  of  on-site  personnel
           responsible for  emergency  actions   along  with  the  special
           training they have.

       --  Post the  location  of  nearest  telephone   (if none  at  site).

       --  Provide alternative means for emergency communications.

       --  Provide a list of emergency services organizations  that  may  be
           needed.   Names,  telephone  numbers,  and  locations   must   be
           posted.   Arrangements for using emergency organizations  should
           be made beforehand.  Organizations  that might  be  needed are:

           -  Fire

           -  Police

           -  Health

           -  Explosive experts

           -  Local hazardous material response units

           -  Civil defense

           -  Rescue

       --  Address  and  define  procedures   for  the  rapid  evacuation  of
           workers.  Clear,  audible  warnings  signals  should  be  estab-
           lished,  well-marked  emergency   exits  located  throughout  the
           site, and  internal  and  external  communications plans  devel-
           oped.  An example  of  codes that  could  be used  for  emergency
           operations based on direct-reading instruments is contained  in
           Annex 7.

       --  A  complete list  of emergency equipment should  be attached  to
           the safety pl-an.  This  list should include emergency  equipment
           available  on-site, as  well  as  all available  medical,  rescue,
           transport,  fire-fighting, and mitigative equipment.
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        Address  emergency medical care.
        --   Determine   location  of  nearest  medical  or  emergency  care
            facility.   Determine their capability to handle chemical
            exposure cases.

        --   Arrange  for treating,  admitting, and transporting  of injured
            or  exposed  workers.

        --   Post  the medical or emergency care facilities location, travel
            time,  directions, and telephone number.

        --   Determine local physician's office location, travel directions,
            availability,  and post telephone number  if  other  medical  care
            is  not available.

        —   Determine nearest ambulance service and post telephone number.

        —   List  responding organization's physicians, safety officers, or
            toxicologists  name and telephone number.  Also include nearest
            poison control center, if applicable.

        —   Maintain accurate records on any exposure or potential exposure
            of  site  workers  during an emergency  (or  routine  operations).
            The minimum amount  of  information   needed   (along   with  any
            medical test  results)  for personnel  exposure  records is  con-
            tained in Annex 8.

     -   Advise  workers of their duties during an emergency.  In particular,
        it  is  imperative  that the  site  safety   officers,  standby rescue
        personnel, decontamination workers, and  emergency medical techni-
        cians practice  emergency procedures.

        Incorporate  into the  plan, procedures for  the  decontamination of
        injured workers and for their transport  to medical  care facilities.
        Contamination of  transport  vehicles,  medical care  facilities, or
        of  medical  personnel  may  occur  and  should  be  addressed  in the
        plan. Whenever  feasible  these procedures  should  be discussed with
        appropriate medical personnel in  advance  of operations.

     -   Establish procedures in cooperation with  local and state  officials
        for evacuating  residents who  live near the  site.

                  »
VII.  IMPLEMENTATION OF  THE SITE SAFETY PLAN

     The site   safety   plan,  (standard  operating  safety  procedure  or   a
     generic safety  plan  for  emergency  response) must be  written to  avoid
     misinterpretation, ambiguity,  and  mistakes  that verbal  orders cause.
     The plan  must be  reviewed and approved by qualified personnel.   Once
     the safety plan  is implemented,  its  needs to be  periodically examined
     and modified,  if  necessary,  to reflect any  changes  in  site'-work and
     conditions.
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      All agencies and  organizations which have an active role at  the  incid-
      ent must  be familiar  with the  plan.   If  possible  the plan  should
      be written  in  coordination  with the  organizations   involved.   Lead
      personnel  from these  organizations  should  sign  the  plan  to  signify
      they agree with it and will follow its  provisions.

      All personnel involved at  the  site  must be familiar with  the  safety
      plan, or the parts  that  pertain  to  their  specific activities.   Fre-
      quent safety meeting  should  be  held  to keep all  informed  about  site
      hazards, changes  in operating plans,  modifications of safety  require-
      ments and  for  exchanges  of information.   It  is the  responsibility
      of personnel involved at  the  site as  workers  or visitors to  comply
      with the requirements in the plan.

      Frequent audits by the incident manager or the safety designee  should
      be made to  determine compliance  with  the plan's  requirements.   Any
      deviations should be brought  to the attention of the incident  manager.
      Modifications in  the plan should  be reviewed and approved by appropri-
      ate personnel.
VIII.  SAMPLE SAFETY PLANS

       Annex 9 and 10 are two examples of Site  Safety Plans.   Since  no  one
       sample plan or plan format can  adequately address all safety require-
       ments for the variety  of  incidents  that occur, they should be  used
       as a guide to help develop an incident-specific plan.  They can  also
       be used, with necessary  adaptation,  as generic plans  for  emergency
       response.

       In some incidents, the sample  plans contained in Annex 9 and 10 might
       be satisfactory  to use by themself.  Filling in  the blanks provides an
       effective safety plan.  In many incidents  they  should only be consid-
       ered as  a  check list.  Since  they  do not e-haustively  cover every
       condition which  may need addressed,  users  of these  sample  plans  and
       any other type  examples  must  realize  their  application to any  one
       incident may not  be acceptable.  Therefore they  must  be  used  with
       discretion and  tempered  by  professional  judgement   and  experience.
       They are not meant  to be all  inclusive  but  examples  of  considera-
       tions, requirements, and format  which should be adapted   for inci-
       dent-specific conditions.
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                                 ANNEX  7

                        Emergency Operation  Codes
                            Real-Time Monitor
                     (suggested  minimum action  plan)

                 	(Site Name)	


CODE DESIGNATIONS

1.  Green

    A.  Normal  operations

2.  YELLOW A

    A.  Cessation of specific  work  activity  on-site because of:

        (1)  Continuous  organic  readings  on  direct-reading instrument  of
               *   ppm above background (measured 20-30  ft. from  point  of
             suspected release),  and

        (2)  Current or  projected meteorological conditions indicate
             a  probable  impact on work  activity.

    B.  If background readings above    *   ppm  are obtained during
        cesssation of activity,  redesign  activity to  lower releases
        and/or  delay that  on-site activity until off-site air monitoring
        indicates accepted off-site concentration.

    C.  Site personnel will  immediately notify  EPA/State of site  condi-
        tion.

3.  Yellow B

    A. Termination of all  work on-site  because  of:

        (1)   Continuous organic readings on direct-reading instrument
                *   ppm  above  background  (measured approximately  1,000 ft.
              from work  area or  site  property  limits),  and

        (2)   Current or projected meteorologic conditions  indicate  a
              potential  impact on inhabited  areas.

    B.  Site personnel will  immediately notify  EPA/State of site
        conditions.

    C.  EPA/State will modify  off-site  air monitoring to meet  the
        needs of contingency plan.
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4.  RED

    A.  Termination of all  work on-site because of:

        (1)  Continuous organic readings on direct-reading instruments
               *   ppm above background (measured downwind at  the  nearest
             occupied area  off-site, and

        (2)  Current or projected meteorologic conditions  indicate a  po-
             tential impact on inhabited areas.

    B.  Site personnel  will immediatley notify EPA/State of site condi-
        tions.

    C.  Local officials making evacuation/public health decisions  will be
        advised by EPA/State to:

        (1)  Release a  public health advisory to potentially affected
             areas since on-site control methods will  not  reduce the
             source of contamination; and/or

        (2)  Implement  a temporary relocation plan because on-site activi-
             ties indicate  a potential  for continuous  above background/
             acceptable readings  at the nearest inhabited  area(s).


             Concentration should be determined by  appropriate
              response  personnel.
                                   A7-2
                                   M-14

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                                ANNEX 8
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                                                               New Paqe  M-15
                    RESPONSE SAFETY CHECK-OFF SHEET

                         (minimum required data)
BEFORE RESPONSE
1. Incident: Site
2.
3.
4.
5.
a. Response Dates
Type of Response: Spill 	
Incident Safety Plan: Region
Suspected chemical (s) involved
(c)
Protective Level (s) involved:
(a) If Level C - 1. Identify
2. Describe
Emp 1 oyee
City State

__ Fire 	 Site 	 Train 	
ERT Not Devel
: (a) (b)
(d)
ABC
Canister
air monitoring source(s)


Other 	
oped


D


        (b)  If  Level D JUSTIFY  (in comments section at bottom of page).

    6.   SCBA-Identify Buddy:  Name/Organization 	
    7.   Last  Response:   (a) Level Used:  A	 B
                 •       (b) Medical Attention/Exam Performed:  Yes	 No

II.  AFTER RESPONSE

    1.   Protective  Level Used:   A            B            C            D
        a.  Level  C  -  identify  cannister:  	 b. Level D (comment below)
        c.  Level  B  or C  skin protection: Tyvek/Saran      Acid/Rain 	 Other

    2.   List possible chemical  exposure:  Same as above: 	(a)
                                  (c) 	Td~
        Equipment  Decontamination:   (a) clothing   (b)  respirator   (c) monitoring
                         Disposed: 	
                          Cleaned:	
                        No Action:
    4.  Approximate time  in  exclusion  area: _______ hours  per  day  for	days

    5.  Was medical  attention/exam  required for this  response:  Yes 	 No 	

Part  I: DATE PREPARED: 	Reviewed by	Date  	

Part II: DATE PREPARED: 	 Reviewed by 	 Date  	

COMMENTS:
                                 A8-1
                                  M-15

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                                 ANNEX 9                             1/11/85
                                                              New  Paqe M-16
             (Suggested format for minimum site safety plan)

                             SITE SAFETY PLAN

                   (Name of Hazardous Waste Site/Spill)

I.  General Information

    As a minimum, all personnel involved with emergency response, waste
site cleanup, drum handling and opening, sampling, site investigations,
etc., will follow the applicable Federal/State rules and regulations.   In
addition, all site personnel will follow, as a minimum, U.S.  Environmental
Protection Agency. Office of Emergency and Remedial  Response,  Hazardous
Response Support Division's, Standard Operating Safety Guides  and Chapter
9 Hazardous Substance Response, from the EPA Occupation Health and  Safety
Manual.

    In the event of conflicting plans/requirements,  personnel  must  Imple-
ment those safety practices which afford the highest personnel protection.

    If site conditions change and It is necessary to modify Levels  of
Protection A, B, or C the safety designee on-site shall notify the  On-Scene
Coordinator before making recommendations to site personnel.

II. APPROVALS

  (SIGNATURE)	  (SIGNATURE)	
  On-Scene-Coordinator (OSC)DATE   Safety Officer             DATE


  (SIGNATURE)	  (SIGNATURE)	
  REVIEW COMMITTEE                 DATE   OTHERS                     DATE

III. Summary of Minimum Requirements

    A.  The safety officer/designee shall:

        1.  Describe chemicals, hazards, and risk involved

        2.  List key personnel

            a.  Response manager (OSC)/alternate 	

            b.  Safety officer(s)/alternate 	

            c.  Ot'her responsible site personnel/alternate	

        3.  Prescribe Levels of Protection

        4.  Designate work zones:  Support area, contamination reduction
            area, exclusion area.

        5.  Implement procedures to control site access.
                                 A9-1
                                  M-16

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ATTACHMENT B

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                                                                        DRAFT

                               ATTACHMENT B
                       LEVELS OF DECONTAMINATION

A.I  Level A Decontamination

Equipment Worn

The  full  decontamination procedure  outlined  is  for  workers  wearing Level  A
protection (with  taped  joints between  gloves, boots, and suit).  Such  protection
consists of

     1.  Fully encapsulating suit with integral boots and gloves
     2.  Self-contained breathing apparatus (SCBA)
     3.  Hard hat (optional)
     
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                                                                       DRAFT
Station 2;   Boot Cover and Glove Wash

Scrub outer boot covers and gloves with decon solution or detergent/water solution.

Necessary equipment includes

      1.  Container (20 to 30 gal)
      2.  Decon solution
      3.  Detergent/water solution
      *f.  Two or three long-handle, soft-bristle scrub brushes

Station 3;   Boot Cover and Glove Rinse

Rinse off decon solution from Station 2 using copious amounts of water.  Repeat as
many times as necessary.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  High-pressure spray unit
      3.  Water
      it.  Two or three long-handle, soft-bristle scrub brushes

Station fr;   Tape Removal

Remove tape around boots and gloves and deposit in container with plastic liner.

Necessary equipment includes

      1.  Container (20 to 30 gal)
      2.  Plastic liners
                                    SO-60

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                                                                       DRAFT
Station 5;   Boot Cover Removal

Remove boot covers and deposit in container with plastic liner.

Necessary equipment includes

      1.  Container  (30 to 50 gal)
      2.  Plastic liners
      3.  Bench or stool

Station 6;   Outer-Glove Removal

Remove outer gloves and deposit in container with plastic liner.

Necessary equipment includes

      1.  Container  (20 to 30 gal)
      2.  Plastic liners

Station 7:   Suit/Safety Boot Wash (Exhibit SOA-1)

Thoroughly wash fully encapsulating suit and boots. Scrub suit and boots with long-
handle,   soft-bristle scrub  brush  and  copious  amounts  of decon  solution or
detergent/water solution.Repeat as many times as necessary.

Necessary equipment includes

      1.  Container  (30 to 50 gal)
      2.  Decon solution
      3.  Detergent/water solution
      4.  Two or three  long-handle, soft-bristle scrub brushes
                                     SO-61

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                                                  DRAFT
                 EXHIBIT SOA-1
LEVEL A DECONTAMINATION; SUIT/SAFETY BOOT WASH
                   SO-62

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                                                                       DRAFT
Station 8;   Suit/Safety Boot Rinse

Rinse off decon solution or detergent/water  solution using copious amounts of
water. Repeat as many times as necessary.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  High-pressure spray unit
      3.  Water
      
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                                                                      DRAFT
     3. Bench or stool
     4. Boot jack

Station 11;  Fully Encapsulating Suit and HardHat Removal

With assistance of helper, remove fully encapsulating suit and hard hat. Hang suits
on rack or lay out on drop cloths.

Necessary equipment includes

     1. Rack
     2. Drop cloths
     3. Bench or stool

Station 12;  SCBA Backpack Removal

While  still wearing  facepiece, remove backpack and place on table.  Disconnect
hose from regulator valve and proceed to next station.

A table is necessary  for  this procedure.

Station 13;  Inner-Glove Wash

Wash with decon  solution  or  detergent/water solution  that  will  not harm  skin.
Repeat as many times as necessary.

Necessary equipment includes

     1. Basin or bucket
     2. Decon solution
     3. Detergent/water solution
     4. Small  table
                                    SO-64

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                                                                        DRAFT
Station  14;  Inner-Glove Rinse

Rinse with water.  Repeat as many times as necessary.

Necessary equipment includes

      1.  Water
      2.  Basin or bucket
      3.  Small table

Station  15;  Facepiece Removal

Remove  facepiece.  Deposit in container  with  plastic  liner.  Avoid touching face
with fingers.

Necessary equipment includes:

      1.  Container (30 to 50 gal)
      2.  Plastic liners

Station  16;  Inner-Glove Removal

Remove inner gloves and deposit in container with plastic liner.

Necessary equipment includes

      1.  Container (20 to 30 gal)
      2.  Plastic liners

Station  17:  Inner-Clothing Removal

Remove  clothing soaked with  perspiration.  Place in container with plastic liner.
Do  not  wear inner clothing  off the site, since there  is a possibility  that small

                                     SO-65

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                                                                       DRAFT
amounts of contaminants have  been transferred in removing  fully encapsulating
suit.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  Plastic liners

Station 18;  Field  Wash

Shower if highly toxic, skin-corrosive,  or skin-absorbable  materials are known  or
suspected to be present.  Wash hands and face if shower is not available.

Necessary equipment includes

      1.  Water
      2.  Soap
      3.  Small table
      4.  Basin or bucket
      5.  Field showers
      6.  Towels

Station 19;  Redress

Put on clean clothes. A dressing trailer  is needed in inclement weather.

Necessary equipment includes

      1.  Tables
      2.  Chairs
      3.  Lockers
                                    SO-66

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                                                                        DRAFT
Full Decontamination (Situation 1) and Three Modifications

The preceding description outlines each  station that  is included in a  complete
worst-case decontamination protocol. It is obvious  that different sites will present
different hazard levels and thus that site-specific  modifications  of  this protocol
will be required.   The following table illustrates  the  modifications that  can be
made in response to a variety of conditions.
                                    STATION NUMBER
               I  2   3  55  6   7  8  9  10  11 12  13  1*  15 16  17  18 19
             1XXXXXXXX     XXXXXXXXXX
             2XXXXXXXXX
             3X                   XXXX            XXX
             f X                   XXX
Situation  1

The   individual  entering  the  Contamination  Reduction  Corridor  (CRC)  is
observed to be grossly contaminated, or extremely  toxic  substances are known or
suspected to be present.

Situation  2

Same as Situation  1 except  that individual needs new air tank and will return to
Exclusion Zone.

Situation  3

Individual  entering  the  CRC  is  expected  to  be   minimally contaminated.
Extremely toxic or skin-corrosive  materials are  not present.  No  outer gloves or
boot covers  are worn. Inner  gloves are not contaminated.
                                     SO-67

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                                                                       DRAFT
Situation  4

Same as Situation 3 except that individual needs new air tank and will return to
Exclusion Zone.

Exhibit SOA-2 shows the layout for Level A decontamination.

A.2  Level B Decontamination

Equipment Worn

The  full  decontamination procedure outlined  is  for  workers  wearing Level  B
protection (with  taped joints between gloves,  boot, and suit).  Such  protection
consists of

      1.  One-piece, hooded, chemical-resistant splash suit
      2.  Self-contained breathing apparatus
      3.  Hard hat
      4.  Chemical-resistant boots with steel  toe and shank
      5.  Boot covers
     6.  Inner and outer gloves
                                    SO-68

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                                                                               DRAFT
                               EXHIBIT SOA-2
         DECONTAMINATION LAYOUT LEVEL A PROTECTION
  Tank Change
                      Outer Glove
                       Removal
  EXCLUSION
     ZONE
          Tape
         Removal
                                                     Boot Cover
Glove Wash   < <
                                                                   Segregated
                                                                   Equipment
                                                                     Orop
                                                                   — Hotline
                         Do]
Suit/Safety Boot
Wash

Suit/Safety Boot
Rinse

Safety Boot
Removal
CONTAMINATION
   REDUCTION
      ZONE
Fully Encapsulating Suit
and Hard Hat Removal

SCBA Backpack
Removal

Inner Glove
Wash
                              Inner Glove
                              Rinse

                              Face Piece
                              Removal
                    Wash
                         M6j
Inner Glove
Removal

Inner Clothing
Removal
                                                                 Contamination
                                                                  Control Line
                                      1
                        SUPPORT
                          ZONE
                                     SO-69

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                                                                       DRAFT
Procedure for Full Decontamination

Station 1;   Segregated Equipment Drop

Deposit  equipment  used  on the  site  (tools,  sampling devices and  containers,
monitoring  instruments,  radios, clipboards,  etc.) on  plastic  drop  cloths  or  in
different containers with plastic liners.  Each will be contaminated  to a different
degree.  Segregation at the drop reduces the probability of cross-contamination.

Necessary equipment includes

      1.  Containers of various sizes
      2.  Plastic liners
      3.  Plastic drop cloths

Station 2;   Boot Cover and Glove Wash

Scrub outer boot covers and gloves with decon solution or detergent/water solution.

Necessary equipment includes

      1.  Container (20 to 30 gal)
      2.  Decon solution
      3.  Detergent/water solution
      14.  Two or three long-handle, soft-bristle scrub brushes

Station 3;   Boot Cover and Glove Rinse

Rinse off decon solution from Station  2 using copious amounts of water.  Repeat as
many times as necessary.

Necessary equipment includes
                                    SO-70

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                                                                        DRAFT
      1. Container (30 to 50 gal)
      2. High-pressure spray unit
      3. Water
      *. Two or three long-handle, soft-bristle scrub brushes

Station fr;    Tape Removal

Remove tape around boots and gloves and deposit in container with plastic liner.

Necessary equipment includes

      1. Container (20 to 30 gal)
      2. Plastic liners

Station 5;    Boot Cover Removal

Remove boot covers  and deposit in container with plastic liner.

Necessary equipment includes

      1. Container (30 to 50 gal)
      2. Plastic liners
      3. Bench or stool

Station 6;    Outer-Glove Removal

Remove outer gloves and  deposit  in container with  plastic  liner.   Necessary
equipment includes

      1. Container (20 to 30 gal)
      2. Plastic liners
                                     SO-71

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                                                                       DRAFT
Station 7;   Suit/Safety Boot Wash

Thoroughly wash chemical-resistant splash suit, SCBA, gloves, and safety boots.
Scrub with  long-handle, soft-bristle  scrub brush  and copious amounts of decon
solution or detergent/water solution.  Wrap SCBA regulator (if belt-mounted type)
with plastic to keep out water. Wash backpack assembly with sponges or cloths.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  Decon solution
      3.  Detergent/water solution
      4.  Two or three long-handle, soft-bristle scrub brushes
      5.  Small buckets
      6.  Sponges or cloths

Station 8;   Suit/SCBA/Boot/Glove Rinse

Rinse off  decon solution  or  detergent/water solution using copious  amounts  of
water. Repeat as many times as necessary.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  High-pressure spray unit
      3.  Water
      <4.  Small buckets
      5.  Two or three long-handle, soft-bristle scrub brushes
      6.  Sponges or cloths
                                    SO-72

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                                                                       DRAFT
Station 9;   Tank Change

If  worker leaves Exclusion  Zone to change air tank, this is the last step in the
decontamination procedure.  Worker's air tank is exchanged, new outer  glove and
boot covers donned, and joints taped. Worker returns to duty.

Necessary equipment includes

      1.  Air tanks
      2.  Tape
      3.  Boot covers
      *f.  Gloves

Station 10;  Safety Boot Removal

Remove safety boots and deposit in container with plastic liner.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  Plastic  liners
      3.  Bench or stool
      4.  Boot jack

Station 11;  SCBA Backpack Removal

While still wearing facepiece,  remove  backpack and  place on table.  Disconnect
hose from regulator valve and proceed to next station.

A table is necessary for this procedure.
                                    SO-73

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                                                                       DRAFT
Station 12;  Splash Suit Removal

With assistance of  helper, remove splash suit.  Deposit in container  with plastic
liner.

Necessary equipment includes

      1.  Container  (30 to 50 gal)
      2.  Plastic liners
      3.  Bench or stool

Station 13;  Inner-Glove  Wash

Wash inner  gloves  with  decon solution or detergent/water solution  that will not
harm skin. Repeat as many times as necessary.

Necessary equipment includes

      1.  Decon solution
      2.  Detergent/water solution
      3.  Basin or bucket
      4.  Small  table

Station 1^;  Inner-Glove  Rinse

Rinse inner gloves with water.  Repeat as many times as necessary.

Necessary equipment includes

      1.  Water
      2.  Basin or bucket
      3.  Small  table
                                    SO-74

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                                                                        DRAFT

Station 13;  Facepiece Removal

Remove facepiece.  Avoid touching face with gloves.  Deposit in  container  with
plastic liner.

Necessary equipment includes

      1. Container (30 to 50 gal)
      2. Plastic liners

Station 16;  Inner-Glove Removal

Remove inner gloves and deposit in container with plastic liner.

Necessary equipment includes

      1. Container (20 to 30 gal)
      2. Plastic liners

Station 17:  Inner-Clothing Removal

Remove clothing soaked with perspiration.  Place in container with  plastic liner.
Do  not wear inner clothing  off  the site  since  there is  a possibility  that small
amounts  of contaminants have been transferred in  removing  fully encapsulating
suit.

Necessary equipment includes

      1. Container (30 to 50 gal)
      2. Plastic liners
                                     SO-75

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                                                                        DRAFT
Station 18;  Field Wash

Shower if highly toxic, skin-corrosive, or skin-absorbable  materials are known or
suspected to be present. Wash hands and face if shower is not available.

Necessary equipment includes

      1.  Water
      2.  Soap
      3.  Small tables
      4.  Basins or buckets
      5.  Field  showers

Station 19;  Redress

Put on clean clothes.  A dressing trailer is needed in inclement weather.

Necessary equipment includes

      1.  Tables
      2.  Chairs
      3.  Lockers

Full  Decontamination  (Situation 1) and Three Modifications

The  preceding  description  outlines each station that  is included in  a complete
worst-case decontamination protocol. It is obvious  that different sites will present
different hazard levels and  that site-specific  modifications of this protocol will be
required.  The  following table illustrates the  modifications that can be made in
response to a variety of conditions.
                                     SO-76

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                                                                       DRAFT
                                   STATION NUMBER
               1  2  3   4   5  6  7  8   9   10 11  12  13  If 15 16  17  18 19
             1XXXXXXXXXXXXXXXXXX
             2XXXXXXXXX
             3X                  XX      XXX         XXXX
             * X                  XXX
Situation  1

The  individual entering the  CRC  is observed  to be  grossly  contaminated, or
extremely toxic substances are known or suspected to be present.

Situation  2

Same as Situation 1 except that individual needs new air tank and will return to
Exclusion Zone.

Situation 3

Individual entering the CRC is expected  to be minimally contaminated. Extremely
toxic or skin-corrosive materials are not present.  No outer gloves or boot covers
are worn. Inner gloves are not contaminated.

Situation 4:  Same as Situation 3 except that individual needs new air tank and will
return to Exclusion Zone.

Exhibit SOA-3 shows the layout for Level B contamination.
                                    50-77

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                                                                         DRAFT
                          EXHIBIT SOA-3
    DECONTAMINATION LAYOUT LEVEL B PROTECTION
 Tank Change
CONTAMINATION
   REDUCTION
      ZONE
EXCLUSION

Outer Glove
Removal
ZONE
Tape
Removal
Boot Cover
&
Glove Wash
                                                                  Segregated
                                                                  Equipment
                                                                    Drop

                                                                   »-  Hotline  -»—
Suit/Safety Boot
Wash

Suit/SCBA/Boot/Glove
Rinse

Safety Boot
Removal

SCBA Backpack
Removal

Splash Suit
Removal

Inner Glove
Wash
                            Inner Glove
                            Rinse

                            Face Piece
                            Removal

                            Inner Glove
                            Removal
                            Inner Clothing
                            Removal
                  Reid
                 Wash
                                                              Contamination
                                                               Control Une
     -•ft 9 ] Redress
                                                   SUPPORT
                                                     ZONE
                                SO-7S

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                                                                        DRAFT
A.3  Level C Decontamination

Equipment Worn

The  full  decontamination procedure  outlined  is  for  workers  wearing  Level C
protection (with  taped  joints between gloves, boots, and suit).  Such protection
consists of

      1.  One-piece, hooded, chemical-resistant splash suit
     2.  Canister-equipped full-face mask
     3.  Hard hat
     4.  Chemical-resistant boots with steel toe and shank
     5.  Boot covers
     6.  Inner and outer gloves

Procedure for Full Decontamination

Station h   Segregated Equipment Drop

Deposit  equipment  used  on  the  site  (tools,  sampling devices and containers,
monitoring  instruments,  radios, clipboards,  etc.) on  plastic  drop  cloths  or in
different  containers with  plastic liners.  Each will be contaminated to a  different
degree. Segregation at  the drop reduces the probability of cross-contamination.

Necessary equipment includes

      1.  Containers of various sizes
     2.  Plastic liners
     3.  Plastic drop cloths
                                     SO-79

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                                                                       DRAFT
Station 2;   Boot Cover and Glove Wash

Scrub outer boot covers and gloves with decon solution or detergent/water solution.

Necessary equipment includes

      1.  Container (20 to 30 gal)
      2.  Decon solution
      3.  Detergent/water solution
      4.  Two or three long-handle, soft-bristle scrub brushes

Station 3;   Boot Cover and Glove Rinse

Rinse off decon solution from Station 2 using copious amounts of water. Repeat as
many times as necessary.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  High-pressure spray unit
      3.  Water
      
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                                                                        DRAFT
Station 5;   Boot Cover Removal

Remove boot covers and deposit in container with plastic liner.

Necessary equipment includes

      1.  Container (30 to  50 gal)
      2.  Plastic liners
      3.  Bench or stool

Station 6;   Outer-Glove Removal

Remove outer gloves and deposit in container with plastic liner.

Necessary equipment includes

      1.  Container (20 to  30 gal)
      2.  Plastic liners

Station 7;   Suit/Safety Boot Wash

Thoroughly wash splash suit and safety boots.  Scrub with long-handle, soft-bristle
scrub brush and copious amounts of decon solution or detergent/water  solution.
Repeat as many times as necessary.

Necessary equipment includes

      1.  Container (30 to  50 gal)
      2.  Decon solution
      3.  Detergent/water solution
      4.  Two or three long-handle, soft-bristle  scrub brushes
                                    SO-81

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                                                                       DRAFT

Station 8;   Suit/Safety Boot Rinse

Rinse off decon solution or detergent/water  solution using copious amounts of
water. Repeat as many times as necessary.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  High-pressure spray unit
      3.  Water
      *.  Two or three long-handle, soft-bristle scrub brushes

Station 9:   Canister or Mask Change

If worker leaves Exclusion Zone to change canister (or mask), this is the last step in
the decontamination procedure.  Worker's canister is exchanged,  new outer glove
and boot covers donned, and joints taped. Worker returns to duty.

Necessary equipment includes

      1.  Canister (or mask)
      2.  Tape
      3.  Boot covers
      4.  Gloves

Station 10;  Safety Boot Removal

Remove safety boots and deposit in container with plastic liner.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  Plastic liners

                                    SO-82

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                                                                       DRAFT
      3.  Bench or stool
      4.  Boot jack

Station 11:  Splash Suit Removal

With  assistance of  helper, remove splash suit.  Deposit in container  with plastic
liner.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  Bench or stool
      3.  Plastic liner

Station 12;  Inner-Glove Wash

Wash inner  gloves with decon solution or detergent/water solution  that  will not
harm skin.  Repeat as many times as necessary.

Necessary equipment includes

      1.  Decon solution
      2.  Detergent/water solution
      3.  Basin or bucket

Station 13;  Inner-Glove Rinse

Rinse  inner gloves  with water.  Repeat as many times as necessary.  Necessary
equipment includes the following:

      1.  Water
      2.  Basin or bucket
      3.  Small table

                                    50-83

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                                                                        DRAFT
Station 14;  Facepiece Removal

Remove facepiece.   Avoid  touching  face  with  gloves.   Deposit  facepiece  in
container with plastic liner.

Necessary equipment includes

      1.  Container (30 to 50 gal)
      2.  Plastic liners

Station 15;  Inner-Glove Removal

Remove inner gloves and deposit in container with plastic liner.

Necessary equipment includes

      1.  Container (20 to 30 gal)
      2.  Plastic liners

Station 16;  Inner-Clothing Removal

Remove  clothing soaked with perspiration.   Place in container with plastic liner.
Do not wear inner clothing off the site since there is  a possibility small amounts of
contaminants have been transferred in removing fully encapsulating suit.

Necessary equipment includes

      1.  Container  (30 to 50 gal)
      2.  Plastic liners

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                                                                        DRAFT
Station  17;  Field Wash

Shower  if highly toxic, skin-corrosive, or skin-absorbable  materials are known or
suspected to be present. Wash hands and face if shower is not available.

Necessary equipment includes

      1.  Water
      2.  Soap
      3.  Tables
      4.  Wash basins or buckets
      5.  Field showers

Station  18:  Redress

Put on clean clothes. A dressing trailer is needed in inclement weather.

Necessary equipment includes

      1.  Tables
      2.  Chairs
      3.  Lockers
      k.  Clothes

Full Decontamination (Situation 1) and Three Modifications

The  preceding description  outlines each  station  that  is  included in a  complete
worst-case decontamination protocol. It is obvious that different sites will present
different hazard levels and thus that site-specific modifications of this  protocol
will  be   required.   The  following table illustrates the  modifications that can be
made in response to a variety of conditions.
                                     SO-85

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                                   STATION NUMBER
               1  2   3   »  5  6  7   8  9  10  11  12  13 14 15  16  17  18  19

             1XXXXXXXX     XXXXXXXXXX
             2XXXXXXXXX
             3X                  XXXX           XXX
             f X                  XXX
Situation  1


The  individual  entering  the CRC is observed  to be  grossly  contaminated or

extremely skin-corrosive substances are known or suspected to be present.


Situation  2


Same as  Situation  1  except that individual needs  new  canister  or  mask  and

will  return to Exclusion Zone.


Situation  3


Individual  entering  the  CRC  is expected  to  be  minimally  contaminated.

Extremely  skin-corrosive materials are  not  present.   No  outer gloves  or boot

covers are  worn. Inner gloves are not contaminated.


Situation  *»
Same as  Situation  3  except  that  individual needs  new  canister  or  mask  and

will  return to Exclusion Zone.


Exhibit  SOA-4 shows the layout for Level C decontamination.
                                          SO-86

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                              EXHIBIT SOA-*
         DECONTAMINATION LAYOUT LEVEL C PROTECTION
                                                                            DRAFT
                                  EXCLUSION
                                     ZONE
    Canister or
  Mask Change
                      Outer Glove
                       Removal
                                                                 Segregated
                                                                 Equipment
                                                                   Drop

                                                                —•- Hotline -~—
CONTAMINATION
   REDUCTION
      ZONE
Suit/Safety
Boot Wash

Suit/Safety Boot
Rinse

Safety Boot
Removal

Splash Suit
Removal

Inner Glove
Wash

Inner Glove
Rinse
                             Face Piece
                             Removal

                             Inner Glove
                             Removal

                             Inner Clothing
                             Removal
                                                             Contamination
                                                              Control Line
                                        Redress

                                                 SUPPORT
                                                   ZONE
                                   SO-87

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10

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                                                                   DRAFT
                        MONITORING INSTRUMENTS
                                CONTENTS
SECTION                                                             PAGE

1.0     INTRODUCTION                                               MM

2.0     COMBUSTIBLE GAS INDICATOR                                  MM
2.1      DESCRIPTION AND USE                                         MM
2.2      LIMITATIONS                                                  MI-6
2.3      NIOSH CRITERIA                                               MI-6

3.0      OXYGEN DETECTOR                                            MI-6
3.1      DESCRIPTION AND USE                                         MI-6
3.2      LIMITATIONS                                                  MI-6
3.3      NIOSH CRITERIA                                               MI-6

4.0      COLORIMETRIC TUBES                                          MI-7
4.1      DESCRIPTION AND USE                                         MI-7
4.2      LIMITATIONS                                                  MI-7

5.0      RADIATION SURVEY METERS AND DOSIMETERS                    MI-7
5.1      DESCRIPTION AND USE                                         MI-7
5.2      LIMITATIONS                                                  MI-7
5.3      OSHA (GENERAL INDUSTRY) REGULATIONS                        MI-7

6.0      ORGANIC VAPOR DETECTORS                                   MI-9
6.1      INTRODUCTION                                               MI-9
6.2      OVA                                                         MI-11
6.2.1     GAS CHROMATOGRAPH  FUNCTIONS                              MI-11
6.2.2     CALIBRATION                                                 MI-11
6.2.3     LIMITATIONS                                                  MI-12
6.3      HNU                                                         MI-12
6.3.1     INSTRUMENT CONFIGURATIONS                                 MI-12
6.3.2     CALIBRATION                                                 MI-13
6.3.3     SPECIALIZED USES                                             MI-13
6.3.4     ADVANTAGES                                                 MI-13
6.4      AID 580  ORGANIC VAPOR METER                                MI-14
6.4.1     INSTRUMENT CONFIGURATION                                  MI-14
6.4.2     CALIBRATION                                                 MI-14
6.4.3     SPECIALIZED USES                                             MI-15
6.4.4     ADVANTAGES                                                 MI-15
6.4.5     LIMITATIONS                                                  MI-15
6.5      GENERAL CONSIDERATIONS                                     MI-16
                                   Ml-ii

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                                                                  DRAFT

                          CONTENTS (CONTINUED)



SECTION                                                            PAGE

7.0      COLLECTION MEDIA AND AIR-SAMPLING PUMPS                   Ml-17
7.1      USE                                                        MI-17
7.2      LIMITATIONS                                                 MI-17

8.0      RATIONALE FOR RELATING TOTAL ATMOSPHERIC                  MI-17
        CONCENTRATIONS TO SELECTION OF THE LEVEL
        OF PROTECTION
8.1      INTRODUCTION                                              MI-17
8.2      FACTORS FOR CONSIDERATION                                 MI-19
8.3      INSTRUMENT SENSITIVITY                                      MI-20



                                 EXHIBITS



SECTION                                                            PAGE

MI-1    INSTRUMENTATION FOR AIR MONITORING                         MI-2

MI-2    ATMOSPHERIC HAZARD GUIDELINES                             MI-3

MI-3    FLAMMABLE RANGES OF SELECTED COMPOUNDS                  MI-5

MI-4    EXTERNAL RADIATION                                         MI-8

MI-5    COMPARISON OF THE OVA AND HNU                            MI-10

MI-6    SELECTED COLLECTION MEDIA FOR AIR  SAMPLING                 MI-18

MI-7    DECISION GUIDANCE FOR ASSIGNING LEVELS OF
        PROTECTION
                                  Ml-iii

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                                                                         DRAFT
1.0   INTRODUCTION

The  combustible gas  indicator (CGI), oxygen  meter,  colorimetric tubes, radiation
detector, photoionization detector (PID), and portable  gas chromatograph (GC) are
used  to qualitatively  and  quantitatively  define  airborne  chemical  and  physical
hazards.  They can also be used  to  help  identify sampling locations, thus limiting
the  number  of  samples  needed  to be  taken.    The  portable  GC  in the  gas
chromatographic  mode, as  well  as  collection   media  in  conjunction  with  air-
sampling pumps,  are used to characterize and identify  specific chemical compounds
present in  the  air.   All  equipment  described  is  portable,  battery  operated,  and
intrinsically safe, and is sufficiently rugged  for field use (Exhibit MI-1).

The objective for this  portion of the  course is to discuss the  philosophy, use,  and
limitations  of  the  above-mentioned  pieces of  analytical  equipment  as  used  in
investigative and remedial  response  activities,  and  to use the  information derived
from the analytical instrumentation to perform a hazard assessment (Exhibit  MI-2).

2.0   COMBUSTIBLE GAS INDICATOR

2.1   Description and Use

A  typical  CGI  determines  the  level  of organic  vapors  and  gases  present  in an
atmosphere  as  a percentage of the  lower  explosive limit (LEL).  This  is done   by
measuring the  change in electrical resistance in  a Wheatstone bridge  circuit.  The
LEL is the lowest concentration  of a gas or vapor in air by volume that will explode
or burn when there is an ignition source.

The  indicator  measures from  0 percent to 100  percent  of  the LEL,  100 percent
being an explosive atmosphere.
                                      MI-1

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                                                                   DRAFT
        EXHIBIT MI-1.  INSTRUMENTATION FOR AIR MONITORING
    Hazard
 Direct Reading
Collection Media
Explosive atmosphere
Oxygen-deficient
  atmosphere

Toxic atmosphere
Radioactivity
Combustible gas
  indicator

Oxygen  meter
Photoionization
  detector (PID)
Flame ionization
  detector (FID)
  with GC option
Colorimetric tubes

Radiation survey
  meters
Passive  monitors
Not used
Not used
Sampling pumps in
conjunction with
absorption tubes,
filters, impingers
Dosimeters
Film  badges
                                MI-2

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                                                                           DRAFT
                   EXHIBIT MI-2.  ATMOSPHERIC HAZARD GUIDELINES
    Monitoring Equipment
    Hazard
Ambient Level
Action
Combustible gas indicator
Explosive
atmosphere
Oxygen concentration meter
Oxygen
Radiation survey
Radiation
 < 10% LEL    Continue investigation
 10%-25%     Continue onsite
               monitoring with
               extreme caution  as
               higher levels are
               encountered.

 > 25% LEL    Explosion  hazard;
               withdraw from area
               immediately.

 < 19.5%       Monitor wearing  SCBA.
               NOTE:  Combustible gas
               readings are not valid
               in atmospheres with
               < 19.5% oxygen.

 19.5%-25%    Continue investigation
               with caution. SCBA not
               needed, based on
               oxygen content only.

 > 25.0%       Discontinue inspection;
               fire hazard potential.
               Consult specialist.

 < 1 mR/hr    Continue investigation.
               If radiation is detected
               above background levels,
               this signifies the
               presence of possible
               radiation sources; at
               this level, more
               thorough monitoring is
               advisable.  Consult  with
               a health physicist.
                                        MI-3

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                                                                            DRAFT
             EXHIBIT MI-2.  ATMOSPHERIC HAZARD GUIDELINES (CONTINUED)
    Monitoring Equipment
    Hazard      Ambient Level
                      Action
                                                >  10 mR/hr
Colorimetric tubes
NHU photoionizer
Organic and
inorganic
vapors/gases
Organic
vapors/gases
Organic vapor analyzer
Organic
Depends  on
species
1)  Depends
   on
   species
2)  Total
   response
   mode

1)  Depends
   on
   species
                                               2)  Total
                                                   response
                                                   mode
Potential radiation
hazard;  evacuate site.
Continue monitoring
only upon the advise of
a health physicist.

Consult standard
reference  manuals  for
air concentrations/
toxicity  data.

Consult standard
reference  manuals  for
air concentrations/
toxicity  data.

Consult EPA Standard
Operating  Procedures.
Consult standard
reference manuals for
air concentrations/
toxicity data.

Consult EPA Standard
Operating  Procedures.
                                        MI-4

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                                                         DRAFT




EXHIBIT MI-3. FLAMMABLE RANGES OF SELECTED COMPOUNDS
                        MI-5

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                           EXHIBIT - 3
    FLAMMABLE RANGES OF SELECTED COMPOUNDS
                                                         250,000
                                                      —  200,000
   COMPOUND

  CONCENTRATION

  (% BY VOLUME)
— 150,000

       COMPOUND
     CONCENTRATION
     (PARTS PER MILLION)

   100,000
                                                      —  50,000
                   METHANE     GASOLINE   ETHANOL
                              (92 OCTANE)
                             COMPOUND
THIS CHART ILLUSTRATES THE FLAMMABLE RANGE OF SELECTED COMPOUNDS; THE

LOWEST VALUE REPRESENTS THE LOWER EXPLOSIVE LIMIT (L.E.L) 0AND THE

HIGHER VALUE THE UPPER EXPLOSIVE LIMIT (U.E.L) (b)
                KEY

                 NOT ENOUGH OXYGEN FOR COMBUSTION

                 FLAMMABLE RANGE

                 NOT ENOUGH FUEL FOR COMBUSTION

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                                                                          DRAFT
2.2   Limitations

The CGI  cannot be used  in the presence of silanes, silicones, silicates, and  leaded
gasoline  vapors, all of which can destroy the instrument's sensitivity.  The CGI does
not indicate if  a  given  atmosphere is toxic.  Also, the CGI readings are influenced
by the level of oxygen, and should not be used to determine the presence of organic
vapors in a given atmosphere.  The instrument must be calibrated frequently.

2.3   NIOSH Criteria

NIOSH guidelines  on  the use of the CGI are as follows:

      1.  10 Percent  LEL—limit activities in area  to  those that do  not generate
         sparks; wear non-sparking gear.

      2.  20 percent LEL—limit all activities in area.

3.0   OXYGEN DETECTOR

3.1    Description  and Use

A  typical oxygen detector measures  the  atmospheric 02 concentration directly  by
means of a  galvanic  cell.  Since the readings of the CGI are influenced by the level
of oxygen, oxygen detectors are frequently combined with CGI's.

3.2   Limitations

The readings  on  the  oxygen detector are influenced  by the difference  from  sea
level.

3.3   NIOSH Criteria

Oxygen levels  lower  than  19.5 percent require the  use  of supplied-air respirators.
                                      MI-6

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                                                                          DRAFT
4.0   COLORIMETRIC TUBES

4.1   Description and Use

The colorimetric tube and pump  measure the  concentrations of specific inorganic
and organic vapors  and  gases that cause a discoloration that is proportional to the
amount of material present.

4.2   Limitations

Specific tubes  must be  selected before going  into field; therefore, it is  difficult to
assess unknown atmospheres.  There are many interferences.   The results can be
erroneous  because of cross sensitivity. Response time is relatively slow.

5.0   RADIATION SURVEY METERS AND DOSIMETERS

5.1   Description and Use

Radiation  survey meters are  used to  determine  the  level of alpha, beta, and gamma
radiation.   Dosimeters are used to measure whole-body radiation exposure  over a
given period of time (Exhibit  MI-4).

5.2   Limitations

Radiation survey meters  must only be used by persons who have been trained in the
proper interpretation of their readings.  They must  be frequently calibrated  and
checked.   Dosimeters do not give real-time readouts of radiation levels.

5.3   OSHA (General Industry) Regulations

OSHA Regulations for exposure to radiation for any individual  in  a restricted area
are as follows:
                                      MI-7

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                                               DRAFT




EXHIBIT MI-4.  EXTERNAL RADIATION
              MI-8

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                                                                         DRAFT
      1. Whole Body - 1.25 REM/Calendar quarter average.
      2. NOT to exceed 3 REM in any calendar quarter.

Radiation  survey  meters   display  incoming   geiger  counts   as   mR/hr  (milli
Rotegens/hour).   It is important to understand the relationship between mR/hr and
REMs (Radiation  dose Equivalent in Man).

      1  Rotegen = 0.83 to 0.93 RADs (Radiation Absorbed Dose)

(1 RAD  is the quantity of radiation required for  100 ergs of energy to be absorbed
by  1 gram  of body tissue.)

      RADs x QF (quality factor)   REMs

      QF =   10 for a
            1.7 for 6 above 30 keV
            1 for  6  below 30 keV
            1 for  y

A  general  rule of thumb is  that,  if a  radiation  can be ruled out,  multiply mR/hr
by 2 to  get milli  REM/hr.

6.0   ORGANIC VAPOR DETECTORS

6.1    Introduction

The  HNU System  photoionizer,  AID 580, and the  Century organic  vapor analyzer
(OVA) are used  in the field  to  detect  a variety of compounds  in air.  The three
instruments differ in their modes  of  operation  and in the  number and types  of
compounds  they  detect  (Exhibit MI-5).  Both instruments can  be used  to detect
leaks of  volatile  substances  in drums and tanks,  determine the presence of volatile
compounds in soil and water, make ambient-air surveys, and collect continuous air-
monitoring  data.   These instruments are valuable  tools for  helping  to decide the
                                     MI-9

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                                                                        DRAFT
                EXHIBIT MI-5  COMPARISON OF THE OVA AND HNU
Parameter
           OVA
       HNU and AID 580
Response
Application
Detector

Limitations
Calibration gas


Ease of Operation



Detection limits

Response time


Maintenance
Useful range

Service life
Responds to all combustable
organic gases  and vapors.
In survey mode, detects total
concentrations of gases and
vapors.  In GC mode, identifies
and measures specific
compounds.
Flame ionization detector

Does not respond to inorganic
gases and vapors.  No
temperature control.
Methane


Requires  experience to
interpret  correctly,
especially in GC mode.

0.1 ppm (methane)

2-3 sec (survey mode)
Periodically clean and inspect
particle filters, valve rings,
and burner chamber.  Check
calibration and pumping system
for leaks.  Recharge battery
after each use.

0-1000 ppm

8 hr; 3 hr with strip chart
recorder.
Responds to many organic
and some inorganic gases
and vapors.

In  survey mode, detects
total concentrations of
gases and vapors.  Some
identification of compounds
possible if more than  one
probe is used.

Photoionization detector.

Does not respond to methane.
Does not detect a compound
if probe has a  lower energy
(eV) than compound's
ionization  potential.

Benzene (HNU),
Butadiene (580)

Fairly easy to use and
interpret.
0.1 ppm (benzene)

3 sec for 90percent of total
concentration

Clean UV lamp frequently.
Check calibration
regularly.  Recharge
battery after each use.
0-2000  ppm

10 hr; 5 hr with  strip
chart recorder.
                                    MI-10

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                                                                          DRAFT
levels   of  protection  to  be  worn,  for  assisting  in  determining  other  safety
procedures, and for determining  subsequent monitoring or sampling locations when
personnel  are  thoroughly  trained to operate the instruments and to  interpret the
data.

6.2   OVA

The  OVA operates in  two different modes.   In the survey mode, it  can determine
the  approximate  concentration  of  all  detectable  species  in  air.  With  the gas
chromatograph  option,  individual   components  can  be  detected and measured
independently,  with  some  detection limits as low as a few  parts per million. This
instrument can be used to screen for sample locations.

6.2.1    Gas Chromatograph Functions

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

6.2.2    Calibration

The  OVA is internally calibrated to  methane by  the manufacturer.  When measuring
methane,  it indicates  the  true concentration.   In response  to  all other detectable
compounds, however,  the  instrument reading my be higher or lower  than  the true
concentration.   Relative response   ratios for substances  other  than  methane are
available.   To interpret  the   readout  correctly,  it  is  necessary either  to  make
calibration  charts  relating  the  instrument readings to the true concentration or to
adjust  the  instrument  so  that  it  reads  correctly.  This is done by turning  the 10-
                                     MI-11

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                                                                         DRAFT
turn, gas-select knob, which adjusts  the  response of  the  instrument.  The knob is
normally set at 300  when calibrated to methane.  Secondary calibration to another
gas is done  by sampling a  known concentration  of the gas and  adjusting the gas
select knob  until the instrument reading equals the true concentration.

6.2.3    Limitations

The OVA  has an  inherent limitation  in that  it can detect only organic molecules.
Also, it  should  not  be used  at temperatures  lower than about 40 F  because gases
condense  in the  pump  and column.   It  has no temperature control,  and  since
retention  times  van/  with  ambient  temperatures for  a  given  column,  absolute
determinations  of contaminants are  difficult.   Despite these  limitations, the  GC
mode can  often  provide tentative information   on  the  identity  and  number of
contaminants in air without relying on costly,  time-consuming laboratory analysis.

6.3   HNU

The HNU System  portable photoionizer detects the concentration of organic gases
as well  as  a few inorganic gases.  The  basis  for detection is the ionization of
gaseous  species.   The incoming  gas molecules  are  subjected  to  ultraviolet  (UV)
radiation,  which is  energetic  enough  to  ionize many  gaseous compounds.   Each
molecule  is  transformed into  charged-ion pairs,  creating a current between two
electrodes.   Every molecule  has a characteristic  ionization  potential, which  is  the
energy  required to  remove  an electron  from the molecule,  yielding a  positively
charged ion and the  free electron.

6.3.1    Instrument Configurations

Three probes, each  containing a  different UV light  source, are available for  use
with the  HNU.   Energies  are 9.5,  10.2, and 11.7   eV.   All  three detect  many
aromatic  and large-molecule  hydrocarbons.    The 10.2-  and 11.7  -eV  probes, in
addition,  detect   some  smaller  organic   molecules   and   some  halogenated
                                     Ml-12

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                                                                         DRAFT
hydrocarbons.  The 10.2-eV probe  is the most  useful for environmental response
work, as it  is more durable than  the 11.7-eV  probe and detects more  compounds
than the 9.5-eV probe.

6.3.2    Calibration

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

6.3.3    Specialized Uses

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

6.3.4    Advantages

The HNU is  easier to  use than  the OVA.   Its lower  detection  limit is also  in the low
ppm range.  The response time is  rapid; the meter  needle reaches 90 percent of the
indicated concentration  in 3 sec.
                                     MI-13

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                                                                          DRAFT
6.4   AID 580 Organic Vapor Meter

The AID  580  Organic Vapor  Meter has been designed for measurement of low levels
of most  organic  vapors in  air.  The principle of detection is  photoionization,  the
same as  the  HNU.

6.4.1   Instrument Configurations

Two lamps,  10.0eV and  11.8eV are available for use on the AID 580.  Both of these
lamps  are capable  of  detecting  some  smaller organic  molecules  with the  11.8eV
lamp  detecting more than 10.0eV. Most applications of the 580 will dictate the  use
of the  10.0eV lamp because  it is very useful for environmental survey  work and it is
more durable than the 11.8eV lamp.

6.4.2   Calibration

The  580  is first supplied  with effectively zero air.   This  simply  means that  the air
has  no contaminants which will  elicit  a response  from  the 580.  In most  cases,
ambient air will be sufficient to perform this calibration step.

When  monitoring zero  air,  the zero adjust  on the  rear panel of  the  580 can be
adjusted  so that the  readout of the  LCDK on the front panel reads 0.00.  The 580 is
then presented with  a sample  of known concentration of butadiene.  The Span  Pot,
again  located  on the   rear   panel is adjusted with  a  screwdriver for the  proper
reading.   While  carrying  out this  calibration step, the  Sensitivity/Calibrate  Pot
should be set  at 200.   Following this initial calibration  to  butadiene, various other
concentrations of the calibration gas should be introduced to the  instrument.  The
readout of the  LCD should correspond to the known  concentration values.  This will
provide a linear check of the instrument.
                                     Ml-14

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                                                                         DRAFT
6.4.3    Specialized Uses

While the  primary  use of the 580 is  a survey instrument, it  can  be calibrated to
specific compounds to give  an  exact  reading.  However, the specific compounds
must be known in  advance and specific calibration steps taken.  These  procedures
are spelled out in detail in the operating manual of the instrument.

The AID 580  may also be used to collect air samples in a media such as a charcoal
tube or air bag. This is possible because the UV energy source of the instrument is
a  non-destructive  testing method (i.e., the compounds  are  discharged from  the
instrument in tact).  Sampling tubes  may  be connected via the  outlet part  on  the
rear panel  of the 580.  When utilizing this  feature  of  the instrument, the flow rate
of the air  being passed  through the  sampling  media must  be  known.   This  will
involve   further  calibration   using  a  bubble  meter  so  that   a  quantitative
measurement of the contaminants can  be calculated.

6.4.4    Advantages

The AID 580  has a built in  audible alarm that can be set from 0 -  1000 ppm.  This is
done  by simply adjusting  the  top  dial  on the front  of the instrument.  The dial is  a
ten-turn select knob with  each full turn equal to 100 ppm.

6.4.5    Limitations

As with any  photoionization detector,  not all compounds  are  detected, for example
low  molecular weight  hydrocarbons  such as  methane, ethane, propane,  methyl
alcohol, and  some  of  the  freons.  Also, not all  compounds are  detected  with  the
same sensitivity.  Therefore, the  results  of any survey using this instrument  should
be  taken  as   just  that, a  survey.   A  zero  reading  can not  be  interpreted as  a
contaminant-free environment.
                                     MI-15

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                                                                          DRAFT
6.5   General Considerations

These instruments  can monitor  only certain  vapors  and  gases  in  air.    Many
nonvolatile  liquids,  toxic solids,  particulates,  and  other  toxic  gases  and  vapors
cannot be  detected.  Because the types of compounds  that the HNU, AID 580 and
OVA can potentially detect are only  a  fraction of the chemicals possibly present on
a site, a  zero reading on either instrument does not necessarily signify the absence
of air contaminants.

The   instruments  are   generally  not   specific,  and  their  response  to  different
compounds is relative to the calibration gas.  Instrument readings may be higher  or
lower than the  true concentration. This can  be  an especially  serious problem when
monitoring for  total contaminant concentrations  if several different compounds are
being detected  at once.  In addition, the response of these instruments is not linear
over the entire  detection range.   Care must therefore  be taken  when  interpreting
the data.  All  identifications should  be  reported as tentative  until they  can be
confirmed by more precise analysis.  Concentrations should be reported in terms  of
the calibration gas and span potentiometer knob or gas-select knob setting.

Since the OVA,  AID 580, and  HNU are small, portable instruments, they cannot be
expected  to yield   results  as accurate  as  laboratory  instruments.   They were
originally designed  for  specific industrial  applications.   They are relatively  easy  to
use and  interpret  when detecting total concentrations  of known  contaminants  in
air,  but   interpretation  becomes  more   difficult  when  trying  to  identify the
components  of  a   mixture.   Neither  instrument can  be used  as  an  indicator for
combustible gases  or oxygen deficiency.

The OVA (Model 128) is certified  by Factory Mutual to  be used in  Class  I,  Division
1, group A, B, C, and D environments. The HNU is certified by Factory Mutual for
use in Class I, Division 2, Groups A, B,  C, and D.
                                     MI-16

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                                                                         DRAFT
7.0   COLLECTION MEDIA AND AIR-SAMPLING PUMPS

7.1   Use

Collection  media are used  in conjunction with air-sampling pumps to collect and
concentrate air samples for subsequent laboratory analysis (Exhibit MI-6).

7.2   Limitations

There  is  the  possible  loss  of  organic  material  due  to  temperature  changes,
absorption  on  container  walls,  desorption,  etc.   Since laboratory  analysis  is
required, the method does not provide a real-time readout of pollutant levels.

8.0   RATIONALE FOR RELATING TOTAL ATMOSPHERIC VAPOR/GAS
      CONCENTRATIONS TO SELECTION OF THE LEVEL OF PROTECTION

8.1   Introduction

The  following  rationale  is  the  suggested  operating  guide  for Superfund  and  is
excerpted from  the Standard Operating  Guides, Office of  Emergency and  Remedial
Response, Hazardous Response Support Division.

The  objective of using total atmospheric vapor/gas concentrations for  determining
the appropriate  Level A,  B, or C.  In situations  where the presence of  vapors  or
gases is  not known,  or  if  present,  the  individual  components are  unknown,
personnel  required to  enter that environment must  be   protected.  Exhibit MI-7
depicts  the  decision  guidance  for  assigning  levels  of  protection.    Until the
constituent  substances and  corresponding  atmospheric  concentrations  of  vapor,
gas,  or particulates can  be determined and  respiratory and/or  body  protection
related  to  the  toxicological  properties  of  the  identified substances,  the total
vapor/gas concentration,  with judicious interpretation, can be  used as  a guide for
selecting personnel protection equipment.
                                     MI-17

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                                                                   DRAFT
    EXHIBIT MI-6.  SELECTED COLLECTION MEDIA FOR AIR SAMPLING
   Pollutant
Collection Medium
Laboratory Analysis
Volatile organic
Particulate
  organic

Pesticides
PCBs

Metals

Volatile
  inorganic

Particulate
  inorganic

Cyanides
 Carbon tubes
 Tenax tubes
 XAD-2 tubes
 Silica  gel tubes

 Glass  filter
 Florisil tubes
 PUPs
 Glass filters
 Impingers

 Glass filters

 Membrane filters

 Impingers
 Reagent solutions

 Membrane filter
 Glass filter

 Filters
 Impingers
      GC/MS
      GC/MS
      GC/MS
      GC/EC
      GC/MS

      AA

      Wet methods


      Wet methods


      Wet methods
                               MI-18

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                                                              DRAFT




EXHIBIT MI-7.  DECISION GUIDANCE FOR ASSIGNING LEVELS OF PROTECTION
                              MI-19

-------
                                   EXHIBIT -  7
                 DECISION GUIDANCE FOR ASSIGNING
                          LEVELS OF PROTECTION
  ADD APRON OR
OTHER APPROPRIATE
   CLOTHING
WAIT UNTIL
HAZARDOUS
ATMOSPHERE
 DISSIPATES
  SPLASH
PROTECTION
NEEDED FOR
  INITIAL
  NTRY
                                                                 WEAR
                                                                LEVELA
                                                            ADO APRON OR
                                                           OTHERAPPROPRIATE
                                                              CLOTHING
                                                               SPLASH
                                                             PROTECTION
                                                             REQUIRED FOR
                                                               INVEST-
                                                               GATION
                                         CONDUCT
                                       INVESTIGATION
                                         IN INITIAL
                                      ENTRY PERSONAL
                                      PROTECTION GARB
                      COMPLETE
                    INVESTIGATION
                      WITHOUT
                     RESPIRATORY
 CONDUCT
    AIR
 MONITORING
                                        GO TO RESPIRATORY
                                       PROTECTION DECISON
                                        LOGIC BASED ON AIR
                                        MONITORING DATA

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                                                                          DRAFT
Although total  vapor/gas  concentration  measurements  are  useful  to a  qualified
professional for the selection of protection equipment, caution should be exercised
in interpretation.   An instrument does not respond  with  the same sensitivity  to
several  vapor/gas contaminants as it  does to a single contaminant.  Also, since
total vapor/gas  field  instruments  see all  contaminants in  relation  to a  specific
calibration  gas, the  concentration  of  unknown gases  or vapors may be over-  or
underestimated.

Suspected  carcinogens,   particulates,   highly   hazardous  substances,  or   other
substances that do  not elicit an instrument response  may be  known  or believed  to
be  present. Therefore, the protection level should not be based solely  on the total
vapor/gas criterion.   Rather,  the level should be selected case by case,  with special
emphasis  on potential exposure and  chemical and toxicological characteristics  of
the known  or suspected material.

8.2  Factors for Consideration

In using total atmospheric  vapor/gas concentrations as a guide for selecting a Level
of Protection, a number of  other factors should also  be considered:

     1.  The  uses,  limitations,  and operating  characteristics  of  the monitoring
        instruments must be recognized and understood.  Instruments  such as the
        HNU     System     photoionizer,    Century    OVA,    MIRAN    infrared
        spectrophotometer,  AID 580,  and others  do not respond identically to the
        same  concentration   of  a  substance  or  respond  to   all  substances.
        Therefore,  experience,  knowledge, and  good  judgment  must  be  used  to
        complement the data obtained with instruments.

     2.  Other  hazards may  exist, such as  gases  not  detected by the HNU  or OVA
        (i.e.,   phosgene,   cyanide,   arsenic,  chlorine),  explosives,   flammable
        materials,   oxygen  deficiency,  liquid/solid  particles,   and  liquid or solid
        chemicals.
                                     MI-20

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                                                                          DRAFT
     3.  Vapors/gases with  very  high toxicities  at  low  concentrations  could be
         present.

     4.  The risk to personnel entering an area must  be  weighed against the need
         for entering.   Although this  assessment is  largely a value  judgment, it
         requires a conscientious balancing of the variables involved and the  risk to
         personnel  against the need to enter  an  unknown  environment.

     5.  The knowledge  that suspected carcinogens or substances  extremely toxic
         or  destructive to  skin are present or suspected  to  be  present (which  may
         not be  reflected   in  the  total  vapor/gas  concentration)   requires  an
         evaluation  of  factors  such  as  the  potential  for   exposure,  chemical
         characteristics   of  the  material,  limitations  of  instruments, and  other
         considerations specific to the  incident.

     6.  What needs to be done  on  the site  must be  evaluated. Depending on  the
         total atmospheric vapor concentrations, Level C  protection may be judged
         adequate;  however,  tasks such as moving drums, opening  containers, and
         bulking of materials, which increase the probability of liquid  splashes or
         the  generation  of vapors,  gases,  or  particulates,  may  require a  higher
         level of protection.

     7.  Before  any  respiratory  protective  apparatus   is  issued,  a  respiratory
         protection program  must be developed  and implemented  according to
         recognized standards (ANSI  Z88.2-1980).

8.3   Instrument Sensitivity

Although  the  measurement  of total  vapor/gas  concentrations  can  be a  useful
adjunct  to  professional   judgment  in  the   selection  of  an appropriate  level  of
protection, caution should  be used  in  the interpretation  of  the  readout  of  the
measuring  instrument.   The response of an instrument  to a  gas  or  vapor  cloud
containing  two  or more  substances  does  not  provide  the   same  sensitivity  as
                                     MI-21

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                                                                         DRAFT
measurements  involving the  individual,  pure constituents.   Hence, the instrument
readout  may  overestimate  or  underestimate  the  concentration  of an  unknown
composite  cloud.  This same type of inaccuracy could also  occur in  measuring a
single  unknown substance with the instrument calibrated to  a different substance.
The  idiosyncrasies of each  instrument must be considered in conjunction with the
other parameters in selecting the protection equipment needed.

Using  the  total vapor/gas concentration to determine levels of  protection should
provide  protection  against  concentrations   greater  than  the   readout   of  the
instrument.   However,  when  the  upper  limits of Levels  C and  B are approached,
serious consideration  should be  given  to selecting  a higher level of protection.
Cloud  constituents must be identified as rapidly as possible and levels of protection
based  on the toxic properties of the specific substances identified.
                                     MI-22

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11

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                                                                 DRAFT

                     TOXICOLOGY/FIRST AID CHAPTER

                               CONTENTS



SECTION                                                           PAGE

1.0      INTRODUCTION                                             TOX-1
1.1      DEFINITIONS                                                TOX-1
1.2      TOXIC EXPOSURES AS A FUNCTION OF  DAILY LIFE                TOX-2
1.3      DOSE-RESPONSE RELATIONSHIP                               TOX-3
1.3.1     MEASUREMENT OF RESPONSE                                 TOX-3
1.3.2     DOSE-RESPONSE TERMS                                     TOX-5
1.3.3     USE OF DOSE-RESPONSE RELATIONSHIP                        TOX-8
1.3.4     SHORTCOMINGS OF DOSE-RESPONSE DATA                     TOX-11
1.4      FACTORS AFFECTING  DOSE-RESPONSE  RELATIONSHIP             TOX-14
1.4.1     EXPOSURE                                                 TOX-14
1.4.2     SEX                                                      TOX-14
1.4.3     AGE                                                      TOX-16
1.4.4     SYNERGISM, ANTAGONISM, AND POTENTIATION                  TOX-16
1.4.5     GENETIC CHARACTERISTICS                                   TOX-17
1.4.6     SPECIES VARIATION                                          TOX-17
1.5      TOXIC EFFECTS                                             TOX-18
1.5.1     TOXIC RESPONSES OF THE CNS                               TOX-19
1.5.2     TOXIC RESPONSES OF THE LIVER                               TOX-24
1.5.3     TOXIC RESPONSES OF THE KIDNEY                             TOX-30
1.5.4     TOXIC RESPONSES OF THE EYE                                TOX-31
1.5.5     TOXIC RESPONSES OF THE RESPIRATORY SYSTEM                TOX-32
1.5.6     TOXIC RESPONSES OF THE BLOOD                             TOX-35
1.5.7     TOXIC RESPONSES OF THE REPRODUCTIVE  SYSTEM               TOX-37
1.6      ACCEPTABLE EXPOSURES                                    TOX-39
1.6.1     TIME-WEIGHTED AVERAGES (TWAs)                            TOX-40
1.6.2     TLVs DESIGNATED WITH  "SKIN" NOTATION                       TOX-41
1.6.3     EXCURSIONS (STEL, TLV-C)                                   TOX-41
1.6.4     MIXTURE TLV                                               TOX-42
1.6.5     MINERAL DUST AND NUISANCE DUST TLV                       TOX-43
1.6.6     PHYSICAL AGENTS                                          TOX-43

2.0      CARCINOGENS                                              TOX-44
2.1      DEFINITIONS                                                TOX-44
2.2      DNA AS A TARGET FOR CARCINOGENS                          TOX-46
2.3      "CAUSES" OF CANCER                                       TOX-46
                                 TOX-ii

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                                                              DRAFT

                              EXHIBITS



NUMBER                                                        PAGE

TOX-1   HYPOTHETICAL RESPONSE OF A GIVEN SPECIES TO              TOX-4
        A GIVEN DOSE
TOX-2   TYPICAL DOSE-RESPONSE RELATIONSHIP                      TOX-6
TOX-3   DOSE-RESPONSE TEST                                    TOX-7
TOX-4   TOXICITY RATING CHART                                   TOX-9
TOX-5   COMPARISON OF EFFECTIVE DOSE AND LETHAL                 TOX-10
        DOSE RESPONSE CURVES
TOX-6   CALCULATION OF A TLV ON THE BASIS OF A                   TOX-12
        DOSE-RESPONSE CURVE
TOX-7   DOSE-RESPONSE CURVES  OF TWO SUBSTANCES                TOX-13
TOX-8   CLASSIFICATION OF FACTORS INFLUENCING TOXICITY            TOX-15
TOX-9   CLASSIFICATION OF NEUROTOXICANTS BY SITE                 TOX-21
        OF PRIMARY ACTION
TOX-10  LIVER DAMAGE BY SOME ACUTE HEPATOTOXIC                 TOX-26
        CHEMICALS
TOX-11  ORGANELLES AFFECTED BY VARIOUS HEPATOTOXINS             TOX-28
TOX-12  PULMONARY DISEASES AND SOME SELECTED                   TOX-34
        OCCUPATIONALLY INHALED AGENTS
TOX-13  CLASSES OF CARCINOGENIC CHEMICALS                       TOX-45
                               TOX-iv

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                                                                          DRAFT
1.0   INTRODUCTION

1.1   Definitions

The  following  definitions  will  be  useful  in  understanding the  remainder  of  the
chapter:

Toxicology

The  qualitative  and especially the  quantitative  study of  the  injurious  effects  of
chemical  and physical  agents,  as observed  in  alteration  and  response  in  living
systems;  it  includes  the  application  of  the  findings  of these  studies  to  the
evaluation  of safety and to  the  prevention  of  injury to man and  to  all forms  of
useful life.
Poison
Any  substance which, when  ingested, inhaled,  or  absorbed,  or when applied to,
injected  into,  or developed  within  the body  in relatively  small  amounts,  by its
chemical action may cause damage to structure or disturbance of function.
Dose
The quantity  of a substance to which an organism is exposed.  The dose determines
whether effects of a substance  are toxic,  nontoxic, or beneficial.   All substances
are poisons;  there  is none  which is not a  poison.  The right dose  differentiates  a
poison and a remedy.

Toxicity

The quality of being poisonous, especially the  degree  of potency of  a toxic  microbe
or of  a poison.   It  is expressed  by  a  fraction  indicating the  ratio  between the
smallest amount that will  cause an animal's death and the weight of  that animal.
                                     TOX-1

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                                                                          DRAFT
Threshold Limit Value (TLV)

The  airborne concentration of a  substance with  specified conditions (time-weighted
average, short-term  exposure,  or  ceiling value)  under  which it  is  believed  that
nearly all workers may be  exposed day after day without adverse effects.

Permissable Exposure Limit (PEL)

The  airborne concentration of a substance set by OSHA as  an enforcable standard
which may not be exceeded.

1.2   Toxic Exposures as a Function of Daily Life

Everyone is exposed to toxic materials in daily life  in a variety of ways:

      1.  Deliberate exposures  such  as:

         a.  Cigarette smoke
         b.  Drugs (medicinal  and recreational)
         c.  Household  aerosols

      2.  Unintentional exposures such as:

         a.  Cigarette smoke (passive  smoking)
         b.  Air pollution
         c.  Occupational exposure

The  deliberate exposure can  be controlled; for the  most  part,  the unintentional
exposure  is  beyond the   individual's ability  to  control.   The  exception  is  the
occupational  exposure,   it  is  the employer's legal, as well as  moral, obligation to
provide the worker with  safe breathing air.
                                     TOX-2

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                                                                          DRAFT
1.3   Dose-Response Relationship

A  particular  toxicity  test exhibits  a  dose-response relationship when  there  is  a
consistent   mathematical  relationship  between   the   proportion   of  individuals
responding and a given dose for  a given exposure period.  For example, the number
of mortalities increases as the dose  of  a  chemical  given  to  a  group of organisms
increases.

1.3.1    Measurement of Response

Different species  of  test  organisms  differ in how  they respond to  a  specific
chemical.   In addition,  there are variations in response to  a given dose  within  a
group of test organisms of  the same  species.  Typically, this intraspecies  variation
follows  a normal  (Gaussian) distribution  when the number of  organisms responding
is  plotted against the  degree of response for a  given dose  (Exhibit TOX-1).

Statistical techniques  exist for describing normal distribution:

      1.  Two-thirds  of  the test population will exhibit a response that  is within one
         standard deviation  of the mean  response.

      2.  Ninety-five  percent  lie within  two standard  deviations of the mean.

      3.  Ninety-nine  percent lie within three standard deviations of the mean.
Thus,  a  relatively  small  number  of  experimental  groups  can  be tested,  and
statistical techniques  can be  used to  define the probable response of the  average
organism to a given dose.  Graphically, this average response is depicted as a point,
with bars  used to exhibit one standard deviation above  and below the average.
                                     TOX-3

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                                                                 DRAFT
                           EXHIBIT TOX-1
    HYPOTHETICAL RESPONSE OF A GIVEN SPECIES TO A GIVEN DOSE
«. °a
vi c
    No reaction
                                                          Extreme reaction
                              TOX-4

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                                                                         DRAFT
Typically,  frequency-response  curves are  not  used.    Instead,  cumulative  dose
response curves are  utilized, which  depict the summation  of the frequency response
curves over the  range of doses.  A further refinement is made by  plotting the
cumulative response versus the logarithm of the dose, which  yields  plots that are
generally  linear.   Several  basic  relationships can  be readily  identified from the
plots  (Exhibit TOX-2).  A  dose is often described as either a  lethal dose (LD) in a
test where the  response is mortality, or  an effective dose (ED) in a test  where the
response is some other observable effect.

Constructing an ultimate  dose-response  curve enables the identification  of doses
that affect  a given percent of the exposed population (e.g., the ED^Q is thai  dose
at which there is an observable effect in 50 percent of the test  organisms).

1.3.2   Dose-Response Terms

The  National  Institute  for  Occupational  Safety  and  Health  (NIOSH)   defines  a
number  of  dose-response  terms   (Exhibit  TOX-3)  in  the  Registry  of  Toxic
Substances (1980, p.  xxiv):

      1. Toxic dose  low (TDLO): the lowest dose of a substance introduced  by any
        route other than inhalation, over any given  period of time, and  reported to
        produce any  toxic effect  in humans or  carcinogenic, neoplastigenic,  or
        teratogenic  effects in animals or humans.

      2. Toxic  concentration  low (TC(_0): the lowest concentration of a  substance
        in air to which humans or  animals have  been exposed for any given period
        of  time  that  has produced  any  toxic  effect in humans  or  carcinogenic,
        neoplastigenic, or teratogenic effects in animals or humans.

      3. Lethal dose  low (LD|_O): the  lowest dose,  other than 1050,  of substance
         introduced by  any route other than inhalation which  has been  reported to
         have  caused death  in humans or animals.
                                     TOX-5

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                                                         DRAFT
                     EXHIBIT TOX-2
          TYPICAL DOSE-RESPONSE RELATIONSHIP
§><=
en ws
II
                             Dose
                        TOX-6

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                                                         DRAFT
    EXHIBIT TOX-3.  DOSE-RESPONSE TEST
Category
TDLo



TCLO



Exposure
Time
Acute or
chronic


Acute or
chronic


Route of
Exposure
All except
inhalation


Inhalation



Toxic
Human
Any non-
lethal


Any non-
lethal


Effects
Animal
Carcinogenic,
neoplastigenic.
tumorigentic,
teratogenic
Carcinogenic,
neoplastigenic,
tumorigenic,
teratogenic
Acute or
chronic

Acute
Acute or
chronic

Acute
All except
inhalation

All except
inhalation
Inhalation
Inhalation
Death
Not
applicable
Death
Not
applicable
Death
Death
(statistically
 determined)

Death
                                                   Death
                                                   (statistically
                                                    determined)
                   TOX-7

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                                                                         DRAFT
      4.  Lethal dose  (LDX):  a  calculated dose of a substance which  is expected to
         cause the death of  x-percent  of defined experimental animal population.
         Fifty-percent (LD50) is usually used.

      5.  Lethal concentration  low (LC|_0): the lowest  concentration of a  substance
         in  air, other than \-C$Q,  which has been reported to have caused death in
         humans or animals.

      6.  Lethal concentration  (LCX): a  calculated concentration  of a substance in
         air, exposure to  which for a  specified length of time is expected to  cause
         the death of x-percent  of defined experimental animal population.   Fifty-
         percent  (LC5o) is usually used.

1.3.3    Use of Dose-Response Relationship

Comparing the LD5Q of chemicals in animals gives a relative ranking of potency or
toxicity of each.   For  example,  DDT (LD5Q for rats  = 113 milligrams per  kilogram)
would be considered more toxic  than ethyl alcohol (LD5Q for rats  = 1400 milligrams
per kilogram).  Using this LD$Q  and multiplying  by  70 kilograms  (average mass of
man)  gives  a rough extrapolation to humans, assuming they are as sensitive as the
species tested to the substance tested.

The LD5Q serves  only as a rough estimate of the toxic potential of a  substance, but
it  is  easy  to compute the  approximate  potency and  hence the  approximate  risk
associated with a substance (Exhibit TOX-4).

Dose-response curves are useful  when the response is mild,  such  as  odor or tearing,
rather than severe, such as coma. The difference between the curves provides the
margin of safety (Exhibit TOX-5),  which  is usually defined  as equal  to
                             Toxic
                             Nontoxic
                                     TOX-8

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                                                                          DRAFT
                     EXHIBIT TOX-4  TOXICITY RATING CHART
    Toxicity Rating
       or Class
              Oral Acute 1050
                  for Rats
Extremely toxic
Highly toxic
Moderately toxic
Slightly  toxic
Practically nontoxic
1 mg/kg or less (dioxin, botulin toxin)
1 to 50 mg/kg (strychnine)
50 to 500 mg/kg (DDT)
0.5  to  15 g/kg (morphine)
5 to 15 g/kg  (ethyl alcohol)
                                     TOX-9

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                                                                     DRAFT
                            EXHIBIT TOX-5


COMPARISON OF EFFECTIVE DOSE AND LETHAL DOSE RESPONSE CURVES
         IOO%T-
     1.1
     g. «

     J 1  50%
                             ED
                               50
ED
                                                50
                                     Dose
             Key: ED = effective dose (dose response for smell)

                LD = lethal dose (dose response for mortality)
                                TOX-10

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                                                                         DRAFT
Another ratio sometimes used is

                            Toxic dose-|
                             Nontoxic  dosegg

This gives a  smaller  margin  of safety than the  previous  ratio,  but it  is  more
realistic.

A  TLV is  an  airborne concentration  of a substance  in  the workplace  to  which
workers can presumably  be exposed without undesirable  effects.  Using the lower
end  of  the dose-response curve  (LD, TD,  or  no  effect)  and  a  1/10  or  1/100
protection factor permits  assigning a TLV (Exhibit TOX-6).

1.3.4   Shortcomings of  Dose-Response Data

Several shortcomings must be recognized  in a dose-response data.  One is that an
TD5Q  or 1050  is a single value and does not indicate the  shape of the curve—that
is, what the dose-response interval is, which is as important  as how high or low the
LDgQ  is.    Thus,  comparing  these   values  can  give  the   wrong  impression
(Exhibit TOX-7).

Most  1050 data  are for an  acute (single dose)  exposure   rather than a chronic
(continuous, long-term) exposure.  Data cannot be extrapolated if the disposition  of
the chemical (that is,  bioaccumulation,  metabolism,  excretion) or  the  target  is not
known.   For example, carcinogens are unsually  more dangerous  if  the dose  is
administered over several exposures instead of in one single exposure.

A  third shortcoming  is that usually  there is little information to guide the choice of
the animal data that mimic human exposure.  Are humans  less or more  sensitive
than the test  species?   For example,  in human studies arsenic  has been found  a
carcinogen, while in  animal studies it has not.
                                    TOX-11

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                                                              DRAFT
                         EXHIBIT TOX-6
 CALCULATION OF A TLV ON THE BASIS OF A DOSE-RESPONSE CURVE
oc jo
                   I TLV
                                             No Effect
                                 Dose
                            TOX-12

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                                                                    DRAFT
                       EXHIBIT TOX-7
      DOSE-RESPONSE CURVES OF TWO SUBSTANCES
S .1
                                 Dose

      (Chemical A is assumed to be more toxic than Chemical B based on
      ID50, but at lower doses the situation is reversed. At LD20
      Chemical B is more toxic than Chemical A.)
                            TOX-13

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                                                                         DRAFT
In  chronic  human exposure, the best guide is to extrapolate chronic animal data
that give a  "no  effect dose".   Usually this  dose is  not found  in the literature,  and
thus the dose-response curve is needed.

1.4   Factors Affecting Dose-Response Relationship

Man,  being a complex biologic system, does not respond  uniformly to a given dose
of a toxic substance.  There are a  variety of modifying factors.  A classification of
these  factors  is  presented  as Exhibit  TOX-8, and  certain  major  factors  are
discussed in the following sections.

1.4.1    Exposure

Tcxicity to  humans  and  other mammals  may  vary  depending  on  the  route of
exposure.   Material may be more or less toxic  by a given  route depending  on  the
modification  of  the  chemical,  if any, through  biotransformations.   These will  be
discussed in  more detail in  Section  1.5.  Two major entry routes,  namely the lungs
and the skin, are the most likely ways for  chemical toxicants to enter the body.

1.4.2    Sex

Some  substances  may be  more toxic  to one  sex  than  the other.   For  example,
women have a larger  percent  of fat in their total body weight, which means they
can accumulate more fat-soluble substances than men. Women also have different
susceptibilities to teratogenic chemicals.  Some cancers and other diseases are sex-
linked.  Animal data also shows sex-linked differences.
                                    TOX-14

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                                                                           DRAFT
        EXHIBIT TOX-8.  CLASSIFICATION OF FACTORS INFLUENCING TOXICITY
           Type
                     Examples
Factors related to chemical
Factors related to exposure
Factors  related to person  exposed
Factors  related to environment
Composition  (salt,  free  base,  etc.);  physical
characteristics  (particle   size,   liquid,   solid,
etc.);  physical properties  (volatility,  solubility,
etc.);   presence   of   impurities;   breakdown
products;  carrier.

Dose; concentration;  route of exposure (inges-
tion,  skin  absorption,   injection,  inhalation);
duration.

Heredity;   immunology;   nutrition;  hormones;
age; sex; diseases.

Carrier  (air,  water,  food,   soil);   additional
chemicals   present   (synergism,   antagonism);
temperature; air pressure.
                                     TOX-15

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                                                                          DRAFT
1.4.3    Age

Older people have  different blood  systems,  musculature,  metabolism, and excretory
patterns than younger people, which  change  the  disposition and  toxic effects  of
chemicals.  Also, children  are not  small adults.   For example,  they have higher
respiration rates and  different susceptibilities  (less  sensitive  to  stimulants of the
central  nervous  system  but   more  sensitive  to  depressants),  metabolism,  and
excretory patterns.

1.4.4    Synergism, Antagonism, and  Potentiation

Some combinations of chemicals produce different effects from those attributed  to
each individually:

      1.  Synergists

         Chemicals that, when  combined, cause a greater  than  additive effect.

      2.  Potentiation

         Potentiation  is a type of synergism where  the  potentiator  is a chemical
         not  usually  considered to be  toxic, but it increases  the toxicity  of other
         chemicals.

      3.  Antagonists

         Chemicals  that,  when combined,  lessen  the predicted  effect.  There are
         four types of antagonists.

         a.  Functional

            Produces  opposite effects  of the normal physiologic function.
                                     TOX-16

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                                                                         DRAFT
         b.  Chemical

            Reacts in  a way that  affects the toxicity of another  chemical.   For
            example,  phosphate  reduces  lead  absorption  in  the  gastrointestinal
            tract by forming  insoluble lead phosphate.

         c.  Dispositional

            Alters  absorption,   metabolism,   distribution,   or  excretion.     For
            example,  some  alcohols  use the  same enzymes in their metabolism.
            Ethanol is more  readily  metabolized  than  methanol, so  when  both  are
            present, methanol is not  metabolized and  can  be  excreted  before
            forming formaldehyde.   Another  dispositional antagonist is  Antabuse
            which,  when  administered  to alcoholics,  inhibits  the  metabolism  of
            acetaldehyde, giving the  patient a  more severe, prolonged hangover.

         d.  Receptor

            Occurs when a  relatively nontoxic chemical binds to the same tissue
            receptor  as  a  toxic  chemical  and thereby lowers  the  toxic effect  of
            the  second  chemical.

1.4.5    Genetic Characteristics

People are not borne genetically  equal.   Some lack genes which produce  enzymes
that  can alter the toxicities  of some chemicals.   For example, when people  with
GGPD  enzyme deficiency  are given  aspirin or certain antibiotics, they  are  likelier
than normal people to suffer damage to  their red  blood cells.

1.4.6    Species  Variation

The  physiologic  differences among various animal species lead to  the "Catch 22" of
toxicology.  Animals  are used as models  to  study the  mechanisms of toxicity of

                                    TOX-17

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                                                                         DRAFT
chemicals;  therefore,  the  proper selection of test animals requires  knowing which
one  most closely resembles  humans  with  respect to the chemical of interest.  The
goal  of  animal studies  is  to  predict  chemical effects  on  humans.   However,
selecting  the right  animal  requires  knowledge of  the fate  of the chemical  in
humans (the  goal), as well as its fate  in  various animals.

1.5   Toxic Effects

Toxic chemicals act on different organ systems.  The various effects are:

      1.  Local

         Certain chemicals  cause injury  to  the  upper  respiratory  tract or  to the
         lungs.  Many chemicals can produce lung disease.

      2.  Organotoxic

         Organotoxic  chemicals are those that are  absorbed into the blood stream
         and travel to  a  specific organ  where they  do their damage.   Examples
         would be central nervous system depressants such as methanol  or ethanol,
         hepatotoxins such  as  chlorinated hydrocarbons, or hematopoietic poisons
         such as benzene.

      3.  Asphyxiant

         Asphyxiants fall into two classes:  gases that are present in high  enough
         concentrations to  dilute the  oxygen  content  of respired  air to  where
         serious deleterious effects can  be observed, and chemicals  such  as  cyanide
         or  carbon  monoxide, which  prevent the body from receiving an adequate
         oxygen supply.
                                    TOX-18

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                                                                         DRAFT
      4.  Irritant

         Certain chemicals  irritate  the air  passages and  can  cause a  pulmonary
         edema. Examples are chlorine gas  and hydrogen fluoride.
         Bronchoconstriction and  chronic  pulmonary  disease  can result  from the
         inhalation  of  a  variety of  materials  that appear to  act  wholly  or partly
         through  an  allergic  response.    Many  respiratory  allergic  reactions are
         attributable to dusts, baceterial contaminants, or spores.  However, some
         chemicals  produce the same type of response.  One example is toluene
         diisocyanate (TDI), which can produce an  allergic reaction when inhaled.

     6.  Carcinogenic

         Many chemicals  are suspected  of causing cancer in  man.  This  topic will
         be discussed  in  detail in another section of this manual.

A discussion of toxic effects on specific organs or tissues follows.

1.5.1    Toxic Responses  of the CNS

The CNS is  defined  as  that part of the nervous system in vertebrates  which consists
of the  brain and  the spinal  cord.   It  receives  environmental input  through the
sensory nerves and responds by sending impulses through the motor nerves to the
muscles.  The CNS  serves the purpose  of  supervising and coordinating activities  of
the entire nervous system, and as  such  is vital for normal function  and survival.

The  CNS is protected from a  large number of  toxic  materials  by  the  so-called
blood-brain barrier.  The evidence for  the existence  of this barrier  is based upon
numerous  observations that some  agents which may enter  and  affect  other soft
body tissues such  as  the liver,  kidney,  and muscle, fail to  reach the brain.  Highly

                                    TOX-19

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                                                                         DRAFT
polar  compounds  are  in  general the  most readily  excluded.    However,  this
preferential  exclusion  does not  exist  for  all  substances,  especially  the  non-polar,
lipid soluble compounds.  This barrier is  not  so  well established  in children  as  in
adults.   A good example  is inorganic lead salts, which  may accumulate to  toxic
concentrations  in   the  CNS   of  children,  whereas   they   may   instead  cause
development of marked  adverse effects in  the  peripheral  nervous  system in adults
(Norton,  1980).

Two general types  of CNS toxicity may  result from exposure  to  toxic  materials:
(1)  structural  toxicity and  (2)  functional toxicity.  Both  may be  produced by direct
contact  with  a chemical  toxicant or by  secondary effects  such  as  anoxia (  a
diminished supply of oxygen).

There  are several  types of functional  changes  which  can  occur as a  result  of
physiological damage to  the CNS. These include:

      1.  Symbol Formation

         Impaired memory or learning.

      2.  Sensory-motor  Integration

         a.  Impaired  life  support  systems   such   as  eating,  reproduction,  and
            respiration.

         b.  Impaired voluntary and involuntary movement.

      3.  Emotional Responses

         Emotional instability and psychosis.

Neurotoxicants can  be classified also by  their  primary actions, according to the
following  types: (See Exhibit TOX-9)

                                    TOX-20

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                                                                       DRAFT
             EXHIBIT TOX-9.  CLASSIFICATION OF NEUROTOXICANTS BY
                       SITE AND TYPE OF PRIMARY ACTION
Agent

Anoxin
(Type 1)

Myelin
(Type 2)

Peripheral Nerves
(Types 3,4,5)

Localized CNS
(Type 6)
Acetylpyridine

Alcohol(s)3

Azide

Carbon disulfide

Carbon monoxide

Cyanide

DDT

Hexachlorophene

Lead (inorganic)
  child
  adult

Mercury (organic)

Nitrogen trichloride

Organophosphates
a Exposure to  ethanol  or  methanol  may  involve metabolism, which  enhances  the
  activity of other agents.
                                   TOX-21

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                                                                   DRAFT
1.  Anoxic Response

   Neurons and astrocytes (gray  matter) may be damaged, and responses will
   vary depending on  which  of the  three types of  anoxia  is responsible.
   Anoxic Anoxia  is  caused by inadequate  oxygen supply in the presence of
   adequate  blood  flow,  which  can   result from  direct  interference  with
   respiration by a toxicant.  Neuromuscular blocking  agents and compounds
   which  interfere  with  the   oxygen-carrying   capacity  may  cause   this
   response.    Even if  adequate oxygen  is  restored  after such  events  as
   cardiovascular failure, neurons of the CNS can  be destroyed without death
   of the individual.

   Ischemic anoxia causes a decrease  in arterial  blood pressure so that the
   brain does not receive enough oxygen. The blood supply stagnates, leading
   to  accumulation  of metabolites  such  as  lactic  acid,   ammonia,   and
   inorganic  phosphate.  This type of  anoxia can  occur during cardiac arrest
   or with extreme hypotension from vascular dilation.

   Cytotoxic  anoxia  is  caused by interference with   cell  metabolism in the
   presence of both adequate oxygen and blood  supply.  The oligodendroglia
   rather than  the neurons are  the cells are most greatly affected  by this
   process, which can  occur during hypoglycemia (excess insulin)  or in the
   presence of metabolic inhibitors such as  cyanide, azide, or dinitrophenol.

   The damage to the  CNS  as a result  of  anoxia depends primarily on the
   extent of  neuronal death.   Neurons are differentiated cells  which do not
   divide and cannot be replaced. However, there is an excess of neurons so
   that  normal  function  may  be  restored  after  many  nonfatal  neurotoxic
   experiences.   Some  permanent loss  of  function will occur when the cell
   destruction  proceeds beyond  a critical  number.   If cell death  does not
   occur, the  neurotoxic  reaction  will  last only  until the toxic  material is
   removed,  metabolized,  or  until the  altered cell constituents  have  been
   regenerated.

                              TOX-22

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                                                                   DRAFT
   The  CNS  cells  are  deficient  in their  ability to use anaerobic metabolism
   and  can therefore  be  greatly damaged  under conditions  of a  reduced
   oxygen  supply.   When this occurs, there may  be  cellular swelling  and  cell
   organelle   disorientation  which  will  be  accompanied  by   decreased
   cytoplasmic pH, decreased activity of oxidative enzymes, and  serious loss
   in the  capacity to synthesize protein.  During  anoxia, the  cell membrane
   integrity is  lost  and  edema  (fluid  accumulation  and swelling) develops
   rapidly.  The CNS cell type most seriously affected is the  neuron, which
   may be damaged within minutes after oxygen  ceases to flow to the brain.
   Some neurons will die even before oxygen or glucose transport stops.

2.  Damage to Myelin

   Substances which effect the Schwann  cells  and  oligodendrocyte may cause
   damage to  the  myelin  sheath surrounding the  neurons.   If the  central
   white  matter  (CNS)   is  involved,   encephalopathy  will  occur   and   if
   peripheral  cells  are damaged, polyneuritis will develop.

3.  Damage to Peripheral  Axons

   In addition to the myelin  damage just described, there can be  secondary
   axonic  degeneration, damage at the myoneural  junction, or damage to  the
   dorsal root ganglion.
                              TOX-23

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                                                                          DRAFT
      4.  Primary Damage to the  Peripheral Neuron Cell Body

         Damage  to  this  structure impairs  normal  function  of the entire  neuron
         because it is the  main site of protein  synthesis.

      5.  Damage at the Neuromuscular Junction of the Motor  Nerve

         Damage at this site affects pre- and postsynaptic binding, which includes
         the activity  of cholinesterase.   This  site is  especially vulnerable because
         it  is not protected by  the  myelin  sheath or the brain-blood barrier  (i.e.,
         substances diffusing  through capillaries of  the  skeletal muscle reach  this
         site directly).

      6.  Localized CNS Lesions

         Toxic compounds may cause these  lesions to occur in  regions that are not
         protected   by  the   brain-blood  barrier  and   that   may  have   unique
         biochemical specilization.

1.5.2    Toxic Responses of the Liver

The  liver  has a  major role  in  response to  chemical   toxicants  because  of  its
capability  to  carry  out  numerous  detoxifying  biotransformations.   It  has  the
capability,  for  example, to  render many  lipophilic  materials  into  water  soluble
forms  that can  be  excreted  in  the  urine  or  feces.    It  is  especially  active in
oxidative  transformation and  in  the  production  of  esterified  forms of potentially
toxic  organic  substances    It  may,  however,  produce toxic metabolites from
otherwise  inactive substances, which  may lead to either  liver injury or to  injury of
other organs  and tissues.   Liver  injury  is  by no means a single entity and  the
consequence of damage can only be assessed  when the precise nature  of the injury
is defined.
                                    TOX-24

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                                                                          DRAFT
The  period of exposure and the  concentration of the toxic  agent are important for
determining the type of lesion  produced  by a given substance.  After acute  toxic
exposure, one  generally  observes lipid  accumulation in the  hepatocytes,  cellular
necrosis, or a malfunction of the  hepatobiliary system.   On  the other hand,  chronic
and  low  level exposures may cause cirrhotic (hardening due  to  excessive connective
tissue) or  neoplastic  (cancer) transformations.   The injury to the  liver  may be
either  reversible or  permanent.   Since there is  heterogeneity  among cell types in
the liver  with regard to their function, it  only stands to reason that the  hepatotoxic
(toxic to  liver) response may occur by a variety of mechanisms.

1.5.2.1    Acute  Hepatic Damage

Chemically induced  acute  injury may have a  variety  of  different morphological
manifestations.   Fatty liver and  necrosis (degenerative  processes leading  to  cell
death)  may be produced.   The necrosis  may affect small  groups  of  parenchymal
cells, groups  of cells within defined zones of the liver (focal necrosis), or almost all
of the cells within a liver  lobule (massive  necrosis).  Likewise, lipid accumulation
may be  confined to small areas  or zones, or more  generally distributed.  Classical
damage  caused  by halogenated  hydrocarbons, carbon tetrachloride and chloroform
results in both fatty liver and necrosis.  Other  chemicals such as tannic  acid may
cause  only necrotic manifestations.   Exhibit  TOX-10  (modified  data from   Plaa,
1980) gives some  examples of acute hepatotoxic chemicals.

1.5.2.2    Chronic Hepatic  Damage

Chronic  exposures  may  result  in  very  significant  alterations in  the  total  liver
structure.  There  can be  variations in  the types  of cirrhosis, and either  or both
degerative   and   proliferative   (all    division)   changes   of   different    sorts.
Carcinogenesis (production  of cancer) is yet another manifestation.

1.5.2.3   Types of Hepatitis (Liver Injury)

The two types of  hepatitis and the characteristics thereof are as follows:

                                     TOX-25

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                                                                      DRAFT
                EXHIBIT TOX-10.  LIVER DAMAGE BY SOME ACUTE
                           HEPATOTOXIC CHEMICALS
Agent                                 Necrosis                      Fatty Liver
Carbon Tetrachloride                       +                             +
Chloroform                               +                             +
Bromobenzene                            +                             +
Dimethylnitrosamine                       +                             +
Aflatoxin BI                               +                             +
Tannic Acid                               +                             +
Ethionine
Tetracycline
Ethanol                                   -                             +
                                  TOX-26

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                                                                           DRAFT
      1.  Toxic hepatitis

         a.  Production of distinct lesions.

         b.  Dose-related production of lesions or severity of damage.

         c.  Lesions  appearing  after a  predictable,  usually  short,  latent  period
            (period with no obvious structure or activity changes).

      2.  Drug-associated hepatitis

         a.  Effect cannot be produced in experimental animals.

         b.  Effects not dose-dependent.

         c.  No latent period.

         d.  Few individuals in exposed population affected.

         e.  Often involves hypersensitivity (allergic response).

         f.  Considerable   variation  in   lesion   expression   among   different
            individuals.

1.5.2.4   Sites of  Cell Injury

Hepatotoxic chemicals  are  capable  of causing injury  to  liver  cells at a variety of
subcellular sites.   These sites or organelles are  among  those which  are  affected:
plasma  membrane, endoplasmic reticulum,  mitochondria, lysosomes,  and  nucleus.
Exhibit TOX-11 lists  a  few hepatotoxic  compounds  and the organelle which  they
affect.  It  should  be  mentioned  that  data  on  carbon  tetrachloride  (CCI4) has  been
of major  significance in defining the  nature of hepatic injury.   Carbon tetrachloride


                                     TOX-27

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                                                             DRAFT
        EXHIBIT TOX-11.  ORGANELLES AFFECTED BY

                 VARIOUS HEPATOTOXINS
Cell Structure
       Agent
Plasma membrane

Endoplasmic reticulum




Mitochondria




Lysosomes


Nucleus
Carbon tetrachloride

Carbon tetrachloride
Dimethylnitrosamine
Phosphorous
Tannic acid

Carbon tetrachloride
Phosphorous
Hydrazine
Dimethylnitrosamine

Carbon tetrachloride
Pyrrolizidine alkaloids

Pyrrolizidine alkaloids
Dimethylnitrosamine
Hydrazine
Aflatoxin B-|
Tannic acid
                         TOX-28

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                                                                          DRAFT
affects  the  cell  membrane, altering  its  permeability,  and  diminishes  activity of
Krebs cycle  enzymes.  Oxidative phosphorization is also uncoupled.  Some evidence
(Recknagel and Ghoshal, 1966) shows that the lipid structure or microsomes derived
from  the endoplasmic  reticulum  are •  affected  by  0014.    They  proposed   that
peroxidative decomposition of the lipids in this  structure occurs during the  early
stages  of intoxication.   Present evidence  shows that  CC1-4  is  biotransformed to
produce chloroform and C02-

1.5.2.5  Mechanisms of  Hepatic Injury

Mechanisms  by which  hepatic  injury may occur are:   (1) lipid  accumulation,  (2)
inhibition  or alteration of protein  synthesis, (3) lipid peroxidation, (4) necrosis (cell
degeneration  and  death),  (5)  cholestasis  (involving bile products),  (6)  cirrhosis
(characterized  by collagen distributed throughout the liver),  and  (7) carcinogensis
(a  series of changes leading to hepatic cancer).

Before completing this discussion  it should be noted that hepatic enzymes,  such as
cytochrome   P-450/mixed  function  oxidases  (MFO),  may   convert  a  variety  of
chemical  substances  into metabolic  forms  which  may  react  with   the   cell's
chromosomes  (genotoxic  metabolites)  or  with   other   structures   previously
mentioned.    Typically,  this  results from  a   chemical  being  activated  to  an
electrophilic  form  by  an  MFO  in  an  attempt  to   enhance  its excretion.    The
electrophile  is now capable of reacting with nacleophilic species  present in the
cell, including many of the components of DNA.  Alteration of DNA in this manner
is  felt to  be  a major function in mutagenesis. There  are  also compounds to  which
individuals may be  exposed that  can potentiate the action  of other agents.  For
example,  consumption  of  or  exposure  to  ethanol  increases  an   individual's
susceptibility to halogenated hydrocarbons.  Those halogenated hydrocarbons whose
toxicities  are  increased  by  ethanol  include   carbon   tetrachloride,   chloroform,
trichloroethylene,  and  1,1,2-trichloroethane  (Klaassen  and  Plaa,  1967).     Other
aliphatic alcohols  such as methanol, isopropanol, n-butanol,  sec-butanol, and tert-
butanol also  exert  potentiating effects  on the  acute toxicity of CCI3 (Cornish and
Adefuin, 1967).   The  potent  teratogen,  2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)

                                     TOX-29

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                                                                          DRAFT
has the capability of potentiating carcinogenic activity of 3-methylcholanthrene  in
rodents that otherwise  fail  to  develop liver tumors, and  it increases the incidence
of tumors  substantially  in  susceptible  animals  (Kouri,  Schechtman, and  Nebert,
1980).   Although each type  of potentiating effect  should  be  considered  to  operate
through a variety  of mechanisms, the enhancement can frequently  be attributed  to
stimulation  of a specific  set of enzymes or by altering the rate at which an agent
may penetrate,

1.5.3    Toxic Responses of the Kidney

The kidney  is an organ likely to have  considerable exposure to toxic chemicals that
may enter the body.  About  25 percent of the  heart's blood flow output reaches the
kidney and  about 1/3 of the  plasma water reaching  the kidney is filtered (Hook,
1980),  so  that approximately 98 percent of the salt and water is reabsorbed. Since
the blood flow is very high and because  reabsorption from the glomerular filtrate  is
also high, materials  remaining in  the urine  may  be  concentrated  in this tubule.
Thus,  a  potential  renal  toxicant may also be concentrated  in the kidney.   As  a
consequence, the kidney  may be  highly  susceptible  to  systemic  toxicants.  The
kidney also  carries out  numerous  metabolic functions, some of which are unique.
The following agents are some specific nephrotoxins (kidney toxins):

      1  Heavy Metals

         Heavy  metals  are  especially   toxic   to   the  kidneys.    At low  doses,
         glucosuria,  amino-aciduria,  and polyuria  may occur whereas  increased
         concentrations   lead  to  renal  necrosis,  anuria,  increased blood  urea
         nitrogen, and  death.    Mercury, chromium,  and  uranium  toxicity to the
         kidneys are well documented, and  other metals have been demonstrated  as
         nephrotoxic.
                                    TOX-30

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                                                                           DRAFT
      2.  Halogenated Hydrocarbons

         Hydrocarbons  such  as  carbon  tetrachloride  and  chloroform  are both
         hepatotoxic  and nephrotoxic, but it  appears that their biotransformation
         to  the  active  metabolite  occurs  in  the   liver.    Hepatic   potentiating
         chemicals,  such  as  the  aliphatic  alcohols  and  acetone,  are  likewise
         potentiators for  nephrotoxicity, and  other halogenated hydrocarbons  also
         are toxic to the kidneys.

      3.  Antibiotics

         Antibiotics  such as  neomycin, streptomycin, kanamycin, and  gentamycin
         also exhibit nephrotoxicity.

      4.  Analgesics

         Analgesics such as aspirin taken over long periods may cause nephritis and
         even renal failure  (loss of concentrating capability).

      5,  Anesthetics

         Anesthetics especially among  halogenated hydrocarbons, may  also produce
         nephrotoxicity.

1.5.4    Toxic Responses of the Eye

The  eye  is  a  highly  specialized organ  which  has  unique  features that make  it
sensitive to  toxic substances.  It  contains at least four photosensitive pigments, and
organ-specific  lens  proteins.   In addition  to  these components, the  eye contains
true   neural   tissue  (inner retina  and  optic  nerve),  light-sensitive  neural  tissue
(photoreceptors), the  lens and  cornea surrounded  by  unique  fluids   required  for
transparency, and an isolated cerebrospinal fluid  system.  The  barrier to circulating
                                     TOX-31

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                                                                         DRAFT
blood is as specific and effective as that of the  brain.  A  breakdown of this barrier
would likely result in blindness.

Contact with external agents  is of special consequence to the cornea, conjunctive,
and  neighboring tissues.   Acids  may  be  counteracted  by  washing procedures;
however,  the effectiveness  of eye washing can  be  variable.  For instance, HCI can
cause severe  damage at pH  1.0, but may  have virtually  no effect at about pH  3,
whereas sulfuric acid may be  injurious at a  wide range of  pHs.  Sulfur dioxide (S02)
will  combine with  corneal  liquid to form H2S03.  H2SC>3  is fat  soluble,  and will
penetrate through the cornea  and cause a more severe and variable response.  For
example,  NaOH exposures for short periods, e.g., 1/20  normal for  30  sec.,  may not
have lasting effects whereas exposures  of over  three minutes may lead  to corneal
opacity  or even  ulceration and  perforation.   Ammonium hydroxide,  on the other
hand, will penetrate rapidly into the anterior (front)  chamber because  of the fat
solubility  of nonionized NHs (e.g., in  a few seconds).  Lime burns,  organic solvents,
and war gases (nitromustards) may also cause  severe burns.

Organic  solvents  can be  of  significant  concern.   Naphthalene,  for  example,  can
cause  significant  acute toxicological damage  to  the  retina  on  external  contact.
Systemic  absorption of naphthalene  vapor may result in the formation of cataracts.

Methanol, a well publicized poison  of the  CNS  can likewise damage the ganglion
cell  layer  of  the  optic  nerve  (GCN) and  lead to  permanent  visual impairment.
Carbon  disulfide  and  pentavalent  arsenic are  also  examples of  agents that  can
selectively damage the GCN.

1.5.5    Toxic Responses of the Respiratory System

There is  a vast  array  of  materials  that  are known to  produce lung  diseases.
However,  the responses to  these agents can be divided  into five  broad  categories
for practical consideration (Hook, 1980):
                                    TOX-32

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                                                                         DRAFT
     1.  Air passage Irritation

        This  response causes  airway  constriction,  which  may  be followed  by
        edema.  Secondary bacterial  or  viral  infections may further  complicate
        the damage

     2.  Damage to Cells Lining the Air Passages

        This will cause  necrosis, edema,  and increased permeability.  There will,
        in general,  be accumulation  of fluid and swelling  within  the  air  space
        rather than within the cells lining the airways.

     3.  Fibrosis

        If  the fibrosis becomes  massive, there  will  be a  sharp decline  in  the
        respiratory capacity of  the  lung.   Localized  fibrosis  of  the pleura may
        occur, resulting in  pain, irritation, and restriction of lung movement.

     4.  Allergic Response

        As  a  consequence  of  response  to  complex  organic  material  or  simple
        compounds acting  as antigens (agents  evoking antibody production)  or
        haptens (small molecules that combine  with carrier molecules,  often body
        proteins, thereby  becoming  antigenic themselves)  allergic  alveolitis may
        occur.

     5.  Tumoriqenesis

        The production  of  primary lung tumors  may  occur as a consequence of
        exposure  to a procarcinogen or carcinogenic agent.

Exhibit  TOX-12  lists  these  five   responses  and   some  agents  encountered
occupationally that may elicit each response.

                                    TOX-33

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                                                                       DRAFT
          EXHIBIT TOX-12. PULMONARY DISEASES AND SOME SELECTED

                      OCCUPATIONALLY INHALED AGENTS
Toxicant
             Air Passage
               Irritation
Air Passage
 Necrosis
 Fibrosis
Production
 Allergic    Carcino-
Response    genesis
Asbestos

Ammonia

Chlorine

Chromium

Coal Dust

Hydrogen
fluoride

Phosgene

Silica

Sulfur
dioxide

Toluene
                                   TOX-34

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                                                                         DRAFT
1.5.6    Toxic Responses of the Blood

Toxicants which affect blood cells or the tissues and organs in which these  cells are
produced can  cause considerable damage or death to  an exposed  individual.  This
discussion  will  consider the  effects  of  toxicants  on  the  hematopoietic (blood
forming) system  and red blood  cells (RBCs).

The bone marrow is an important source of blood cells because  it contains the  stem
cells,  which are the the immature precursors of these cells.  The pool of stem cells
is  stimulated  to  form red blood  cells (ervthrocytes),  platelets  (thrombocytes), or
white blood cells (several types of leukocytes).  A  decrease in  the number  of these
elements is termed anemia, thrombocytopenia, or leukopenia, respectively.

Factors  present in the blood which stimulate the stem  pool to form each  type are
called  "poietins,"  for  which  each element has  its own type.    Hence, the name
eruthropoietin  describes  the  factor that stimulates RBC formation,  etc.   Organs or
tissues  other  than the  bone  marrow,  such  as  the  kidney,  are  responsible for
producing  these  poietins, and therefore regulation  of cell  production  may  be
affected by toxicants that damage tissues other than bone marrow.

Chemicals  that are toxic to the bone marrow can  cause a  decrease in  the  number
of  blood  cells   in  the  circulating  blood.    This  systematic  condition,  called
pancytopenia,  can  be  attributed  to  excessive   exposure  to  ionizing  radiation,
mustard  type  chemicals, arsenic, trinitrotoluene,  and  chloramphenicol  (Harris and
Kellermeyer, 1970).  If damage to the  bone  marrow is  severe, stem cells  may fail
to proliferate  (aplastic anemia), but  the marrow may have normal  cellular  content
or  even greater  numbers (hypercellularity)  and  still  fail  to  produce  the normal
numbers of circulating cells.  The normal numbers of these cells in humans should
be  approximately 4.9 x  106  erythrocytes  per  cubic  millimeter,  5  to 10 x 104
leukocytes  per cubic millimeter, and 250,000  platelets per cubic millimeter.

The binding  or  reacting with  hemoglobin by a variety of agents  may lead to  a
condition where  there is an inadequate supply of oxygen  to the tissues (hypoxia).

                                    TOX-35

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                                                                        DRAFT
These  agents produce a form  of hemoglobin that is incapable  of  transporting
oxygen  and,  as  a result,  the  PC>2  (oxygen  pressure) in the arterial blood will  be
lower than  normal  causing  oxygen  deficiency.   Carbon  monoxide is  especially
potent in  this regard, forming  carboxyhemoglobin.   Exposure to  a gas mixture with
0.1   percent  CO  will  result  in  half  of the  erythrocytes  becoming  saturated
(50 percent carboxyhemoglobinemia) at sea level.

When an oxidizing reagent reacts with heme iron, its valence may be elevated from
the ferrous  state (Fe"1"1" or Hb"1"1") to the ferric  state (Fe+++ or Hb+++).  When this
occurs,  a  pigment (methemoglobin) of  greenish brown  to  black color  is produced
and this hemoglobin is unable to accept oxygen. Among the best know chemicals
that generate methemoglobin are sodium nitrite and organic hydroxylamines.

Sulfhemoglobin is a  hemoglobin pigment  generated  by  exposure of oxyhemoglobin
(normal  hemoglobin) to high concentrations of  hydrogen sulfide.  This pigment plays
no  role  in acute hydrogen  sulfide  poisoning.   Unlike  carboxyhemoglovinemia and
methemoglobinemia,  no mechanism  is known  for  reversing sulfhemoglobinemia.
Therefore  this condition  is  more  of a toxic  threat.   However, this condition  is
either self  limiting  or it may  lead  to  production of Heintz  bodies  (denatured
hemoglobin).  These bodies  attach firmly  to the cytosplasmic membrane, impairing
cellular transport systems. This causes hyperpermeability and cell lysis.  Aromatic
amino (aniline) and  nitro  (nitrobenzene) compounds, phenols, and  dichromate  are
among the agents which appear to be capable of inducing Heintz  body formation.

There are  known ways to reverse or manage the hypoxic conditions described  in the
preceding  paragraphs.  Carboxyhemoglobinemia can be treated by supplying oxygen
unless the dose  and  exposure time has been too great.  For methemoglobin anemia,
methylene blue  administered at one  to two milligrams per  kilogram (Gosselin  et.
al.,  1976) can provide protection, and  administration of four atmospheres  of oxygen
(Goldstein and Doull, 1971) may decrease mortality.

When there  is a hemolytic  disease  caused by toxic  agents or microbial agents,
spleen engorgement  may occur because of a need to destroy  damaged RBCs.  Other

                                    TOX-36

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                                                                         DRAFT
reticuloendothelial systems  are  capable  of  performing this function in  addition to
the spleen.  Thus the presence of white  cells and the enlargement  of these organs
may be related to the presence of a hematotoxic response.

1.5.7    Toxic Responses of the Reproductive System

The  exposure  of the human  reproductive system to toxic  agents  is  a matter of
major health concern because of the  consequence to  future  generations.  Recently,
in  California,  male factory  workers exposed  to  1,2-dibromo-3-chloropropane  were
reported to be sterile and to have  a variety of  sperm defects or reduced  count
(Dixon, 1980).  Factory workers handling  the organic solvents  toluene,  benzene, and
xylene also have  been observed to display low sperm counts, abnormal  sperm, and
variable infertility.   Diethylstilbesterol, cadmium,  methylmercury,  and a  variety of
anticancer chemicals have been shown to cause genetic damage to male and female
reproductive organs (Lucier, et al.,  1977; Habison and Dixon, 1978).

The following reproductive events  and  processes must function normally in  order to
produce healthy progeny (Dixon,  1980):

      1. Preservation of the germ  line
      2. Gametogenesis  (germ cell production)
      3. Release  and transport of gametes
      4. Fertilization
      5. Preimplantation cleavage  and  blastocyst formation
      6. Implantation
      7  Maternal metabolism
      8. Embryogenesis
      9. Fetal  development
     10. Placental functions
     11.  Birth  and postnatal adjustment
     12. Lactation and postnatal care
     13.  Growth  and maturation of offspring
                                    TOX-37

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                                                                         DRAFT
The  testes  are  afforded  some  protection from  systemic chemical toxicants  by a
blood-testes (BTB) barrier similar  to  that which protects  the  brain.   A  series of
membranes and tubules forming layers around the tubes and  germ cells, the BTB
greatly  reduces the penetration of foreign  substances.   No blood-ovarian barrier
with comparable capabilities has  been identified, but the ovary  appears  incapable
of  metabolizing  certain  exogenous  chemicals  to  toxic  metabolites.  Various
biotransformations  can  be  made  in  the  testes  because  they  possess  active
cytochrome, glutathione S-transferase, expoxide  hydrase, and hydroxylase systems.
Thus, potentially genotoxic (active  on  DNA) metabolites  may be produced, some of
which can  cause cancer.

The following noninclusive list of agents may affect male  reproduction:

      1.  Metals

         Lead, mercury, cadmium.

      2.  Insecticides

         DDT,   dieldrin,  chlordane,   organophosphorus  pesticides,   carbamates,
         phenoxyacetic  acids  (2,4-D   and  2,4-T),  paraquat, DBCP, and  ethylene
         dibromide.

      3.  Food Additives and Contaminants

         DES, aflatoxin nitrofurans,  and  cyclamates.

      4.  Radiation

         a,  8, y, and x-ray.

The following are some agents  that may affect  female reproduction:
                                    TOX-38

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                                                                        DRAFT
      1.  Steroids

         Natural and synthetic estrogens, androgens, and progestins.

      2.  Pesticides

         Chlordane, DDT, parathion, carbaryl.

      3.  Food Additives and Contaminants

         DES,  nitrofuran derivatives, nitrosamines.

      4.  Industrial Chemicals

         PCS,  phthalic acid  esters.

Finally, it  should be mentioned that mammalian  systems are capable of repairing
damaged  DNA.  However, the repair systems  are interrelated with such  important
processes as recombination and the possibility exists for mutations to arise as well
as for the normal restoration of genetic damage.

1.6   Acceptable Exposures

Every  year  the  American  Conference  of  Governmental  Industrial  Hygienists
(ACGIH) revises their publication  Threshold Limit Values for  Chemical Substances
and Physical Agents in the Workroom Environment with  Intended Changes.

The   current   booklet  on  TLVs  contains  time-weighted  average  concentrations
(TWAs) for the 8-hour  work day  or 40-hour week and  short-term exposure  limits
(STELs) for excursions above  the  TWA.   Other TLVs  are found  in  the  booklet
concerning carcinogens, nuisance  dusts, and other physical agents.
                                    TOX-39

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                                                                          DRAFT
The  TLVs are to  be used  by a trained  industrial  hygienist to ensure the  proper
interpretation  and application  of these values.  The  TLV booklet states  that TLVs
"are  not  intended for use or for modification for use

      1.  As a relative index of hazard toxicity,

      2.  In the evaluation or control of community air pollution nuisances,

      3.  In estimating the  toxic potential of continuous, uninterrupted exposures  or
         other extended work periods,

      4.  As proof or disproof of an existing disease or physical condition..."

1.6.1    Time-Weighted Averages (TWAs)

The  average  chemical  concentration most workers can be exposed to during a 40-
hour week of 8-hour days without adverse  effects, chronic or acute, is designated
as the  TLV-rwA-x;  where  x  is the  unit of time  overwhich  the concentration  is
averaged.  Eight hours is the  unit of time which corelates  to  a  typical workday
(TLV-ywA-s)-   However, the time can  vary, as in the  case of TLVjwA-STEL which
is  usually measured  over  a 15 minute exposure  period. The TLVywAs are given  in
parts per million  and/or milligrams per cubic meter.  In general, parts per million  is
used for gases and vapors and  milligrams per  cubic meter for particulates, although
this is  not always true.

The  following  is  a  sample  calculation  of the TWA  of worker  exposure  to  a
compound for comparison with the accepted TLV:

        Given:              Concentration'*                   Exposure Time"
                           C]  = 15 ppm                     ti  =  2.5 hr
                           C2  21                          t2  =  2.5
                           C3  18                          t3  =  2.5


                                    TOX-40

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where i = 1,2,3,...,n          TWA
                                                                               DRAFT

                                    [(Cj) (tj)]
        TWA = [(C^t!)] + [(C2)(t2)] + [(C3)(t3)] + [(Cn)(tn)]
                        ti + t2 + t3 • + • • • tn
        TWA = [(15H2.5)] + [(21)(2.5)] + [(18)(2.5)] + [(0)(.5)1
                       2.5  + 2.5 +  2.5  +  .5
        TWA = 37.5  +  52.5  + 45  +  0
                          8
        TWA = 16.9  ppm
      *AII  units of concentration and time must be consistent.

This  TWA must  be  compared  with  the  TLV  of  the chemical  to determine  whether
conditions are acceptable.

1.6.2    TLVs Designated with "Skin" Notation

Various substances may be listed in  the TLV booklet  with the special  designation "skin"
This is  to draw attention  to  another effect of the  substance  that  may be  as  harmful  as
inhaling the substance.  Direct skin  contact  with the substance should be  avoided  when
this designation is noted  in the  booklet.  Some chemicals can be absorbed through  the
skin and transported by the blood system to  their respective target organ where  the toxic
effect  occurs.  Documentation  of TLVs, published  by the ACGIH, should  be consulted  to
determine how and why the TLV for the skin  was established in the booklet.

1.6.3    Excursions (STEL, TLV-C)

A  TLV may  be exceeded  for a short  period of time  if the listed  TLV is  not  designated
with  "C"   The C  refers to the  ceiling  value  of  the  TLV,  otherwise referred to  as  the
TLV-C.  This TLV-C  cannot be  exceeded at any time or for  any reason because of the
inherent health risks.  If no TLV-C  exists,  the TLV  may  be  exceeded up  to the  time  and
concentration  limit   designated  in  the  TLV  booklet   as  the  Short  Term  Exposure
                                      TOX-41

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                                                                        DRAFT
Limit  (STEL).    If  no  STEL is  given  for  that compound,  then any  excursion
attempted  must be  based on applicable  industrial  hygiene and toxicological data,
provided that the TLV-TWA-S is not exceeded.
STEL's are intended to provide guidance for  planned  excursions above the TLV.  A
STEL  based excursion above the TLV cannot exceed 15 minutes  in duration and only
four excursions  are permitted each  day.  At least  one hour must elapse between
each  excursion.     The  excursion   exposure  time  and  concentration   must  be
calculated into the TWA and must not exceed  the TLV  for the day.

Thus, any excursion, be it based on the STEL or  other data, must be accompanied
by  an excursion of equal  magnitude  below the TLV.   It must  be remembered that
any  excursion limit  given  by the STEL is essentially  the same as  a TLV-C and
should not be exceeded.

1.6.4    Mixture TWA

For  situations  in  which   more  than  one  substance  may  be  in  the working
environment, it is important  to  determine  a  mixture  TWA.  The first  consideration
is the overall effect of the mixture on the worker.  If the substances have the same
physiological or toxicological effects, then the TWA can be   considered additive.
Such  a TWA can be calculated as follows:
                 Concentration                TLV
                C-|  =  400 ppm              1    1000  ppm
                C2  = 150 ppm              2  =  200 ppm
                63  = 100 ppm              3  =  200 ppm
        C-|    C2    03         en
TWA    — + ,-  + ,-  • • •  + T—    .
       TT    T2    T3         Tn =  1
        lo
                                    TOX-42

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                                                                          DRAFT
If  the  preceding  sum  (n) is equal to or  greater than  unity,  then the TLV  of  the
mixture has been exceeded.  If the value is one or less,  then the value is within  the
TLV for the mixture.

When the effects of the individual  substances  are known to be different,  therefore,
not additive,  the  actual TWA of each substance  must be compared to its own TLV
separately.  An example might  be a  mixture of  two gases, one  having  a narcotic
effect and the other simply acting  as an  irritant.  To determine what kind of effect
the TLV is based on,  one  must  refer  to the ACGIH Documentation  of  TLVs.   It
relates such information and cites  references where more data  may be found.

1.6.5    Mineral Dust and Nuisance Oust TLV

Dusts  with  less  than  one  percent  quartz content  have  a  general  TLV  of  10
milligrams  per  cubic meter or  30 million  parts  per  cubic  foot.  Such dusts  are
considered a  nuisance  because  they may be deposited in the  ears, nasal  passages,
and eyes. They may block visibility. Such dusts  may also be collected in  the lungs
but any damage is  usually reversible.  A  list of nuisance dusts is found of the TLV
booklet.

Dusts  with greater  than  one percent quartz  composition  are considered  mineral
dusts and  must  be calculated  using  the formula for  quartz in the  TLV booklet.
Other  mineral  dusts include  silica, silicates,  and coal  dusts, all  of which have
formulas for TWA calculations.  Mineral dusts can  cause  irreversible lung damage.

1.6.6    Physical Agents

A  formula for determining  a TWA value for heat stress  to be  compared with a  TLV
is  given in  the booklet,  but  it  is suitable  only for  light  summer  clothing.   The
formula is not compatible with  rain suits or full encapsulated clothing.
                                    TOX-43

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                                                                          DRAFT
Several other physical agents  such as radiation  (ionizing, ultraviolet,  microwaves,
and  noise) are also discussed.   These factors  certainly  should  be considered  on a
working  site.   Noise is  especially  important  when activity is  prolonged  around
heavy  machinery or impact tools.

2.0   CARCINOGENS

2.1   Definitions

The   following   definitions  will  be  useful   in  understanding  the  section  on
carcinogenicity:

Carcinogen

A  substance (chemical, physical, biological) with  the ability to cause  a  neoplastic
transformation  in an  animal  cell which could  lead  to  the production  of  a  solid
tumor or a leukemia.

Genotoxic  Carcinogen

A  carcinogen that causes  a modification or change in DNA.

Epigenetic  Carcinogen

A  carcinogen for which  no  evidence  of  direct  interaction with  genetic  material
(DNA)  exists.

A  listing  of  the classes  of  carcinogenic  chemicals and  information  pertinent to
each class  is presented as Exhibit TOX-13.
                                     TOX-44

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                                                                         DRAFT
            EXHIBIT TOX-13.  CLASSES OF CARCINOGENIC CHEMICALS
Type
      Mode of Action
    Example
Direct-acting or
  primary
  carcinogen
Procarcinogen or
  secondary
  carcinogen
Inorganic
  carcinogen
Solid-state
  carcinogen
Hormone
Immunosuppressor
Cocarcinogen
Promoter
Electrophile, organic compound,
  genotoxic, interacts with
  DNA
Requires conversion through
  metabolic activations by
  host or in vitro to
  type 1
Not directly genotoxic, leads
  to changes in  DNA by selec-
  tive alterations in fidelity
  of DNA replication

              Epigenetic

Exact mechanism unknown;
  usually affects only mesen-
  chymal cells and tissues;
  physical form  vital

Usually not genotoxic, mainly
  alters endocrine system
  balance and differentiation;
  often acts as promoter

Usually not genotoxic; mainly
  stimulates "virally in-
  duced," transplanted
  or metastic neoplasms

Not genotoxic or carcinogenic,
  but enhances  effect of type
  1 or 2 agent when given
  at the same time.  May
  modify conversions of type
  2 to type  1

Not genotoxic or carcinogenic,
  but enhances  effect of
  type 1  or  type 2 agent
  when given subsequently
Ethylene imine,
  Bis  (chloromethyl)
  ether
Vinyl chloride,
  benzo (a) pyrene,
  2-naphthylamine
  dimethylinitros-
  amine

Nickel, chromium
Polymer or metal
  foils, asbestos
Estradoil,
  diethylstil-
  bestrol
Azathioprine,
  antilymphotocytic
  serum
Phorbol esters,
  pyrene,
  catechol,
  ethanol,
  n-dodecane,
  S02

Phorbol esters,
  phenol, anthra-
  lin, bile acids,
  tryptophan
  metabolites,
  saccharin
                                    TOX-45

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                                                                          DRAFT
2.2   DNA as a Target for Carcinogens

The  pnme effect of most carcinogens is  on the genetic material that specifies all
cell functions and reproduction. There is evidence of the following:

      1.  Many carcinogens  are,  or  can  be  metabolized  into,  chemicals that are
         known to interact  with DNA.  In  vitro  studies with many carcinogens have
         shown damage  to DNA or  modifications of the integrity of the genetic
         code.    These  carcinogens  stimulate   DNA  repair  activities  in   tissue
         cultures.

      2.  Many carcinogens  are mutagens.

      3.  Defects  in   DNA   repair,  such   as   the  genetic  defect  in  xeroderma
         pigmentosa, usually correlate with an increased  incidence of cancer.

      4.  A variety  of  inherited  chromosomal abnormalities can  be  correlated with
         an increased  incidence of cancer.

      5.  Neoplastic transformations in a  cell are  usually found  in most, if not all,
         progeny  cells,  indicating a heritable  (can  be inherited) change  resulting
         from a modification of DNA structure or expression.

      6.  Most  cancer  cells and cells  in  culture that have undergone a  neoplastic
         transformation display chromosomal abnormalities.

2.3   "Causes' of Cancer

Since cancer is a generic term encompassing a variety of neoplastic conditions and
very  little  is  really  understood concerning the molecular events involved  in the
initiation or maintenance  of a cancer, very little can  be  said concerning the cause.
At this point, it is sufficient to discuss those  things that  we can  reasonably assume
to increase the risk of  developing  cancer.

                                     TOX-46

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                                                                    DRAFT
1.  Environmental Cancers

   A  variety of items in  our environment  have been  implicated as potential
   carcinogens.   These  include  iatrogenic  carcinogens  (carcinogenic  side
   effects  of materials prescribed by  a  physician) and chemicals  released or
   effects  from  our  "normal"  activities  such as  tanning  in  the  sun  and
   smoking.

2.  Occupational Cancers

   A  variety of occupations  expose  individuals to a particular type of  cancer.
   A  chemical  or biological laboratory  worker, especially  one attempting to
   determine  the carcinogenicity  of  materials,  is  subject to  many more
   cancers  than  the  average  worker.   The  laboratory  person and  persons
   involved with  hazardous  waste face  the added  danger that results  from
   the interaction of many agents.

3.  Dietary  Cancers

   There  are still  many questions concerning the  relationship  of  diet to
   cancer.    For  example,  50  years  ago,  it  was  established  that  the
   consumption of alcohol is related to  the incidence of  cancer of the mouth,
   pharynx, larynx,  and  esophagus.   It  is  still'unknown if  it  is  the  alcohol
   itself that is responsible (possibly by  solubilizing a specific agent) or some
   other component  of  alcoholic drinks.   The lack  of research in  this  area
   may be  attributable to the fact  that pure  alcohol  is not carcinogenic to
   lab animals or to  a  natural distaste for  investigations of the effects of
   alcohol  on  human beings.   Other  dietary  questions  concern the  ratio of
   fiber and  animal fat in one's diet  and  the incidence of cancer of the colon.
                               TOX-47

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                                                                    DRAFT
4.  Interaction of Agents

   The  synergism  discussed in the toxicology section  is  also  a factor  in
   carcinogenesis.   Examples  of  this include the interaction of Hepatitis B
   virus  and aflotoxins in producing cancer  of the liver;  and, perhaps more
   germane  to  laboratory personnel, the interaction of  both  asbestos and
   ionizing radiation with  smoking to produce cancer of the lung.

5.  Viruses

   There  has   been  a  tremendous amount  of  indirect  evidence,  both
   epidemiological  (e.g.,  Herpes  Virus  Type II  and  cervical  cancer),  and
   biochemical  (e.g., the  detection  of viral  components  or virally induced
   enzymes  in  cancer cells).   Cancer  viruses  have  been  identified  in  all
   mammalian  species with the  exception  of man.   There is,  however, a
   growing  body  of  evidence   indicating that there may  be cocarcinogenic
   effect  between  viral   genetic   material   and   chemical   carcinogens  to
   produce cancers.

6.  Systemic  Factors

   There  is  some thought that the  breakdown of systemic  control and the
   accumulation  of  cellular  mutagenic  from  both  natural  mutation  and
   environmentally  induced  mutation (chemicals  and  radiation)  may lead to
   the development of cancer.   Cancer has  been called a disease  of the aged
   due to the greatly increased incidence of  cancer with age.  In addition to
   the increase  in  genetic damage,  there is a loss in  the  efficiency  of the
   immune system  with age.  Immunosurveillance is thought to  be a factor in
   protecting man  from  developing  cancer.    The  relationship between
   immunodeficiencies and certain cancers is  well  documented.
                              TOX-48

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                                                                    DRAFT
7.  Genetic Factors

   When  considering the  causes of cancer, one  must always  consider the
   effect  of heredity on the likelihood  of developing  cancer.  There are four
   possibilities:

   a.  Genetic predisposition to cancer even in the absence of environmental
      variation.

   b.  Predisposition  imposed  by environmental variation in the absence  of
      genetic variation.

   c.  Predisposition by both environmental  and genetic factors.

   d.  Neither genetic nor environmental predisposition.

      The first class is quite small,  possibly one percent of the  total number
      of cancers.   It is felt that the second and third classes combined are
      responsible  for 70  to 80 percent of all  cancers.   The  fourth group
      results  from  "spontaneous" or "background"  mutations  and represents
      the endemic  level  of  cancer within the  population  that  cannot  be
      prevented. The main area of  interest for this audience is classes a and
      b  above.   Research data  indicate  that controllable  elements  in the
      environment  are involved in the development of most  cancers.
                               TOX-49

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                                                                  DRAFT
                   RESPIRATORY PROTECTION PRINCIPLES
                               CONTENTS
SECTION                                                           PAGE

1.0      GENERAL PRINCIPLES                                         RP-1
1.1      INTRODUCTION                                              RP-1
1.2      ROUTES OF EXPOSURE                                       RP-1
1.2.1     RESPIRATORY TRACT                                         RP-1
1.3      TYPES OF INHALED TOXICANTS                                RP-7
1.4      OXYGEN  DEFICIENCY                                         RP-8
1.4.1     OXYGEN  AND THE RESPIRATORY PROCESS                       RP-8
1.4.2     OXYGEN  LEVELS/PHYSIOLOGICAL EFFECT                        RP-9
1.5      PARTICULATE CONTAMINANTS-AEROSOLS                       RP-9
1.6      GASEIOUS CONTAMINANTS                                    RP-12
1.7      EXPRESSING AIR CONTAMINANT CONCENTRATIONS                RP-14
1.8      MEASURES OF RESPIRATORY HAZARDS                          RP-14
1.9      RESPIRATORY PROTECTION                                    RP-16
1.10     EMERGENCY SIGNALS                                         RP-19

2.0      SELECTION OF EQUIPMENT                                    RP-19
2.1      INTRODUCTION                                              RP-19
2.2      GENERAL DECISION LOGIC FLOWCHART                          RP-20
2.3      SPECIFIC  DECISION LOGIC CHARTS                              RP-25
2.4.1     SKIN ABSORPTION AND IRRITATION                             RP-25
2.4.2     POOR WARNING PROPERTIES                                  RP-28
2.4.3     SORBENTS                                                  RP-31
2.4.4     EYE IRRITATION                                              RP-37
2.4.5     IDLH                                                       RP-38
2.4.6     LOWER FLAMMABLE LIMIT AND FIREFIGHTING                     RP-46
2.4.7     PROTECTION FACTORS                                       RP-47
2.4.8     VARIATIONS WITH 30 CFR 11                                  RP-47
2.4.9     ESCAPE                                                    RP-50
                                  RP-ii

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                                                                DRAFT
                   RESPIRATORY PROTECTION PRINCIPLES
                               EXHIBITS
NUMBER                                                         PAGE

RP-1    HUMAN RESPIRATORY SYSTEM                               RP-2
RP-2    INDUSTRIAL TOXICANTS THAT PRODUCE DISEASE                RP-5
        OF THE RESPIRATORY TRACT
RP-3    ATMOSPHERIC COMPOSITION                                 RP-10
RP-4    PHYSIOLOGICAL EFFECTS OF OXYGEN DEFICIENCY                RP-10
RP-5    FORMAT FOR DETERMINING RESPIRATORY  PROTECTION            RP-21
RP-6    SELECTION OF RESPIRATORY EQUIPMENT                       RP-22
RP-7    ANSI Z88.2 PROPOSED RESPIRATORY MAXIMUM USE LIMITS        RP-23
RP-8    SPECIFIC DECISION LOGIC CHART FOR RESPIRATORY              RP-26
        PROTECTION AGAINST GASES OR VAPORS
RP-9    SPECIFIC DECISION LOGIC CHART FOR RESPIRATORY              RP-27
        PROTECTION AGAINST PARTICULATES
RP-10   COMPARISON OF SELECTED ODOR THRESHOLDS AND TLVS         RP-29
        FOR CHEMICAL COMPOUNDS
RP-11   EFFECT OF SOLVENT VAPOR ON RESPIRATOR CARTRIDGE          RP-35
        EFFICIENCY
RP-12   IDLH LEVELS                                               RP-39
RP-13   QUALITATIVE PROTECTION FACTORS                           RP-48
                                 RP-iii

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                                                                          DRAFT
1.0   GENERAL PRINCIPLES

1.1   Introduction

Since  the  lungs  are  not  completely  effective  in  protecting  the  body  against
respirable chemical hazards, they  must  be  protected  from toxic  gases, vapors, and
particulates.   In addition,  the  body  must be  supplied  with  enough  oxygen  to
maintain a  normal capacity  to perform tasks.   To do this, the function of the lungs
must be understood, along  with  types of respiratory  protective devices  and the
method of selecting which ones  to use.

1.2   Routes  of Exposure

1.2.1    Respiratory Tract

The  respiratory  tract is  the only  organ system  with vital functional elements in
constant,  direct contact  with  the environment.   The  lung  also  has  the  largest
exposed surface  area  of  any organ—a surface area of 70  to  100 square  meters
versus  2 for the skin  and  10 for the digestive system.   The lung is  exposed  by
inhalation and by exhalation  of chemicals absorbed  through other routes (ingestion,
skin).

The   volume  of  air   inhaled   during   "normal"  activities   is   approximately
six liters/minute (l/min).   The volume of air inhaled during brisk activity or during
periods of stress can go  up  to 75  l/min.

Air is inhaled through  the nose  and mouth and travels  an extremely turbulent path
to the lungs  (Exhibit RP-1).  This  turbulency  results  in the air  impinging  on many
sites, thus allowing the  insoluble particulates  to  become  impacted  and  soluble
particulates, vapors, and gases to  become absorbed.
                                      RP-1

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                  EXHIBIT RP-1
         HUMAN RESPIRATORY SYSTEM

           (PRITCHARD, JOHN, 1976)
                                                             DRAFT
Nasal Passages
   Diaphragm
                                      Pharym
                                        Bronchiole
                                        Terminal Bronchiole
                        Aveoli
                       RP-2

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                                                                          DRAFT
The respiratory tract is divided  into three regions:

      1.  Nasopharvngeal

         This  region extends from nose to larynx.  These passages are lined with
         ciliated  epithelium  and  mucous  glands.   They  filter  out  large  inhaled
         particles, increase  the relative humidity of inhaled air, and  moderate its
         temperature.

      2.  Tracheobronchial

         This region consists of the trachea,  bronchi, and bronchioles and serves as
         a  conducting  airway  between  the  nasopharyngeal  region  and  alveoli.
         These passageways are  lined with ciliated epithelium coated  by  mucus,
         which serves as an  escalator to move particles  from deep  in the  lungs
         back  up  to the oral cavity so they can  be  swallowed.   These  ciliated  cells
         can be temporarily paralyzed by smoking or using  cough suppressants.

      3.  Alveolar

         This  is the basic functional unit  in the lung  and the  primary  location  of
         gas  exchange.  The  alveolar  region  consists of  small  bronchioles which
         connect  to the  alveoli.   The alveoli, of which  there are 100  million  in
         humans, contact  the pulmonary capillaries.

The inhaled air passes through the pharynx, the  common passageway for both food
and air,  and  enters the  trachea at the larynx.  The trachea (or windpipe) divides
into two bronchi, which lead to the two lungs.  All  of  these organs are  collectively
called the  conducting tubes,  since  they  lead the air to the  alveoli,' the site  of
gaseous exchange with the  pulmonary capillaries (i.e., the blood).
                                      RP-3

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                                                                         DRAFT
Toxic substances can be absorbed at any point in the  respiratory tract causing  harm
as shown in Exhibit RP-2.  The  conducting tubes are lined with mucous and cilia.
Insoluble contaminants caught  in the mucous are swept up to the esophagus by the
cilia  and swallowed, thus causing an ingestion problem.

Not  only can  various chemicals  affect the  respiratory tract, but the tract is also a
route  for  chemicals to  reach  other  organs.    Solvents,  such as  benzene  and
tetrachloroethane,  anesthetic  gases,  and  other  compounds  containing  lead  or
mercury can be  asborbed through the  respiratory tract and affect other organs.

It is  important to remember how anatomy of the  respiratory system may be related
to entry of  a given  material.  The airway system is lined  by a  moist  mucous layer.
Therefore, a substance such as a gas may be absorbed in the airways  leading to the
lungs,  especially at the  entry  points,  such as the nose.  Gases of  high  solubility,
such as sulfur dioxide (S02>, will, therefore, be absorbed mainly in the upper airway
provided the concentration is not too high.  It is  for this reason that SC>2 and gases
of similar solubility will  predominantly  affect the upper passages.   Gases of low
solubility such as nitrogen dioxide (N02), will be absorbed rather evenly throughout
the system  and may have  the greatest  effect  on the thinner, smaller airway  and
alveolar surfaces.

A description  of the toxic responses  of the respiratory system  will  be given  later.
However, it  should  be recalled  that oxygen  enters the  blood from the alveoli.  It is,
therefore, easy  to  see how any inhaled  gas may contact  the  blood, be  absorbed,
and,  because  the  blood  is in  contact with many tissues and  organs,  produce a
systemic effect.

Asphyxia (also  called hypoxia  or hypoxemia)  can occur  when  there is  a lack of
oxygen that  is  sufficient  to   endanger  life.    Any  inert  gas in  high enough
concentrations can  cause simple  asphyxia if it causes  the amount of oxygen to drop
below  the critical level.   However, a chemical asphyxiant, such  as carbon  monoxide
                                      RP-4

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                                                                      DRAFT
      EXHIBIT RP-2.  INDUSTRIAL TOXICANTS THAT PRODUCE DISEASE OF THE
                     RESPIRATORY TRACT (SHEET 1 OF 2)
Toxicant
Chlorine
Chromium
(VI)
Site of Action
Acute Effect
Chronic Effect
Aluminum
Ammonia
Arsenic
Asbestos
Beryllium
Boron oxide
Cadmium
oxide
Carbides of
tungsten
titanium,
tatalum
Upper airways
Upper airways
Upper airways
Lung parenchyma
Alveoli
Alveoli
Alveoli
Upper, lower
airways
Cough, shortness
of breath,
irritation
Irritation, edema
Bronchitis, irrita-
tion, pharynigitis
—
Edema, pneumonia
Edema, hemorrhage
Cough, pneumonia
Hyperplasia,
metaplasia of
bronchial cells
Fibrosis, emphysema
Bronchitis
Cancer, bronchitis,
laryngitis
Fibrosis, cancer
Fibrosis,
ulceration
—
Emphysema
Fibrosis
Upper airways
Nasopharnyx
upper airways
Cough, irritation,
asphyxiation (by
muscle cramps in
larynx)

Nasal  irritation,
bronchitis
Cancer
                                    RP-5

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                                                                       DRAFT
      EXHIBIT RP-2.  INDUSTRIAL TOXICANTS THAT PRODUCE DISEASE OF THE

                      RESPIRATORY TRACT (SHEET 2 OF 2)
Toxicant
Site of Action
Acute Effect
Chronic Effect
Cobalt


Hydrogen

Iron  oxides
Manganese
Nickel
Nickel
Pthalic
anhydride

Sulfur
dioxide
Tin
Toluene
Vanadium
Xylene
Lower airways,
alveoli

Upper airways

Alveoli, bronchi
Isocyanates     Lower airways,
                alveoli
Lower airways,
alveoli

Nasal mucosa,
bronchi

Alveoli
Lower airways,
alveoli

Upper airways
Bronchioles,
pleura
Upper airways
Upper, lower
airways

Lower airways
Asthma


Irritation, edema

Cough
Bronchitis,
pulmonary
edema, asthma

Pneumonia, often
fatal

Irritation
Edema
Fibrosis, inter-
stitial pneumonitis
Benign
pneumoconiosis
Recurrent pneumonia
Cancer
Bronchitis,
fibrosis,
pneumonia
Bronchitis, asthma     Emphysema
Bronchoconstriction,
cough, tightness in
chest
Bronchitis, edema,
bronchospasm

Irritation, nasal
inflammation, edema

Edema, hemorrhage
Bronchitis,
nasapharyngitis
                     Widespread mottling
                     of X-ray without
                     clinical signs
                     (benign
                     pheumoconiosis)
                                                           Bronchitis
                                     RP-6

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                                                                          DRAFT
(CO),  may  react  with  hemoglobin (Hb) preventing  this Hb  from  combining  with
oxygen.  As a result, oxygen is not available to various  organs and toxic responses
will occur.   Some of the  more significant  effects of CO are exerted on the  central
nervous system (CNS).

1.3   Types of Inhaled Toxicants

Many chemicals used or produced  in industry can produce acute or chronic  diseases
of the  respiratory tract when they  are inhaled  (Exhibit RP-2).  The  toxicants can
be classified according to  how they affect the respiratory tract.

     1.  Asphyxiants

         Gases that deprive the body tissues of oxygen.

         a.  Simple  asphyxiants   are   physiologically  inert  gases  that  at  high
            concentrations   displace   air,  leading  to  suffocation.    Examples:
            nitrogen, helium, methane,  neon, argon.

         b.  Chemical asphyxiants are  gases that prevent the tissues  from getting
            enough  oxygen.  Examples:   carborv  monoxide  and cyanide.   Carbon
            monoxide binds to hemoglobin 200 times more  readily than oxygen, and
            cyanide  prevents the transfer of  oxygen  from  blood to tissues  by
            inhibiting the  necessary transfer enzymes.

     2.  Irritants

         Chemicals that  irritate   the   air  passages,  causing  constriction   of  the
         airways  and  possibly leading to pulmonary  edema (liquid  in the lungs) and
         infection.  Examples:  hydrogen fluoride, chlorine, hydrogen  chloride, and
         ammonia.
                                      RP-7

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                                                                          DRAFT
      3.  Necrosis Producers

         Chemicals  that  result in cell  death  and  edema.   Examples:   ozone  and
         nitrogen dioxide.

      4.  Fibrosis Producers

         Chemicals  that  produce fibrotic tissue  which,  if massive, blocks airways
         and  decreases   lung   capacity.   Examples:     silicates,  asbestos,   and
         beryllium.

      5.  Allergens

         Chemicals   that   cause    an   allergic   response    characterized    by
         bronchoconstriction  and pulmonary disease.  Examples:  isocyanates  and
         sulfur dioxide.

      6.  Carcinogens

         Chemicals  that  cause  lung  cancer.    Examples:   cigarette  smoke,  coke
         emissions,  asbestos, and arsenic.

1.4   Oxygen Deficiency

1.4.1    Oxygen  and  the Respiratory Process

It  is not the percentage  of 02  in the air, but rather its  partial pressure (p02>, that
is  important in  respiration.   As  one increases in altitude,  the  percentage of  02
stays constant,  but  pO2  drops.   Additionally, as  the percentage of 02  in the  air
drops, so  does  its  partial  pressure.  The  chemical  composition of normal  air is
presented in Exhibit  RP-2.
                                      RP-8

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                                                                          DRAFT
The  "anatomic  dead space  volume" of the respiratory tract  is about  150 ml.   The
average  breath  draws  in  about  500  ml  of  air;  this  air  is  mixed  with the  air
remaining in the dead  space from the previous exhalation, which  has been depleted
in oxygen due to the normal respiratory process. The overall effect is a  lowe'  p02
in the  respiratory  tract as compared with the ambient air.  The  average respirator
adds about  TOO ml of dead  space to the respiratory system, which further lowers
the pC>2  in the  respiratory system, causing  a slight oxygen  deficiency and adding to
the effort required to breath.

1.4.2    Oxygen Levels/Physiological  Effect

The  currently  accepted  National  Institute for  Occupational  Safety  and  Health
(NIOSH) standards  specify that if an  atmosphere contains less than 19.5  percent by
volume 02 at sea level, then an atmosphere-supplying device must be used.
Note that as altitude increases, the percentage of 02 stays  constant, but the
drops.   There  is  currently  no  standard  that  accounts for the  drop in  pO2  with
altitude; the problem is currently under study by NIOSH.

The physiological effects of  oxygen deficiency are indicated in  Exhibit  RP-3.

1.5  Paniculate Contaminants - Aerosols

Aerosol is  a term  used  to describe particulates in air without  regard  to their origin.
Particulates are collected  on the  walls  of the  respiratory  tract  depending  upon
their size as follows:

      1.  Pharynx  - 10-30  pm
     2.  Trachea  - 10  ym
     3.  Bronchus  - 5-10 ym
     4.  Alveoli  - 0.1-1 pm
                                      RP-9

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  DRAFT
               EXHIBIT RP-3. ATMOSPHERIC COMPOSITION
             Gas
        Volume           Partial Pressure
         (%)          (mm Hg at sea level)
Nitrogen
Oxygen
Argon
Carbon Dioxide
78.9
20.95
0.93
0.04
594
159
7
0.03
   EXHIBIT RP-4.  PHYSIOLOGICAL EFFECTS OF OXYGEN DEFICIENCY
 02 Volume
 Percentage
at  Sea Level
     Physiological Effect
 16-12
 14-10
 10-6
 Less than 6
Increased  breathing volume.
Accelerated heartbeat.
Impaired attention  and thinking.
Impaired coordination.

Very faulty judgment.
Very poor  muscular coordination.
Muscular exertion causes rapid fatigue that may
cause permanent heart damage.
Intermittent respiration.

Nausea.
Vomiting.
Inability to perform vigorous movement, or loss
of all movement.
Unconsciousness, followed by death.

Spasmatic breathing.
Convulsive movements.
Death in minutes.
                              RP-10

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                                                                            DRAFT
Participates less  than 0.5  Mm may never be  deposited in  the  respiratory tract and
may simply be exhaled.

Particulates are classified  in  two  ways:  by their  physical  classification  and  by  the
effect they have on  the  body.  The  physical  classifications of  participates  are  as
follows:

      1.  Dust

         A  solid,  mechanically-produced  particle  with sizes  varying  from sub-
         microscopic to visible or macroscopic.

      2.  Spray

         A  liquid,  mechanically-produced  particle  with  sizes  generally   in the
         visible or macroscopic range.

      3.  Fume

         A  solid  condensation particle of  extremely small particle  size, generally
         less than  1  micron in diameter.

      4.  Mist

         A  liquid condensation particle with sizes ranging from submicroscopic  to
         visible or  macroscopic.

      5.  Fog

         A mist of  sufficient concentration to  perceptibly obscure vision.
                                      RP-11

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                                                                          DRAFT
      6.  Smoke

         A system that includes the products of  incomplete combustion of organic
         substances in the form of solid and  liquid particles and gaseous  products
         in   air.    Smoke is usually of  sufficient  concentration   to   perceptibly
         obscure vision.

Particles are produced by mechanical  means by the  disintegration processes  of
grinding,  crushing, drilling, blasting, and spraying or by physiochemical reactions
such  as combustion,  vaporization,    distillation,   sublimation,   calcination,   and
condensation.

1.6   Gaseous Contaminants

Gaseous contaminants are  "filtered" to a  small  degree by  the respiratory tract
before they reach  the alveolar  spaces.   However, if the contaminants  are  soluble,
they can be directly absorbed through the walls of the respiratory tract.

Gaseous contaminants are  classified by their  chemical  type and  by  the  effect they
have on the body.  The chemical types of gaseous contaminants are as follows:

      1.  Inert

         Substances that  do not react with other  substances under  most conditions
         and create a respiratory  hazard by  displacing air and  producing oxygen
         deficiency (for example: helium, neon, and argon).

      2.  Acidic

         Substances that  are acids  or that  react with water to produce an acid.  In
         water  they produce positively-charged  hydrogen ions.   They  taste sour
                                     RP-12

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                                                                    DRAFT
   and  many are corrosive to tissues (for example:  hydrogen chloride, sulfur
   dioxide, fluorine, nitrogen dioxide, acetic acid, carbon dioxide,  hydrogen
   sulfide, and  hydrogen cyanide).

3.  Alkaline

   Substances  that are alkalies  or that react with water to produce an alkali.
   When in  water  solutions, they  result in the  production of  negatively-
   charged hydroxyl ions  (OH~).  They  taste bitter,  and  many  are  corrosive
   to tissues (for example: ammonia, amines, phosphine, arsine, and stiline).

4.  Organic

   These are the compounds of carbon.  Examples are saturated  hydrocarbons
   (methane,    ethane,   butane),    unsaturated   hydrocarbons   (ethylene,
   acetylene),   alcohols  (methyl  alcohol, propyl  alcohol),  ethers  (dimethyl
   ether,  diethyl  ether),   aldehydes   (formaldehyde),  ketones   (dimethyl
   ketone),  organic acids  (formic  acid,  acetic  acid),  halides  (chloroform,
   carbon    tetrachloride),    amides   (formamide,    acetamide),    nitriles
   (acetonitrile),  isocyanates (toluene diisocyanate),  amines  (methylamine),
   expoxies   (epoxyethane,   propylene   oxide),  and   aromatics   (benzene,
   toluene, xylene).

5.  Organometallic

   Compounds in which metals are  chemically bonded to organic groups  (for
   example, tetraethyl  lead).

6.  Hydrides

   Compounds in which hydrogen is chemically bonded to metals and certain
   other elements  (for example, diborane and lithium hydride).
                                RP-13

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                                                                         DRAFT
1.7   Expressing Air Contaminant Concentrations

Any  substances  that are not normal components of breathing air (oxygen, nitrogen,
etc.)  are  considered  to  be  contaminants.    The  respiratory threat  posed  by
contaminants  is a function  of  the  actual contaminant and  its  concentration in the
air.  The concentration is expressed in a variety of ways,  as  listed below.

      1.  Particulates

         a.  mppcf - millions of particles per cubic foot.
         b.  ppcc - particles per cubic centimeter.
         c.  mg/m^ - milligrams per cubic meter.

      2.  Gases and Vapors

         a.  ppm - volumes per million volumes of air (parts per million).

         b.  ppb - volumes  per billion volumes of  air (parts  per billion).

         c.  mg/m3 - milligrams per cubic meter.

         d.  Conversion of units.  The following equation converts ppm to mg/m3,
                        24 45             T
            ppm =	;	r^	^T— mg/mj,  at 25  C and 760 mm Hg.  This equation is
            KK     molecular weight
            extremely useful for determining respiratory  protection  requirements.

1.8   Measures of Respiratory Hazards

Every contaminant contained in breathing air has a limit, above  which it becomes a
threat to human health.  These  limits are determined either from animal  studies or
from  epidemiological data.   Unfortunately, animal  studies can only  approximate
human  responses  and may vary widely for individual  chemicals.   Epidemiological
studies, although capable of providing a more precise forecast  of human response
are  limited  by  a  lack  of  accurate  records and  a  lack  of  controlled  studies.

                                     RP-14

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                                                                          DRAFT
Therefore, the "safe" limits of various chemicals must be viewed only as guidelines.
Furthermore,  these  guidelines are  primarily  designed  for  the  industrial  situation
where  an individual is being exposed to one or two well-defined substances. These
guidelines  do  not  address  the  problems  of synergism,  potentiation,  or allergic
response.

The guidelines used  in measuring respiratory hazards are listed below.

     1. Threshold Limit Value

        The   threshold   limit  value  (TLV)   is  recommended  by  the  American
        Conference of Governmental Industrial  Hygienists  (ACGIH)  and is derived
        from consensus  review.  It is a time-weighted average concentration set
        for a particular substance  that represents a level that  almost all  workers
        can  be exposed  to for an 8-hr day (40-hr week) without suffering  adverse
        health effects.  It is assumed that following each  8-hr exposure there will
        be a 16-hr  recovery  period and that after 5  days  there will  be  a 48-hr
        recovery period.  The TLV lists are revised on a yearly basis.

     2. Permissible Exposure Limits

        The   permissible  exposure limits  (PELs)  are  set  forth  in   the OSHA
        Standards  29 CFR 1910.1000,  Tables  Z-\,  7.2, and  Z%.   These  levels  were
        promulgated  initially  from  the  ACGIH TLV lists  (1968).   As  part  of the
        law,  they   represent  the   legal   maximum  concentrations  for  personnel
        exposure.   They  are  not   updated on a  yearly  basis,  as  is  the TLV list.
        Therefore,   the  most  current   ACGIH   TLV   list  should  be   used  in
        determining respiratory  protection,  rather than the PEL listing.   However,
        the  level  selected  must  be  in  conformance   with  the  PEL  in  order to
        comply with OSHA regulations.
                                     RP-15

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                                                                          DRAFT
      3.  Immediately Dangerous to Life and  Health.

         30 CFR 11.3 defines  conditions that are  immediately dangerous to life  and
         health  (IDLH)  as "conditions that  pose an  immediate  threat to  life  or
         health or  conditions that pose an immediate threat of severe exposure to
         contaminants  such as  radioactive  materials, which are  likely to have  an
         adverse cumulative or delayed effect on  health."

         OSHA adds these criteria:

         a.  The worker must  be able to escape  without losing his life or suffering
            permanent health  damage within 30 minutes.

         b.  The worker must  be able to escape  without severe eye or respiratory
            irritation or other  reactions.

      4.  Lower Flammable Limit

         The lower flammable limit  (LFL) is  the lowest concentration by volume of
         a gas or vapor in air that will  explode  when there  is an ignition source.
         Lack of  oxygen  in high concentrations of flammable gases or toxic gases
         generated during fires  limit  the types of respirators available for  use in
         these  atmospheres.

1.9    Respiratory Protection

When it has been determined  that the ambient atmosphere is hazardous, it  becomes
necessary to protect the individual by--

      1   Avoiding  and/or minimizing exposure.
      2.  Applying  engineering  controls such  as  ventilation.
      3.  Using  a  respirator to  either filter the ambient  air or supply clean air.
                                     RP-16

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                                                                           DRAFT
The legal requirements for respiratory protection are summarized below.

      1.  Williams  and   Steiger  Occupational  Safety  and  Health  Act  of  1970
         established  standards  that  state  that  "approved or  accepted respirators
         shall be used when they are available."

      2.  29 CFR 1910.134  gives  legal  requirements for the selection and  use  of
         respiratory  equipment  as  promulgated  by  OSHA and  based on  American
         National  Standards  Institute  (ANSI)  Standard  Z88.2,  "American  National
         Standards  Practices for  Respiratory  Protection."   Standard  Z88.2 is  a
         consensus standard, but now has been cited as a  Federal regulation.

      3.  30 CFR Part  11  describes  tests for permissibility  of respiratory protective
         apparatus and  updates or  deletes approvals.  30 CFR Part  11  also cites
         ANSI Z88.2 as the basis for respiratory protection.

         According to 29 CFR 1910.134, employers  will  supply suitable respiratory
         protection equipment and establish  a respiratory protection  program  that
         includes the following items:

      1.  Standard  operating  procedures for selection and use of respirators.

      2.  Proper selection of  respirators on the basis of hazard.

      3.  Training of  personnel in use and limitations.

      4.  Regular cleaning and maintenance.

      5.  Proper storage.

      6.  Routine monthly inspections and inspections before and after use.
                                      RP-17

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                                                                         DRAFT
      7.  Constant  monitoring  of work area  for  adverse conditions and  worker
         stress.

      8,  Continual   evaluation   of   respiratory  compliance   program   once  in
         operation.

      9.  Determination of medical fitness of potential user.

     10.  Use of only approved equipment  and only after proper fit testing has been
         performed.

Testing schedules for all respiratory  equipment are listed in 30  CFR 11:

      1.  Subpart H - Self-Contained Breathing Apparatus - Schedule 13.
      2.  Subpart I - Gas Masks - Schedule 14.
      3.  Subpart J - Supplied Air Respirators -  Schedule 19.
      4.  Subpart K - Dust, Fume, and Mist Respirators - Schedule 23.
      5.  Subpart L - Chemical  Cartridge Respirators  - Schedule 23.

This document  also updates  or deletes  approval for  respiratory equipment.   Any
equipment that  is altered,  hybridized, or changed in  any unapproved  way loses its
approval.  The  approval number  must  be on the respirator or  its container.  NIOSH
publishes a list  of  all  approved respirators  titled the  NIOSH  Certified  Equipment
List (1980).

The  physiological/psychological  limitations  of  respiratory equipment  are  listed
below.

      1.  Pulmonary  problems
      2.  Cardiovascular problems
      3.  Skin sensitivity, diabetes, perforated eardrum
      4.  Claustrophobia, anxiety,  discomfort
                                     RP-18

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                                                                          DRAFT
1.10  Emergency Signals
Verbal communications while  wearing respirators  are  difficult because  talking is
muffled and distorted  by  the face mask.  A  set of hand signals  known  to  all  site
personnel is essential for working  together safely.

Typical emergency hand signals include:
                Signal
               Meaning
    •  Hand gripping throat:
    •  Grip partner's wrist or place
      both hands  around waist:
    •  Hands on top of head:
    •  Thumbs  up:
    •  Thumbs  down:
Out of air, can't breath.

Leave area immediately, no  debate!
Need  assistance.
OK, I'm all right, I understand.
No, negative.
2.0   SELECTION  OF EQUIPMENT

2.1   Introduction

The  purpose of  respirator  decision logic is to  ensure  technical  accuracy  and
uniformity in the  selection  of  respirators and  to  provide  necessary  criteria  to
support  this selection.   The  decision  logic  is  a  step-by-step  elimination  of
inappropriate respirators until only  those that  are acceptable remain.   Judgment
by   persons knowledgeable of  inhalation   hazards   and  respiratory   protection
equipment is essential to ensure appropriate selection of respirators.

The  primary technical  criteria  for  what  constitutes  a  permissible  respirator  are
based on the technical requirements  of 30 CFR  11.   Safety  standards and NUS
policy will  allow only  respirators  approved  under  30 CFR 11.   The  referenced
Subparts of 30  CFR 11  give technical descriptions  concerning each type or class of
respirators  referenced  in the decision  logic; 30 CFR 11  should  be  used with  the
                                     RP-19

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                                                                           DRAFT
decision logic  in order to  properly understand the criteria for the specification  of
allowable respirators.   Protection  factors  are criteria  used  in  determining what
limiting  concentrations  are  to  be permitted  for each respirator  type that will
afford adequate protection to the wearer.

Throughout  this  text,  reference is made  to   PELs.    Prudent,  accepted  practice
dictates  the  use of  the  most restrictive between the  current ACGIH TLVs, which
are updated each year, and the PEL, which  is only periodically updated.

2.2   General Decision Logic Flowchart

The   following   material   used  in  concert   with   the  decision  logic   charts
(Exhibit RP-5,  RP-6,  and   RP-7)  provides   a   formalized  selection   guide  for
respiratory protection.

      1.  Step 1 - Assemble Information on  Substance

         Assemble  necessary lexicological, safety,  and research  information  for
         the  particular contaminant.  The following are required:

         a.   Permissible exposure limits  specified in  29 CFR 1910.1000 (Tables Z-1,
            2-2, and Z-3).

         b.  Warning  properties  if  the  substance  is a  gas or a  vapor.   Refer  to
            Section 2.4.2 below.

         c.  Eye  irritation  potential  of  the  substance.   Refer  to  Section 2.4.4
            below.

         d.  LFL for the substance.  Refer to Section 2.4.6 below.

         e.  IDLH concentration for the substance.  Refer to Section 2.4.5  below.
                                      RP-20

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                                                                                           DRAFT
                                       EXHIBIT RP-5
             FORMAT FOR DETERMINING  RESPIRATORY PROTECTION
                                        QUESTIONNAIRE
                   GAS MASK AND  RESPIRATOR RECOMMENDATION
Name and address of company
seeking recommendation	
Name of individual.
His phone number.
  1  Material—
       a. Chemical name.
       b. Trade name	
       c. Formula	
       d. TIV or TWA     OSHA 1910.1000	Current ACGIH.
    Form in which it will be used—
       a. Liquid?	b. Solid?	c.  Gaseous?	
       d. If gaseous, is it an organic vapor?	or add  gas?	
         other?	
 3. Maximum expected concentration—
       a.__	parts per million, or
       b	milligrams per cubic meter
 4. Will material be heated?	
       a.  If so, to what temperature?	°F.
 5. What is the odor threshold of the material?	
 6. At what concentration is the material considered to be immediately dangerous to life or health?.
 7. Can the substance be absorbed through the skin?	
 8. Irritant to ayes?	respiratory tract?__ skin?	
 9. At what concentration is it an irritant?	
 10. If the substance is known to be flammable, what are the lower and upper flammable limits, in percent by volume?

 11  What is the vapor pressure of the material?	
 12. Will material be mixed with other chemicals?	If so, give details	
 13. Any possibility of oxygen deficiency?	
 14. Can good ventilation of the area be maintained?	
 15. Will exposure be continuous?	or intermittent?	
 16. Will the respiratory device be used for routine exposures, or will it be used as an escape device?.
 17  Provide as much detail as possible concerning exposure conditions.
                                            RP-21

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                                              EXHIBIT RP-5

                          SELECTION OF RESPIRATORY EQUIPMENT (LUNDIN, A., 1979)

-------
                                                                                       DRAFT
                                        EXHIBIT RP-7

            ANSI  Z88.Z  PROPOSED RESPIRATORY MAXIMUM USE LIMITS

RnptfAtOf
1 1/4 or 1/2 Facepiece
Particulate Rltar'
2. 1 /4 or 1-/2 Facepiece
Vapor Gar
3. Full Facepiece
Paniculate Filter"
4. Full Facepiece
Vapor Gas
5. Powered Air-Purifying
(Any Respiratory Inlet
Cover)'
Pwmmtd for Uu
m Atmatghtrn
0, Dif.
No
No
No
No
No
IDLH
No
No
No
No
NO
MUL Rnpmor Fit Indu According to Fitting Mtihod Uud
Qualmim
10
Lower of
10 or MUL-C
100
Lower of
100 or MUL-C
MUL-C
S»rra-Quamranv«
200
Lower of
200 or MUL-C
1000
Lower of
1000 or MUL-C
MUL-C
Qujnmaov*
As
Measured
on
Each
Parson
or
MUL-C

MUL-C IMUL of Caitndgt or CaitaM Ustdl
"UM High Effiatncy Filters for PamcuJnu win TLV Lja than .05 mq/mi
S. Air-Una (Demand)
1 /4 or 1 /2 Facepiece
7. Air-Una (Demand)
Full Facepiece
3 Line (Demand)
Facepiece with
Escape Provision
9. Hose Mask
Full Facepiece
10. Air-Line (Pressure
Demand or Constant
Flow)
1 1. Air-Uns (Pressure
Demand with
Escape Provision)
12. Air-Une (Constant
Flow with Escape
Provision)
No
No
Yas'
No
No
Yes*
Yes*
No
No
Yas
No
No
Yes
Yas
10
100
100
100
N/A
N/A
N/A
200
1000
1000
1000
N/A
N/A
N/A
As
Measured
an
Each
Person

N/A
N/A
N/A
'Escagt Provision Must S» an Auuliarv Self-Contained Air Supply
13. Demand SCBA
(Open or Closed
Circuit) Full Facepiece
or Mouthpiece
14. Pressure Demand
SCBA Half or
Yes



Yes

Full Facepieca
Yes



Yes


100



N/A


1000



N/A


As
Measured
on Each
Person
N/A


15.  Combination Devices
    Not Usted
Use Lowest MUL Usted
                                           RP-23

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                                                                      DRAFT
   f.   Any  possibility  of  poor  sorbent  efficiency at IDLH  concentration and
       below.  Refer to Section 2.4.3 below.

   g.  Any  possibility of systemic injury or death  resulting from  absorbance
       of the substance (as  a  gas or vapor) through the skin.  Refer to Section
       2.4.1 below.

   h.  Any  possibility of severe skin  irritation resulting  from contact of the
       skin  with corrosive  gases,  vapors,  or  particulates.   Refer to Section
       2.4.1 below.

   i.   The vapor pressure of the substance (and  equivalent ppm for saturated
       air).

   j.   Any  possibility  of  high  heat  of  reaction  with  sorbent  material  in
       cartridge or canister.

   k.   Any  possibility of shock  sensitivity of substance  sorbed on  sorbent  of
       cartridge or canister.

2.  Step  2 -  Determine Physical  State of Substance

   Determine  the  physical  state(s) of  the substance  as  it  is  likely to  be
   encountered in the occupational environment.  It will be either a  gas  or
   vapor; a particulate (dust, fume or mist); or a combination.

3.  Step  3  -  Assemble  a  Table  of  Permissible Respiratory  Protection for
   Substance

   This  is done using the  material from Step  1  and the appropriate specific
   decision  logic  chart  from  Section  2.3  below  and  respirator  protection
   factors.  See Section 2.4.7 for a discussion of  protection  factors.
                                 RP-24

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                                                                           DRAFT
2.3   Specific Decision Logic Charts

Specific decision logic charts for respiratory protection  against gases or vapors and
against particulates are shown in Exhibits RP-8 and RP-9,  respectively.

2.4   Decision Logic Criteria

2.4.1    Skin Absorption and  Irritation

Respirator  selection criteria  are based primarily  on the  inhalation  hazard  of the
substance.    A   supplied-air  suit   may  protect  the  skin  from  extremely  toxic
substances that may be absorbed  through  the  skin  or from  substances which  may
cause  severe skin  irritation  or injury.    Supplied-air suits  are  not  covered  in
30 CFR 11.    Data  are  not  available  upon  which  to make  recommendations  for
supplied-air suits for all types  of exposures.

Where information  is  available indicating systemic  injury or  death  resulting from
absorbance  of a gas or vapor through the skin  or where severe  skin  irritation  or
injury  may  occur  from  exposure  to  a  gas,  vapor, or  particulate, the  following
statement is  included as a footnote to  the  respirator tables, and  both the  employee
and employer are cautioned in  the appendices concerning  their use:

      •  Use of  supplied-air suit  may be  necessary to  prevent skin  contact and
         respiratory exposure  from  airborne concentrations of (specific substance).
         Supplied-air  suits  should  be  selected, used, and   maintained  under the
         immediate  supervision  of  persons knowledgeable  in  the  limitations and
         potential  life endangering  characteristics  of  supplied-air  suits.   Where
         supplied-air suits are used  above  a  concentration  which may be  IDLH
         (concentration),  an  auxiliary  positive-pressure,   self-contained  breathing
         apparatus must also be worn.
                                      RP-25

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                                                                           DRAFT
                 EXHIBIT RP-8.  SPECIFIC DECISION LOGIC CHART

           FOR RESPIRATORY PROTECTION AGAINST GASES OR VAPORS
Condition
          Selection Sequence
Routine use
Entry and escape from
unknown concentrations
Firefighting
Escape
Consider  skin  irritation  and   sorption   of
material through the skin (see Section 2.4.1).
                     the
Poor  warning  properties  -   Eliminate  all  air-
purifying respirators (see Section 2.4.2).

Eye  irritation  - Eliminate  or  restrict use  of half
mask respirators (see Section 2.4.4).

IDLH or LFL - Above  this concentration eliminate
all but positive-pressure, self-contained breathing
apparatus   and   combination   positive-pressure
supplied-air   respirator  with   auxiliary  positive-
pressure, self-contained breathing apparatus.

List  all  allowed respirators  by condition  and use
and type.

Use  positive-pressure, self-contained   breathing
apparatus   or   combination    positive-pressure,
supplied-air   respirator  with   auxiliary  positive-
pressure, self-contained breathing apparatus.
Use   positive-pressure,
apparatus.
self-contained  breathing
Use  gas mask or escape self-contained  breathing
apparatus (see Section 2.4.3).
                                      RP-26

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                                                                          DRAFT
               EXHIBIT RP-9. SPECIFIC DECISION LOGIC CHART FOR

                RESPIRATORY PROTECTION AGAINST PARTICULATES
Condition
          Selection Sequence
Routine use
Entry  and escape from
unknown concentrations
Firefighting
Escape
Consider   skin   irritation   or  sorption   of   the
material through the skin (see Section 2.4.1).

Eye  irritation  - Eliminate  or  restrict  use of half-
mask respirators (see Section 2.4.4).

Systemic  poison  -  Eliminate  single-use respira-
tors.
                                              3
For permissible exposures less than 0.05 mg/m  -
Eliminate  dust, fume,  and mist respirators  except
with high-efficiency  paniculate filter.

IDLH  or LFL - Above  this concentration eliminate
all but positive-pressure, self-contained breathing
apparatus   and   combination   positive-pressure,
supplied-air   respirator  with  auxiliary  positive-
pressure  self-contained  breathing apparatus  (see
Section 2.4.5).

List  all allowed  respirators by  condition  of  use
and type.

Use   positive-pressure,  self-contained  breathing
apparatus   or   combination    positive-pressure,
supplied-air   respirator   with   positive-pressure,
self-contained breathing apparatus.

Use   positive-pressure,  self-contained  breathing
apparatus (see Section 2.4.6).

Use  gas mask or escape  self-contained breathing
apparatus (see Section 2.4.3).
                                     RP-27

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                                                                          DRAFT
The  supplied-air  suit statement is an advisory footnote.  The decision as to whether
to include the footnote is made by  the  NIOSH/OSHA Review  Committees on the
basis of available information.  Since most information concerning  skin irritation  is
not  quantitative but rather is presented in commonly used descriptive terms, such
as "a strong skin irritant,  highly  irritating  to the  skin" and "corrosive  to  the  skin,"
the  decision made  by the committees concerning skin  irritation is  a judgmental
decision often  based  on  nonquantitative information.   As a guideline  for inclusion
of the supplied-air suit statement for substances that are sorbed through the skin, a
single skin penetration LD5Q of 2 g/kg for any species is often used.

The  footnote  is  advisory  in  nature and its inclusion  does not  make  the use of
supplied-air suits mandatory.   Further, employers  may use supplied-air suits in any
situation  where  they  provide adequate  protection, whether there is  an  advisory
footnote in the respirator table or not.  To ensure the health and safety of persons
using  supplied-air suits,  it is  imperative  that the the  suits  be used  under the
immediate supervision of  persons  knowledgeable in  the limitations and potential
life-endangering  characteristics of supplied-air suits.

2.4.2   Poor Warning  Properties (Refer to Exhibit RP-10)

It is important  to realize that 30 CFR 11  approvals for  air-purifying (organic vapor)
devices  prohibit  use against  organic   vapors   with  poor  warning   properties.
Specifically, 30 CFR  11.90  (b)  (note  4)  covers gas  masks (canister  respirators) and
30 CFR 11.150 (note 7) covers chemical cartridge  respirators.  The  approvals  in 30
CFR  11  thus are only for those organic vapors with adequate warning properties.

Warning properties include odor,  eye irritation,  and respiratory irritation.   Warning
properties  relying upon  human senses are not foolproof.   However, they provide
some indication to the wearer of possible  sorbent exhaustion or  of poor facepiece
fit or other respirator malfunction.
                                      RP-28

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                                                                       DRAFT

   EXHIBIT RP-10.  COMPARISON OF SELECTED ODOR THRESHOLDS AND TLVS FOR
                           CHEMICAL COMPOUNDS
                               (SHEET 1 OF 2)
 COMPOUNDS                  ODOR THRESHOLD (ppm)           TLV (ppm)
             Group 1 - Odor Threshold and TLV Approximately the Same

Arsine                                  0.21                       0.05
Cyclohexane                             300                        300
Cyclohexanol                             100                         50
Ethyl  benzene                            200                        100
Ethylene  diamine                           11                         10
Hydrogen  chloride                          10                          5
Methyl acetate                           200                        200
Methylamine                               10                         10
Methyl chloroform                        500                        350
Nitrogen  dioxide                            5                          3
Propyl alcohol                            200                        200
Turpentine                               200                        100

                Group 2 - Odor Threshold from  2 to 10 Times the TLV

Acrolein                                 0.2                        0.1
Ally! alcohol                                7                          2
Crotonaldehyde                              7                          2
1,2 Dichloroethylene                     500                        200
Dichloroethyl ether                        35                          5
Dimethyl  acetamide                        46                         10
Epichlorhydrin                              10                          2
Hydrogen  selenide                        0.3                       0.05
Isopropyl glycidyl ether                   300                         50
Styrene monomer                        200                         50

                Group 3 - Odor Threshold At Least 10 Times the TLV

Acrylonitrile                               21                          2
Bromoform                              530                        0.5
Camphor (synthetic)                    1.6-200                        2
Carbon disulfide                            (a)                       10
Carbon tetrachloride                       75                          5
Chloroacetophenone                         1                       0.05
Chloroform                              200                         10
Chloropicrin                                 1                        0.1
Diglycidyl  ether                             5                        0.1
Dimethylformamide                       100                         10
Ethylene  oxide                           500                         10
                                    RP-29

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                                                                   DRAFT

  EXHIBIT RP-10. COMPARISON OF SELECTED ODOR THRESHOLDS AND TLVS FOR
                    CHEMICAL COMPOUNDS (CONTINUED)
                              (SHEET 2 OF 2)
 COMPOUNDS                 ODOR THRESHOLD (ppm)           TLV (ppm)


          Group 3 - Odor Threshold At Least 10 Times the TLV (Continued)
                                                                       3
Mercury vapor                          (a)                       0.1 mg/m
Methyl  bromide                         (a)                          5
Methyl  chloride                         (a)                        50
Methyl  formate                         2000                      100
Methanol                              2000                      200
Methyl  cyclohexanol                      500                      50
Phosgene                               1.0                      0.1
Toluene 2,4 diisocyanate                    2                     .005
                                  RP-30

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                                                                          DRAFT
Adequate warning properties  can be assumed  when the substance  odor, taste,  or
irritation effects  are  detectable  and persistent  at  concentrations  at  or  below the
permissible exposure  limit.

If the odor or irritation threshold of a  substance is more  than  three  times  greater
than the permissible  exposure limit, this substance should be  considered to  have
poor warning properties.  If the  substance  odor or  irritation threshold is  somewhat
above  the  permissible exposure  limit (not  in excess of three  times the limit) and
there is  no ceiling  limit, consideration  is given to whether undetected exposure  in
this  concentration range could cause serious or irreversible health effects.  If not,
the substance is considered to have adequate warning properties.  Some substances
have extremely low thresholds of odor and irritation in relation to the permissible
exposure limit.  Because of this, these substances can be  detected by  a  worker
within  the  facepiece  of  the  respirator even  when  the  respirator  is functioning
properly.   These  substances  are,  therefore,  considered  to  have  poor  warning
properties.

Though  30 CFR 11  does  not specifically  eliminate  air-purifying  respirators for
pesticides with poor  warning  properties, prudent practice  dictates  that a respirator
should not  be used to protect against any substance with poor warning properties.

2.4.3    Sorbents

There   are   certain   limitations   involved   with   the  use   of   sorbents   in
cartridge/canister  sorbents.    When  the   following  conditions occur,  a   sorbent
cartridge is not recommended:

      1.  Where supporting  evidence exists of immediate (less  than  three minutes)
         breakthrough time at the IDLH concentration  and below for a cartridge  or
         canister sorbent, air-purifying devices shall  not  be allowed  for any use,
         escape or otherwise.  See  Exhibit RP-11.
                                      RP-31

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                                                                      DRAFT
     EXHIBIT RP-11.
EFFECT OF SOLVENT VAPOR ON RESPIRATOR CARTRIDGE
             EFFICIENCY
  Solvent
                      Time  to Reach One Percent
                             Breakthrough
Aromatics
   Benzene
   Toluene
   Ethyl benzene
   m-Xylene
   Cumene
   Mesitylene
Alcohols
   Methanol
   Ethanol
   Isopropanol
   Allyl alcohol
   n-Propanol
   sec-Butanol
   Butanol
   2-Methoxyethanol
   Isoamyl alcohol
   4-Methyl-2-pentanol
   2-Ethoxyethanol
   Amyl alcohol
   2-Ethyl-1-butanol
Monochlorides
   Methyl chloride
   Vinyl chloride
   Ethyl chloride
   Allyl chloride
   1-Chloropropane
   1-Chlorobutane
   Chlorocyclopentane
   Chlorobenzene
   1-Chlorohexane
   o-Chlorotoluene
   1-Chloroheptane
   3-Chloromethyl heptane
Dichlorides
   Dichloromethane
   Trans- 1,2-dichloroethylene
   1 ,1-Dichloroethane
   cis-1,2-Dichloroethylene
                                 73
                                 94
                                 84
                                 99
                                 81
                                 86

                                0.2
                                 28
                                 54
                                 66
                                 70
                                 96
                                115
                                116
                                 g7
                                 75
                                 77
                                102
                               76.5

                                .05
                                3.8
                                5.6
                                 31
                                 25
                                 72
                                 78
                                107
                                 77
                                102
                                 82
                                 63

                                 10
                                 33
                                 23
                                 30
                                    RP-32

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                                                                        DRAFT
     EXHIBIT RP-11. EFFECT OF SOLVENT VAPOR ON RESPIRATOR CARTRIDGE
                            EFFICIENCY (CONTINUED)
  Solvent
Time  to Reach  One Percent
       Breakthrough
    1,2-Dichloroethane
    1,2-Dichloropropane
    1,4-Dichlorobutane
    o-Dichlorobenzene
Trichlorides
    Chloroform
    Methyl chloroform
    Trichloroethylene
    1,1,2-Trichloroethane
    1,2,3-Trichloropropane
Tetra and Pentachlorides
    Carbon tetrachloride
    Perchloroethylene
    1,1,2,2-Tetrachloroethane
    Pentachloroethane
Acetates
    Methyl acetate
    Vinyl acetate
    Ethyl acetate
    Isopropyl acetate
    Isopropenyl  acetate
    Propyl acetate
    Allyl acetate
    sec-Butyl acetate
    Butyl acetate
    Isopentyl acetate
    2-Methoxyethyl acetate
    1,3-Dimethylbutyl acetate
    Amyl acetate
    2-Ethoxyethyl acetate
    Hexyl acetate
Ketones
    Acetone
    2-Butanone
    2-Pentanone
    3-Pentanone
    4-Methyl-2-pentanone
    Mesityl oxide
    Cyclopentanone
    3-Heptanone
    2-Heptanone
           54
           65
          108
          109

           33
           40
           55
           72
          111

           77
          107
          104
           93

           33
           55
           67
           65
           83
           79
           76
           83
           77
           71
           93
           61
           73
           80
           67

           37
           82
          104
           94
           96
          122
          141
           91
          101
                                     RP-33

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                                                                      DRAFT
     EXHIBIT RP-11.  EFFECT OF SOLVENT VAPOR ON RESPIRATOR CARTRIDGE
                           EFFICIENCY (CONTINUED)
  Solvent
Time to Reach One Percent
       Breakthrough
   Cyclohexanone
   5-Methyl-3-heptanone
   3-Methylcyclohexanone
   Diisobutyl ketone
   4-Methylcyclohexanone
Alkanes
   Pentane
   Hexane
   Methylcyclopentane
   Cyclohexane
   Cyclohexene
   2,2,4-Trimethylpentane
   Heptane
   Methycyclohexane
   5-Ethylidene-2-norbornene
   Nonane
   Decane
Amines
   Methyl amine
   Ethyl amine
   Isopropyl amine
   Propyl amine
   Diethyl amine
   Butyl amine
   Triethyl amine
   Dipropyl amine
   Diisopropyl amine
   Cyclohexyl amine
   Dibutyl amine       .
Miscellaneous Materials
   Acrylonitrile
   Pyridine
   1-Nitropropane
   Methyl iodide
   Dibromomethane
   1,2-Dibromoethane
   Acetic anhydride
   Bromobenzene
          126
           86
          101
           71
          111

           61
           52
           62
           69
           86
           68
           78
           69
           87
           76
           71

           12
           40
           66
           90
           88
          110
           81
           93
           77
          112
           76

           49
          119
          143
           12
           82
          141
          124
          142
                                   RP-34

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                                                                           DRAFT
      EXHIBIT RP-11.  EFFECT OF SOLVENT VAPOR ON RESPIRATOR CARTRIDGE
                             EFFICIENCY (CONTINUED)

Sources  for  reprints  of  respirator cartridge efficiency studies (by G. 0. Nelson  et
al.) are given below.

Ruch, W. E., G.  0. Nelson,  C.  L  Lindeken,  R.  E.  Johnsen,  and D. J. Hodgkins:
Respirator   Cartridge   Efficiency   Studies:  I.   Experimental   Design.     American
Industrial Hygiene Association Journal, 33, 105  (1972).

Nelson,   G.  O.,  and  D.  H.  Hodgkins:  Respirator  Cartridge  Efficiency  Studies:  II.
Preparation   of   Test  Atmospheres.    American   Industrial   Hygiene  Association
Journal, 33,  110 (1972).

Nelson,   G.   O.,   R.  E.   Johnsen,   C.  L  Lindeken,  and  R.  D.  Taylor:  Respirator
Cartridge  Efficiency Studies: III.   A  Mechanical  Breathing  Machine To  Simulate
Human  Respiration.   American  Industrial  Hygiene  Association  Journal,  33,  745
(1972).

Nelson,   G.   0.,   and  C.  A.   Harder:  Respirator  Cartridge   Efficiency  Studies:  IV.
Effects   of   Steady-State   and  Pulsating   Flow.     American  Industrial  Hygiene
Association  Journal, 33, 797 (1972).

Nelson,   G.   0.,   and  C.  A.  Harder:  Respirator  Cartridge  Efficiency  Studies:  V.
Effect of Solvent Vapor.  American Industrial  Hygiene Association Journal, 35, 391
(1974).

Nelson,   G.   O.,   C. A.  Harder,  and  B.  E.  Bigler:   Respirator  Cartridge  Efficiency
Studies:    VI.  Effect  of  Concentration,  Lawrence   Livermore Laboratory,  Report
UCRL-76184 (November  1974).
                                      RP-35

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                                                                         DRAFT
      EXHIBIT RP-11.  EFFECT OF SOLVENT VAPOR ON RESPIRATOR CARTRIDGE
                            EFFICIENCY (CONTINUED)
Nelson,  G.O.,  A.N.  Correia,  and   C.A.  Harder:   Respirator  Cartridge  Efficiency
Studies:   VII.  Effect  of  Relative Humidity and  Temperature, Lawrence  Livermore
Laboratory, Report UCRL-77390 (August 1975).

Nelson,  G.O.,  and  A.N.  Correia:   Respirator  Cartridge   Efficiency  Studies:  VIII.
Summary and Conclusions.  American Industrial Hygiene Association Journal, 37, 9
(1976).

Note:   The cartridge pairs  were tested  at  1000  ppm, 50 percent relative  humidity,
        22°C, and 53.3  l/min (equivalent to  a moderately active workload).  Time to
        achieve a  one  percent  breakthrough  is  noted for  each cartridge  pair.
        Cartridges  were  preconditioned at  room temperature  and  50  percent
        relative humidity for at least 24 hours prior to testing.  MSA cartridges or
        AO cartridges were  used  for most tests.
                                     RP-36

-------
                                                                          DRAFT
         The purpose  of  establishing  an IDLH exposure  concentration  is to ensure
         that the  worker can  escape  without  injury or irreversible health effects
         from an  IDLH  concentration  in  the event  of failure of  the respiratory
         protective equipment.  The IDLH is  considered a maximum concentration
         above which  only  highly  reliable breathing apparatus providing maximum
         worker protection  is permitted.  Since IDLH values  are conservatively set,
         any approved respirator may  be used up  to its maximum use concentration
         below the IDLH.

     2.  Where  there  is  reason to suspect  that the  cartridge  sorbent does not
         provide  adequate  sorption efficiency against  a specific  contaminant, use
         of  such sorbent is not to be  allowed.  However, where  another sorbent
         material  has  been  demonstrated  to   be  effective  against  a  specific
         contaminant,  approved  respirators  using  the  effective  sorbent  material
         are allowed.

     3.  Where there is reason to  suspect that a sorbent  has  a high heat of reaction
         with a substance, use of that sorbent is not allowed.

     4.  Where there is reason to suspect that a substance sorbed on a  sorbent of a
         cartridge or canister is shock sensitive,  use of air-purifying respirators  is
         not allowed.

2.4.4    Eye  Irritation

In  addition to respiratory protection, it  is quite important  to consider  a chemical's
potential for producing  eye irritation  or  damage.   The following  guidelines  deal
with eye protection:

      1.  For routine  work  operations, any perceptible  eye  irritation is considered
         unacceptable.   Therefore,  only full  facepiece  respirators  are  permissible
         in  contaminant  concentrations that produce  eye irritation.    Protection
         may  be  required  in  certain  concentrations  of  gases  and  vapors.    For
                                      RP-37

-------
                                                                            DRAFT
         escape,  some  eye  irritation  is  permissible  if it  is  determined that such
         irritation would  not  inhibit escape and such irritation  is reversible.

      2.  Where  quantitative  eye  irritation   data   cannot  be  found  in  literature
         references,  and theoretical considerations indicate that  substance  should
         not be an eye irritant, half-facepiece respirators are allowed.

      3.  Where  a  review  of the  literature   indicates  a  substance  causes  eye
         irritation  but no  eye  irritation  threshold is specified,  the data  will  be
         evaluated to determine  whether quarter- or half-facepiece respirators can
         be used.

2.4.5    IDLH

The definition of IDLH provided in 30 CFR  11.3(t) is  as  follows:

"Immediately dangerous to life or health" means conditions that pose an immediate
threat to life  or  health  or  conditions that  pose  an immediate threat of  severe
exposure  to  contaminants, such  as radioactive materials,  which are likely to have
adverse cumulative or delayed effects on  health.

In  establishing  the IDLH concentration the following factors are considered:

      1.  Escape  without  loss of life or irreversible health  effects.   Thirty minutes
         is considered the maximum permissible exposure time for escape.

      2.  Severe eye  or  respiratory irritation or other  reactions that would  prevent
         escape without  injury.

IDLH should be determined from the following sources:

      1.  Specific  IDLH  provided  in  the  literature,  such  as  the  AIHA  Hygienic
         Guides or Exhibit RP-12.
                                      RP-38

-------
              Chemical  Name
                                                          IDLH Level
                                                                                      Chemical Name
                                                                                                                                    IDtH Level
33
T>
GJ
CO
Acelaldehyde
Acelic acid
Acelic anhydride
Acetone
Acelonilrile
Acetylene  letrabromide
Acrolein
Acrylamide
Acrylonilrile
Aldrin
Ally! alcohol
Ally! chloride
Allyl glycidyl ether
2-Aminopyridine
Ammonia
Ammonium cullamale
n-Amyl acelale
sec-Amy! acetate
Aniline
Anisidine lo.p isomersl
Antimony and compounds
ANTU
Arsine
Azinphos-melhyl

Barium  soluble
Benzene
Benzoyl peroxide
Benzyl chloride
Boron oxide
Boron Irifluoride
10.
1.
1.
20.
4.



4.






5.
4.
9.








2.
1.



000 ppm
000 ppm
000 ppm
000 ppm
000 ppm
10 ppm
5 ppm
NA
000 ppm (Ca)
100 mg/m3
150 ppm
300 ppm
270 ppm
5 ppm
500 ppm
000 mg/m3
000 ppm
000 ppm
100 ppm
50 mg/m3
80 mg/m3
100 mg/m3
6 ppm
5 mg/m3

250 mg/m3
000 ppm
000 mg/m3
10 ppm
NA
100 ppm
Bromine
Bromolorm
Butadiene
2-Bulanone
2-Buloxyl elhanol
sec~Butyl acetate
lerl-Bulyl acetate
Butyl acetate
sec-Butyl alcohol
ten-Butyl alcohol
Butyl alcohol
terl-Butyl chromate












n-Bulyl glycidyl ether
Butyl mercaptan
Bulylamine
p-(erl-Butyl toluene

Cadmium dust
Cadmium fume
Calcium arsenale
Calcium oxide
Camphor
Carbaryt (sevin)
Carbon black
Carbon dioxide
Carbon disulfide
Carbon monoxide
Carbon telrachloride
Chlordane
















Chlorinated camphene
Chlorinated diphenyl
oxide


20
3

10
8
10
10
8
8
3
2
2
1







50

1




10

.000
.000
700
.000
.000
.000
.000
.000
.000
.500
.500
.000
.000
40
40
100
250
200
625

.000
500
.500
300
500
200
5
ppm
NA
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
?
ppm
ppm
ppm
ppm
mg/m3
mg/m3
mg/m3
mg/m3
mg/m3
mg/m3
NA
ppm
ppm
ppm










0
X
LEVELS



















m
X
DC
CO
H
7)
TJ
to









ppm (Cal
mg/m3
mg/m3
mg/m3






                                                                                                                                                            O
                                                                                                                                                            33

-------
               Chemical Name
                                                          IDLH Level
13
 1
Chlorine
Chlorine dioxide
Chlorine Irifluoride
1-Chloro-l-nitropropane
Chloroacelaldehyda
alpha-Chloroacetophenone
Chlorobenzene
o-Chlorbenzylidene molononitrile
Chlorobromome thane
Chlorodiphenyl  (4?% chlorine)
Chloroform
Chloropicrm
Chloroprene
Chromic acids and chromates
Chromium metal and insoluble
  sails
Chromium as soluble chromic
  and chromous salts
Coal lar pitch volaliles
Cobalt metal fumes and dust
Copper dusls and mists
Copper fume
Cotton dust (raw)
Crag herbicide
Ctesofl
Crolonaldehyde
Cumene
Cyanide
Cyclohexane
Cyclohexanol
                                                                                        Chemical Mama



2


2

5

1












5


B

10
3

25
10
20
.000
250
100
,400
2
.000
10
.000
4
400
30

500

250
400
20


500
.000
250
400
.000
50
.000
.500

ppm
ppm
ppm
ppm
ppm
mg/m3
ppm
mg/m3
ppm
mg/m3 (Cal
ppm (Ca)
ppm
ppm (Cal
mg/m3

mg/m3

mg/m3
mg/m3
mg/m3
NA
NA
mg/m3
mg/m1*
mg/m~
prig/m3
ppm
mg/m^
ppm
ppm

CycloheNanone
Cyclopentadiene

2.4 -D
DDT
Decaborane
Demelon
Diacelone alcohol
Diazomelhane
Diborane
Oibulyl phosphate
Dibulylphthalate
1,1-Dichloro-1-nitroelhane
1.3~Dichloro'5,5~dimethvlhvdanloin
o- Die hloroben zone
p-Dichlorobenzene
Dtchlorodilluoromethane
1.1-Dichloroelhane
Dichloroethyl ether
1.2~Dichloroethylene
Dichlorornonofluoromethane
Dichloroletrafluoroelhane
Dichlorvos
Dieldrin
Dielhylamine
Dielhylamino ethanol
Difluorodibromomethane
Diglycidyl ether
Diisobulyl kelone
Diisopropylamine
Dimethyl acelamide
                                                                                                                                    IDLH Level
5.000 ppm
2.000 ppm
500 mg/m3
NA
20 ppm
20 mg/m3
2.100 ppm
10 ppm
40 ppm
125 ppm
9,300 mg/m3
150 ppm
5 mg/m3
1,700 ppm
1,000 ppm
50,000 ppm
4,000 ppm
250 ppm
4.000 ppm
50.000 ppm
50.000 ppm
200 mg/in3
450 mg/m3
2,000 ppm
500 ppm
2,500 ppm
85 ppm
2,000 ppm
1,000 ppm
400 ppm


























DRAFT

-------
                                                                                                                                      m
          Chemical Norn*
                                                    lOLHLevel
 Cyclohenene
 Dimethyl-t.2-dibromo-
  2.2-dichloroethyl phosphate
 Dimelhylamina
 Dimelhylaniline
 1.1-Dime! hylhydrazino
 Dimethylphlhalale
 Dimethylsulfate
 Oinilro-o-cresol
 Dinilrobeniene
 Dinitrotoluene IDNT)
 Oio>ane
 Diphenyl
 Dipropylena glycol methyl ether
 Endrin
 Epichlorohydrin
 EPN
 Elhanolamine
 2-Elhoxyelhanol
 2-Ethoxyethvlacelale
 Ethyl  acelate
 Ethyl  acrylale
 Ethyl  benzene
 Ethyl  bromide
Ethyl  butyl Irelone
Elhyl  chloride
Elhyl  ether
Ethyl  formate
Elhyl  mercaptan
Elhyl  silicate
tihylamme
                                                                                         Chemical Name
                                                    10.00 ppm
  1.800
  2.000
    100
     50
  9.300
     10
      5
    200
    200
    200
    300

    200
    100
     50
  1.000
 6.000
 2.500
10.000
 2.000
 2.000
 3.500
 3.000
20.000
19.000
 8.000
 2.500
 1.000
 4.000
 mg/m3
 ppm
 ppm
 ppm
 mg/m^
 ppm
 mg/m^
 mg/m'
 mg/m^
 ppm (Ca|
 mg/m*
 NA
 mg/m-*
 Ppm
 mg/m^
 Ppm
 ppm
 ppm
 ppm
 ppm
 Ppm
 Ppm
 ppm
 ppm
 ppm
 Ppm
 ppm
ppm
ppm
Dimethyl lormamide
Elhylene dibromide
Elhylene dichloride
Ethylone glycol dinitrale
  (niiioglycerin)
Elhylene onide
Elhylenediamine
n-Ethylmorpholine

Ferbam
Ferroranadium dust
Fluoride dust
Fluorine
Fluorolrichlorome thane
Formaldehyde
Formic acid
Furfural
Furfuryl alcohol

Glycidol
Graphite, natural

Hafnium and compounds
Heptachlor
Heptane
HeMachlorelhane
Hexachloronaphthalene
Henane
2-He«anone
He^one
iec-He«yl acetate
                                                                                                                                    IDLH Level
 3.500 ppm
   400 ppm
 1.000 ppm

    80 ppm
   800 ppm
 2.000 ppm
 2.000 ppm

       NA
   500 mg/m3
   500 mg/m3
    25 ppm
10.000 ppm
   100 ppm
   100 ppm
   250 ppm
   250 ppm

   500 ppm
       NA
   250
   100
 4.250
   300
     2
 5.000
 5.000
 3.000
 4.000
mg/m3
mg/m3
ppm
ppm
mg/m3
ppm
ppm
PPm
ppm
                                                                                                                                                O
                                                                                                                                                33

-------
                                                                                                                                      >p
                                                                                                                                      O i
                                                                                                                                      m
                                                                                                                                      3§
                                                                                                                                      C 23
              Chemical Name
                                                        IOIH Laval
                                                                                            Chemical Name
                                                                                                                                       IOLH Level
3D
t)
Ethylene chlorohydrin
Hydrogen bromide
Hydrogen chloride
Hydrogen cyanide
Hydrogen fluoride
Hydrogen peroxide
Hydrogen selenide
Hydrogen sulfide
Hydroquinone

Iodine
Iron oxide fume
Isoamyl ncelale
Isoamyl alcohol
Isobulyl acelale
Isobutyl alcohol
Isophonone
Isopropyl acetate
Isopropyl alcohol
Isopropyl glycidyl
Isopropylamine
Isopropylether

Kelene

Lead and inorganic
  lead compounds
Lead arcenale
Lindane
Lithium hydride
                                                           10  ppm
                                                           50  ppm
                                                          tOO  ppm
                                                           50  ppm
                                                           20  ppm
                                                           75  ppm
                                                            2  ppm
                                                          300  ppm
                                                          200  mg/m3
    10

 3.000
 8.000
 7.500
 8.000
   800
16.000
20.000
 1.500
 4.000
10.000
                                                              NA
                                                              ppm
                                                              ppm
                                                              ppm
                                                              ppm
                                                              ppm
                                                              ppm
                                                              ppm
                                                              ppm
                                                              ppm
                                                              Ppm
                                                          25 ppm
                                                      variable
                                                         300 mg/m3
                                                       1.000 mg/m3
                                                          50 ma/m3
Hydrazino
Magnesium oxide lume
Malathion
Maleic anhydride
Manganese
Mercury
Mesityl oxide
Methoxychlor
o-Methylcyclohexanone
Melhyl(n-amyl)kelone
5-Melhyl'3-heplanone
Methyl acetate
Methyl acetylene
Melhylacelv1ene~Dropadiene
  mixture (based on LFL)
Methyl acrylale
Methyl alcohol
Methyl bromide
Methyl cellosolve
Methyl cellosolve acetate
Methyl chloride
Methyl chloroform

Methyl formate
Methyl iodide
Methyl itobulyl carbinol
Methyl isocyanate
Methyl mercaptan
Methyl melhacrylate
Alpha~methyl styrene
     80

 5.000

 10,000
     28
 5.000
 7.500
 2.500
 4.000
 3.000
 10.000
 11.000

20.000
 1.000
25.000
 2.000
 2.000
 4.500
10.000
 1.000
ppm
NA
mg/m3
NA
ppm
mg/m3
ppm
mg/m3
Ppm
ppm
ppm
ppm
ppm

ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
 5.000 ppm
   800 ppm
 2.000 ppm
    20 ppm
   400 ppm
 4.000 ppm
 5.000 ppm
                                                                                                                                                a
                                                                                                                                                33

-------
                                                                                                                                       Q
                                                                                                                                       m
                                                                                                                                             33
                                                                                                                                             T3
             Chemical Name
                                                      IDLH Level
   LPG (Liquified petroleum
     gas)
   Melhylcyclohexane
   Melhylcyclohe xanol
   Melhylene bisphenyl isocyonole
   Malhylene chloride
   Mica
   Molybdenum soluble compounds
   Molybdenum insoluble compounds
   Monomelhyl amiline
-p Monomelhyl hydrazine
~P Morpholine
4^
00 Naphthalene
   Naphtha, coal tar
   Nickel carbonyl
   Nickel metal and soluble
    compounds
   Nicotine
   Nitric acid
   Nitric oxide
   p-Nilroaniline
   Nitrobenzene
   p-Nilrochlorobenzene
   Nilroelhane
   Nilrogen dioxide
   Nitrogen trilluoride
   Nilromelhane
   1-Nilropropane
   Nitrololuene
19.000  ppm

10.000  ppm
10.000  ppm
    10  ppm
 5.000  ppm
        NA
        NA
        NA
   100  ppm
     5  ppm
 8.000  ppm

   SOO  ppm
10.000  ppm
 0.001  ppm (Ca)
        NA
                                                                                           Chemical Name
    35
   100
   too
   300
   200
  .000
  ,000
    50
   000
   300
   300
   200
mg/m*
ppm
ppm
mg/m3
Ppm
ppm
Ppm
Ppm
Ppm
ppm
ppm
ppm
 Methylal
 Melhylamine
 di-sec-Octyl phlhalale
 Oil mist, mineral
 Organo (alkyl) mercury compounds
 Osmium lelroxide
 Oxalic acid
 Oxygen difluoride
 Ozone

 Paraquat
 Paralhion
 Penlaborane
 Penlachloronaphlhalene
 Penlachlorophenol
 Pentane
 2-Penlanone
 Perchloromethyl mercaplan
 Perchloryl fluoride
 Petroleum distillates mixture
  (naphtha)
 Phenol
 Phenyl ether
 Phenyl elher-biphenyl mixture
 Phenyl glycidyl ether
p-Phenylene diamine
Phenyl hydrazine
Phosdrin
Phosgene
Phosphine
Phosphoric acid
                                                                                                                                      IDLH Level
10.000 ppm
   100 ppm
       NA
       NA
    10 mg/m3
     1 mg/m3
   500 mg/m3
   0.5 ppm
    10 ppm

   1 .5 mg/m3
    20 mg/m3
     3 ppm
       NA
   ISO mg/m3
 5.000 ppm
 5.000 ppm
    10 ppm
   385 ppm
10,000 ppm

   100 ppm
    25 mg/m3
   250 ppm
    40 mg/m3
     2 ppm
   200 ppm
       NA
                                                                                                                                                 O
                                                                                                                                                 3J

-------
              Chemical Name
30
TJ
 I
Oclachloronaphlhalene
Octane
Phosphorus trichloride
Phosphorus, yellow
Phlhalic anhydride
Picric acid
Pival
Platinum soluble sails
Portland cement mixture
Propane
n-Propyl acetate
Propyl alcohol
n-Propyl nitrate
Propylene dichloride
Propylene imine
Propylene o»ide
Pyrethrum: (mixtures)
Pyridine

Quinone

Rhodium metal fume  and  dusts
Rhodium soluble salts
Ronnel
Rolenone (commercial)

Selenium compounds
Selenium hexafluoride
Silica, amorphous
Silica, cryslaline
Silver metal, soluble compounds
                                                        IDUH Level
                                                                                              Chemical Name
                                                                                                                                          IOLH Level
                                                          200  mg/m3
                                                        3.750
                                                           SO
                                                       10.000
                                                          100
                                                          200
                                                       20.000
                                                        8.000
000
000
000
500
000
000
                                                        3.600
ppm
ppm
NA
ppm
mg/m3
mg/m3
NA
NA
ppm
ppm
ppm
ppm
ppm
ppm
ppm
mg/m3
ppm
                                                           75 ppm

                                                              NA
                                                              NA
                                                        5.000 mg/m3
                                                        5.000 mg/m3

                                                          100 mg/m3
                                                            5 ppm
                                                              NA
                                                              NA
                                                              NA
Phosphorus penlachloride
Phosphorus pentasulfide
Sodium hydroxide
Slibine
Sloddard solvent
Strychnine
Slyrene
Sulfur dioxide
Sulfur monochloride
Sulfur penlafluoride
Sulfuric acid
Sulfuryl fluoride

2.4.5-T
Talc
Tantalum metal, oxide dusls
TEDP
Tellurium, compounds (as tellurium)
Tellurium hexalluoride
TEPP
Terphenyls
1.1.2.2-Telrachloro-1.2-
  difluoroelhane
1.l.2.2-Tetrachloro-2.2-
  difluoroelhane
1.1.2.2-Telrachloroethane
Telrachloroelhylene
Telrachloronaphihalene
Telraelhyl lead
Tetrahydrofuran
Telramalhyl load




5

5




1
5





3
200 mg/m3
750 ma/m3
200 mg/m3
40 ppm
.000 ppm
3 mg/m3
.000 mg/m3
100 ppm
10 ppm
1 ppm
80 mg/m3
,000 ppm
.000 mg/m3
NA
NA
35 mg/m3
NA
1 ppm
10 mg/m3
.500 mg/m3
                                                                                15.000  ppm

                                                                                15.000  ppm
                                                                                   150  ppm
                                                                                   500  ppm
                                                                                    20  mg/m3
                                                                                    40  mg/m3
                                                                                20.000  ppm
                                                                                    40  mg/m3
                                                                                                                                                     O
                                                                                                                                                     30

-------
(Cal - NtOSH has recommended thai the substance be treated as en occupational carcinogen.

                                                                                                                                      m
                                                                                                                                      en m
                                                                                                                                        5<
                                                                                                                                        m
                                                                                                                                      m r—
                                                                                                                                      2 W
          Chemical Name
                                                    IOLH level
 Soapslone
 Sodium lluoroacetate
 Tetryl
 Thallium compounds, soluble
 Thiram
 Tin compounds, inorganic

 Tin compounds, organic
 Titanium dioxide
 Toluene
 Toluene-2.4-diisocyanale
 o-Toluidine
 Tribulyl phosphate
 1.1.2-Trichloro-1.2.2-
  IriMuoroelhane
 1,1,2-Trichloroethane
 Trichloroethvlene
 Trichloronaphthalene
 1.2.3-Trichloco propane
 Trielhylamine
 Trifluoromonobromo methane
 Trinitrotoluene (TNT)
        NA
      5 mg/m^
        NA
     20 mg/m^
  1,500 mg/m3
    400 mg/m3

    200 mg/m3
        NA
  2.000 ppm
     10 ppm
    100 ppm
  1.300 mg/m3

  4,500 ppm
    500 ppm
  1.000 ppm
     50 mg/m3
  1.000 ppm
  1.000 ppm
50.000 ppm
        NA
                                                                                         Chemical Name
T«lramalhyl tuccinonilrile
Telranilromethana
Triorlhocresyl phosphate
Triphenyl phosphate
Turpentine

Uranium and insoluble compounds
Uranium and soluble compounds
Vanadium penloxide dust
Vanadium penloxide fume.
Vinyl toluene

WarUrin

Xylene (xylol)
Xylidine

Yttrium  and compounds

Zinc chloride fume
Zinc oxide fume
Zirconium compounds
                                                                                                                                    IOLH Level
     5 ppm
     5 ppm
    40 mg/m3
       NA
 1.900 ppm

    30 mg/m3
    20 mg/m3
    70 mg/m3
    70 mg/m3
 5.000 ppm

   200 mg/m3

10.000 ppm
   150 ppm

       NA

 2.000 mg/m3
       NA
   500 mg/m3
                                                                                                                                                O
                                                                                                                                                3)
                                                                                                                                                >
                                                                                                                                                31

-------
                                                                          DRAFT
      2.  Human exposure data.
      3.  Acute animal exposure data.

Where such  data  are  lacking,  acute toxicological  data  from analogous  substances
may be considered.

The  following guidelines should  be  used to interpret toxicological data  reported in
the literature for animal species:

      1.  Where  acute  animal   exposure  data  are  available   (30-min  to   4-hr
         exposures),   the   lowest  exposure   concentration   causing  death   or
         irreversible health effects  in  any species  is determined  to  be the  IDLH
         concentration.

      2.  Chronic  exposure  data  may  have no  relevance  to the  acute effects and
         should  be  used  in  determining  the  IDLH  concentration   only  upon
         competent toxicologic judgment.

      3.  Where there  is no  toxicologic evidence  of an  IDLH  concentration, 500
         times the permissible exposure limit shall determine the upper  limit above
         which only highly  reliable  breathing apparatus providing maximum worker
         protection is  used.

2.4.6    Lower Flammable Limit and Firefighting

In  addition to toxic  chemicals and  irritants, it  is necessary to consider flammable
substances.   In any atmosphere where there is  a likelihood of  a chemical fire, there
is  the risk  of creating toxic vapors  in  the  fire  or  of  asphyxiation  caused  by
reduction of oxygen content in the air  by the products of combustion.
                                     RP-46

-------
                                                                           DRAFT
Contaminant concentrations in excess of  the  LFL  are  considered to  be IDLH.  At or
above the LFL, the  use of respirators is  limited to those devices that provide the
maximum  protection  (i.e.,  positive-pressure,  self-contained   breathing  apparatus
(SCBA)   and  the  combination   positive-pressure,   supplied-air  respirators  with
auxiliary positive-pressure SCBA).

Firefighting  is defined by  ANSI Z88.5-1971 as being  immediately dangerous to  life.
For firefighting,  the only  device  providing  adequate protection is the  positive-
pressure, self-contained breathing apparatus.

2.4.7    Protection Factors

The protection factors of  respiratory  protection  devices are  a  useful numerical tool
to assist in  the choice  of  a  protective system.  Protection factors are a measure of
the overall  effectiveness  of  a  respirator.    Filtering  efficiency is  a  part  of  the
protection factor  and  becomes a  significant consideration for less  efficient air-
purifying respirators.

The protection factor of a  given respirator  for a specific user times the PEL (or
TLV)  for  a  given  substance  is the  maximum  allowable  concentration  for that
substance for which the respirator  may be used.   For example, say the protection
factor for a full-face mask respirator is 100.  For substance X  with a  PEL (or TLV)
of 10 ppm,  the full-face  mask  respirator will provide protection up to 1000 ppm.
Note  that there  is  a  difference  between  "quantitative" protection  factors  and
"qualitative" protection  factors.   The correct protection  factor must  be  used in
determining the  maximum allowable  concentration.   Exhibit RP-13  lists qualitative
protection factors for several types  of respirators.

2.4.8    Variations with 30 CFR 11

The  Type A  supplied-air  respirator is  allowed  in   30  CFR   11  for  use  in  IDLH
atmospheres.   However,  the  air flow  requirement  of 50  l/min is  insufficient to
maintain  a  positive  pressure  in  the facepiece  under  all   working  conditions.
                                      RP-47

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                                                                        DRAFT
               EXHIBIT RP-13.  QUALITATIVE PROTECTION FACTORS
Type  Respirator
Facepiece
Pressure
Protection
  Factor
    Air-purifying

    A.  Particulate-removing
        Single-use, dust
        Quarter-mask, dust
        Half-mask, dust
        Half- or quarter-mask, fume
        Half- or quarter-mask, high-
        efficiency
        Full-facepiece,  high-
        efficiency
        Powered, high-efficiency, all             Positive
        enclosures
        Powered, dust or fume, all               Positive
        enclosures

    B.  Gas and vapor-removing
        Half-mask
        Full-facepiece

    Atmosphere-supplying

    A.  Supplied-air
        Demand, half-mask
        Demand, full facepiece
        Hose mask without blower, full-
        facepiece
        Pressure-demand, half-mask            Positive
        Pressure-demand, full-facepiece         Positive
        Hose mask with blower, full-facepiece
        Continuous flow,  half-mask              Positive
        Continuous flow,  full-facepiece          Positive
        Continuous flow,  hood, helmet,          Positive
        or suit

    B.  Self-contained  breathing apparatus
        Open-circuit, demand, full-facepiece
        Open-circuit, pressure-demand,          Positive
        full-facepiece
        Closed-circuit,  oxygen  tank-type,
        full-facepiece
                         5
                         5
                         10
                         10
                         10

                         50

                     1,000

                     Indeter-
                     minate
                        10
                        50
                        10
                        50
                        50
                       000
                       000
                        50
                       000
                       000
                     2,000
                        50
                     10,000

                        50
                                    RP-48

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                                                                        DRAFT
               EXHIBIT RP-13.  QUALITATIVE PROTECTION FACTORS

                                 (Continued)
                                          Facepiece             Protection
Type Respirator                            Pressure                Factor
     Combination respirator

     A. Any combination of air-purifying and
        atmosphere-supplying respirator       Use minimum protection
                                             factor listed above
     B. Any combination of supplied-air        for type and mode of
        respirator and an SCBA                operation
                                    RP-49

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                                                                         DRAFT
Therefore,  this device should have the same protection  factor as applied  to  other
air-purifying  and atmosphere-supplying respirators  having  a  negative  pressure  in
the facepiece (see Appendix I).  30  CFR  11  will  require a  revision  to  eliminate
approval of Type A supplied-air  respirators for IDLH  atmospheres.

Protection  factor requirements are not contained in 30 CFR 11.   Protection factors
are used in the  decision logic.   A future  amendment to 30 CFR  11  is planned to
include  protection factor requirements for specific air-purifying respirators.

In addition, 30 CFR 11 does not permit the  use  of an escape gas  mask against acid
gases or organic vapors with poor warning properties.   A change to 30 CFR  11  is
necessary  to permit the use of an escape  gas  mask against substances with poor
warning properties.

2.4.9    Escape

The employer shall provide and  ensure that employees  carry  an  escape respirator
where  exposure  may  occur to  extremely  toxic substances.  (An  extremely  toxic
substance  is defined as a gas or  vapor having an LC   of less than 10 ppm.)

The cartridge  pairs were tested at  1000 ppm,  50  percent relative humidity, 22 C,
and 53.3 l/min  (equivalent to a  moderately  achieve a  1 percent breakthrough  is
noted  for   each   cartridge  pair.    Cartridges  were  preconditioned  at   room
temperature and  50 percent relative humidity for at least 24 hours prior to testing.
MSA cartridges or AO cartridges were  used  for most tests.
                                     RP-50

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                   RESPIRATORY PROTECTION WORKSHOP
                               CONTENTS
                                                                  DRAFT
SECTION

1.0
1.1
1.2
1.3
1.4

2.0
2.1
2.1.1

2.1.2

2.2
2.2.1
2.2.2
2.3
2.3.1
2.3.2

3.0
3.1
3.2

3.3
3.3.1
3.3.2
3.3.3
3.4
3.4.1

4.0
4.1
4.2
4.3
4.4
AIR-PURIFYING RESPIRATORS
INTRODUCTION
TYPES OF AIR-PURIFYING RESPIRATORS
DONNING OF RESPIRATORS
ESCAPE MASK USE

RESPIRATOR FIT TESTING
STAGE I
POSITIVE-PRESSURE SEALING CHECKS FOR
AIR-PURIFYING RESPIRATORS
NEGATIVE-PRESSURE SEALING CHECK FOR
AIR-PURIFYING RESPIRATORS
STAGE II
PROCEDURES FOR ODOR TEST
PROCEDURES FOR THE  IRRITANT SMOKE TEST
FIT-TESTING RESPIRATOR EXERCISE
OBJECTIVE
PROCEDURE

SELF-CONTAINED BREATHING APPARATUS
INTRODUCTION
INSPECTION OF POSITIVE-PRESSURE,
SELF-CONTAINED BREATHING APPARATUS
SCBA EXERCISE
OBJECTIVE
SCBA CHECKOUT
SCBA FIELD EXERCISE
RECHARGING SCBA AIR CYLINDER EXERCISE
PROCEDURE

CARE AND CLEANING OF RESPIRATORS
INSPECTION
CLEANING AND DISINFECTION
REPAIRS
STORAGE
 PAGE

RPW-1
RPW-1
RPW-3
RPW-4
RPW-4

RPW-5
RPW-7
RPW-7

RPW-8

RPW-8
RPW-8
RPW-10
RPW-12
RPW-12
RPW-12

RPW-14
RPW-14
RPW-15

RPW-20
RPW-20
RPW-20
RPW-21
RPW-22
RPW-22

RPW-23
RPW-24
RPW-25
RPW-31
RPW-31
                                 RPW-ii

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                                                                DRAFT
                               EXHIBITS
NUMBER                                                          PAGE

RPW-1   COLOR CODE FOR CARTRIDGES AND GAS MASK CANISTERS        RPW-2
        (ANSI K13.1-1973)

RPW-2   FIT-TEST RECORD                                          RPW-13

RPW-3   SCBA EXERCISE                                            RPW-21

RPW-4   AIR MANIFOLD                                             RPW-21

RPW-5   ULTRA-TWIN RESPIRATOR                                   RPW-26

RPW-6   MSA AIR MASK MODEL 401                                  RPW-28

RPW-7   MSA AIR MASK MODEL 401 REMOVAL AND CLEANING             RPW-29
        PROCEDURE
                                RPW-iii

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                                                                           DRAFT
1.0   AIR-PURIFYING RESPIRATORS

1.1   Introduction

The following  basic facts are important for the use of the air-purifying respirator:

      1.  Air-purifying  respirators   filter  air  with   mechanical   filters   and/or
         sorbents.

      2.  Air-purifying respirators  must not be used in atmospheres that are oxygen
         deficient (less than  19.5 percent 0~ at sea level).

      3.  Air-purifying  respirators  must not  be  used   in  atmospheres  that  are
         immediately dangerous to life and health.

      4.  The  specific  contaminant   must  be  identified,  both  qualitatively  and
         quantitatively.  (A  tabulation  of  specific atmospheric contaminants and
         the colors  assigned  to cartridges  and gas mask canisters used to protect
         against such contaminants is presented as Exhibit RPW-1.)

      5.  Monitoring  of the atmosphere  must be  performed  while  an air-purifying
         respirator is used.

      6.  A  respirator  fit test  must  be  performed  and  passed before the  specific
         respirator can be used.  The fit of the  respirator changes  with the growth
         of facial hair, weight  loss/gain, dental  work, etc.   The biggest cause  of
         leakage is facial hair.

      7.  Protection  factors must  be used  to  determine if a  specific respirator can
         be used in  a given atmosphere.
                                      RPW-1

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                                                                         DRAFT
         EXHIBIT RPW-1. COLOR CODE FOR CARTRIDGES AND GAS MASK

                          CANISTERS (ANSI K13.1-1973)
                 Atmospheric Contaminants
                   To Be Protected Against                          Color Assigned
Acid gases                                                        White
Organic vapors                                                    Black
Ammonia  gas                                                     Green
Carbon  monoxide gas                                              Blue
Acid gases and organic vapors                                     Yellow
Acid gases, ammonia, and organic vapors                           Brown
Acid gases, ammonia, carbon monoxide, and organic vapors          Red
Other vapors and gases not listed above                            Olive
Radioactive  materials (except tritium and noble gases)                Purple
Dusts, fumes, and mists (other than radioactive materials)            Orange
      Notes:
      1.  A  purple   stripe   shall   be  used  to  identify  radioactive  materials  in

         combination with any vapor or gas.


      2,  An  orange stripe  shall  be  used to  identify  dusts, fumes, and  mists  in

         combination with any vapor or gas.


      3.  Where  labels only  are colored to conform with  this table, the  canister  or

         cartridge body shall be gray or a metal canister or cartridge body may  be

         left  in its natural metallic color.


      4.  The user shall refer to the  wording  of the label to determine the  type and

         degree of  protection the canister or cartridge will afford.
                                    RPW-2

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                                                                           DRAFT
1.2   Types Of Air-purifying Respirators

There are many different types of respirators for use in various circumstances:

      1.  Disposable dust  respirators are only for use with dusts.

      2.  Mouthbit respirators

         a.  Only used as an escape device.
         b.  Not useful for hazardous waste work.

      3.  Quarter-mask respirators

         a.  Not for use with hazardous chemicals.
         b.  High degree of leakage.

      4.  Half-mask respirators

         a.  Can be used  in restricted conditions with  hazardous  chemicals.
         b.  High degree of leakage.
         c.  Only 50 percent of population  can get a satisfactory fit.

      5. Full-face-mask respirators

         a.  Cover  entire  face  from  under  the  chin to  above  the  eyes,  thus
            providing eye protection as well as respiratory  protection.

         b.  Provide  much  better  respirator protection than previously  mentioned
            respirators, since full-face respirators tend to give a better fit.

         c.  Are usually made  of either butyl, neoprene, or silicone rubber.
                                      RPW-3

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                                                                          DRAFT
      6. Powered  air-purifying  respirators  are  more  effective than  standard  air-
        purifying  respirators.

      7  Gas masks are more effective than chin-cartridge, air-purifying  respirators
        due to the larger sorbent capacity.

1.3   Donning Of Respirators

The  respirator is  placed  over the face,  and the straps are  drawn  securely.  The
bottom  straps are  secured first.   The mask should  not be so  tight as to cause
discomfort  or   headache.     Once  the  respirator   is  secured,   positive  and
negative-pressure tests are conducted.

1.4   Escape Mask Use

Response personnel  may  have to carry  escape  masks when  on sites  presenting
potential respiratory hazards.  These  masks are used  when  IDLH atmospheres are
encountered, breakthrough  is noticed  when using  a respirator, or someone in the
work  party shows symptoms  of respiratory distress.  Escape masks  are  to  only be
used for escape, not rescue or regular work tasks.

Procedure for  donning a typical escape mask is listed below:

      1.  Open case.

      2.  Pull  out air capsule.   (Mask  should  be packed so  that it  can  be pulled
         forward  out of case.)

      3.  Unfold hood.

      4.  Pull start ring.

      5.  Remove and discard other respirator (if one is being  worn).
                                     RPW-4

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                                                                           DRAFT
      6.  Slip hood over head starting  from back of head.

      7.  Pull drawstring tight and adjust elastic neck band.

2.0   RESPIRATOR FIT TESTING

Only  approved  or  accepted  National   Institute  for  Occupational  Safety  and
Health/Mine   Safety   and   Health   Administration   (NIOSH/MSHA)   air-purifying
respirators can be used.  Those with full-face masks provide maximum eye and skin
protection.  Air-purifying  respirators can be used for work in  an atmospheres that
are known to contain adequate oxygen (above  19.5 percent 02)  and contaminants
with good warning properties and that are not immediately dangerous to life and
health because of the  presence  of  toxic  contaminants.   Several  manufacturers
(Wilson,  Norton,  MSA, Scott, etc.)  carry  these  respirators which are suitable  for
use.     Each   company  manufactures   one   or  more  types   of  air-purifying
cartridge/canister  respirator.   Each make and  model  has a  slightly different  fit.
Although  each  manufacturer designs his facepieces to fit as broad a section  of the
working   population  as  possible, no   respirator  marketed  will   fit   everyone.
Conditions that affect a good facepiece fit include: growth of beard, sideburns, a
skull cap that projects under the  facepiece, temple pieces on  glasses, facial scars,
facial injuries, and presence or absence of dentures.  Several manufacturers  should
be  used  so  that  each  employee can  take  advantage of  the  different  fitting
characteristics  to find  a respirator that  fits  properly.   Also, the  opportunity  to
select from various manufacturers allows  the wearer to choose  a respirator  that is
reasonably comfortable while  providing good  protection.   It  is  in the process  of
matching the  respirator  to  the   individual user  that  a  fit-testing procedure  is
needed.

OSHA regulations (29 CFR  Part  1910.134)  requires  that each  person who wears a
respirator shall  have  it properly fitted, test the facepiece for face seal, and wear it
in a test  atmosphere. In  compliance  with this regulation, each respirator  user must
use a fit test  to  determine his ability to  obtain a  satisfactory fit with a "negative
pressure", air-purifying respirator.  The results  of the fit test will be  used to  select
                                     RPW-5

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                                                                           DRAFT
the specific type, make,  and model of "negative pressure", air-purifying respirator
for use by the wearer.

The  following  policies  will  also  be  adhered  to  in  the fitting and  use  of the
respirators:

      1.  An employee must have passed the fit test in order to use a respirator.

      2.  If it  is  found that an employee  cannot obtain a good respirator-to-face
         seal  because  of facial or medical  characteristics, that  employee  will not
         use and/or enter an atmosphere that will require the use of a respirator.

      3.  Facial  hair  such  as beards, sideburns, or  certain  mustaches  that  may
         interfere with the fit test are not allowed.

      4.  Persons  requiring   corrective  lenses  shall   be  provided  with  specially
         mounted lenses  inside the full-face mask.  Under  no  circumstances will
         contact lenses and/or  glasses be worn while  using respirators.

      5.  Although   fit   testing  for  positive-pressure   self-contained  breathing
         apparatuses is  not required  as described  in  ANSI 288.2 (revision  1980), a
         less-than-acceptable respirator-to-face  seal  will increase  the use of  air
         via  leakage and therefore  reduce  effective  breathing  time.  Such  leaks
         may  pose a hazard to the user if sufficient air is  not available to reach an
         uncontaminated  air supply.

      6.  A person may only  use the  specific make(s) and model(s)  of  air-purifying
         respirators  for which he has obtained  a satisfactory  fit via the qualitative
         fit-testing procedures.  Under  no  circumstances shall  a  person be allowed
         to use  any make or  model respirator that  has  not  been   previously fit
         tested or that has failed a fit test.
                                     RPW-6

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                                                                           DRAFT
In the fulfillment  of  the  commitment to comply with the fit-testing requirement,
usually  qualitative rather than  quantitative  fit-testing  procedures  are  selected.
This selection is made because the two-stage, cross-checking procedures described
below will afford the necessary quality assurance that the  user  of an air-purifying,
cartridge/canister  respirator  is properly fitted in a hazardous  atmosphere.   During
any  fit test, the  respirator headstraps  must  be  as  comfortable  as  possible.
Overtightening the straps will sometimes  reduce or increase facepiece leakage,  but
the wearer may not be able  to tolerate the mask for  any  period  of time.   Passing  a
qualitative fit test allows the respirator  wearer to  enter  atmospheres  up  to  the
TLV or PEL times the  protection factor.

Qualitative fit-test  procedures involve two  stages of testing.   Stage I  involves  a
simple respirator  positive and  negative-pressure  sealing  check for facepiece  fit.
Stage II involves the  exposure of the respirator wearer to a test atmosphere. This
will include two separate  atmosphere tests to double-check the  adequate fit of  the
respirator.
2.1
2.1.1    Positive-Pressure Sealing Check for Air-Purifying Respirators

This test is  very much  like the  negative-pressure sealing check.   This test  is
performed  after donning an  air-purifying respirator that contains  an  exhalation and
inhalation valve.   The test  is conducted  by closing off the exhalation valve and
exhaling gently.  The fit  of a respirator equipped with a facepiece is  considered  to
be  satisfactory if a slight positive pressure can  be  built up inside the facepiece for
at  least 10 seconds without detecting any outward leakage  of  air  between the
sealing  surface of the facepiece and the respirator wearer's face.

This test is made only as a gross determination of fit when the respirator is to  be
used in relatively  toxic atmospheres.  Nonetheless,  this test  shall  be  used just prior
to entering any toxic atmosphere.
                                     RPW-7

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                                                                           DRAFT
2.1.2    Negative-Pressure Sealing Checks for Air-Purifying Respirators

The wearer can  perform this test by himself  or  herself in the field or office after
donning the air-purifying respirator.   The  test consists of closing  off the  inlet of
the cartridge(s) to  prevent  the passage of air.  The test is performed by closing off
the inlet opening of the respirator cartridge(s) by covering it with the palm of the
hand(s) so that it will not allow the passage of air, inhaling gently,  and holding the
breath  for at  least 10  seconds.  If  a facepiece collapses slightly and no inward
leakage of air  into  the facepiece is detected, it can be reasonably assumed that the
fit of the respirator to the wearer is satisfactory.

This test,  like  the  positive-pressure  sealing check, is to  be used only as a gross
determination  of  fit  when  the respirator  is  to  be  used  in  relatively  toxic
atmospheres.   (Both the  positive and  negative-pressure sealing  checks  can be used
on  the  SCBA air mask to determine the gross  fit characteristics.)  This  test shall be
used  just before  entering any toxic atmosphere.
A  person wearing  an air-purifying respirator  will  be exposed to two  test  agents:
isoamyl  acetate—an odorous vapor—and stannic  chloride—an  irritant smoke.   An
air-purifying  respirator  is used equipped  with  an  air-purifying  cartridge  which
effectively removes the test agents from respired  air.   If the respirator wearer is
unable to detect penetration of the test  agent into the respirator,  he has achieved
a satisfactory fit.

2.2.1    Procedures for the Odor Test

Isoamyl  acetate  is  a  chemical  that produces a pleasant banana-smelling  organic
vapor.   It  is  an easily detectable odor.   The  isoamyl acetate  fit test  will  be
conducted by using a plastic garbage bag as a test  hood covering  hung from  the
ceiling over  a  coat  hanger suspended by twine.  Inside  the plastic  bag,  a piece of
cloth  saturated with  isoamyl acetate  is  attached to the top portion  of the bag.
                                      RPW-8

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                                                                          DRAFT
This procedure will produce a rough concentration of  approximately TOO ppm in the
test atmosphere inside the plastic bag.  Most people  can  detect isoamyl acetate at
1 to 10 ppm.  The  permissible TLV exposure is 100 ppm.

The following  isoamyl acetate fit test will be performed as  follows:

      1.  The wearer  puts  on the respirator in  a  normal  manner.  If  it is an air-
         purifying   device,   it  must  be  equipped with  a  cartridge  specifically
         designed  for protection against organic vapors.

      2.  The wearer enters the test enclosure,  so that his head and shoulders are
         well inside the bag.

      3.  If the wearer smells banana oil, he returns to clean air and readjusts the
         facepiece and/or adjusts the headstraps without unduly tightening  them.

      4.  The wearer repeats  the second step.  If he does not smell banana  oil, he is
         assumed  to  have obtained a  satisfactory  fit.  If he smells the vapor, an
         attempt should  be made to find the leakage point.  If the leak cannot be
         located, another respirator of the same type  and  brand should be tried. If
         this leaks, another brand of respirator with a facepiece  of the  same  type
         should be tried.

      5.  After  satisfactory  fit is obtained,  if  the respirator  is  an  air-purifying
         device, it  must be  equipped  with the  correct filter, cartridge, or canister
         for the anticipated hazard.

During the test, the subject  makes movements  that approximate a normal working
situation.  This may include the following:

      1.  Normal breathing.

      2.  Deep breathing, as during heavy exertion.

                                     RPW-9

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                                                                          DRAFT
      3.  Side-to-side and up-and-down head movements. These movements should
         be exaggerated, but should  approximate those that  take place on the job.

      4.  Talking.   This  is most  easily accomplished by reading  a  prepared text
         and/or reciting the alphabet loudly enough to be understood by someone
         standing nearby.

      5.  Other exercises may be  added depending upon the situation.  For example,
         if the wearer is going to spend a significant part of his time bent over at
         some task, it may  be desireable  to include an exercise approximating this
         bending.

The major drawback of  the isoamyl acetate test is that the  odor  threshold varies
widely among individuals.  Furthermore, the sense of  smell is  easily dulled and may
deteriorate  during  the  test so  that  the  wearer  can  detect only  high vapor
concentrations.    Another disadvantage  is that  isoamyl  acetate  smells pleasant,
even  in  high  concentrations.  Therefore, a wearer  may say that the  respirator fits
although  it  has   a  large  leak.   Therefore, these  test  results  must be checked
carefully and confirmed by the next test atmosphere.

2.2.2    Procedures for the Irritant Smoke Test

This qualitative test is similar to  the isoamyl test in concept.  It involves exposing
the respirator wearer  to an  irritating smoke.   Sealed  glass tubes, approximately 12
cm long by 1 cm in diameter, filled  with pumice  impregnated with  stannic chloride
are used to produce the smoke.   When the tube ends are broken and air is  allowed
to enter, the material  inside  reacts with the moisture  in the  air to produce a dense.
highly-irritating smoke.

As  a  qualitative  means  of  determining  respirator  fit, this  test  has  a  distinct
advantage  in that  the  wearer usually reacts involuntarily to  leakage by coughing or
sneezing.  The likelihood  of  his  giving a  false indication of  proper fit is reduced.
However,  because this smoke is  very irritating, it can cause  problems for the test

                                    RPW-10

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                                                                          DRAFT
applicators or other persons in  the  same room.   Therefore, it is advisable to have
good ventilation in the room in which the testing is to be conducted.

The  irritant smoke test will  be conducted by  using a  plastic garbage bag as a test
hood.  The bag shall be  hung from  the  ceiling  over a coat hanger suspended by
twine.  A small hole is made in the top portion of the  bag  so that the irritant  smoke
can be dispensed into the bag when the test subject has entered the bag.

The  air-purifying  respirator to be  used in this test must be equipped with a high-
efficiency, particulate filter.

The irritant smoke fit test  will  be performed  as follows:

      1. The  wearer puts on the respirator  normally, taking care not to tighten the
        headstraps  uncomfortably.   Once  the respirator  is  on,  the subject is to
        enter the suspended bag  so that his head and shoulders are well inside the
        bag  hood.

      2. Once  the  subject is  inside  the  bag, the tester  may increase the  smoke
        density,  still remaining alert to the  wearer's reactions.

      3. If the wearer  detects  no  leakage,  the tester  may  increase  the  smoke
        density,  still remaining alert to the  wearer's reaction.

      4. At this point, if no leakage has been detected, the wearer  may cautiously
        begin  the head movements and exercises mentioned in the isoamyl acetate
        test.   The  tester should  remain especially alert  and be prepared to stop
        producing  smoke immediately  and  remove the subject from  the bag.

      5. If a  leakage is detected at any time,  the tester should stop the  smoke and
        let the  wearer  out  of the bag  to   readjust the facepiece or  headstrap
        tension. The tester should then  start the test at the second step.
                                    RPW-11

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                                                                            DRAFT
      6.  If at the end  of all the  movements  and exercises the wearer is  unable to
         detect penetration  of the irritant smoke into the respirator,  the  respirator
         wearer has a  satisfactory fit.

      7.  After the  test is completed, the subject should  be removed  from the test
         atmosphere.

2.3   Fit-Testing Respirator Exercise

2.3.1    Objective

Participants  learn  to  fit-test  a full-face,  air-purifying respirator  with procedures
suitable for field  use.

2.3.2    Procedure

      1.  Instructor  demonstrates  proper  fit-testing  with   isoamyl   acetate  and
         irritant smoke.

      2.  Each  person  must  successfully  fit-test at  least  one participant.    It is
         desirable  for each person to fit-test a  full-face  mask using  both  methods
         of testing.

      3.  Each  participant  must be fit-tested  until  a  full-face  mask  is found  that
         provides a good 'face seal.

      4.  Fill  out Fit-Test  record (Exhibit RPW-2.)
                                     RPW-12

-------
                                                                         DRAFT
                                 EXHIBIT RPW-2
                                FIT-TEST RECORD
Name:
Location:
Signature:
         Date:
Name of Fit-Tester:

Signature:  	
         Date:
 TYPE OF TEST

Type of Mask:
Manufacturer:
Model:
ISOAMYL
ACETATE

Pass/Fail
IRRITANT
 SMOKE

Pass/Fail
Type of Mask:
Manufacturer:
Model:
Pass/Fail
Pass/Fail
Type of Mask:
Manufacturer:
Model:
Pass/Fail
Pass/Fail
Type of Mask:
Manufacturer:
Model:
Pass/Fail
Pass/Fail
Type of Mask:
Manufacturer:
Model:
Pass/Fail
Pass/Fail
Comments:
                                     RPW-13

-------
                                                                         DRAFT
3.0   SELF-CONTAINED BREATHING APPARATUS

3.1   Introduction

The  self-contained  breathing  apparatus  is  the  most  effective of the  protective
breathing devices.   SCBAs  are  used if  the nature of the  respiratory  hazard  is
unknown or if the concentration  of toxic  pollutants  is too  high  to allow the use  of
air-purifying  respirators.    There  are two  types   of  SCBAs: open-circuit  and
closed-circuit.

      1.  Closed-circuit is a rebreathing system that  adds fresh oxygen.

      2.  Open-circuit has  a  supply of breathing  air; exhaled  air is returned to the
         ambient atmosphere.

The SCBA has two modes of operation: demand and  pressure-demand.

      1.  Demand.  Negative-pressure is created inside the facepiece and breathing
         tubes upon inhalation.

      2.  Pressure-Demand.  Positive-pressure  is maintained  inside  the face-piece
         and breathing tubes at all times.

Only pressure-demand SCBAs are approved for use in IDLH  atmospheres.

Maintenance  of  SCBA regulators  must   be  performed  by personnel  trained  and
certified  by the  manufacturer.  Because the use of SCBAs  places physiological and
psychological burdens on the user, personnel must  be medically fit and extensively
trained.
                                    RPW-14

-------
                                                                           DRAFT
3.2   Inspection of Positive-Pressure, Self-contained Breathing Apparatus

The following checklist is to be used by students whenever they have to check out
an SCBA.  (Note: Any  discrepancy found should  be  cause to  set the unit  aside  until
it can be repaired  by a certified repair-person.)

      1.  Preliminary inspection. Check to  ensure that

         a.  High-pressure hose connector is tight on cylinder fitting.
         b.  Bypass valve is closed.
         c.  Mainline valve is closed.
         d.  There is no  cover  or obstruction  on  regulator outlet.
         e.  Pressure in the tank is at least 1800 psi.

      2.  Backpack and harness assembly

         a.  Straps

            (1) Visually inspect for complete  set.

            (2) Visually  inspect  for frayed  or  damaged straps  that  may break
               during use.

         b.  Buckles

            (1) Visually inspect for mating ends.
            (2) Check locking function.

         c.  Backplate and cylinder lock

            (1) Visually  inspect backplate  for  cracks  and  for  missing  rivets  or
               screws.
                                     RPW-15

-------
                                                                     DRAFT
       (2) Visually  inspect  cylinder  hold-down  strap  and  physically check
          strap tightener and lock to ensure that it is fully engaged.

3.  Cylinder and cylinder valve assembly

    a.  Cylinder

       (1) Physically  check cylinder  to  ensure  that  it  is tightly  fastened to
          backplate.

       (2) Check  hydrostatic test date monthly to ensure that it is current.

       (3) Visually inspect cylinder monthly for large dents or gouges in metal.

    b.  Head and valve assembly

       (1) Visually inspect cylinder valve lock monthly for presence.

       (2) Visually inspect cylinder gauge monthly for  condition of  face, needle,
          and  lens.

       (3) Open cylinder valve and listen or  feel for  leakage around packing.  (If
          leakage is  noted, do  not  use until  repaired.) Note function  of  valve
          lock.

4.  Regulator and high-pressure hose

    a.  High-pressure  hose and connector

       Listen  or  feel  for  leakage  in  hose  or  at  hose-to-cylinder  connector.
       (Bubble  in outer hose covering may be caused by seepage of air through
       hose when stored under pressure.  This does  not necessarily mean a faulty
       hose.)

                               RPW-16

-------
                                                                DRAFT
b.  Regulator and  low-pressure alarm

   (1) Cover outlet  of regulator with palm  of hand.  Open mainline valve and
      read  regulator gauge (must read at least 1800  psi and  not  more than
      rated cylinder pressure).
   (2) Close cylinder  valve  and slowly move hand from  regulator outlet to
      allow slow flow of air.  Gauge should begin to show immediate loss of
      pressure as air flows.  Low-pressure alarm should sound between 650
      and  550  psi.  Remove hand completely from outlet  and close mainline
      valve.

   (3) Place mouth onto  or  over regulator  outlet  and  blow.   A positive
      pressure should be  created  and  maintained for 5 to  10  sec without any
      loss  of air.  Next, establish  a slight  negative pressure in regulator and
      hold  for  5  to 10 sec.   Vacuum  should remain constant.  This tests the
      integrity  of the  diaphragm.  Any loss of pressure or  vacuum during this
      test  indicates a leak in the apparatus.

   (4) Open cylinder valve.

   (5) Place hand over regulator  outlet and  open mainline  valve.   Remove
      hand from  outlet and  replace in  rapid movement.  Repeat twice.

      Air   should  escape  when  hand  is  removed each  time,  indicating  a
      positive  pressure in  chamber.   Close mainline valve and remove hand
      from outlet.

   (6) Ascertain that  no obstruction is in or over the regulator outlet.  Open
      and  close  bypass valve  momentarily  to  ensure flow  of  air through
      bypass system.
                            RPW-17

-------
                                                                     DRAFT
   c.  Don backpack.


5.  Facepiece and corrugated breathing tube

   a.  Facepiece

       (1) Visually  inspect  head  harness   for   damaged  serrations   and
          deteriorated  rubber.   Visually  inspect  rubber facepiece body for
          signs of deterioration or extreme distortion.

       (2) Visually inspect lens for  proper seal  in  rubber facepiece,  retaining
          clamp properly in place, and  no cracks or large scratches.

       (3) Visually  inspect  exhalation   valve  for  visible   deterioration  or
          buildup of foreign materials.

   b.  Breathing tube and connector

       (1) Stretch  breathing  tube and  visually inspect  for  deterioration  and
          holes.

       (2) Visually inspect  connector to ensure good condition of threads  and
          for presence  and proper condition of "0"  ring or rubber gasket seal.

       (3) Negative/positive-pressure test on facepiece

          (a)  Don  facepiece.

          (b)  Stretch breathing tube to open corrugations and place thumb
              or hand over end of connector.
                                RPW-18

-------
                                                                         DRAFT
               (c)   Inhale.   Negative  pressure should  be  created  inside  mask,
                    causing  it  to  pull  tightly  to face.    This  negative pressure
                    should be maintained for 5 to 10 seconds. If negative-pressure
                    leaks down, the facepiece assembly is not adequate and should
                    not be worn.

               (d)   Exhale.    Positive  pressure  should  be  created  inside  mask
                    causing  it  to press away from  face.   This positive pressure
                    should be maintained for 5 to 10 seconds.  If positive-pressure
                    leaks down, the facepiece assembly is not adequate and should
                    not be worn.

3.3   SCBA Exercise

3.3.1    Objective

Participants  become more   familiar  with   the  proper  techniques of  inspection,
donning and doffing, and  use of the  SCBA.  The students wear  SCBA and become
more confident in using it by performing various tasks at exercise stations.

3.3.2    SCBA Checkout

Checkout  exercises  are  designed  to give the  student  experience in  identifying
faults commonly found in SCBAs and  in remedying the faults.

      1.  Participants leave the room while the instructor alters the  SCBAs.

      2.  Participants return,  check  out their SCBAs,  note  any problems, determine
         cause, and  restore their SCBAs to proper working  order.

      3.  Participants on SCBAs and facepieces.

      4.  Participants connect breathing hose and turn on mainline valve.

                                    RPW-19

-------
                                                                          DRAFT
3.3.3    SCBA Field Exercise

The  respiratory  protection  field  exerc'se is  designed  to  give the  student  the
experience of actually using a self-contained breathing apparatus and performing a
variety of activities while wearing  it.  Those activities will  include:

      1.  Simple  movements  such as  walking, bending,  reaching, walking up  and
         down hills,  climbing  over  obstacles,  and maneuvering in  confined  areas
         (Exhibit  RPW-3.)

         a.  Start in garage with one minute step-ups on  core boxes.

         b.  Run  jogging course and up the bank using a rope.

         c.  Jog  to  the  tires, run through the  tires (tallest first) and  the  ropes, at
            the end form a human tunnel at the flags.

         d.  Carry cooler to the top  of  hill and back.

         e.  Walk down  the  bank using  a  rope,  jog  around  the building to  the
            driveway, run  up  driveway  to  finish at garage.   People  with  air
            remaining jog around the parking lot until air  is used up.

      2.  Change  air tanks using the  buddy system.

      3.  Refill air tanks using a  cascade system.

      4.  Perform strenuous exercise.

      5.  Use the emergency bypass as a source of breathing air.

      6.  Exhaust  the tank  to  experience  the  low-air   alarm  and  the  feelings
         associated with a loss  of air.

                                    RPW-20

-------
                                                                         DRAFT
                                EXHIBIT RPW-3
                                SCBA EXERCISE
                                   EXHIBIT RPW-4
                                   AIR MANIFOLD
                                                 START
      Tires
Human Tunnel
4} \ N
1 ' (•-•
£ i -? '
> H 1*?
— . 1 . 'ffl
d.' Flags 1 I
3' f 1 1
1 Rope Hll| Climb,
[sicTooir^v \_
1 min. Stap-upa
on Core Boxes
	 \ *
1
1 Garage
1
1- _— — -
LAB BLDG.


••» ^^•^-••t ^BBi
* r

\


j f
1 flope 4 v^. ^> 	 ••-. 	 __ _ •* — — *
Around Bldg. — • — — — — __ ___ _
to Garage
     Carry Coolers Up & Back
                                     RPW-21

-------
                                                                         DRAFT
      7.  Participate  in  team  sports  such as soccer  or volleyball  to  demonstrate
         how  rapidly air can  be exhausted from  the tank by exertion.

3.4   Recharging SCBA  Air Cylinder Exercise

The air cylinder of an SCBA can supply air for up to 30 or 60 minutes, depending on
the units  rating.  Then  the cylinder must be  removed and refilled,  either by an air
compressor or a cascade  system.  A cascade system consists of several large air
cylinders and  a filling system.  This system is used  almost exclusively  on sites.  All
persons who  must  wear a SCBA should  be familiar with the  proper procedures for
recharging the cylinder.

3.4.1    Procedure

The recharging system  operates on the principle of cascading—(the equalization of
pressure between the supply cylinders and the apparatus cylinder in  sequence).  The
proper procedure (Exhibit RPW-4) for  SCBA recharging is as follows:

      1.  Open and  close the valve on  each supply cylinder (check all to make  sure
         Grade D air) to find  its air pressure relative to other supply cylinders.

      2.  Mark supply cylinders from in  order of  least pressure to highest pressure.

      3.  Attach high pressure hose from  cascade manifold to  SCBA  cylinder valve.

      4.  Check pressure in SCBA cylinder.

      5.  Slowly open valve on SCBA  cylinder.

      6.  Slowly open valve on high pressure hose from  cascade manifold.
                                    RPW-22

-------
                                                                          DRAFT
      7.  Determine which  supply cylinder should  be used to begin the  cascading
         operation.   The  supply  cylinder with  the lowest  pressure,  but greater
         pressure than that in the SCBA cylinder should  be used  first.

      8.  Slowly open the valve on this  supply cylinder #1.

      9.  When  pressure on the  manifold  gauge  stabilizes, pressure  in  the two
         cylinders  has equalized.

     10.  Close the supply cylinder valve.

     11.  If apparatus cylinder has  not  reached desired  pressure, repeat procedure
         using the next highest pressure cylinder.

     12.  If the  final  supply cylinder does not  fully recharge  apparatus  cylinder,
         remove supply cylinder #1 and replace with a full cylinder.

     13.  Return to Step #7,

     14.  Once apparatus cylinder is at  desired pressure, close all values  in system
         and disconnect apparatus cylinder from  cascade high pressure hose.

     15.  Mark any  empty supply cylinders for recharge.

Each  participant  recharges  at  least  one air  cylinder   according  to  the  method
described.

4.0   CARE AND CLEANING OF RESPIRATORS

Any  organization using  respirators on a  routine basis must have  a program for their
care and cleaning.  The  purpose  of such a program  is to ensure that air respirators
                                    RPW-23

-------
                                                                          DRAFT
are maintained  at  their original effectiveness.   If they are  modified  in  any  way,
their  protection factors  may  be voided.   Usually  one person in an organization is
trained to inspect, clean, repair, and store respirators.

The  program  should be based  on the number and  types of respirators, working
conditions, and hazards involved.  In general, the program should include:

      1.  Inspection (including a leak check)
      2.  Cleaning and disinfection
      3.  Repair
      4.  Storage

4.1   Inspection

Respirators should  be inspected after  each use.  Respirators that are kept  ready for
emergency use must be inspected once a month to  ensure that they  will perform
satisfactorily.

All connections  on  air-purifying  respirators should  be  thoroughly  checked for
gaskets and  "0"  rings and for  proper tightness.   In  addition, the  condition of the
facepiece and  all  its parts,  the connecting  air  tube,  and  headbands should  be
checked, and rubber  or elastomer parts should be inspected for  pliability and signs
of deterioration.

Inspecting SCBA (Monthly)

         a.  Check  cylinder label for current hydrostatic test date.
         b.  Inspect cylinder for large  dents or gouges in metal.
         c.  Inspect cylinder gauge for any damage to the face, needle,  and lens.
         d.  Inspect SCBA  through full check out procedure.
         e.  Fill out appropriate records with results and  recommendations.
                                    RPW-24

-------
                                                                          DRAFT
A record should be maintained of each respirator inspection,  including the  date, the
inspector, and any unusual conditions or findings.

4.2   Cleaning and Disinfection

Respirators are to be collected  at a  central location.   Employees required to wear
respirators should be briefed  on the  respirator  program and  assured that  they  will
always receive  a  clean and sanitized respirator.  Such  assurances can boost morale.
Respirators should be cleaned and disinfected as follows:

     1.  Air-Purifying Respirators  (Exhibit RPW-5)

         a.  Remove acetate  shield from facepiece lens and discard.

         b.  Remove both cartridges and cartridge receptacle gaskets.

         c.  Unscrew cartridge receptacles from inhalation  valve  seats.

         d.  Remove inhalation valves and inhalation valve  seats  from face mask.

         e.  Remove exhalation valve  cover.

         f.  Remove  nosecup,   unscrew   retainer   ring,   and   remove   speaking
            diaphragm and speaking-diaphragm gasket.

         g.  Wash entire mask and all parts in  cleaner/sanitizer  powder mixed with
            warm water,  preferably at  120  to 140 F,  and  let soak for three  to  five
            minutes.

         h.  Remove  all  parts from  wash  water and rinse  twice  in clean,  warm
            water.
                                    RPW-25

-------
                                    EXHIBIT RPW-5

                              ULTRA-TWIN RESPIRATOR
                                                                                 DRAFT
  458173
  Head harness
       466202 Facepiece blank, black
       466203 Facepiece blank, green
                                                    96677 Lens
      96662
 Buckle assembly
   (3 required)
457190 Buckle assembly
 with D-ring (2 required)
            78584
  Inhalation valve (2 required)

  459711 Inhalation valve seat
         (2 required)
 460184
 Cartridge receptacle
 (2 required)
                        464358 Lens ring kit assembly

                       462709  Lens ring (2 required)
                                        61765
                                               Nut (2 required)

                                                    60532  Screw (2 required)
    Q
  461958
  Exhalation
  valve seat
   78703
 Exhalation
flapper valve
            458212 Clamp,
                   band
                  96666 Retainer ring
                    83635 Speaking diaphragm

                      83630 Speaking diaphragm gasket
 459035 Cartridge receptacle
     gasket (2 required)
   462185
  Valve and
seat assembly
                                                         o
          449507
Speaking diaphragm housing
     with bonded plug
           82382
      Exhalation valve
           cover
      459058 •
      Speaking
      diaphragm and
      housing assembly
                                        RPW-26

-------
                                                                    DRAFT
   i.  Air-dry parts in a  designated  clean area.  Speaking  diaphragm  only
      may be dried immediately using a  warm-air source such as a  hair dryer
      or radiator grill.

   j.  Re-assemble entire  unit when  parts are dry  and replace acetate shield
      on the face mask lens.

   k.  Make sure  unit is working properly before using.

2.  MSA Air Mask (Exhibit RPW-6)

   a.  Remove acetate  shield from lens.

   b.  Remove breathing hose from adapter assembly.

   c.  Unscrew  adapter assembly from  speaking-diaphragm  housing  and
      remove valve spider and disc valve.

   d.  From inside face mask,  remove  retaining  ring,  speaking diaphragm,
      and  speaking-diaphragm gasket.

   e.  Remove and clean  exhalation valve  only as  necessary as  described  in
      Exhibit RPW-7.

   f.  Clean  entire mask  following the same  procedure  as outlined for air-
      purifying respirators.

   g.  Re-assemble entire  unit when  parts are dry  and replace acetate shield
      on the face mask lens.

   h.  Make sure  unit is working properly before using.
                              RPW-27

-------
                                                                                                DRAFT
                                      EXHIBIT RPW-6

                              MSA AIR  MASK MODEL 401
4SJ173 HARNESS
                          - MM1 SUCKLE ASS-r (3 REQ'D)
                                 •)	*«!70I LENS SING (2 REQ'D)
                                     _ 'NOSECUP ASST
                                      (SHOWN IN POSITION)
        Ultravue   Facepiece
         Pressure Demand Type, Complete
        U.S. Patent Hot. 3,323,135 and 3.348,537
    *4M19I
     LENS Rim
     REPLACEMENT KIT
                                                        UU9 SPEAKING DIAPHRAGM



                                                           • (MM GASKET
                                                                             • 96S72 INHALATION SPEAKING
                                                                                   DIAPHRAGM ASSEMBLY
   WII1J EXHALATION
        VALVE
         17 INHALATION
           SPEAKING DIAPHRAGM
           (SECTION VIEW)


           • MM1 DISC VALVE
                                                                          • MMt GASKET AND
                                                                                VALVE SPIDER
  441(64 EXHALATION VALVE
        ASS7 COMPLETE
                               It VALVE SEAT 12 REQ'O)
                                INHALATION
                                DISC VALVE
                                12 REQ'DI
        4J713S NOSECUPASS7
             lACCESJCHY ONin
NOTE:  This damp is to be
        checked and tightened
        prior to each  use of
        truSCB A.
' 37MI CLAMP



„ 73«l COUPLING
                                                                                                    - T340I BREATHING
                                                                                                         TUBE
                                                                                                         INSERT
                                              RPW-28

-------
                                                                                         DRAFT
                                     EXHIBIT RPW-7
       MSA AIR MASK MODEL 401 REMOVAL AND CLEANING PROCEDURE
Cleaning Instructions

General:  Moisture in the breath,  saliva, and perspira-
tion adhering to the valve create a bonding effect on
the valve which may cause it to stick on the first ex-
haled breath. The following procedure is recommended
to clean the valve on a periodic basis.

1. Remove the valve from the Ultravue* facepiece by
unscrewing the nut. Part Number 461610, inside the
facepiece with the special  wrench supplied with the
apparatus. Remove the valve from the Clearvue* face-
piece by removing the clamp, Part Number 57909.
   CAUTION: Whan performing the next step
   do not stretch or deform the spring which I*
   Inside the valve. Handle the sest spring and
   reive stem assembly  carefully.  DO  NOT
   scratch or nick the valve seats.
2. Disassemble the valve by removing the four screws
shown in figures 1  and 2 with the proper size screw-
driver.

3. Clean the valve seat and rubber flapper on the valve
stem assembly with a soft  cloth or soft bristle brush.
See  figures  3 and 4.  Use warm water and MSA*
Cleaner-Sanitizer, Part  Number 34337 (12 2 oz. pkgs.
per canon).  Add one  package (2 oz.) of powdered
Cleaner Sanitizer to a gallon  of warm water (about
120°F.).  It is not necessary to clean the compression
spring. Rinse parts thoroughly with warm clear water.
   CAUTION: Cleaning and sanitising at the re-
   commended 120"F temperature will avoid
   overheating and  distortion of parts  which
   would  necessitate replacement.
4. Dry all the parts by air drying or blowing clean dry
breathable compressed air over the parts.
             Flgura 1 — Rwnovlng 3cr««i»
                        BODY AND SEAT
                           VALVE STEM ASSY.
                                                                                          COVER
Figure 2 — DlMiMflibtod Vilv*
                                                     Flgura 3 — Body uid SMC
                                                     Flgura 4 — Rubbw Flappw
                                                      on V.tv»St«m AnvnMv
                                          RPW-29

-------
                                                                                             DRAFT

                                         EXHIBIT  RPW-7

 MSA AIR  MASK  MODEL 401 REMOVAL AND CLEANING  PROCEDURE (CONTINUED)
 5. Reassemble the valve by setting the valve body on
 a clean surface with the seat side up. see figure #5.
 Insert the stem of the valve stem assembly into the
 guide hole of the  body, set the spring in  place on the
 valve stem assembly and  insure that spring seats in
 the guide socket inside  the cover.  Install the four
 screws. The last one or two turns of the screws will
 have greater  resistance  to turning.  This is the self
 locking feature of the screw. Damaged screws should
 be discarded  and  replaced with new ones.
*6. Install  the valve  assembly in the facepiece and
 insure that the nut is firmly tightened.
 7. Don mask and test for leaks as per the  apparatus
 instructions.
 8. Before storage, the valve must be forced air dried.
 Do this by disconnecting  the breathing tube from the
 facepiece, hold the end of the tube over the exhalation
 valve inside the facepiece and  blow air through the
 valve, by opening the BY  PASS  valve slightly. Make
 sure  air passes through the  valve for about one-half
 minute.
 After Each Use:  The facepiece should  be  washed,
 rinsed and wiped  dry. Before the facepiece  is stored,
 the valve must be forced air dried as described in
 Step #8.  The purpose of this procedure is to  insure
 the valve is stored in a dry condition.
 Storage:  Store the mask in the  plastic bag  furnished
 with  the  apparatus.
       » Om Ultravm fan»Mca mil. Nr dam frapra tigkw 57901
 IMPORTANT NOTE: When you install the valve assem-
 bly  in the Ultravue facepiece (Step 6), it is  recom-
 mended that you  rub  a  small amount of Never-Seez
 compound (Part Number 29527)  on the threads of
' the  valve.
                       SOCKET TO HOLD SPRING
  COVER
Figun B —
                               VALVE STEM ASSY.
                                    GUIDE HOLE
                                                                                        Figure 6
                                            RPW-30

-------
                                                                          DRAFT
Most   respirator  manufacturers   market  their  own  cleaners/sanitizers   as   dry
mixtures of a  bactericidal agent and  a  mild detergent.   One-ounce  packets for
individual use and bulk packages  for quantity use are usually available.
Only a  trained person  with  proper tools and  replacement parts should  work on
respirators.   No  one  should  ever attempt  to  replace  components  or  to  make
adjustments or repairs  beyond the manufacturer's recommendations.   It may be
necessary  to  send  high-pressure-side  components  of  SCBAs  to  an  authorized
facility for repairs.

Repairs  should be made as follows:

     1.  Disassemble  and  hand   clean  pressure-demand  and   exhalation   valve
         assembly  (SCBAs  only).   Exercise  care to  avoid  damage  to  rubber
         diaphragm.

     2.  Replace  all faulty or  questionable  parts  or  assemblies.   Use  only parts
         specifically  designed for the particular respirator.

     3.  Re-assemble  entire  respirator,  visually inspect  completed  assembly, and
         test completed assembly to ensure proper operation.

     4.  Insert new  filters, cartridges,  or canisters, as required.   Make  sure that
         gaskets or seals  are in place and tightly sealed.

4.4   Storage

Follow manufacturer's  storage  instructions,  which  are always  furnished  with new
respirators  or  affixed  to  the  lid  of  the carrying case.   The  following  general
instructions may also be helpful:
                                    RPW-31

-------
                                                                     DRAFT
1.  After respirators have  been  inspected, cleaned,  and repaired, store them
   so  that  they are  protected  against  dust,  excessive  moisture,  damaging
   chemicals, extreme temperatures, and direct sunlight.

2.  Do not store respirators in clothes lockers, bench drawers,  or tool boxes.
   Place them in a sealed bag,  wall  compartments at work stations, or in  a
   work area designated  for emergency  equipment.   Store them in original
   carton or carrying case.

3.  Draw  clean  respirators from storage for each  use.    Each unit can be
   sealed  in a  plastic  bag, placed  in a  separate  box, and  tagged  for
   immediate use.

4.  Storage of SCBA units.  Check to ensure that

   a.  Cylinder is refilled  as necessary and unit is cleaned and inspected.

   b.  Cylinder valve is closed.

   c.  High-pressure hose connector is tight  on cylinder.

   d.  Pressure  is bled off high-pressure hose and regulator.

   e.  Bypass valve is closed.

   f.   Mainline valve is closed.

   g.  All straps  are completely loosened  and laid straight.

   h.  Facepiece is properly  stored to  protect against  dust,  sunlight, heat,
       extreme cold, excess moisture, and damaging chemicals.
                               RPW-32

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                                                                 DRAFT
                          PROTECTIVE CLOTHING
                               CONTENTS
SECTION                                                          PAGE

1.0      INTRODUCTION                                            PC-1

2.0      SKIN                                                     PC-1
2.1      STRUCTURE                                               PC-1
2.2      NATURAL DEFENSE                                         PC-3
2.3      ABSORPTION CHARACTERISTICS                              PC-3

3.0      CONSIDERATIONS FOR SELECTION OF                          PC-9
        PROTECTIVE CLOTHING

4.0      TYPES OF PROTECTIVE MATERIALS                            PC-10

5.0      CHARTS REFLECTING RESISTANCE OF MATERIALS                PC-11
        TO CHEMICAL DEGRADATION

6.0      TYPES OF PROTECTIVE CLOTHING                             PC-11

7.0      PROTECTIVE LEVELS                                        PC-13
7.1      LEVEL 1  DERMAL PROTECTION                                PC-13
7.2      LEVEL 2  DERMAL PROTECTION                                PC-14
7.3      LEVEL 3  DERMAL PROTECTION                                PC-15
7.4      LEVEL 4  DERMAL PROTECTION                                PC-15
                               EXHIBITS
NUMBER                                                          PAGE

PC-1    CROSS-SECTION OF HUMAN SKIN                             PC-2
PC-2    COMMON INDUSTRIAL METALS                               PC-6
PC-3    HAZARD OF COMMON METAL TREATMENT PROCESSES            PC-8
PC-4    CHEMICAL PROTECTION  OF CLOTHING MATERIALS BY             PC-12
        GENERIC CLASS
                                 PC-ii

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                                                                           DRAFT
1.0   INTRODUCTION

Protective clothing is  necessary  to  ensure the health  and safety of  field  personnel
involved with hazardous substances.  Specific protective garments are  selected on
the basis of a variety of criteria.  An overall  protective clothing scheme providing
various levels of protection is a  convenient means of selecting  protective clothing.
Levels A, B, and C are used to denote degrees of  respiratory  protection; In order to
distinguish  respiratory protection levels  from  protective clothing levels below  the
fully  encapsulating  suit,  this  training  module will  discuss  protective  clothing  in
terms of Levels  1, 2, 3, and 4.

2.0   SKIN

The skin is, in terms of weight, the largest single  organ of the  body. It provides  a
barrier between  the  environment and other organs (except the lungs  and eyes), and
therefore is a defense against many chemicals.   A cross-section of  human skin is
presented as Exhibit PC-1.

2.1   Structure

The skin consists  of the epidermis and the dermis.  In the dermis are sweat glands
and  ducts,  sebaceous glands, connective  tissue,  fat,  and  blood  vessels.   Hair
follicles  penetrate both  the  epidermis and  dermis.   Chemicals can  penetrate  the
epidermis, sweat glands, sebaceous  glands, or  hair follicles.

Although the follicles and glands  may permit a small amount of chemicals to enter
almost  immediately, most pass through the epidermis,  which constitutes  the  major
surface area.  The top layer is the  stratum  corneum, a thin cohesive membrane of
dead  surface skin.  This  layer turns over every two weeks by a complex process of
cell dehydration  and polymerizations of  intracellular material.  The epidermis plays
the critical  role  in  skin permeability, and abrasion  can  lower the  skin's  defenses
dramatically.  Below the epidermis  lies the  dermis, a collection of cells providing a
porous, watery,  nonselective diffusion medium.
                                      PC-1

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                                                                                                                        INJURED BY:
o
K>
                 Stratum    I Disjunctum
                 Corneum   «
                           [ Conjunctum
                 Stratum      Granulosum
                 Stratum      Spinsoum<—
                 Stratum      Germantivum
                 Sweat duct

                 Sebaceous1
                   gland
                 Sweat gland

                 Blood vessel

                 Connective tissue
                 Fat
                 Hair follicle

                 Capillary
Soap, solvents, alkalies, and
hot water.
Alkalies, detergents, solvents.
keratolytic chemicals, trauma,
and certain internal diseases.
                                                                                                                                               O
                                                                                                                                               •33
                                                                                                                                               O
                                                                                                                                               CO
                               w
                               !H
                               S?
                               c  -
                               2
C/i
S
Z
                                                                                                                Trauma (physical, mechanical.
                                                                                                                chemical) and internal diseases.
                                         O
                                         3D

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                                                                           DRAFT




2.2   Natural Defenses






Intact skin  has a number of natural defenses:






      1.  Epidermis






         Prevents  absorption of chemicals and is a  physical barrier to bacteria.






      2.  Sebaceous glands






         Secrete fatty acids that are bacteriostatic and fungistatic.






      3.  Melanocytes (skin pigment)






         Prevent damage from ultraviolet radiation in  sunlight.






      4.  Sweat Glands






         Regulate  heat,






      5.  Connective Tissue






         Provides  elasticity against trauma.






      6.  Lymph-blood System






         Provides  immunologic  responses to  infection.






2.3   Absorption Characteristics






The ability  of skin  to  absorb foreign substances depends on:






      1.  Properties and health of skin.






                                      PC-3

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                                                                           DRAFT
      2.  Chemical properties  of the substances.
      3.  Environment (vehicle).

Absorption is enhanced by:

      1.  Breaking top layer of skin.

      2.  Increasing water  content  of skin.

      3.  Increasing temperature of skin, which

         a.   Causes  sweat cells to  open  up  and  secrete sweat, which  dissolves
             solids.

         b.   Causes more  blood to flow to the skin.

      4.  Increasing concentrations of the substance.

      5.  Altering skin's normal pH  of five.

      6.  Decreasing  particle size  of  substance, thereby increasing the  amount  of a
         chemical (absorbed to the paniculate) delivered  to the site  as the  number
         of particles  increases.

      7.  Adding surface-active agents  or organic chemicals.  Solvents  for example.
         can act as a carrier of the substance.

      8.  Inducing ion movement by an  electrical charge.

Absorption of a  toxic chemical through  the  skin can lead to:

      1.  Local effects such as irritation and necrosis.
      2.  Systemic effects.

                                      PC-4

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                                                                           DRAFT
Many chemicals  can cause  a reaction  with the skin resulting  in  an inflammation
called dermatitis.  These chemicals can be divided into three categories:

      1.  Primary Irritants

         Act directly on normal  skin at the  site of contact  if  the chemical  is  in
         sufficient  quantity for a  sufficient length  of  time.   Skin  irritants  include
         acetone,  benzyl  chloride,  carbon   disulfide,   chloroform,   chromic  acid,
         other  soluble   chromium  compounds,  ethylene oxide,  hydrogen chloride,
         iodine,  methyl  ethyl ketone,  mercury,  phenol, phosgene,  styrene,  sulfur
         dioxide, picric acid, toluene, and xylene.

     2.  Photosensitizers

         Increase  sensitivity   to  light,   which  results  in  irritation  and redness.
         Photosensitizers   include   tetracyclines,   acridine,  creosote,   pyridine,
         furfural, and naphtha.

     3.  Allergic Sensitizers

         Produce  allergic-type  reaction  after  repeated  contact.    They   include
         formaldehyde,   phthalic   anhydride,   ammonia,   mercury,  nitrobenzene,
         toluene diisocyanate,  chromic  acid  and  chromates, cobalt, and  benzoyl
         peroxide.

Exhibit PC-2 lists industrial metals that may be of serious  consequences if contact
with the  skin  occurs.   The  hazards  of specific  metal treatment  processes are
presented in Exhibit PC-3.
                                       PC-5

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DRAFT
                        EXHIBIT PC-2. COMMON INDUSTRIAL METALS
                                      (SHEET 1 OF 2)
     Metal
Skin  Irritant
  Allergic
Sensitizer
Comments
     Aluminum     Yes, the soluble
                   aluminum  salts (ace-
                   tates and fluorides)
                   and aluminum
                   chlorhydroxide

     Antimony     Yes, antimony
                   trioxide, anti-
                   mony trifluoride
                   and andimony
                   trichloride

     Arsenic       Yes, arsenic
                   trioxide which  is
                   enhanced  by moisture

     Beryllium      Yes, possible
                   irritant
     Chromium     Yes,  most chro-
                   mates - character-
                   istic  lesion the
                   "chrome hole".
                     Yes, aluminum
                     chloride
                      None reported
                      None reported
                     None reported
                        Metallic aluminum and
                        insoluble compounds
                        considered nontoxic
                        Chief hazard is
                        chronic granulom-
                        atous disease of
                        the lungs.
                     Yes, hexavalent
                     chromium compounds -
                     chromium trichloride,
                     chromium chloride,
                     sodium dichromate,
                     potassium
                     dichromate
     Cobalt        Yes,  metallic
                   cobalt dust

     Copper        Yes,  concentrated
                   copper salts -
                   sulfates, oxides
                   and cyanides
                      Yes
                      None reported
                                           PC-6

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                                                                        DRAFT
                   EXHIBIT PC-2.  COMMON INDUSTRIAL METALS
                                 (SHEET 2 OF 2)
Metal
  Skin Irritant
  Allergic
Sensitizer
Comments
Mercury
Nickel
Yes, mercuric
salts and organic
mercurials.
None reported
Phosphorous   Yes, white, or
              yellow phosphorous
  Yes, mercuric salts,
  and organic mercurials.
  Most common are  mercury
  bichloride and ammoniated
  mercury
Zinc
Yes, zinc chloride
  Yes
                       None reported
  Rare sensitizer
                       Red or Black phosphorous
                       does not cause dermatitis.
                                     PC-7

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                                                                           DRAFT
                                  EXHIBIT PC-3

               HAZARD OF COMMON METAL TREATMENT PROCESSES
    Metal Treatment
           Hazards that May Injure the Skin
Anodizing


Electroplating
Forging and iron
working

Foundry operations
Galvanizing

Grinding, polishing,
buffing
Metal cleaning


Metal inspection




Soldering




Welding
Exposure  to  acid and acid  bath mist (chromic,  sulfuric,
or oxalic).

Exposure  to  acid mist  (chromic)  and contact allergens:
nickel, chromates, and cobalt.
Exposure to high temperatures and infrared.

Exposure  to  excessive heat,  possible  reaction to resin
used to bond sand.

Exposure to strong irritant:  zinc chloride
Exposure  to  cutting  oils  and  coolants  skin  may  be
abraded,  phenolic   resin   binding   agents  may   be
sensitizers.

Exposure  to  corrosive  agents, some  of which are also
sensitizers, exposure to degreasing solvents.

Exposure  to  solvents,  fluorescent  dyes  may  sensitize
and  possible  photodermatitis  from  prolonged exposure
to black  light and contact  with  substances  such  as
germicidal agents  in soap.

Exposure  to  irritants:   zinc  chloride  and  hydrochloric
acids;   allergic   sensitizers:     rosin,  turpentine   and
hydrazine compounds.    In  silver:    soldering possible
exposure  to corrosives.

Fumes   of   various   metals  may   cause  dermatitis,
ultraviolet exposure.
                                       PC-8

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                                                                         DRAFT
3.0    CONSIDERATIONS  FOR SELECTION OF PROTECTIVE CLOTHING

The  choice of  protective clothing  is a  function  of hazard  potential and  task
requirements.  The following factors are taken  into consideration:

      1.  Performance Requirements

         Clothing must  be able to withstand  a variety  of  physical abuses.  The
         advantages and disadvantages of disposable versus  reusable clothing must
         be considered,

      2.  Construction Requirements

         The construction requirements of any garment depend on the intended use
         of  the  garment.   The material that  the garment is made  of  is selected
         because of its  effectiveness as a barrier against  specific hazards—there is
         no such thing as "universal" protection.

         a.  The  physical construction  of  the  garment must prevent  penetration
            (e.g., location of seams and zippers, size of clothing).

         b.  The  material  that  the   garment   is  constructed  of  must   resist
            penetration   at the  molecular level.   In  many   instances,  it may  be
            necessary  to  layer  protective   clothing  to  achieve  the  desired
            protection.

      3.  Permeation Rate

         Permeation rate  is  affected  by a  combination  of  the base material,  the
         nature of the chemicals to which the material is  exposed, and the duration
         and nature of exposure.  Most materials allow some degree of permeation.
                                     PC-9

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                                                                        DRAFT
     4.  Ease and Cost of Decontamination

         Considerations that should be  made  upon  purchasing  garments are the
         ability and degree  to which the garment can  be  decontaminated and the
         cost of  decontamination.   Disposable  clothing may be advantageous  in
         some situations; however,  such clothing is rather expensive  in the long
         run.   In  most  instances, field  personnel will  use  a  combination   of
         disposable and reusable clothing.

4.0  TYPES OF PROTECTIVE MATERIALS

The following materials are generally available for a variety  of garments:

      1.  Cellulose or paper

     2.  Natural and synthetic fabrics

         a.  Tyvek
         b.  Nomex

     3.  Elastomers

         a.  Polyethylene
         b.  Saran-Dow-Product
         c.  Polyvinyl chloride
         d.  Neoprene
         e.  Butyl rubber
         f.  Chlorapel
         g.  Viton
                                     PC-10

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                                                                         DRAFT
5.0   CHARTS REFLECTING RESISTANCE OF MATERIALS
      TO CHEMICAL DEGRADATION

Charts  are   available  which  indicate  the  effectiveness  of  materials  to  resist
degradation   (Exhibit PC-4).    Note that degradation  is  not  an  indication  of the
material's permeability.

6.0   TYPES OF PROTECTIVE CLOTHING

The selection of appropriate gear is based on the level of protection  needed.   The
following gear forms the basis of the protective clothing scheme.

      1.  Hard Hats

         Regulated   by  29   CFR   1910.135;   specified  in  ANSI  Z89.1,  Safety
         Requirements for Industrial Head Protection  (1969).

      2.  Face Shields and Safety Glasses

         Regulated  by 29 CFR 1910.133(a); specified in ANSI  Z87.1, Eye and  Face
         Protection  (1968).

      3.  Foot Protection

         Regulated  by  29  CFR  1910.136; specified  in  ANSI Z41.1, Safety  Toe
         Footwear (1967).

      4.  Hand Protection

         Not specifically regulated.
                                     PC-11

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                                                                      DRAFT
               EXHIBIT PC-4.  CHEMICAL PROTECTION OF CLOTHING
                         MATERIALS BY GENERIC CLASS
Generic Class
Alcohols
Aldehydes
Amines
Esters
Ethers
Fuels
Halogenated
hydrocarbons
Hydrocarbons
Inorganic acids
Inorganic bases
and salts
Ketones
Natural fats
and oils
Organic acids
Butyl
Rubber
E
E-G
E-F
G-F
G-F
F-P

G-P
F-P
G-F

E
E

G-F
E
Polyvinyl
Chloride
E
G-F
G-F
P
G
G-P

G-P
F
E

E
P

G
E
Neoprene
E
E-G
E-G
G
E-G
E-G

G-F
G-F
E-G

E
G-F

E-G
E
Natural
Rubber
E
E-F
G-F
F-P
G-F
F-P

F-P
F-P
F-P

E
E-F

G-F
E
Key:  E, excellent; F, fair; G, good; P, poor.

Source:     "Survey  of  Personnel Protective Clothing  and  Respiratory  Apparata.
           September 1974, DOT, USCG, Office of Research and Development.
                                   PC-12

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                                                                           DRAFT
      5.  Respiratory Protection

         Regulated by 29  CFR  1910.134;  specified  in  ANSI  Z88.Z,  Standards  for
         Respiratory Protection (1976).

      6.  Overall  body protection  (e.g.,  fully  encapsulating  suits,  aprons).    Not
         specifically regulated.

7.0   PROTECTIVE LEVELS

7.1   Level 1 Dermal Protection

Level  1 dermal  protection (a fully encapsulating  suit)  is  used when percutaneous
hazards exist or when there  is no  known data that positively rule out percutaneous
hazards.    Since  Level  1   dermal  protection  is  extremely  physiologically  and
psychologically  stressful, the  decision  to use  this  protection must be  carefully
considered.  The following conditions suggest a need  for Level 1 dermal protection:

      1.  Confined facilities where probability of skin contact is high.

      2.  Sites containing known  percutaneous hazards.

      3.  Sites with no established  history to rule out  percutaneous hazards.

      4.  Atmosphere  immediately  dangerous   to  life   and   health,   either   via
         inhalation or  skin absorption route.

      5.  Site  exhibiting  signs  of acute  mammalian toxicity  (e.g.,  dead  animals,
         illnesses associated with  past entry into site by humans).

      6.  Sites at which sealed drums of unknown  material must be  opened.
                                      PC-13

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                                                                          DRAFT
The following  items  constitute  Level 1 dermal protection:

      •  Totally encapsulating  suit
      •  Gloves,  inner (surgical type)
      •  Gloves,  outer, chemical  protective
      •  Boots, chemical protective, steel toe and shank
      •  Radiation detector
      •  Thermal-luminescent  dose (TLD) badge
      •  Communications

7.2   Level 2 Dermal Protection

The  Site Manager must select Level 2 dermal protection when the highest  level of
respiratory  protection  is  needed,  but  hazardous  material  exposure to  the  few
unprotected areas of the body  (i.e., the back of the neck) is  unlikely.

Personal Protective Equipment  for Level 2  includes:
      •  Chemical protective

         -  Overalls  and  long-sleeved jacket
         -  Coveralls

      •  Gloves,  inner (surgical type)

      •  Gloves,  outer, chemical  protective

      •  Boots, chemical  protective, steel toe and shank

      •  Radiation detector
                                     PC-14

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                                                                          DRAFT
      •  TLD badge

      •  Communications optional

7.3   Level 3 Dermal Protection

Level 3 is the basic work uniform.

Personal  Protective Equipment for Level 3 includes:

      •  Coveralls
      •  Safety boots/shoes
      •  Safety glasses
      •  Hard hat with optional faceshield
      •  Radiation detector
      •  TLD badge

7.4   Level 4 Dermal Protection

Level 4 dermal  protection is used when radioactivity above 10 mr/hr is obtained on
a hazardous waste site.  Procedure is to immediately evacuate to a safe distance (2
mr/hr level).  Radiological safety experts  must be consulted to determine adequate
safety and  sampling  equipment,  protective  gear,  monitoring  methods,  handling
procedures, and remedial options.

Personal  Protective Equipment for Level 4 typically includes:

      •  Coveralls
      •  Air purifying respirator
      •  Time limits on exposure
      •  Appropriate dermal protection  for type of radiation present
      •  Radiation dosage monitoring
                                     PC-15

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12

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                                                                DRAFT

                        EQUIPMENT OPERATIONS

                              CONTENTS



SECTION                                                          PAGE

1.0      OBJECTIVE                                                 EO-1

2.0      EXERCISE: USING AIR MONITORING INSTRUMENTS                 EO-1
2.1      OBJECTIVE OF EXERCISE:                                     EO-1
2.2      EXERCISE PROCEDURE                                       EO-1
2.2.1     STATION  1: RADIATION SURVEY INSTRUMENTS                    EO-1
2.2.2     STATION  2: OXYGEN AND COMBUSTIBLE GAS                     EO-2
        INDICATORS
2.2.3     STATION  3: COLORIMETRIC TUBES AND PUMPS                    EO-2
2.2.4     STATION  4: ORGANIC VAPOR DETECTORS                        EO-2

3.0      DRAEGER TUBE AIR GRAB SAMPLER                            EO-4
3.1      GENERAL DESCRIPTION AND APPLICATION                        EO-4
        OF THE INSTRUMENT
3.2      OPERATION OF THE INSTRUMENT                               EO-5
3.3      LIMITATION AND WARNINGS                                   EO-6

4.0      MSA MODEL 260 COMBUSTIBLE GAS/OXYGEN ALARM              EO-7
4.1      GENERAL DESCRIPTION AND APPLICATION OF THE                 EO-7
        INSTRUMENT
4.2      CALIBRATION                                               EO-8
4.3      OPERATION                                                 EO-8
4.4      LIMITATIONS AND WARNINGS                                  EO-9
4.5      STANDARD OPERATING PROCEDURE                            EO-10

5.0      DREAGER-ECOLYZER COMBUSTIBLE GAS/OXYGEN MONITOR         EO-11
5.1      GENERAL DESCRIPTION AND APPLICATION OF THE                 EO-11
        INSTRUMENT
5.2      CALIBRATION                                               EO-11
5.3      OPERATION                                                 EO-12
5.4      LIMITATIONS AND WARNINGS                                  EO-13
5.5      STANDARD OPERATING PROCEDURE                            EO-14

6.0      VICTOREEN MODEL 490 THYAC III  SURVEY METER                 EO-15
6.1      GENERAL DESCRIPTION                                       EO-15
6.2      USE AND OPERATION                                        EO-15
6.3      MAINTENANCE                                             EO-16
                                 EO-ii

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                                                                 DRAFT

                         EQUIPMENT OPERATIONS

                         (CONTENTS CONTINUED)



SECTION                                                          PAGE

7.0      SOLAR ELECTRONICS RADIATION ALERT-MINI                    EO-16
7.1      GENERAL DESCRIPTION                                      EO-16
7.2      USE AND OPERATION                                        EO-16
7.3      MAINTENANCE                                              EO-17
                                 EO-iii

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                                                                          DRAFT
1.0   OBJECTIVE

The  student  becomes acquainted with  use  of and  problems associated with  the
operation  of site monitoring instruments.

2.0   EXERCISE: USING AIR MONITORING INSTRUMENTS

2.1   Objective of Exercise

The  participants  operate several  air monitoring instruments and interpret the data
generated.

2.2   Exercise Procedure

The  exercise has been  divided  into four stations.  The  instructor  will move with
each  group  of  students  from   station to   station  explaining  the  instruments
operations and limitations.  The group  will then be split into teams of two students
each.  Each team will be responsible for taking readings with the instruments from
radioactive sources,  unknown  atmospheres contained  in gas sampling  bags,  spiked
soil and water samples,  and completing the answer sheet provided.

2.2.1    Station 1:  Radiation Survey Instruments

At the station, there  are numbered  radioactive sources  that  may emit alpha, beta,
gamma, or a  combination of radiation.

Using  the equipment provided,  identify  the  type of radiation  and  the intensity.
Record your results on the answer sheet provided.
                                      EO-1

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                                                                         DRAFT
2.2.2    Station 2:  Oxygen and Combustible Gas Indicators

Three  gas sampling  bags contain mixtures of flammable gas/vapors  in  different
concentrations of oxygen.  Sample each bag with  each of the instruments provided.
Record the results on the answer sheet.

2.2.3    Station 3:  Colorimetric Tubes and Pumps

Two  gas  sampling  bags  contain  mixtures of toluene  and ethanol.    Using  the
colorimetric  indicator tubes  and  pump, measure the  concentrations  and record
them  on the  answer sheet.

2.2.4    Station 4:  Organic Vapor Detectors

At  this station,  a   Century  Organic  Vapor Analyzer  (OVA), and a  HNU  system
photoionizer  (HNU),  are provided.   One  gas sampling  bag, two  spiked  sample jars,
and one VOA vile and a gas-tight syringe are  provided.  Each pair of students will
be required to operate and record the concentrations of gases/vapors  in the bag and
head spaces.

2.2.4.1     Procedure for Operation of  the HNU PI 101

(1)    Before  attaching the  probe, check  the function switch on the control  panel to
      make sure it is  in the off position.   Attach the probe by plugging in the 12 pin
      plug to the interface  on  the readout module.

(2)   Turn  the six  position function  switch to the battery  check  position.   The
      needle  on the  meter  should  read within or above  the green  battery arc on the
      scale.   If not,  recharge  the  battery.   If the  red indicator light  comes on, the
      battery should  be recharged.
                                     EO-2

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                                                                        DRAFT
(3)   Turn the function switch to any range  setting.  Do not stare into the the end
     of the probe for any length of time as UV light can damage your eyes.   The
     instrument is now ready for operation.

(4)   To zero the instrument, turn the function switch  to the standby position and
     rotate  the zero potentiometer until the meter  reads zero.   Clockwise rotation
     of the span  pot  produces  a  downscale  deflection  while  counter clockwise
     rotations yields an upscale  deflection.

     Note:  No zero gas  is needed since this  is an electronic zero adjustment.  If
     the span adjustment setting is changed after the  zero  is set, the zero should
     be rechecked and adjusted,  if necessary. Wait 15 to 20  seconds to  ensure that
     the zero reading is stable.  If necessary, readjust the zero.

2.2.4.2     Procedure for Operation of the OVA

The following is the procedure  for using the OVA (Model 128) in the survey mode as
a portable total  hydrocarbon analyzer.

;1)   Assemble   the  instrument  by  connecting the  Probe/Readout  connectors
     (electrical   and Swagelock)  to   the  Side  Pack  Assembly.    Connect  the
     appropriate probe to the Probe/Readout Assembly.

 2)   Turn the PUMP switch ON and  leak-check the flow system by plugging the
     end  of the  probe momentarily.  The  SAMPLE FLOW  RATE  indicator should
     drop to zero. Turn PUMP switch OFF.

 3)   Move INSTR switch  ON and allow 5 minutes for warmup.

 4)   Turn PUMP switch ON and verify that the  battery is charged.

 5)   Check  SAMPLE FLOW RATE  indicator for proper flow.
                                     EO-3

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                                                                        DRAFT
(6)    Set  CALIBRATE  switch  to X10;  use CALIBRATE knob and  set meter  to  read
      0.

(7)    Place BACKFLUSH and INJECT valves in UP position.

(8)    Open H2 TANK VALVE and H2 SUPPLY VALVE.

(9)    Depress IGNITER  button.   If unit  is in proper working  order, the  FID  will
      ignite in 1  to 6 seconds.  Do not depress the button longer than 6 seconds. If
      the  instrument does  not  light, allow  the unit to run for several minutes  and
      repeat ignition.

NOTE: It  is  especially  important the the  INJECT  VALVE be in the  UP  position.
When  this valve  is in the DOWN position,  ambient air  is  directed through  the
activated  charcoal filter  before  going  to  the  detector.   Consequently,  many
volatile contaminants  would   be  "scrubbed  out,"  and the  OVA  would   indicate
background levels unless methane was the  primary contaminant.

Following  is the  shut-down procedure:

(1)    Close H2 SUPPLY VALVE  and H2  TANK VALVE (Don't overtighten valves).

(2)    Turn INSTR switch OFF.

(3)    Wait 10 seconds and turn PUMP  switch OFF.

3.0    DRAEGER TUBE AIR GRAB SAMPLER

3.1    General Description and Application of the Instrument

The  Draeger  tube air  grab  sampler  consists  of  a bellows  pump for  drawing air
through detector tubes that are chosen depending on the  material to  be identified.
The  detector tubes are available for  a variety of gases and  concentration ranges.

                                     EO-4

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                                                                         DRAFT
"he  use  of the tubes may be best described as a semi-quantitative method.  There
ire detector tubes available for  gases that are not detected  by the  organic vapor
nalyzer  and that would  actually react with  the  filament of  the  explosimeter  and
ixygen  indicator.    Examples   include  hydrogen  sulfide,  sulfur dioxide,  sulfur
rioxide,  hydrogen chloride,  hydrogen cyanide  and chlorine.  The presence of any of
hese would  obviously affect the level of protection needed on the site.  However,
here must  be sufficient  background  information to determine the  identity of  the
ubstances so that the proper tube could be selected.

'he  test is  performed by drawing air through  the  detector tube and observing  a
olor change or stain in the tube. Scale markings on the tube enable  determination
f subsurface concentration.

.2   Operation of the Instrument

Jthough the operating principles are  quite  simple, the operator's technique must
e correct to be effective.

1)    Break  off  both tips  of  the Draeger tube  in the  break-off  eyelet  or in  the
     break-off husk.

I)    Insert the tube tightly into  the pump head with the arrow pointing toward  the
     pump.

3)    Fully compress the bellows.

I)    Straighten the  fingers.  The suction process takes  place automatically and  is
     completed when the limit chain  is taut.   (The bellows is calibrated to draw  in
     100 cm3 of air per  stroke.   Since the suction  of the pump is caused only by
     the relaxation of the springs, any subjective  influence is  excluded.)

5)    Repeat the  suction  process  as often  as  specified  in  the Tube  Operating
     Instructions. (The nature of the tube filling  will  vary the resistance of the air
                                     EO-5

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                                                                         DRAFT
      coming through  the  tube, and the "opening time" of  the  bellows  is therefore
      affected.  The range of time is 3 to 40 sec).

(6)    Evaluate  the indication  on  the tube  as  described   in  the  tube  operating
      instructions.

(7)    Remove the spent tube and  properly dispose of it on the site.

(8)    Before  putting the bellows  pump away,  flush it out with uncontaminated air
      by making a few strokes without a detector tube in a clean environment.

3.3   Limitation and Warnings

The following principles are important in the correct use of the equipment:

(1)    Try  to  establish  from background information (interviews, etc.)  the  nature of
      the  site contaminants so that an intelligent selection  of a Draeger tube  may
      be made.

(2)    Relative standard deviation  can  range from 5 to 40 percent.

(3)    When drawing air into a  tube, keep your eyes on the  tube to note any  color
      change or stain  development.  For example, if you have selected  a  hydrogen
      sulfide  tube with a  sensitivity range of 0.5  to  1.5 ppm, requiring  10 strokes,
      and you  are  in  an  atmosphere  of much higher  concentration,  the  tube will
      quickly  become  fully  developed  after only one or two strokes.

(4)    Read the tube immediately on completion of the last stroke.   Elapsed time
      may affect the true reading.

(5)    Some tubes require  that an ampule within  the  tube  be  broken to  release a
      reagent before air is  drawn  through.
                                     EO-6

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                                                                         DRAFT
(6)    Because the tubes contain silica gel, high humidity may affect results.

(7)    Many types of tubes are also  sensitive  to  substances  other than the primary
      contaminant   and  will   therefore  give  incorrect  readings  in  atmospheres
      containing substances other than the gas for which the tube was developed.

4.0    MSA MODEL 260 COMBUSTIBLE GAS/OXYGEN ALARM

4.1    General Description  and  Application of the Instrument

The MSA  Model 260 Combustible Gas and Oxygen Alarm is a hand-carried, battery-
operated,  compact  instrument.  It has  been  designed  to  sample atmospheres  for
combustible  gases   or vapors  and  oxygen  content  and  warn  the  user  when
predetermined concentrations  of either are reached.

The  oxygen  and combustible  gas  indicators are  operated  simultaneously.   Each
indicator  has  an alarm warning light which  provides  a visual  alarm signal.   An
alarm signal on either unit will energize  an  audible alarm as well.  A  switch allows
the  audible alarm to be turned off if so  desired.  The alarm lights will stay on until
the  reset  button is pushed after  the  concentration  returns to  the  predetermined
level.

The oxygen  analyzer is a  galvanic  type  cell containing  dissimilar metal  electrodes
in a  special  electrolyte.  The  cell is sealed  with a membrane which  allows oxygen
to diffuse  into  the active  area. The  current generated by the cell is proportional to
the  oxygen partial pressure in the  atmospheric sample passing over the face of  the
membrane.  The generated current passes through a resistance to provide a voltage
input  signal  for an  amplifier.   The  output  of  the  amplifier   drives the  oxygen
indicating  meter and also  serves as an input to the alarm comparator circuitry.

The flammable  properties of combustible gases  are used as a basis  of detection for
the  combustible gas indicator.  The sensor consists of a pair of  pelletized filaments
called  "pelements"  arranged  in  an  electrically  balanced  bridge   circuit.     The
                                      EO-7

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                                                                         DRAFT
detector pelement  is  treated  with  a  special  catalyst.   The  catalyst causes  the
combustible gases to combine  with oxygen at much lower temperatures than would
be required for normal burning.  The inactive  compensator pelement is also exposed
to the  sample  flow  and  acts  to  offset any  electrical  changes  caused by  flow
conditions, sample temperature, pressure and/or humidity.

Combustible  gases  in  the sample  combine  with oxygen at  the  surface  of  the
catalyzed  detector  pelement.    Heat  is  liberated  by  this   chemical  reaction
increasing the temperature of this  pelement  causing an associated increase in  the
pelement electrical resistance.

Increased  resistance  of the detector  pelement  unbalances the  bridge  causing  a
voltage change  in the  mid-point connection between the detector pelement  and
compensating pelement. This voltage signal  is applied to an amplifier which drives
the  combustible  gas  indicating  meter and   provides  an  input  for  an   alarm
comparator circuit.

4.2   Calibration

To calibrate the instrument a small gas tank of known concentration is attached to
the inlet.  A  pot inside  the instrument  is then  adjusted with a screwdriver to bring
it into calibration.

4.3   Operation

The Model 260  should be checked and "zeroed" in  an uncontaminated atmosphere.
                                     EO-8

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                                                                         DRAFT
(1)   Open the  instrument  lid.   Turn  the  center ON-OFF control to the far right
     HORN-OFF position.   Both  meter pointers  will  move  and one  or both alarm
     lights may light.

(2)   If  the  percent oxygen meter  pointer  stabilizes at a  value other than 20.8
     percent,  the  pointer should  be set to  20.8  percent by using the CALIBRATE
     02 control.

(3)   The percent  LEL  meter pointer should  be set to zero  by adjusting the ZERO
     LEL control.

(4)   If either the alarm lights are lighted press the Alarm Reset button.

(5)   Momentarily  place  a  finger  over the  sample inlet  fitting or the  end  of the
     sample  line probe.  Observe that the flow indicator float drops  out of  sight
     indicating  no flow.  If  the float does  not drop, check out the flow system for
     leaks as described under Section  VII.

(6)   Press the  CHECK button  and  observe the percent LEL  meter.   The  pointer
     must read at  80  percent  LEL or  higher as marked  by  the BATTERY zone  on
     the meter.  If  the  pointer  reading is  less, the  batteries must  be recharged.
     No tests should be attempted as  the instrument  will not perform  properly.

(7)   If it is desired that the audible  alarm sound for combustible gas  or low  oxygen
     concentrations, turn the center ON-OFF control back one position to  the ON
     setting.

(8)   Accessory equipment  such  as  sampling lines, probes,  carrying harness, filters
     or line traps should be attached as required.

(9)   The instrument is ready for  atmospheric sampling.
                                     EO-9

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                                                                         DRAFT
4.4   Limitations and Warnings

It  is  important that the instrument response be  appraised  by someone skilled or
experienced  in  properly  interpreting  the  instrument  readings  with  respect  to
particular conditions,  on-going  operations and  safe  practices.   For  example,  an
atmosphere that shows no flammability hazard can still be toxic.

The  Model 260 is  designed to  measure combustible gas or vapor content in air.  It
will  not  indicate  the  combustible gas content in  an  inert gas background, furnace
stack or in a reducing  atmosphere.   Further, this instrument should not be  used
where the  oxygen  concentration exceeds  that  of  fresh  air  (oxygen  enriched
atmospheres).

Proper readings are obtained only when the battery has a sufficient level of charge.

(1)    The battery charge level  should  be checked  occasionally throughout a  testing
      period.

(2)    Upon  receiving  a  new  Model  260, it  is  recommended  that  the battery  be
      charged for at least 16 hours.

(3)    As  a  regular monthly maintenance  item for optimum  battery  service, the
      Model 260 should be run for 8 to 10 hours and then fully charged for 24 to 36
      hours.

(4)    After each day of  use  or if the  indicator has not been  used  for more than 7
      days, the battery should be charged for a minimum of 16 hours.

(5)    Do  not operate Model 260 while  it is charging.

(6)    Recharging  must  be  done  in a  non-hazardous  location,  known to be  free of
      combustible  gases or vapors.
                                     EO-10

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                                                                         DRAFT
4.5  Standard Operating Procedures

(1)   If the percentage of LEL is less than 10, complete the onsite inspection.

(2)   If  the  percentage of LEL  is between  10 and  25,  continue  onsite  inspection
     with extreme caution.

(3)   If the percentage of LEL is more than 25, withdraw from area immediately.

(4)   If the oxygen level  is less  than  19.5 percent,  continue the inspection with a
     self-contained  breathing  apparatus  (SCBA)  and identify the oxygen-deficient
     area.

(5)   If the  oxygen level  is more than  25  percent, discontinue inspection  in that
     area.

5.0  DREAGER-ECOLYZER COMBUSTIBLE GAS/OXYGEN MONITOR

5.1   General Description  and Application of  the Instrument

The  ECOLYZER  Combustible  Gas/Oxygen Monitor is  portable,  battery  powdered,
and designed to  monitor a work area continuously for at least 8 hours.  Audible  and
visual alarms  warn of the presence  of  combustible gases or  vapors  and  oxygen
deficiency.   They also  indicate  instrument  malfunctions.   The  meters  indicate
explosibility  in  terms  of  L.F.L  (Lower Flammability Limit)  and oxygen in percent
of one atmosphere.  L.F.L represents the lowest concentration  of gas  in  air which
can be ignited by a source of ignition and cause an explosion.

A  separate  audible  alarm is  also  provided  in  the  probe assembly for  remote
warning.   The unit also  features  a unique  security  "beep" which gives  an  audible
indication that the instrument  is operating.   An  internal control  is  provided to
adjust the volume  of the security "beep," or to turn it off if it is not desired.
                                     EO-11

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                                                                          DRAFT
The  instrument is  powered  by a rechargeable nickel-cadmium  battery pack which
provides more than  8 hours  of continuous operation,  and is  highly  reliable  and
economical to  maintain.

5.2   Calibration

The  oxygen analyzer  section of this instrument is calibrated by the operator to  20.9
percent in good  air.   Special  calibration  procedures are not necessary.   With the
Sensor Assembly  in   good  air,  calibrate  the  oxygen  meter  by rotating  the CAL
OXYGEN control  until the oxygen meter  indicates  exactly 20.9  percent oxygen, (
symbol on meter).

The  combustible gas  detector is calibrated at the  factory.   Meter indications are
given  in   terms  of  percent  LF.L.    The  abbreviations  L.F.L   stands  for  Lower
Fiammability Limit, and represents  the lowest  concentration of  gas in  air which
can  be ignited by a source  of ignition and cause an explosion.   L.F.L. is also called
the  Lower  Explosive  Limit  (LE.L).    Model 400  is  calibrated  before shipment to
indicate  directly  percent  L.F.L.  of  methane in  air.   The  L.F.L. of  methane is  5
percent by volume.  That is, a  concentration of 5 percent methane will  indicate 100
percent L.F.L.   Other  combustible gases  will  be indicated approximately correctly
in terms of explosibility.  However, for  maximum  accuracy, calibration curves for
various gases should  be used.

The  gas detector  section of  this  instrument requires  periodic  calibration  with  a
standard gas   sample.   With  the ECOLYZER  Calibration Kit  No. 60-460,  use the
following procedure:

(1)    Disassemble case by removing the five retaining screws.

(2)    Allow the instrument to warm  up for 15 minutes.

(3)    Assemble the calibration  gas tank and delivery  tube.
                                     EO-12

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                                                                         DRAFT
(4)    Carefully open the valve on the gas tank to bathe the sensor with just enough
      gas to cause the needle on the LF.L meter to move.

(5)    Adjust  the  LF.L.  CAL  control  until  the   percent  LF.L  meter  indicates
      exactly the correct LF.L as shown on the calibration gas cylinder.

5.3    Operation

(1)    Turn the power switch to the ON position.   Both meters  will  indicate.  Red,
      yellow, and green  lights with audible  alarms will activate briefly, indicating
      they are operable.

(2)    Allow  one  minute for warmup.  After one minute, the green light will come
      on  to indicate that  the unit  is ready to be  calibrated.  DO NOT CALIBRATE
      OR  ZERO   UNTIL   THE   GREEN   LIGHT  COMES  ON  (approximately   one
      minute).

(3)    With the Sensor Assembly in normal  atmospheric air, calibrate the  oxygen
      meter by rotating  the CAL.  OXYGEN control until the oxygen  meter reads
      exactly 20.9 percent  oxygen.  (
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                                                                         DRAFT
(6)    Place  the  probe  assembly  in the  environment to be  tested. If  an ALARM
      occurs (red light and wailing siren), personnel should LEAVE THE AREA.

(7)    If an  instrument malfunction occurs (yellow light and sinking audible tone),
      personnel should LEAVE THE AREA until the problem is corrected.

5.4   Limitations and  Warnings

The operational temperature range is -18° to 49°C (0 to 120°F.)

Prolonged exposure to tetraethyl  lead or  silicone  vapors causes poisoning  of  the
filaments.  Avoid leaded gasoline  and  silicone vapors.  Testing of the gas detector
element  should  be done  with  methane test gas.  An  element which responds  to
methane  will  respond to  other  combustibles.   Elements which  have reduced
sensitivity  or  do  not respond  to methane  are probably poisoned and  must  be
replaced.  The warning systems of the  No.  400 give no indication  of a  poisoned
filament.  To  detect  a  poisoned filament, the  operator  must test  it with methane
test gas.

Most  commonly  encountered   gases  will not  affect  or  interfere  with  accurate
readings of oxygen content when present in  normal  concentrations as  found  in
industrial  atmospheres. However, any gas permeable to the Teflon membrane and
which can be  reduced at 0.8 volts  may add to the meter readings to the  extent it is
present.   (Gases  such as  carbon  dioxide  do  not reduce at  0.8  volts and will  not
affect the sensor  regardless of concentration).   The following gases will interfere
when  present in unusually high  concentrations:  sulfur dioxide, fluorine, chlorine,
bromine, iodine,  and  oxides of  nitrogen.   No one  should enter a confined space in
which such  concentrations (as little as one quarter of a percent) of these gases  are
present without special respiratory protection.
                                     EO-14

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                                                                          DRAFT
5.5   Standard Operating Procedures

(1)    If the percentage of LEL is less than 10, complete the onsite inspection.

(2)    If the  percentage of LEL  is between 10  and 25,  continue onsite  inspection
      with extreme caution.

(3)    If the percentage of LEL is more than 25, withdraw from  area immediately.

(4)    If the  oxygen level  is less than  19.5 percent, continue  the inspection  with  a
      self-contained  breathing  apparatus  (SCBA) and identify the oxygen-deficient
      area.

(5)    If the  oxygen level  is  more than  25 percent, discontinue inspection in  that
      area.

6.0   VICTOREEN MODEL 490  THYAC III SURVEY METER

6.1    General  Description

The  Model  490 is  a pulse-count ratemeter and power  supply.  With  the pancake
detector  probe,  it  acts as a survey  meter  for alpha-beta-gamma  radiation.   Its
range  of  operation  is  0-80,000 cpm or 0-200  mREM/hr  approximate  radiation
intensity with  appropriate  detector.

6.2   Use and Operation

This instrument should be used only  by persons who have been trained  in the  proper
interpretation  of its readings and the  appropriate safety procedures  to be followed
in  the  presence  of  radiation.    Failure to  follow  instructions   may  result  in
inaccurate   readings  and/or  user  hazard.    Indicated   battery  and   operational
(checksource) tests   must be  performed before  each  use  to ensure  that  the
instrument  is functioning properly.  Failure to conduct  periodic performance tests
                                     EO-15

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                                                                          DRAFT
in accordance with ANSI N323-1978, paragraphs 4.6 and 5.4, and  to  keep records
thereof in accordance with paragraph  4.5  of  the  same standard,  could  result in
erroneous readings of potential danger.   Do not connect or disconnect any detector
while the instrument is on.  Wait 2 minutes after it  is turned  off before connecting
or disconnecting  any detector.   Transistor failure  will  occur  if these instructions
are not followed.

The  ratemeter is designed for  100 hours  of continuous use on two "D" cell batteries
and  longer  with  intermittent  use.   Trained  personnel are  required  to  interpret
readings.   Be  sure  to  read the instruction manual  before the  equipment is used.
The  instrument  is  in  a  weatherproof  case,  which  contains  the  two  operating
controls, the function switch and the response switch.

A low-intensity beta checksource is provided on the case.  Temperature limits are
30 to +50°C  (limits for batteries  may be different).  The checksource  may be used
with  a  headset  or an  audio  speaker.   It may  be  put  in  a plastic  bag,  when
appropriate, to prevent contamination.

6.3    Maintenance

The  instrument must  not be  stored with  the  batteries  inside.   Batteries  must  be
replaced as indicated  during the battery  check performed before each use, and  the
instrument should be recalibrated periodically.

7.0    SOLAR ELECTRONICS RADIATION ALERT-MINI

7.1    General Description

The  Radiation  Alert-Mini  is  a  miniature  ionizing-radiation  detector  with selectable
audible  alarms and LED  level indicators.  It is one  of  several  ultra-small  units that
can  be  carried conveniently in your pocket or clipped on  your belt for hands-free
operation.  It's range of operations is 0.1  mR/hr to 30 mR/hr.
                                     EO-16

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                                                                          DRAFT
7.2   Use and Operation

As  with all  geiger-counter-type instruments,  the Radiation Alert-Mini  (RAM) is
calibrated to  Cesium-137 gamma and  is not calibrated for other isotopes.  Its dose,
however, serves as a good relative indicator for other isotopes.  The RAM functions
with the left-hand switch in either the on or audio position.  In audio, you will hear
each  incoming geiger  count as  a beep or click.  Audible alarms will sound in both
the on  and the audio  positions at higher radiation levels.   The yellow  count light
displays  all incoming  geiger  counts.  Random  flashing of the count  light verifies
that the unit  is operating.  At lower elevations, the light will  normally display 10 to
20 random counts every minute  due  to natural background radiation.

The range  switch at the right  selects the  radiation  levels indicated by the  alarm
lights and audible alarm:

      •   In the XI  range, the left light  indicates  at  least 0.1 mR/hr and the  right
         alarm light indicates 0.3  mR/hr.  A two-second alarm tone sounds  every
         45 seconds above the 0.1 mR/hr range  in the X1 range.

      •   In  the  X10   range,  the   two  alarm   lights   indicate  1   and  3  mR/hr
         respectively.  In this range,  the  alarm tone sounds  above 1  mR/hr.

      •   In  the  X100  range, the  two  alarm  lights indicate 10  and  30  mR/hr
         respectively.  In this range,  the  alarm tone sounds  above 10 mR/hr.

If both the alarm  lights are lit  in one of the lower ranges, change  to the  next higher
range.

7.3   Maintenance

The RAM  remains calibrated  as  long as the count light is functioning.  The  9 volt
alkaline  battery  needs  replaced  when the  count  light  dims.  Battery  life is  up to
2,000  hours continuous use at normal background rates.
                                     EO-17

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                          EQUIPMENT OPERATIONS

                          EXERCISE ANSWER SHEET
Station 1
          Source
          Number
    Total
  Exposure
    Rate
   Type Of
  Emission
   O, 6,5)
Station 2
       Bag Number

            1

            2

            3
    0?%
    LEL%
Station 3
       Bag Number

            1

            2
Concentration
 Compound
Station 4
       Bag Number

            1

      Sample Number

            2

            3

            4
Concentration
    OVA
Concentration
    HNU

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13

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                              REPORT ON
                     ACME RECLAIMING CORPORATION

Acme  Reclaiming  Corporation  (ARC)  is  an  abandoned  hazardous  waste
facility, located near Nashville, Ohio.   In 1980,  a series  of citizen
complaints  led  the  State  Board  of  Health's   Division   of  Waste
Management  to identify  ARC  as  a  waste  facility.   The  complaints
stemmed from heavy  Spring rains  that  caused a severe   flood episode,
inundating two ARC  waste  lagoons that  were  situated on  the Minnesota
Creek flood plain.  Citizens  reported  that this occured  every 5  to 8
years, but could  not  explain why  they did  not  report  these  earlier
flooding  problems.    The  State  forced ARC to reinforce  the  lagoon
berms and to  increase their heights to  stabilize  the  structures  and
increase their freeboard.   In  a  later  action, the  state  required  the
installation  of  monitoring  wells  and  the  analysis   of  waters  from
these wells.   During  late  April  1980,   after  the well  installation
phase, the owners  of  ARC abandoned  the   facility  and  fled  the  state
without notifying the State Department of  Health  of their new mailing
addresses.

Site Description

A. Operational History

Operations  at the  site  were  initiated  by  the   Tar  Corporation  of
America  (TCA)  as a wood  treating  facility  in  1930.    TCA  utilized
creosote and other  coal tar by-products to preserve railroad ties and
other wood products such  as  foundation piles and  utility poles.   The
creosote and  coal  tar by-products  were produced  in New  Chicago  at a
coking facility and transferred  by truck  to ARC.   During  the course
of  operation,  TCA  installed  three  lagoons;  Lagoon #1 near  the  main
production  facility,  and Lagoons  #2  and #3  on   the  flood  plain  of
Minnesota Creek (see  Figure  1).   In  addition  to  the  lagoons,  TCA had
landfilled in a 20-foot deep sand pit  along the  southwestern boundary
of  the  site.   In  1957,   the  pit  was  filled with  by-products  and
covered with  asphalt  and  used as a parking area  for autos.   There are
no  records  of exactly  what was placed  in  landfill  or  the  amount.
Excluding the  access  road,  the   parking area  defines  the perimeter of
the  former  pit,   according  to   written  statements  of   former  TCA
employees.
                                   I

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A)/) stfvttt.tr, Off i&
      Li/mr$ OF

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The  facility  continued  operation  through  February 1974.    In  early
March  1974,  TCA ceased  operations  and dismantled  all  buildings  and
storage  tanks  with  the exception  of  the main  building.   In January
1975, TCA sold the property  to  ARC.   Although ARC  had  no  use for the
lagoons,  they purchased  the  complete  property  in  anticipation  of
future expansion and storage needs.

By  May  1975,  ARC  had  completed  the  remodeling  and  installation  of
distillation units and began accepting  solvents  for recycling.   Waste
solvents were received by bulk  tanker and in 55-gallon  drums.   Drums
of materials to be recycled  were  stored on the ground  in  an unstaged
manner,  while bulk  tanker  materials  were   stored in  old  railroad
tanker  cars  (minus wheel  assemblies)  on  the northeast side of  the
main building.  Still bottoms were also placed  in 55-gallon drums and
stored near  the  northeastern perimeter of  the  facility.   There  were
periodic complaints of odors  emanating from these  storage  areas,  but
by  the  time  the  local   Health Department   arrived,   there  were  no
lingering odors.   As  stated earlier,  the  conditions were  brought  to
the attention of the State after flooding  inundated lagoons #2  and  #3
during mid-March  1980.   During the subsequent  State  inspection,  the
State ordered ARC  to  improve  the  lagoon berms, develop  closure  plans
for  the  lagoons,  complete  a  bermed  concrete  pad   with an  overhead
covering for  the  storage  of  the drums, install  four monitoring  wells
around  the  drum storage  area,  and analyze  groundwater samples  from
the  shallow  aquifer.    ARC  completed  the berm  improvements and  the
monitoring well  installation by the  end  of  the  third  week  of  April
1980.  The owners reported  that the  lagoons would  fill  up  with  water
during rain storms but would dry up in  a matter  of  days.

During  the   final  week  of  April   1980,   the  owners  of  ARC  ceased
operations,  abandoned  the facility,   and  fled  the   State.   During May
1980,  the  state took  volatile  organic samples  from  the  four  wells,
results  of   which  are  presented  in  Table  I.    The  well  samples
indicated  the presence  of   1,1 dichloroethane,  1,2  dichloroethane,
TCE, benzene, acetone, xylene,  and ethyIbenzene.

In September  I960,  the owners  of  ARC were located  in Miami, Florida
and  the  State initiated   legal  action to force  them to clean  up the

-------
site.   In order  to  gain  additional  funds,  the owners of TCA were also
sued  to remediate  the  site.   As  a result  of  excessive  procedural
delays  and  legal  manipulation,  the  court wants additional sampling to
clarify  the  problems  at  the site.   The  responsible parties have indi-
cated  that  they  do not  feel  responsible  and  may not  be  around when
the  court  makes  its decision.  As  a result,  the USEPA and  the State
want  to pursue  this   facility  as   a  potential Superfund  site  as  of
September  1983.

B. Local Geology

Figure  2 is  a  map  depicting  the  area  which  surrounds the  site  and
includes  homes,  cities, waterways,  municipal  wells,   and  municipal
surface  water intakes.   The  whole  area is  located  on a Pleistocene
outwash  plain  composed  of  interbedded sand  and  sand/gravel  units.
Minnesota  Creek  is  incised through  the  Pleistocene  unit.   Underlying
this  surficial  unit   is  bedrock  where  the  uppermost  unit  is  lower
interbedded  shale and  shaly dolomitic limestone member at base of the
Platteville  Dolomite.    The Hartford River  cuts  all  the way  to  the
bedrock.   The  river   bed  consists  of  alluvium.    In  this  area,  the
Glenwood  Formation is  not  found   below the  Platteville.    The unit
below  the Platteville  which appears below is  the St. Peter Sandstone,
a  regional  aquifer.   The  bedrock  units have  a 1% dip  to  the  south-
east.

The  surficial  glacial  unit  has  a  variable  thickness, ranging from 15'
thick  in  the  valleys  to  35'  thick in the  adjoining  flat  plains.
Using well  drilling logs submitted  to  the State,  the Platteville has
been  identified  as  being 12  to 13 feet thick  in the  area.   The  St.
Peter has  a vertical  extent  in excess  of  250  feet.   No  wells  in the
area have  penetrated  to the  Shakopee Formation.   Drill  cores  of  the
Platteville  indicate   that  in  the  city of  New  Chicago  the unit  is
significantly  fractured,  although   this structural  feature was  not
identified  in Nashville where it  appears to  be an  unfractured  and
continuous unit.  However,  two wells in New  Bliss  Heights report  the
presence of  the  fractured Platteville Unit.

C. Populations and  Water Usage

Table 2  is  a summary  of populations  of the  various  cities  and towns
in the  area around the  ARC  facility.   Data  is  also  given  on  water
usage for both city and  rural residents.

                                   3

-------
NNIl.es

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TABLE 1
       SAMPLE RESULTS FROM
   ACME RECLAIMING CORPORATION
         NASHVILLE, OHIO

       Data in ug/1 or ppb
Parameter

1,1 dichloroethane
1,2 dichloroethane
benzene
TCE
ethylbenzene
acetone
xylene
                                       duplicate
well #1   well #2   well #3   well #4   Well #4   Blank
60
ND
25
40
26
ND
26
18
35
30
ND
21
ND
18
35
40
47
ND
15
ND
ND
38
19
200
ND
37
80
24
ND
17
ND
ND
35
ND
11
11.2
15.1
ND
10
12
ND
12

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TABLE 2
        MUNICIPALITY DESCRIPTIONS AND DEMOGRAPHIC  INFORMATION

Nashville  -  Located  approximately   one  (1)  mile   downstream of  the
ARC facility at  the  confluence of Little Detroit  Creek  and  Minnesota
Creek.  According to  the  1980  census,  268 people  reside  in  the  town.
The town derives all  its  drinking water from four  (4) small  diameter
rauncipal wells which are  screened in the St.  Peter Formation.

New  Chicago  -   Located   approximately  two   (2)  miles  northwest  of
the ARC facility along  Little  Detroit Creek.   According to  the  1980
census, 2,101 people  reside  in the   town.   The  town's drinking  water
is  provided  by  a  muncipal  system  which  obtains   water from Little
Detroit Creek and two  (2)  wells  screened in  the St.  Peter  Formation.
The water  system serves  the  total population of the  town and totally
integrates both sources into the  system.

New  New York  - Located   approximately  seven  (7)  miles  downstream
of  the  ARC  facility  at  the  confluence of  Minnesota Creek  and  the
Hartford River.  According to the  1980  census, 15,010  people  reside
in  the  city.   The  city obtains  its water  from Minnesota Creek  from
intakes 2.5 miles upstream of  the city's bordens.

Old  New Bedford -  Located  across  the  river  from  New  New  York.
According  to the 1980 census  10,171 people  reside in the city.   The
total population is  served by a  water  system which  is  obtained  from
four (4) high capacity wells screened in  the  St. Peter Formation.

New  Las Vegas  - Located  approximately 4.5  miles  east of  the  ARC
Facility.   According to  the  1980  census,  853  people  reside in the
town.   175 homes lie west of  the Hartford  River  and are served  by a
community  water system which  obtains  its  water  from  the   St.  Peter
Formation.  The  remaining  60  homes  are  located  east  of  the  river and
are also served by a system which draws  from  the St.  Peter.

New  Bliss  Heights  -  a  new housing   development  located  in  an
unincorported  area  south  of  the   ARC  Facility  and  southeast  of
Nashville.   The  homes  are situated  around  a recreational  area.   The
I 10 people obtain  their  water from wells  which  are  screened  in  the
surficial  glacial unit.
                                  5

-------
TABLE 2 - (Continued)

New  Hartford  -  Located  approximately  one-half  (1/2)   mile   down-
stream  from New  Las  Vegas  on  the  Hartford  River  is  New  Hartford.
This city  has  a  population  of  8,000,  according  to  the 1980 census.
The  total  population   is   served   by   high-capacity   shallow   wells
screened in the  surficial  glacial  unit.

Rural  Properties  -  There  are  numerous homes  scattered   throughout
the area and  all use  well water.   According  to  the State  Geological
Survey approximately 60% of  these  wells  are  screened  in the St.  Peter
with the remainder in  the  surficial  unit.

-------
                REPORT ON GOOD  EARTH  NUTRIENTS,  INC.

Good  Earth  Nutrients,   Inc.   (GEN),   a  manufacturer  of  fertilizer
additives,  is  located about  30 miles  west  of  Capital  City  in  Owl
Valley, New Mexico (Paso County).  The  site,  owned  by Ralph  Rooney of
Boise,  Idaho,  occupies   14.5  acres of  land  situated  in the  western
foothills of the Silver Mountains.  This  property  lies  on a  bench  one
mile east of State Highway  85 and is bordered  on  the north by  Bates
Valley Road, on the south and west by the Union  Pacific  Railroad,  and
on  the east  by  the  mountains.    GEN   is  located  about  1.5  miles
southeast of Settlers' Park,  a  subdivision housing approximately  500
residents.  There are two  wells located  about  one  mile  due west  and
downgradient of the site which  supply these homes  with  water.   There
are  approximately  a  dozen  additional  houses  on a  lower bench  about
one-half mile to the northwest.   Just 0.1 miles north of the  site is
Fazio's chicken feed operation.

From 1968 to 1977, GEN was  owned and  operated by Fixative Chemicals,
a fertilizer manufacturer in  Texas.   In June  1977, the  Bob  Recycling
Company purchased GEN from  Fixative  and has been operating  it on  and
off  since then.  As of January  1980, GEN  announced  plans to  close  due
to economic hardship.

Good Earth's  feed  stock is  emmission control  dust  generated  by  and
purchased from Allegheny Steel  of Dry Ridge,  Arizona;  Glyton Steel of
Nebraska, and Oreton, Utah; Midstate  Steel of California; and Apache
Steel  of  Montana and  Phoenix,  Arizona.    Good Earth   receives  this
waste  and  transports  their product  via  the  Union  Pacific  Railroad.
This dust contains high  zinc concentrations  and is  then  palletized,
bagged  and   sold  to  fertilizer  manufacturers  as   a  micronutrlent
additive.    After  processing,   if  the   product  does  not   meet  the
specifications  of  20  percent  zinc,   it  is then piled  on-site  as  a
waste.   These  wastes have  the  potential of   being  sold  to  other
companies  for  metal   reclamation.    In   the  past,   GEN  also  accepted
dried  electroplating  sludge  from Applications,  Inc.  This sludge  had
been mixed with sludge  from Saumur's  Stockpile Division prior  to  GEN
purchasing  it.   GEN orginally  purchased  this   sludge,   which   is
allegedly  nonhazardous,  with  the  hopes  of  extracting  nickel  and
tungsten from it;  however,   it remains piled on-site.

-------
GEN reported  storing  of  4,000 tons of dust in piles on-site annually.
Some  of  this  dust is their  raw  material and some  is  processed mate-
rial  which did  not  meet  their  final  product  specifications.   Good
Earth's  analysis  of  the  dust  showed  high  concentrations of  total
chromium,  lead  and cadmium.

In  May  1977,  Fixative Chemicals felt  they  might be  forced  to close
down  because  of poor  economic conditions and they proposed mixing the
waste on-site with lime  to fix  the metals  and  then  burying it.   This
disposal  method was  never used.   At  this time,  they  were cited with
numerous  violations  including  not  maintaining  records  or  required
plans  on-site,  and not  controlling  wind and water  erosion,  leachate
and runoff  from their  waste  piles.

In  June  1977, Good Earth  was sold to  Bob  Recycling.    At  this time,
they  planned  to extract  metals from the dust in addition to producing
the  fertilizer  additive.  This  process was  never  implemented.   They
were  again  cited  with  the  same violations as in May.

In  February 1979, the State sampled the  incoming  dust  and  the off-
spec  waste  piles.  Analysis  for total  metals  again  showed very high
levels of  chromium,  lead and cadmium.

Throughout  the  Fall  of  1979,  GEN  was cited  several  times with plans
and  records  violations,  as   well  as  noncompliance  with  storage  and
security  standards.   Although GEN attempted to  comply  and cooperate
with  the State  and EPA,  the  plans  they  submitted were inadequate.

In November 1979, GEN shut  down operations once again.   Finally,  in
January  1980,  they  informed  the  State  that  they  were  planning  to
close the  facility because they  could no longer afford to operate and
comply with the State's  hazardous  waste regulations.

According  to  Kyle Kerrick  of  the  State Department  of  Health,  the
wastes remaining  on-site include approximately 3,000 to 5,000 tons  of
both the unprocessed dust  and the  off-spec product.   Of these wastes,
1,000 tons  are  scheduled  to  be  sold to  Base  Metals  Corporation  of

-------
Moxie, Washington.   Caustic  Solutions,  Inc.  of Hanford,  California,
is  purchasing  400   tons  of  the  dust.    Margaret  Chemical  Company
appears to be a  potential  buyer  of GEN's waste sulfuric  acid.   After
these  are  sold,  the wastes  remaining  to  be resold  and disposed  of
include the Applications, Inc.,  residue  and  approximately 2,000 addi-
tional tons  of  the  dust  residue.   The  cost for  disposing of  these
wastes at National Waste Deposit,  Inc.  (NWDI),  located  about 50 miles
west of the site, is estimated at  $200,000.

On Wednesday, 16  February 1980,  State  representatives  Charles  Chang
and Cindy  Court,  accompanied by Chloe  Clump of EPA  Region VIII  and
Carl  Chorapers of  the  State  Department of  Health,  visited the  GEN
facility.  They were met on-site by David Dole  (GEN President),  Edwin
Eaders (GEN  Vice President),  and  Fred  Fling  (Paso  County  Planning
Director).

The State's trip report said there were  five  structures on  site:  one
office building; two round storage bins; a  rectangular  storage  build-
ing; and a building housing the pug  mill.   On  the east side,  there
was  a structure  housing  their  water  supply,   which  flowed  from  a
spring located south of the  site.  Along the  north  border,  there were
two  small  piles  of orange  colored  residue  from  Applications  Inc.
There  was  a  large  black  pile  of  unprocessed  dust  in  the  northwest
corner and two very  large piles  of off-spec  dust residue on the south
side.  All  the  waste piles  were uncovered and  there  appeared  to  be
both a wind and  water  erosion  problem.   The  surrounding land  surface
was  darkened  due to  the migration  of  these  wastes.    Several  dirt
piles  and   scrap  heaps  were  scattered on-site  near   the  southeast
section.    The  eastern  border  was  partially  fenced  and   berraed  to
prevent  water coming  down  off  the  foothills  from running over  the
property.  There was also a  dirt berra along  the west  side between the
site  and  the  railroad; however, there  was  no  fence   posted on this
side.  There  were about  30  drums stored in  the  northeast corner,  six
containing  the  Applications  residue and  the  rest   containing  caustic
soda solution.

-------
/TV^ ^j^ ;	j'Vy Capprx^^oit boorjdarics ) j
// / Si ' ' » V iJ>VVfe '•     I -"
                    ecology and environment, inc.
                                               , CO
               i.^rtlfl : .   U5CAL.   ' • Topo Hop
                              -7-6  FW.O. Jo-its

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ecology and environment, inc.
HlOS  Cavt Flor.io.xAvt,

-------
ecology and environment, inc.
"110*3 £ofct Fhy.du AV
-------
%  / / *•« *  \
            IDEALIZED CROSS-SECTION
                      AT
            GOOO CARTH fi
                   vA_tey MM
           Ecology & Environirent  Feb.  1984

           From Gates (1962)

-------
   DIRECTION OF GROUNOWATER FLOW
Ecology 4 Environment
From Gates (1962)

-------
                                 POTENTIAL HAZARDOUS WASTE SITE
                                     PRELIMINARY ASSESSMENT
                               PART 1 • SITE INFORMATION AND ASSESSMENT
                                                                               I. IDENTIFICATION
                                             01 STATE;
                                               NM
                                                                                      Dlllllllll
 II. SITE NAME AND LOCATION
01 SITE NAME LW «

   Good Earth  Nutrients, Inc.
                                                  02 STBEET ROUTE NO OR SPECIFIC LOCATION IDENTIFIER
                                                     Bat's Canyon  Road
03 CITY
   Owl Valley
                                                  04 STATE
                                                   NM
                                                        05 ZIP CODE
                                                        00000
                                 06 COUNTY
                                  Paso
                     • c o j*>
                     root
                     99
                                                                                               99
09 COORDINATES  LATITUDE
      98 7  6  5 A 3
                                 LONGITUDE
                            34567890
i0 DIRECTIONS TO SITE siting ir0m *„,»,.• Dlrf
   North on  Hwy 92  to County Road  13  (Bat'-s  Canyon Rd.) .   Turn right and 3.265 miles
   further is the  site.   Entrance  on  left.
 Ml. RESPONSIBLE PARTIES
01 OWNER >•.««»«
   Ed  Eaders,  Vice  President
                                                   231 Eagle's  Nest Road
03 CITY
   Owl Valley
                                                 04 STATE
                                                   NM
                       05 ZIP CODE
                         00000
Of TELEPHONE NUMBER
999 illl-llll
37 OPERATOR (H«no»n wxj gtfit'fni iiorf o
                                                  10 STATE II ZIP CODE
                                                                    1 2 TELEPHONE NUMBER

                                                                    (     I
 3 TYPE OF OWNERSHIP.c«.f.
BY icice* «r '*•( wo'r'
C A EPA     C B EPA CONTRACTOR      ~ C STATE
C E LOCAL HEALTH OFFICIAL   C F OTHER  _
                                                                             D 0 OTHER CONTRACTOR
                                 CONTRACTOR NAMElSI
02 SITE STATUS rO-cio™

   D A ACTIVE f. B INACTIVE
                        O C UNKNOWN
                                      03 YEARS OF OPERATION
                                                1971
                             1980
                                                                             D UNKNOWN
 04 DESCRIPTION Of SUBSTANCES POSSIBLY PRESENT KNOWN OR ALLEGED
                                              Unprotected storage  piles  of flue dust from
   electrostatic precipators containing heavy metals.   Flue  dust is a  designated
   hazardous  waste  (K061)  from  steel  production  facilities.   Sulfuric  acid  and caustic
   are  also known  to be  present,
 05 DESCRIPTION OF POTENTIAL HAZARD TO ENVIRONMENT AND OR POPULATION
                                               Potentials for wind dispersion off-site
   and percolation  to ground water  are high.  Ground water  is used for  drinking water
   and irrigation downgradient  of the site.
 V. PRIORITY ASSESSMENT
 01 PRIORITY P
    D A HIGH
                       E B MEDIUM
                                       O C LOW
                                                            D D. NONE
 VI. INFORMATION AVAILABLE FROM
 01 CONTACT
   Carl Chompers
                                      02 OF I40*ncr OfQ«w«jonj
                                       NM  Dept.  of  Health
                                                     03 TELEPHONE NUMBER

                                                     '999'321-0123
 04 PERSON RESPONSIBLE FOfl ASSESSMENT

    Cindy Court/Charles  Chang
                                      05 AGENCY
                                       USEPA
                  0« ORGANIZATION

                  FIT
 07 TELEPHONE NUMBER
  dll 1999-8888
08 DATE
    3 ,14  .80
EPA FORM 2070-12 I?-61)

-------
fl r-TIA POTENTIAL HAZARDOUS WASTE SITE
V>tir\ PRELIMINARY ASSESSMENT
PART 2 - WASTE INFORMATION
(.IDENTIFICATION
01 STATE 02SlTENUMBtR
NM Dllllllin

H. WASTE STATES. QUANTITIES. AND CHARACTERISTICS ~
01 PMYSJCAL STATES .C'>.-t*in««>i», 02 WASTE QUANTITY AT SITE
lM»ttv'tt or ••!!• ouJnMWI
C*A SOLID C E SLURRY ""•" »•"«••«»»"
,_ B POWDER FINES ._ F LIQUID TONS 5000 tOHE
G C SLUDGE . G GAS
CUBIC YARDS
-j 0 OTHER
ha=nly wind blown
iSfrtt, NO OF DRUMS


03 WASTE CHARACTERISTICS <£»•» »m«laM»>;
3CA TOXIC C E SOLUBLE C I HIGHLY VOLATILE
LXB CORROSIVE D F INFECTIOUS C J EXPLOSIVE
L C RADIOACTIVE L G FLAMMABLE I- K REACT VE
C 0 PERSISTENT L H CNITABLE G L INCOMPATIBLE
LJ M NOT APPLICABLE
HI. WASTE TYPE
GATE GOBY
SLU
OlW
SOL
PSD
OCC
IOC
ACC
BAS
MES
SUBSTANCE NAME
SLUDGE
OILY WASTE
SOLVENTS
PESTICIDES
OTHER ORGANIC CHEMICALS
INORGANIC CHEMICALS
ACIDS
BASES
HEAVY METALS
01 GROSS AMOUNT








5000
02 UNIT OF MEASURE 03 COMMENTS








tons
IV. HAZARDOUS SUBSTANCES $.. ^r.~-. ..-nou «.«.«., ».ac.•,
CATEGORY 01 FEEDSTOCK N»ME
FDS
FDS
FDS
FDS
02 CAS NUMBER




CATEGORY 01 FEEDSTOCK NAK-£
FDS
FDS
FDS
FDS
o: CAS NUMBED




VL SOURCES OF INFORMATION c.. u>«c« ..'..»~»i • « rarauu unM»i»,u »P»TI ,
Manifests, limited wastes analyses and company correspondences. Discussions
with State officials, State trip report.
EPAFORM2070 12 17 811

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 SEPA
           POTENTIAL HAZARDOUS WASTE SITE
               PRELIMINARY ASSESSMENT
PART 3 • DESCRIPTION OF HAZARDOUS CONDITIONS AND INCIDENTS
                                                                            I. IDENTIFICATION
                                  01 STATE
                                    NM
02 SITE NUMBe"
 minimi
II. HAZARDOUS CONDITIONS AND INCIDENTS
 01 _ * GROUNOWATER CONTAMINATION
 03 POPULATION POTENTIALLY AFFECTED
              2500
02 ~ OBSERVED IDATE  	
04 NARRATIVE DESCRIPTION
                                                                         3 POTENTIAL
                                                                                      - ALLEGE;
 Heavy  metals  may be  leaching to  the groundwater  which  is used for  drinking/
 irrigation purposes.
 01 Z B SURF ACE WATER CONTAMINATION
 03 POPULATION POTENTIALLY AFFECTED .
                       02 r OBSERVED (DATE 	
                       04 NARRATIVE DESCRIPTION
                                                                         C POTENTIAL
                                                                                      _ ALLEGES
 No surface waters  are proximent  to the  site.
 01 I C CONTAMINATION OF AIR
 03 POPULATION POTENTIALLY AFFECTED
            ~  600
02 H" OBSERVED.DATE  	
04 NARRATIVE DESCRIPTION
                                                                         ". POTENTIAL
                                                                                      JC ALLEGED
Unsubstantiated reports are  on file of fugitive  dust problems,
 100  people within  1/4 mile  and   500 within 1.5  miles
                                                       There are  approximate
 0110 FIRE EXPLOSIVE CONDITIONS
 03 POPULATION POTENTIALLY AFFECTED
                       02 1 OBSERVEDIOATE 	
                       04 NARRATIVE DESCRIPTION
                                                                           POTENTIAL
                                                                                      1 ALLEGED
 None  reported nor  anticipated.
 01 1 E DIRECT CONTACT
 03 POPULATION POTENTIALLY AFFECTED
              600
02 J OBSERVED (DATE 	
04 NARRATIVE DESCRIPTION
                                                                         2? POTENTIAL
                                                                                      _ ALLEGED
 Site is unfenced  and materials  are easily blown off-site.
 01 _ F CONTAMINATION OF SOIL _
 03 AREA POTENTIALLY AFFECTED    100
                        02 3 OBSERVED (DATE 	
                        04 NARRATIVE DESCRIPTION
                                                                         .X POTENTIAL
 Heavy metals, if  leaching from  the storage piles, could be  accumulating in the
 soil column.
 01 _ G DRINKING WATER CONTAMINATION _ 2500
 03 POPULATION POTENTIALLY AFFECTED 	
                        02 1. OBSERVED IDATE 	
                        04 NARRATIVE DESCRIPTION
                                                                         JC POTENTIAL
                                                                                      . ALLEGED
 Downgradient wells about  1.5 miles away are  used for drinking water by  up to  2500
 individuals.
 01 1 H WORKER EXPOSURE INJURY
 03 WORKERS POTENTIALLY AFFECTED
                        02 Z OBSERVED IDATE 	
                        O4 NARRATIVE DESCRIPTION
                                                                         ^POTENTIAL
                                             - ALLEGED
 None reported.   However.probable that  workers are  exposed through breathing
 fugitive  dust and possibly direct contact.
 01 ol POPULATION EXPOSURE INJURY
 03 POPULATION POTENTIALLY AFFECTED
              2500
02 G OBSERVED (DATE 	
O4 NARRATIVE DESCRIPTION
                                                       $ POTENTIAL
                                                                    L- ALLEGED
 Fugitive  dusts may be easily  transported off-site  exposing anyone in  the area.
 Add  in groundwater exposure.
 A FORM 2070.12(7

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^ __.- POTENTIAL HAZARDOUS WASTE SITE
CVHHA PRELIMINARY ASSESSMENT
PART 3 • DESCRIPTION OF HAZARDOUS CONDITIONS AND INCIDENTS
1. IDENTIFICATION
0! STATE
NM
02 SITE NUMBED
Dlllllllll

 II. HAZARDOUS CONDITIONS AND INCIDENTS ,<:«*„»„.<,.
  01 Z J DAMAGE TO FLORA
  04 NARRATIVE DESCRIPTION
02 3 OBSERVED (DATE
                            . )    ED POTENTIAL
                                               C ALLEGED
    Surrounding  vegetation  appears  blackened  by blowing dust.   No adverse  impacts
    have been documented  to date.
  01 Z K DAMAGE TO FAUNA
  04 NARRATIVE DESCRIPTION ««»«c« . , i,«r.»i um»•«<»<• ••»«
    Same as  Part  2 Section VI.
EP>FOflH2070 12(7 -811

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                 BACKGROUND OF SAMPLING ACTIVITES AT
                     FLAMING GLORY AIRPORT LAKE,
                       BROKEN RIDGE,  OKLAHOMA
I.  BACKGROUND

On 30 June  1980, Andy  Anchovy  and Arlene Alebrew, Division  of  Waste
Management,  State  Department of  Health, attended  a public  meeting
before the Flatte County Commissioners.  One of  the  issues  raised at
this  meeting was  the  possible  pesticide  contamination  of  surface
waters resulting  from  disposal of  waste pesticides  into a  shallow
pond on county property near the Flaming Glory Airport  over  the past
twenty years.  The pond, which  is  located north of  the  airport,  was
thought to drain into a canal which  flows into  the  National  Wildlife
Refuge and eventually into the Dry Wash  River.   The  area surrounding
the pond  was reported  to  be  littered with  empty  barrels and  other
refuse.   Mr.   Spider Nasturtium,  State  Agriculture  Plant  and Insect
Specialist,  took  samples  of the  pond and  canal waters  on   13  June
1980.  Laboratory  results  indicate  low  pesticide  levels  (Dieldrin,
DDP and Malathion) in the  water  at  some  location samples.   The data
sheets for  the  samples  collected  in  this area  by the  Department of
Health are  attached.   A phone call  to Arlene Alebrew  clarified  the
laboratory results on the  data  sheets.   These data  are  contained in
Table 1.

The  State  Department  of  Health  notified  EPA  Region  VIII  of  the
potential  problem  at the  Flaming  Glory  Airport  Lake  and  indicated
that  inspectors  from the  State  Health  area  office  would perform a
Preliminary  Assessment.    The  following information  was  developed
during the PA.

II.  SITE DESCRIPTION

A.  General

The Flaming  Glory  Airport  is located  approximately  half-way between
Broken Ridge,  Oklahoma,  and Dusty  Valley.   Oklahoma,  just  south of

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Highway 160. The  lake  Is  situated south and east  of  the airport and
west  of  County Line Road  (T38N,  R8E, SEC.   24,  El/2,  NE1/4).   The
general site location  is shown in Figure 1.  The detailed map showing
the Flaming Glory Airport Lake is provided in Figure 2.

There  are  two  bodies of water at  the airport.   The  big lake covers
approximately  2-1/2  acres.   There is a small pond  (40 yds  x 20 yds)
approximately  .12  miles north of  the big  lake.   There  are numerous
marshy  areas  to the north  and south  of  the lake.   It  appears that
when  the water is  high, these marshy areas  could  become filled with
water  and  become  ponds.  In addition  to the pond,  a  marshy area .28
miles  south  of the lake has  been used as  a disposal  area  for drums
and  containers.    Spider  Nasturtium  indicated  there  were  a "couple
hundred empty  drums" in this  area.    These containers appear to have
contained  pesticides at one time.   Figure 2 is a  principal site map
showing the  location of the  lake,  pond,  marshy area  and  mixing pad
used  by  the  commercial   sprayers  for  filling   the  aircraft  with
pesticide.   Both  the  lake and  pond were found  to have  no surface
inlets or  outlets.

The drainage ditch west of  County Line road  and east  of  the lake was
observed to  be dry  north  of the  lake.   However,   there  was flowing
water  from the south portion  of the  lake to Rock Creek.  The flow was
estimated  to   be  one  cubic  foot  per second  (cfs)  or  less.   This
indicates  a  possible  ground  water  connection  between  the  lake and
this drainage  ditch.

The airport is operated by  the City  of Broken  Ridge.   Mr. Lou Lenny.
Broken Ridge City  Manager,  signed a   "Consent for Access  to Property"
form so that FIT could  enter  the  site for sampling.

B.  Regional Geology

The Flaming Glory Airport  lies in the western  portion of the Flaming
Gorge, a broad structural  depression that has been  down  faulted on
the eastern side and hinged along the west (Emery,  1969).  The valley
is bordered by  two mountain ranges;   the Small Hills  on  the west and

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west and the Stubbed Toe Mountains on the east.   Up to 30,000 feet of
Oligocene to Holocene Age valley  fill  material  comprised  of alluvium
and Interbedded volcanic flows and tuffs overlie Precambrian basement
rock  in the valley.    The  alluvium is  comprised of  unconsolidated
clays, silt, sand, and gravel (Edgery,  1972).

C.  Soils

Within the Flaming Glory Airport boundaries, three soil mapping units
and two land areas are delineated.  The three soil mapping units are:
Mosca  loamy  sand series, 0-1%  slope;  the  Flaming Glory  sandy loam
series,  0-1%  slope;  and the  Villa Grove  sandy  clay loam  series,
saline, 0-1%  slope.   The  two  land  areas  delineated  are  marsh  and
gravel pit (Pannell et al,  1980).

All three  soil series  are  found on  old flood  plains and  alluvial
fans.    The Mosca series  is a  deep,  well drained  soil  formed  in
moderately coarse to  coarse  textured  alluvium.   The  parent material
for this  series weathered from volcanic rocks.   The Flaming  Glory
series is a moderately  deep, somewhat  poorly drained  soil formed in
fine to medium  textured alluvium that  overlies sandy  alluvium.   The
parent  material  for  this  series   weathered  from  volcanic  rocks
containing high concentrations  of sodium.   The  Villa Grove series is
a  deep,  well   drained  soil   formed in   medium  textured  calcareous
alluvium.   The  parent material for  this series  weathered primarily
from quartz latite and rhyolite.  Gypsum found in some of these soils
was derived from the sulfides  and  sulfates found in  these volcanic
materials (Pannell et al, 1980).

Permeability is moderately slow (0.2-0.6  in/hr)  in the Flaming Glory
and Villa Grove series but is moderately rapid (2.0-6.0 in/hr) in the
Mosca series.   Available water capacity is  low to moderate  (0.04-0.16
in/in  of  soil) for  all three  soil  series.  Reaction (pH)  for  the
Mosca series is moderate to very strongly alkaline (7.9-9.0+);  the pH
for  the  San  Luis  series  is  strongly  to  very  strongly  alkaline

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(8,5-9.0+); the pH for the Villa Grove series is mildly to moderately
alkaline  (7.4-8.4).   Salinity  is  low to moderate  (0-8  Mmhos/cm) in
the Mosca  and  Villa  Grove  series and is  moderate  to  very high (4-30
Mmhos/cra)  in the Flaming Glory  series.   Runoff  is  slow and the water
erosion hazard is slight for all three soil series.  The soil blowing
hazard is  high for the Mosca series  (Pannell et al, 1980).

The  above soil   series   descriptions   describe   a  range  of  soil
characteristics  expected  to be  found in this  area.   The  marsh  and
gravel pit land areas are  a small  percentage  of the total area under
consideration  and are too varied to  make  any useful determinations as
to their properties.

D.  Hydrology

Ground Water - Within the valley fill material  there is an unconfined
aquifer  and  an  underlying  confined  aquifer.   Throughout  the major
portion of the valley a ten  to  eighty-foot thick blue clay layer acts
as the  confining  layer  separating  these aquifers.   Volcanic material
extending  from the  San Pedro  acts  as  the confining  layer  in  the
southwest  portion of the valley  (Edgery,  1973).

The  crystalline  basement   rock bears  essentially  no  water.    The
unconfined aquifer  receives recharge primarily through  infiltration
by precipitation.   The depth  to water  in  several observation wells
near the  National  Wildlife Refuge  to the south ranges from one-half
to nine feet below  ground  surface   (Curtis, 1983).   Depth  to the top
of the blue clay  layer  ranges  from 40 to 60 feet  in  the vicinity of
the airport  lake (Edgery,  1973),  and the  direction  of   flow  in  the
region  is  to   the   southeast.    There  is a   high  salinity  hazard
(750-2250  umhos/cm)  in  the unconfined  aquifer in  the  area  of  the
airport lake (Edgery, 1973).

Surface Water  -  There  are several  surface  drainages  in  the vicinity
of  the airport  lake.    The Leyden Lateral,   an   irrigation  ditch,
parallels U.S. highway  160  to  the  north  of the site  and  flows in an
easterly direction.  At County  Line Road, the  Loveland Lateral forks

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in an easterly  direction.   At County Line Road,  the  Loveland Lateral
forks from  the  Leyden  Lateral.   It  parallels  the road,  flowing  in a
southerly  direction,  and passes  within approximately  sixty  feet  of
the  site.   Near the airport  lake this  lateral  crosses  under  County
Line Road  and  flows in  an  easterly  direction.    (See  Figure 2.)   A
borrow ditch, serving also as a drainage ditch  parallels  the Loveland
Lateral along County Line Road.   The borrow  ditch is  about  ten  feet
west of the Lateral placing  it  in a position to  intercept  any  runoff
from the  airport  area.   This ditch  continues  past  the  airport  and
joins  Spring  Creek  in  the  National   Wildlife   Refuge.    At  this
confluence  both water  courses pass  under County  Line Road  and  become
Rock Creek, an  easterly  flowing stream.

     At the  time  of sampling,  the  south  flowing drainage  ditch  was
dry  north  of  the  airport   lake.     South  of  the  airport  lake  it
contained an  intermittent flow  and  south of the  marsh  it  contained a
constant flow.  The Loveland  Lateral  was dry.   There  were no observed
surface  flows  contributing  to   the  south  flowing   drainage   ditch
indicating  that infiltration  from ground water  is contributing  to the
increased flow  to the south.

     This south flowing  drainage ditch  flows  into Rock  Creek one  mile
south  of  the Broken  Ridge  National  Wildlife Refuge  boundary.   The
Parma drain also contributes  some  flow  near here.  Flow  in the creek
is  moderate.    The  FIT has  not  identified  water  use  for  these
ditches.

E.  Ground Water Use
     There  are  122  water  use  wells,   serving  approximately  1,500
people, within  a three mile  radius of the  lake  that  are registered at
the  State  Engineer's  Office.   An  additional  three   wells,  serving
approximately 1,530 people,  are located 3.5  miles to  the  southeast.
These have  been identified   from  the  master list  of  wells  maintained
by the State  Engineer's  office.   Additional  information  was obtained
from the well permit for each well.   The permits  for  nine wells could
not be located  and  these wells  have not been included  in the summary
of water use.   None of  these wells  have been field  checked to deter-
mine if they  are  presently  in use.    A  summary  of water  use within a
three mile  radius of the  site is  presented  in Table  2.

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The  State used  well  completion  information  and  drilling  logs  to
determine the aquifer  in which each well was  screened.   Wells which
are screened above  the  blue  clay layer were determined to be pumping
from the unconfined aquifer, while those screened below the blue clay
layer were determined  to be  pumping  from the confined aquifer.  When
this information  was  not available, the aquifer  of use was  reported
as undetermined.

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   T
            a* *(izpen.-r

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                                                             Dump I Mcrlh  I

                                                                   	''
                         PRIVATE PROPERTY
                                               "R i«WC_ NATION A L


                                                 . fipfiflQ Croak t
                                            WILDLIFE REFUGE
      ecology and environment, inc.
      4106 EAST FLORIDA AVENUE. SUITE 3SQ.
      DENVER, COLORADO 80777
FIGURED   Principal  Locations
              Map

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                               TABLE 1

          FLAMING GLORY AIRPORT LAKE PESTICIDE ANALYSES,1
             (SAMPLES COLLECTED BY MR. SPIDER NASTURTIUM
             STATE DEPT. OF AGRICULTURE, JUNE 13, 1983)
SAMPLE
                   DIELDRIN
Pest
Pest
Pest
Pest
Pest
1022
1023
1024
1025
1026
16

16
2.8
4.1
ppm
-
ppm
ppm
ppra
 DPP

 8 ppm

10 ppm
41 ppm
 4 ppm
MALATHION
                                                             4 ppm
1 Results in ppm

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^ _,_ _ POTENTIAL Hi
WFPA PRELIMIN
•~ - ^™ PART 1 - SITE INFO

II. SITE NAME AND LOCATION
01 SITE NAME t.e« eeflw o, C^.TM,., i
Flaming Glory Airport Lake
03 CITY
Broken Ridge
09 COORDINATES LATITUDE LONGITUDE
iZARDOUS WASTE SITE
ARY ASSESSMENT
RMATION AND ASSESSMEN
1. IDENTIFICATION
01 STATE 02 S|TE NoVe: =
OK D999999999


02 STREET ROUTE NO OR SPECIFIC LOCATION IDENTIFIER
Hwy 1092, 5.2 East of Broken Ridge
04 STATE 06 ZIP CODE 06
OK 00000 F
2
:OUNTY 07COJ'.-.1 :=;?•..-
latte ^fo= ^b

i 0 DIRECTIONS TO SITE s>» — >e "°™ *#»••*• p«e*c '<*e
Take Hwy 1092, 5.2 miles east from Broken Ridge, entrance
to airport on right. Lake is 0.4 miles 'further east, then right on County Road 2
for 3.2 Miles. Lake is located on right" about 150 yards from road.
III. RESPONSIBLE PARTIES
01 OWNER * r~om*
-Broken Ridge
03 CITY
Broken Ridge
C' OPERATOR IT >no.r ««<»>»••••» »0« o-w
Sam Stoddard
OS CITY
Broken Ridge
1 3 TYPE Of OWNERSHIP c».c. o~.
r A PRIVATE " B FEDERAL
R f DTHFR
rSoaff -
14 OWNER OPERATOR NOTIFICATION ON FIL£ Ct*c« uitnutoei,.
r A proA'vx" [>ATF RFCF'vFn / ' ~ ** nnrnt.
MONT- DA' *EA»

02 STREET f&,u*l,c««. «* <«v< *MOT« c/x:.w cowi. »»n » »«.. «<«««». «» >VT J Oncwo. «^^o
Q A MtGM 3d B MEDIUM D C. LOW _ O D NONE
»•« Conaou «• ~-«"">
JCMU imj i v uwrvtj«»tt<
VI. INFORMATION AVAILABLE FROM
01 CONTACT 02 Of '«••"<
Virginia Vance Coun
04 PERSON RESPONSIBLE FO« ASSESSMENT OJ AGf NCY
Art Argyle USEPj
T Orpftnucaon!
ty Commissioner
V FIT
,999, 222-2222
,,.,., ,,, ,rrr 10 ,27 80
J 	 '4H"' JJ 1 — ^T" :" '"•"• —

:ess





EPA FOm 1070.12(7 «1|

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£EPA
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
PART 2 • WASTE INFORMATION
1. IDENTIFICATION
01 STATE
OK

02 SITE NUMBER ' "
D999999999

II. WASTE STATES. QUANTITIES. AND CHARACTERISTICS
01 PHYSICAL STATES C/-.0 r in«' wr
3 A SOLID CM SLURRY
UB POWDER FINES K f LIQUID
3 C SLUDGE LI G 'GAS
D OTHf H

'SMfr
III. WASTE TYPE
CATEGORY
SLU
OLW
SOL
PSD
OCC
IOC
ACD
BAS
MES
02 WASTE QUANTITY AT SITE
ftHrl: M «0»p»«««l.
TONS

WO OF DRUM*
03 WASTE CHARACTERISTICS cC».c' * "»' «e»^'
IJ1A TOXIC CE SOLUBLE C I HCHL" VOL»T|L£
C B CORROSIVE w F INFECTIOUS f> J EXPLOSIVE
3C RADIOACTIVE Ci G FLAMMABLE C'K REACTIVE
l3fO PERSISTENT X' H ONITABLE 3 L INCOMPATIBLE
O M NOT APPLICABLE

"-*„ _ *

SUBSTANCE NAME
SLUDGE
OILY WASTE
SOLVENTS
PESTICIDES
OTHER ORGANIC CHEMICALS
INORGANIC CHEMICALS
ACIDS
BASES
HEAVY METALS
IV. HAZARDOUS SUBSTANCES s««
01 CATEGORY
PSD
PSD
PSD













01 GROSS AMOUNT

unk

unk





02 UNIT OF MEASURE 03 COMMENTS
-
: gals

gals/lbs couple hundred drums





»#**on /o> moii 'r#flv**r r :"*f C*3 ***!&*• t'
02 SUBSTANCE NAME
Dielbrin
DDP
Ilalathion













03CASNUMBEP
















OA STORAGE DISPOSAL METHOD

















05 CONCENTRATION
/ . 0-10
A-41
"













CONGES5' Rl'T.rs
ppra
ppm
ppm













V. FEEDSTOCKS s~*»~., •»<:«*«....
CATEGORY 01 FEEDSTOCK NAME
FOS
FDS
FDS
FDS
VI. SOURCES OF INFORMATION -"
02 CAS NUMBER




CATEGORY oi FEEDSTOCK NAME
FDS
FDS
FDS
FDS
^« ^^... ., ^«. «^.^,-^B1,
OJCASNUMBiC





County Commission Meeting Minutes, State on-site visit and sample analyses,
conversations with State and County officials, pannell Report, 1980.
9AFCDUI2070 12 |7-I1|

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           POTENTIAL HAZARDOUS WASTE SITE
               PRELIMINARY ASSESSMENT
PART 3 • DESCRIPTION OF HAZARDOUS CONDITIONS AND INCIDENTS
                                                                            I. IDENTIFICATION
                                                                                   D999999999
I HAZARDOUS CONDITIONS AND INCIDENTS
 01 iJ A GBOUNOAATER CONTAMINATION    . -~02 D OftSERVED ,DATF            I     S POTENTIAL     O Au_£G£-
 03 POPULATION POTENT,AU.V AFFECTED    1UUU     04 NARRATIVE DESCRIPTION

 Groundwater levels  are  quite  shallow  and contamination could migrate into
 aquifers.


 01 ?B  SURFACE VkATEBCON'AMINATlONft02 .S OaSFgVFn .DATE  O/i-3/oO  ,     Q POTENTIAL     Cj ALLEGE:
 03 POPULATION POTES-.ALLT AFFECTED     	   04 NARRATIVE DESCRIPTION
 Concentrations of dieldrin,  DDP, and Malathion  found  in  samples  from pond
 and canal.  Although  these waters  are not  used  for drinking within 3 miles,
 there  could be contamination of the Wildlife Preserve

 Oi Li C CON'AMisi-iON OF AIR          ,nn      o? DOeSEB.'EO'DATE 	i     QCPOTENTiAL     C' ALLEGE -
 03 POPu.ATlONPD'E>»TiA__v AFFECTED    JUU      CX NARRATIVE DESCRIPTION

 Soils of  the area are  easily  wind  blown especially during  dry summer/fall periods.
 01 _j D FIRE EiP.OS'VE CONDITIONS                 02 ti OBSEOVED .DATE _ |     2 POTENTIAL
 03 POPULATION POTEN1'A.L» AFFECTED _   04 NARRATIVE DESCRIPTION


 None reported  nor anticipated.
 01 '^ E DIRECT CONTACT                        O^UOBSga^g- iDATg            ,     C POTENTIAL    IT ALLEGES
 03 POPULATION POTENTIALLY AFFECTED _   04 NARRATlvt DESCRIPTION


 Site is  fenced,  no reports were located indicating direct contact.


 01 S f CONTAMINAT.ON Of SOIL                   0! PQBSFRi/FP 3ATE  b/3U/BU  i     -, POTENTIAL    C ALLEGED
 03 ARE* POTENTIALLY AFFECTED  *^ 1 _       O4 NARRATIVE DESCRIPTION
                            rACr«l

 County Commissioner notified  EPA of problem including  apparent  soil  contamination

 around fill  stand areas.

 Ol a &  DRINKING _,  ,,,«      OJC OBSERVED (DATE _ )    C POTENTIAL    L AUJ=G£C
 03 POPULATON POTENTIALLY AFFECTED     -}UU      04 NA«R>TIVE OCSCWPTlClN


 None reported.   Potential  for airbom transport  (see  Section  C)

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 6EPA
           POTENTIAL HAZARDOUS WASTE SITE
               PRELIMINARY ASSESSMENT
PART 3 • DESCRIPTION OF HAZARDOUS CONDITIONS AND INCIDENTS
                                                                            I. CENTIFICATION
01 STAT
  OK
C2 SKI NUMBS c

 D999999999
I. HAZARDOUS CONDITIONS AND INCIDENTS
 01 Q J DAMAGE TO FLORA                        02 C OBSERVED (DATE 	)    B POTENTIAL     C ALLEGED
 04 NARRATIVE DESCRIPTION

   None reported; however,  vegetation in  National Wildlife Refuge may be  affected  by
   discharge of pesticide into ditch which runs  into Refuge.
 01 D K DAMAGE TO FAUNA                        02 Z OBSERVES (DATE 	)    £ POTENTIAL     D ALLEGE;
 04 NARRATIVE DESCRIPTION -cw>.~<-.> o let.-.i
    None reported;  however,  National Wildlife Refuge  is immediately  south  of site
    and watered by  streams from site.   Refuge is the  nesting  ground  for the whooping
    crane.
 01 O L CONIAMINA-IOKOF FOODCHAis               02 Ci OBSERVED (DATE 	)    fc POTENTIAL     3 ALLEGE:
 04 NARRATIVE DESCRIPTION

    None reported;  however,  pesticides are known  to bio-accumulate.
 01 »M UNSTABLE CONTAINMENT OF WASTES            Q3 i"l (ItLtFRvCn IPATF  O/i-)/OU  ,    C POTENTIAL     3 ALLEGED
       tip*! •*•*€" t •**-; *o*«i •«••"( e-w^i      « p.
 03 POPJl>TK>. POTENTIALLY AFFECTED *"*  iu	    04 NARRATIVE DESCRIPTION

     Contamination of  the pond and canal, plus the  improper disposal  of drums

     around  the  pond  and marsh
 01 D N DAMAGE TO OFFSITE PROPERTY                02 D OBSERVED IDATE 	I    C POTENTIAL     C ALLEGED
 04 NARRATIVE DESCRIPTION
 01 BO CONTAMINATION OF SEWERS STORM DRAINS WWTPi  02 C OBSERVED (DATE   6/13/80 i    D POTENTIAL     C ALLEGED
 04 NARRATIVE DESCRIPTION

     Canal is contaminated by  pesticides
01 0 P ILLEGAL UNAUTHORIZED DUMPING              02 O OBSERVED (DATE    t>/ 1 J/ BU,   D POTENTIAL     DALLEGED
04 NARRATIVE DESCRIPTION

     Photos provided by  County  Commissioner  shows unauthorized dump at  extreme SE

     corner adjacent to  Wildlife Refuge
05 DESCRIPTION OF ANY OTHER KNOWN POTENTIAL OP. ALLEGED HAZARDS



     NONE
II TOTAL POPULATION POTENTIALLY AFFECTED. *•   *->UU
IV COMMENTS
     NONE
V SOimCES OF MFOAMATION ~~
     Same as Part 2 Section VI.

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