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SEPA
Subway Railcar Decontamination
with Methyl Bromide
March 15, 2017
Decontamination of a Subway Railcar using Methyl Bromide Fumigant on Bacillus anthracis
Sterne Strain Spores
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**NO SVC
Homeland Sandia
Security National. [g
Laboratories
Science and Technology
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Questions concerning this document or its application should be addressed to the following:
Shannon D. Serre, EPA Leroy Mickelsen, EPA
Co-Program Manager Co-Program Manager
serre.shannon@epa.gov mickelsen.leroy@epa.gov
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Disclaimer
This report has been peer- and administratively reviewed and has been approved for
publication as an EPA document. It does not necessarily reflect the views of the EPA. No
official endorsement should be inferred. The EPA does not endorse the purchase or sale of any
commercial products or services. This report includes photographs of commercially available
products. The photographs are included for purposes of illustration only and are not intended
to imply that the EPA approves or endorses any product or its manufacturer.
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Acknowledgements
This study required the collaboration of Federal government, academia, and contractor
personnel for planning and successful execution. The project could not have been successfully
accomplished without the collective commitment and contributions of all involved.
The following are acknowledged for their project planning and execution leadership:
Leroy Mickelsen, CBRN Consequence Management Advisory Division, EPA
Shannon Serre, CBRN Consequence Management Advisory Division, EPA
The following are acknowledged for scientific planning, coordination, and execution:
Larry Kaelin, CBRN Consequence Management Advisory Division, EPA
Leroy Mickelsen, CBRN Consequence Management Advisory Division, EPA
Michael Nalipinski, CBRN Consequence Management Advisory Division, EPA
Elise Jakabhazy, CBRN Consequence Management Advisory Division, EPA
Francisco J. Cruz, CBRN Consequence Management Advisory Division, EPA
Chris Gallo, Environmental Response Team, EPA
Worth Calfee, National Homeland Security Research Center, EPA
Marshall Gray, National Homeland Security Research Center, EPA
Shannon Serre, CBRN Consequence Management Advisory Division, EPA
John Archer, National Exposure Research Laboratory, EPA
Nicole Griffin, Arcadis US
Neil Daniell, CSS-Dynamac
Bill Kern, University of Florida
Renny Perez, University of Florida (Fumigation School Director)
Rudi Scheffrahn, University of Florida
Don Bansleben, Department of Homeland Security
Andrea Allen, Contract Support to the Department of Homeland Security
Mark Tucker, Sandia National Laboratories
Jasper Hardesty, Sandia National Laboratories
Veronica Lopez, Sandia National Laboratories
John Smith, Sandia National Laboratories
Kenneth Black, Sandia National Laboratories
Ellen Raber, Lawrence Livermore National Laboratory
Sav Mancieri, Lawrence Livermore National Laboratory
Hank Khan, Lawrence Livermore National Laboratory
Staci Kane, Lawrence Livermore National Laboratory
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The following are acknowledged for their role in the primary data analysis and authorship of
this report:
Shannon Serre, CBRN Consequence Management Advisory Division, EPA
Leroy Mickelsen, CBRN Consequence Management Advisory Division, EPA
Worth Calfee, National Homeland Security Research Center, EPA
Marshall Gray, National Homeland Security Research Center, EPA
Bill Kern, University of Florida
Rudi Scheffrahn, University of Florida
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Table of Contents
Disclaimer ii
Acknowledgements iii
Table of Contents v
Acronyms and Abbreviations vii
Executive Summary ix
1 Introduction 1
1.1 Previous MB Fumigation Studies 1
1.2 MB Usage and Properties 3
1.3 Health and Safety 5
1.4 Study Objectives 6
1.4.1 Objective 1 6
1.4.2 Objective 2 6
1.4.3 Objective 3 6
1.4.4 Objective 4 6
1.4.5 Objective 5 6
2 Study Materials and Methods 7
2.1 Subway Railcar Preparation 7
2.1.1 Tenting of the Railcar 7
2.1.2 Circulation Fans, Heaters, Humidifiers, and Displacement Bladders 9
2.2 MB Fumigation Process 11
2.3 Temperature and Relative Humidity Monitoring 12
2.4 Test Coupon Preparation and Analysis 12
2.4.1 Coupon Preparation 12
2.4.2 Coupon Analysis 14
2.4.2.1 Spatial Assessment of Efficacy (Qualitative Test) 16
2.4.2.2 Temporal Assessment of Efficacy (Quantitative Test) 17
2.5 Pre- and Post-Fumigation Sponge Stick Sampling 18
2.6 Activated Carbon Scrubber System Deployment 18
2.7 Ambient Air Monitoring 19
2.8 Leak Detection 19
3 Study Results 20
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3.1 Results from Release and Monitoring of the MB 20
3.2 Railcar Temperature and Relative Humidity Results 21
3.3 Test Coupon Results 21
3.3.1 Pre- and Post-Fumigation Coupon Population Comparison 21
3.3.2 Spatial Assessment of Efficacy (Qualitative Test) Results 22
3.3.3 Temporal Assessment of Efficacy (Quantitative Test) Results 23
3.4 Sponge Stick Sampling Results 23
3.5 Activated Carbon Scrubber System Results 24
3.6 Ambient Air Monitoring Results 25
3.7 Post-Aeration Air Sampling Results 26
3.8 Displacement Bladder Observations 26
4 Conclusions and Recommendations 27
4.1 Objective 1, Conclusion 27
4.2 Objective 2, Conclusion 27
4.3 Objective 3, Conclusion 28
4.4 Objective 4, Conclusion 28
4.5 Objective 5, Conclusion 28
4.6 Recommendations 29
5 References 29
Appendix
A Lessons Learned
B Health and Safety Plan
C Ambient Air Monitoring Plan
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Acronyms and Abbreviations
AAMP
Ambient Air Monitoring Plan
ACGIH
American Conference of Governmental Industrial Hygienists
B
Bacillus
Ba
Bacillus anthracis
Bl
biological indicator
CAA
Clean Air Act
CBRN
Chemical, Biological, Radiological, and Nuclear
CDC
Centers for Disease Control and Prevention
CFM
cubic feet per minute
CFU
colony forming unit
CI02
chlorine dioxide
CMAD
Consequence Management and Advisory Division
CRZ
Contaminant Reduction Zone ("warm zone")
DHS
Department of Homeland Security
EPA
United States Environmental Protection Agency
ERT
Environmental Response Team
EtO
ethylene oxide
EVOH
polyethylene vinyl alcohol
EZ
Exclusion Zone ("hot zone")
ft3
cubic feet
HASP
Health and Safety Plan
HAZWOPER
Hazardous Waste Operations and Emergency Response
HDPE
high-density polyethylene
IC
Incident Commander
ID
inner diameter
IDLH
immediately dangerous to life or health
LLNL
Lawrence Livermore National Laboratory
LR
log reduction
MB
methyl bromide
mg/L
milligram per liter
mm
millimeter
MOP
method of procedure
NHSRC
National Homeland Security Research Center
NIOSH
National Institute for Occupational Safety and Health
OEL
occupational exposure limit
OSHA
Occupational Safety and Health Administration
PBST
phosphate buffered saline withTween20
PEL
permissible exposure limit
PHILIS
Portable High-throughput Integrated Laboratory Identification System (EPA
mobile on-site analytic laboratory)
PID
photoionization detector
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PPE
personal protective equipment
PPm
part per million
PVC
polyvinyl chloride
QAPP
Quality Assurance Project Plan
RAP
Remediation Action Plan
REL
recommended exposure limit
RH
relative humidity
RTP
Research Triangle Park
SO
Safety Officer
Sandia
Sandia National Laboratories
SAP
Sampling and Analysis Plan
SCBA
self-contained breathing apparatus
SERAS
Scientific, Engineering, Response & Analytical Services
SZ
Support Zone ("cold zone")
tarp
tarpaulin
TLV
threshold limit value
TSA
tryptic soy agar
TWA
time-weighted average
UTR
Underground Transport Restoration
VHP
vaporized hydrogen peroxide
VOC
Volatile organic chemical
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Executive Summary
As part of the Department of Homeland Security's (DHS) Underground Transport Restoration
(UTR) project, several federal agencies conducted a scientific study to evaluate methyl bromide
(MB) as a fumigant for decontaminating subway railcars contaminated with Bacillus anthracis
(Ba) using Ba Sterne strain spores. In conjunction with the DHS, the United States
Environmental Protection Agency (EPA), Sandia National Laboratories (Sandia), and Lawrence
Livermore National Laboratory (LLNL) participated in the fumigation of a subway railcar using
MB in July 2015. The study was designed to evaluate the operational aspects and the efficacy
of MB for inactivating surrogate Ba spores on the subway railcar. The study was conducted to
gain large-scale information on the use of MB for the decontamination of Ba spores and to
develop site-specific plans and guidance that could be modified and used during a real-world
incident. The fumigant MB was selected because it has shown to be efficacious in the
inactivation of Ba spores during laboratory testing, is less corrosive than most other fumigants,
and can be captured on activated carbon.
A 1980s-era subway railcar was used in this study to examine the efficacy of MB for inactivating
Ba Sterne strain spores. Spores of Ba Sterne 34F2, the vaccine strain, were used as surrogates
in lieu of virulent Ba spores and placed on test coupon materials. The MB fumigation
parameters were 212 milligrams of MB per liter of air (mg/L) at 75 °F, greater than 75% relative
humidity (RH), maintained for 36 hours. Timed-series Ba coupons also were placed inside the
fumigation envelope and were extracted at 6, 12, 18, 24, and 30 hours after the start of
fumigation. At the conclusion of the 36-hour fumigation, the railcar was aerated and the test
coupons were collected and sent to a laboratory for analysis.
The subway railcar was transported to the Sandia campus in Livermore, California, on a
transport trailer and placed on a concrete pad. Before placement of the trailer and subway car
on the concrete pad, a 6-millimeter (mm)-thick, high-diffusion-resistant polyethylene vinyl
alcohol (EVOH) tarpaulin (tarp) was placed on the pad over which the chassis of the trailer was
parked. Another section of EVOH tarp was placed over the top of the railcar, and both tarps
were joined together. Before the EVOH tarp was placed over the top of the railcar, 4-inch-
diameter, perforated, high-density polyethylene (HDPE) tubing was draped over the top and
sides of the railcar, at multiple locations, to provide air space between the railcar and the tarp.
This tented area allowed simultaneous fumigation of the interior and exterior of the railcar
while also reducing the potential for condensation of MB at locations where the tarp and railcar
would be in contact. The area inside the tented volume contained four fans (operating at 3,000
cubic feet per minute [cfm] each), ten 1,500-watt radiant heaters, and four humidifiers to help
maintain temperature and RH equilibrium throughout the tented volume during the duration of
the study.
Before fumigation, 40 coupons were made from each of the following materials previously
removed from a similar railcar: nylon loop-pile carpet, fiberglass wall paneling, aluminum,
rubber flooring, Mylar® on polycarbonate, and vinyl seating. The test coupons were inoculated
with a known amount (about 106 colony forming units [CFU]) of Ba Sterne strain spores. Two
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coupons of each material were placed at 20 locations inside and outside the railcar, including
behind closed panels and confined spaces within mechanical and electrical equipment.
At the conclusion of the 36-hour fumigation period, the railcar was aerated and the coupons
were collected and sent to a laboratory for analysis. Results showed that none of the 40
fiberglass or 40 aluminum test coupons contained viable spores after fumigation. Out of the 40
coupons of each material type, the following numbers of coupons were positive after
fumigation: 2 nylon carpet coupons, 1 rubber flooring coupon, 1 Mylar® coupon, and 8 vinyl
seating coupons. No growth on any of the procedural blank (60 total) coupons suggests that
contamination did not occur during field or laboratory procedures. All 39 positive-control
coupons (inoculated but not exposed) were positive for growth. None of the 31 negative
control coupons (not inoculated and not exposed) were positive for growth.
Timed-series coupons removed from the fumigation envelope at 6, 12, 18, and 24 hours after
the start of fumigation all contained viable spores on some materials. Analysis of the time-
series coupons exposed for 30 hours showed viable spores (10 CFUs) were recovered from only
one (fiberglass coupon) of the twelve coupons, resulting in an average recovery of 5 CFUs for
fiberglass and zero recovered viable spores for all other materials. Log reductions (LR) for the
quantitative temporal assessment portion at 30 hours after exposure were greater than or
equal to 6 LR for all coupons except for the fiberglass coupon, which had an LR value of 5.5. At
the 24-hour exposure time, efficacy was greater than or equal to 2.5 LR for all coupons, with all
material types having recoverable spores.
An activated carbon scrubber system was used to capture the MB after the fumigation. The
system consisted of two scrubber vessels (each containing approximately 900 pounds of
activated carbon), a blower, flexible ducting, a vent stack, and fittings. The activated carbon
scrubber was effectively deployed and used to reduce the MB concentration inside the tented
volume from approximately 55,000 parts per million (ppm) to less than 20 ppm in 5 hours after
active fumigation was complete.
Ambient air monitoring was achieved by placing photoionization monitors at four stationary
locations around the tented railcar. In addition, hand-held monitors of similar technology were
used to leak test the perimeter of the tented railcar and to provide monitoring of those
locations not covered by the stationary monitors.
Based on several positive test coupon results from this study, it is recommended that the
fumigation of a railcar for Ba be extended from 36 to 48 hours and that the temperature, RH,
and MB concentration be maintained above the set points of 75 °F, 75% RH, and 212 mg/L,
respectively, during the 48-hour fumigation period. In addition, based on the result of eight
positive results for the vinyl seat covering coupons, it is recommended that railcar seating
material be sprayed down with pH-adjusted bleach before fumigation to aid in the inactivation
of Ba spores.
This operational study and update of the operational documents improves the capacity of U.S.
agencies to respond to and recover from a biological incident in a subway system.
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1 Introduction
As part of the Department of Homeland Security's (DHS) Underground Transport Restoration (UTR)
project, several federal agencies conducted a scientific study to evaluate methyl bromide (MB) as a
fumigant for decontaminating subway railcars contaminated with Bacillus anthracis (Ba) using non-
pathogenic Ba Sterne strain spores. In conjunction with the DHS, the United States Environmental
Protection Agency (EPA), Sandia National Laboratories (Sandia), and Lawrence Livermore National
Laboratory (LLNL) participated in the fumigation of a subway railcar using MB. The study was designed
to evaluate the operational aspects and the efficacy of MB for inactivating of Ba Sterne spores on a
full-scale subway railcar. The site-specific plans and guidance developed for this study could be
modified and used for a real-world incident. The fumigant MB (also known as bromomethane, CH3Br)
was selected because it has shown to be efficacious in the inactivation of Ba spores during laboratory
testing, is less corrosive than most other fumigants, and can be captured on activated carbon.
The fumigation study was conducted from July 6 through 15, 2015, at the Sandia campus in Livermore,
California. Project planning, coordination, and execution involved members from the following
agencies and organizations: EPA's Chemical, Biological, Radiological, and Nuclear (CBRN) Consequence
Management and Advisory Division (CMAD), DHS, Sandia, LLNL, EPA's National Homeland Security
Research Center (NHSRC), EPA's Environmental Response Team (ERT), the University of Florida, and
several contractors.
This report discusses the study materials and methods (Section 2), the results of the fumigation study
(Section 3), and provides conclusions and recommendations based on the study findings (Section 4).
Section 5 lists references used to prepare this report. In addition, this report includes the following
draft documents that can be used and modified during a real-world response for subway railcars
requiring MB fumigation:
• Appendix A: Lessons Learned
• Appendix B: Health and Safety Plan (HASP)
• Appendix C: Ambient Air Monitoring Plan (AAMP)
The following sections discuss previous MB fumigation studies, MB usage and properties, health and
safety, and study objectives.
1.1 Previous MB Fumigation Studies
In the event of the release of a biological agent such as Ba in a subway system, the areas impacted will
require decontamination, including subway tunnels and railcars. The railcars contain many electrical
components sensitive and subject to damage if exposed to harsh chemicals. Corrosion and
discoloration of materials in these railcars could also occur with the use of some fumigants that are
efficacious against Ba. In the case of sensitive or historic infrastructure, corrosive methods (relying on
oxidation) are not desirable remediation techniques. Studies have been conducted to examine
fumigant efficacy against Ba and the corrosion caused by some fumigants. The studies summarized
below highlight findings for MB fumigation against Ba.
• The EPA has conducted the studies discussed below to examine the compatibility of
decontamination agents with electronics and items of historical value (EPA, 2013).
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o An unpublished EPA study1 examined the impact of chlorine dioxide (CI02) gas,
vaporized hydrogen peroxide (VHP), ethylene oxide (EtO), and MB on several types of
historical materials. This study provided insight into the risk for damage from a
decontamination scenario using different fumigants. Based on the study findings, VHP,
EtO, and MB are the most compatible (of the fumigants and materials tested) with
museum-quality objects. MB is a viable alternative for a whole-building
decontamination scenario when materials such as books, documents, and photographs
are present.
o In another study (EPA, 2012), personal computers were exposed to MB fumigation
under the same conditions necessary to inactivate spore-forming bacteria. The
fumigant included 2% chloropicrin mixed in with the MB (standard use for olfactory
detection). The chloropicrin appeared to oxidize some components in the computer
system, but the MB appeared to not negatively impact materials.
• The EPA conducted a laboratory study (EPA, 2011) on seven different indoor building materials.
The study found that MB fumigation was efficacious for the decontamination of Ba Ames (a
virulent strain of Ba spores) on the indoor building materials tested.
• Corsi et al. (2007) concluded that MB does not engage appreciably in sorptive interactions with
indoor materials, although some diffusion can occur into porous materials and desorb.
Desorption of adsorbed MB from indoor materials appears to be rapid. It also appears that
exposure of some building materials to elevated concentrations of MB increases the desorption
rate of carbonyls and several methylated aliphatic compounds. However, the absolute
increases appear to be small and likely are not a major concern for either disinfection workers
or those who reoccupy a building after disinfection.
• Juergensmeyer et al. (2007) established that a minimum effective dose of MB of 80 milligrams
per liter (mg/L) was lethal to a concentration of 107 spores of Ba for nine different strains
(including Ames and Sterne) on glass slides after a 48-hour period exposure at 37 °C. In
addition, under the same exposure conditions, 9 other strains of Ba (ATCC 10, ATCC 937, ATCC
4728, ATCC 9660, ATCC 11966, ATCC 14187, AMES-1-RIID, AMES-RIID, and ANR-1) were equally
susceptible to MB and were not dependent upon virulence factors. The study showed that
Bacillus (B.) atrophaeus and B. thuringiensis were more resistant than Ba to MB when tested at
similar conditions. All B. thuringiensis and B. atrophaeus spores tested showed a dose-
dependent reduction in spore numbers, but the spores were not reduced to below detection
level by any of the MB concentrations tested. The study concludes that MB has several
advantages as a fumigant. First, because MB is a registered structural fumigant, personnel
trained in its use are available nationally. Additional training in decontamination procedures
would be minimal for these professionals. Second, decontamination is rapid, occurring within
48 hours. Extensive preparation of the contaminated item is not required, and all furnishings or
other internal structures or items may remain in place. Third, MB leaves no residue and is a
noncorrosive alkylating agent that does not damage commodities (such as food supplies),
furnishings, documents, or even sensitive electronic equipment.
• Weinberg and Scheffrahn (2004a, 2004b) conducted an MB field trial within a 30,000-cubic-foot
structure. Filter-paper coupons containing 106 spores of one of three species (Geobacillus
stearothermophilus, B. atrophaeus, and B. thuringiensis) and stainless-steel coupons containing
106 spores of B. atrophaeus were placed in 50 locations within the structure. Fumigation was
1 Point of Contact: Dr. Shannon Serre, EPA
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conducted using 312 mg/L of MB for 48 hours at 35.5 °C with an overall mean relative humidity
(RH) of 76%. The study results found that only one location, a sealed refrigerator, contained
viable spores of B. atrophaeus on a single coupon. It was noted that the performance of
sensitive electronics and electronic media placed in the structure were unaffected by MB
fumigation.
• Field studies by the EPA (2015) and Serre et al. (2016) evaluated operational MB fumigation to
inactivate Ba Sterne strain spores within a structure. The structure was covered with
polyethylene vinyl alcohol (EVOH) tarpaulins (tarp). The MB concentration, temperature, and
relative humidity of 212 mg/L, 27 °C, and 75%, respectively, were maintained for 48 hours.
Spores of Ba Sterne 34F2, the vaccine strain, were inoculated onto wood and glass coupons
with approximately 106 colony forming units (CFU) and placed at 22 separate locations
throughout the structure. After fumigation, all 174 coupons were negative for growth. An
activated carbon scrubber system was effectively deployed to reduce the concentration of MB
inside the structure from approximately 55,000 parts per million (ppm) to below 150 ppm in 4
hours.
1.2 MB Usage and Properties
MB, also known as bromomethane (CH3Br), is a colorless, odorless (at low concentrations), and
nonflammable gas classified as an alkyl bromide. MB is containerized as a liquid under a modest
pressure of approximately 2 atmospheres. The EPA originally registered MB for applications that
included soil fumigation (injected into soil before crop planting to effectively sterilize the soil of
nematodes, weed seeds, and plant pathogens); commodity treatment (post-harvest pest control); and
structural pest control (to fumigate buildings for termites and warehouses and food processing
facilities for insects and rodents) (EPA, 2006). Current domestic use of MB is as a quarantine fumigant
to treat exported and imported commodities such as wood and fresh fruits and vegetables.
MB fumigant concentrations and contact times vary depending on the commodity or structure being
treated, the target pest, temperature, and RH. MB is an effective pesticide because it acts as a
methylating agent that disrupts an organism's internal enzymatic protein chemistry. However, the
production of MB was reduced in 2005 under an international treaty called the Montreal Protocol and
by the EPA under the Clean Air Act (CAA) (http://www.epa.gov/ozone/mbr/) due to its stratospheric
ozone-depleting potential. Use now requires an exemption by the EPA under appropriate provisions in
the CAA. MB currently is used in the U.S. only under these exemptions and is manufactured in the U.S.
by Chemtura Corp., with label provisions developed by Great Lakes Corp. Allowable exemptions
include the Quarantine and Pre-Shipment exemption to eliminate quarantined pests and the Critical
Use Exemption designed for agricultural users with no technically or economically feasible alternatives.
Under these exemptions, approximately 7 million pounds of MB is used annually in the U.S. In
addition, MB has a Section 18 exemption under EPA authority. Due to the need to find an effective
fumigant or method to inactivate Ba spores, the EPA continues to research decontamination
technologies, including MB use at relatively low temperatures and RH levels (EPA, 2014).
Before phase-out of MB as an ozone-depleting substance began in 2005, MB fumigation was widely
used for 60 years against soil and structural pests. Today, most major U.S. seaports and some airports
have facilities regulated by the United States Department of Agriculture for MB fumigations of
imported fruits, vegetables, and other regulated commodities. These facilities have crews trained in
MB fumigation using much of the same equipment and methods as those used in structural
fumigations. Although the crews have the technical expertise to conduct lawful fumigations, only a
small percentage of fumigation crews currently working in the industry meet the requirements for
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entering a biological agent remediation site. Such requirements include Occupational Safety and
Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER)
certification, medical clearance to wear respiratory protection, and annual respiratory protection
training. (Medical clearance, self-contained breathing apparatus (SCBA) use, and respirator training
already are requirements for licensed fumigators.) In addition, fumigation workers at biological agent
remediation sites need site-specific training with a focus on the hazards of Ba and on conducting
fumigation tasks in Level C personal protective equipment (PPE) protective gear, most likely including
powered air-purifying respirators. Initial HAZWOPER technician training is a one-time, 24-hour event
with subsequent 8-hour refresher training required annually. To overcome this deficiency, fumigation
industry workers without the required HAZWOPER training could be prepared with minimal training to
meet these requirements as needed for emergency response remediation work.
Most of the structural fumigation industry in the U.S. (mostly non-MB usage) is located in Florida, the
Gulf Coast, the Southwest, and Hawaii. The quarantine fumigation industry (MB usage) mainly is
located at large sea ports and airports where international cargo is imported. These locations largely
coincide with the locations of major subway systems in the US. During a national emergency involving
the release of Ba in a subway system, this industry could be used to increase the remediation capacity.
MB penetrates quickly and deeply into sorptive materials at normal atmospheric pressure. Also, at the
end of a fumigation treatment, MB vapors dissipate rapidly from the materials (Corsi et al., 2007). MB
gas is non-explosive under ordinary circumstances and may be used without special precautions
against combustion.
In the absence of oxygen, liquid-phase MB reacts with aluminum to form methyl aluminum bromide.
Methyl aluminum bromide ignites spontaneously in the presence of oxygen. Liquid MB should never
be stored in cylinders containing any appreciable amount of the metal aluminum, and aluminum
tubing should not be used for applying the liquid phase of the fumigant. Vapor-phase MB will not
react with aluminum. Table 1 summarizes the chemical properties of MB.
Table 1. MB Chemical Properties
Chemical formula
CH3Br
Boiling point
3.6 °C
Freezing point
-93 °C
Molecular weight
94.95
Specific gravity gas (air = 1)
3.27 at 0 °C
Liquid (water at 4 °C = 1)
1.732 at 0 °C
Vapor pressure
1,400 millimeters (mm) of mercury at 20°C
Latent heat of vaporization
61.52 calories per gram
Flammability limits in air
Flammable between 10 to 15% (some say 20%) in air
Solubility in water
1.34 grams per 100 milliliters at 25 °C
Odor
Odorless at low concentrations; strong musty or sickly sweet odor at high
concentrations (greater than 1,000 ppm)
Pertinent chemical properties
Powerful solvent of organic materials, especially natural rubber; liquid MB
(liquid-phase only)
reacts with aluminum and its alloys to form methylated aluminum
compounds that are spontaneously flammable in air; reacts with zinc,
magnesium, tin, and iron surfaces in the presence of impurities such as
water or alcohol; avoid the presence of acetylenic compounds, ammonia,
dimethylsulfoxide, EtO, oxidizers, and hot metal surfaces
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1.3 Health and Safety
With all fumigants, human exposure is a concern because of the toxic nature and inhalation hazard
associated with fumigants, including MB. MB is a toxic chemical. Because MB dissipates so rapidly to
the atmosphere, it is most dangerous at the fumigation site itself. Human exposure to high
concentrations of MB can result in central nervous system and respiratory system failure as well as
specific and severe deleterious reactions affecting the lungs, eyes, skin, kidneys, and liver.
The risk of exposure to MB without sufficient warning is significant because MB is a colorless and
odorless (at working concentrations) gas. To address this significant risk, a detailed HASP (Appendix B)
and AAMP (Appendix C) were developed to protect workers during this study. MB has a history of
industrial use, and it is fairly well characterized in terms of human toxicity, including recommended
and regulatory occupational exposure limits (OEL). For the purposes of this study, a detailed HASP was
developed that integrates personnel and area monitoring, emergency response, medical monitoring,
PPE requirements, clearance thresholds, and other related issues.
Although this study was a research project, the fumigation site was managed as if it were an
emergency response site, with the designation of an Exclusion Zone (EZ) or "hot zone," a Contaminant
Reduction Zone (CRZ) or "warm zone," and a Support Zone (SZ) or "cold zone." The three zones were
delineated based on the most conservative airborne OELs for MB provided by OSHA, the National
Institute for Occupational Safety and Health (NIOSH), and the American Conference of Governmental
Industrial Hygienists (ACGIH). The ACGIH threshold limit value (TLV) is 1 ppm as an 8-hour time-
weighted average (TWA), and the OSHA permissible exposure limit (PEL) is 20 ppm as a ceiling value
that cannot be exceeded in any part of the workday. NIOSH's immediately dangerous to life or health
(IDLH) value is listed as 250 ppm (NIOSH, 2012). MB has no NIOSH recommended exposure limit (REL)
because NIOSH considers MB a potential occupational carcinogen. Other organizations, such as the
International Agency for Research on Cancer (1986), the National Toxicology Program (1992), and the
EPA (1988) do not classify MB as a potential human carcinogen.
In addition to inhalation exposure limits, the OELs annotate a skin notation for MB, which suggests
potential adverse effects to the skin and/or absorption through the skin. The reports of Jordi (1953)
and Hezemans-Boer et al. (1988) suggest that sweating increases human vulnerability to skin
absorption of MB. Yamomoto et al. (2000) studied cutaneous exposure of rats to MB, but it is not clear
whether the exposure was to MB in liquid or vapor form. This study found an immediate rise in plasma
bromide ion, with a plasma clearance half-life of 5.0 to 6.5 days.
For purposes of this MB fumigation study, the zones were established based on MB concentrations as
follows: EZ greater than 0.5 ppm, CRZ between 0.5 ppm and non-detect, and SZ at non-detect. Wind
directional flags were used throughout the fumigation area, and the SZ was maintained upwind from
the fumigation area. PPE including SCBAs and foot and hand protection were prescribed based on
work task. SCBAs were required for entry into an area with airborne concentrations consistently
exceeding the action level of 0.5 ppm (a level of MB concentration that requires mitigative actions).
Two Certified Industrial Hygienists (American Board of Industrial Hygiene) served as the site Safety
Officers (SOs) and provided 24-hour oversight of the project during all fumigation activities. The SOs
also collected personal breathing zone samples from EPA and contract personnel during tasks
identified as having the potential for MB exposure, including coupon extraction and carbon scrubber
operations conducted during aeration of the railcar.
The HASP restricted entry into the railcar from the time fumigation began until the fumigation was
complete and airborne MB concentrations were measured to be below 5 ppm. Coupons were not
5
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collected until MB concentrations were below 1 ppm. When dispensing MB from cylinders, workers
wore no gloves and loose-fitting clothing (as required by the MB labeling) to reduce the risk of trapping
liquid MB under clothing next to the skin. Engineering controls, work practices, and required PPE all
are detailed in the site-specific HASP. This HASP can serve as an example HASP to be modified and
used at other sites requiring MB fumigation.
1.4 Study Objectives
The overall goal of this study was to conduct and evaluate the operational aspects and efficacy of MB
fumigation for inactivating non-pathogenic Ba Sterne spores in a full-scale subway railcar. The five
objectives summarized below were developed to achieve this overall goal. Achieving these objectives
will result in greater resiliency and capacity to respond to and recover from a Ba release or other
biological incident using MB fumigation.
1.4.1 Objective 1
Under this objective, a Quality Assurance Project Plan (QAPP) was developed for the fumigation of a
subway railcar using MB for inactivating the chosen non-pathogenic surrogate spores. As part of the
QAPP, this study included the development of a site-specific HASP, and an AAMP. With minor changes,
the site-specific HASP, and AAMP, can be easily modified and used for fumigation of one or more
railcars using MB.
1.4.2 Objective 2
This objective was to conduct the fumigation process safely, economically, and effectively. MB
concentration, temperature, and RH were monitored and maintained during the study to ensure that
the following requirements were achieved inside the railcar fumigation envelope during the 36-hour
fumigation period: MB concentration greater than or equal to 212 mg/L, temperature at greater than
or equal to 75 °F, and relative humidity at greater than or equal to 75%. Furthermore, MB
concentration, temperature, and RH were monitored outside the railcar before, during, and after the
same 36-hour fumigation and aeration period.
1.4.3 Objective 3
Under this objective, the efficacy of the fumigation was evaluated by measuring the post-fumigation
viability of Ba Sterne strain spores. This objective was accomplished by inoculating Ba Sterne strain
spores onto six types of material test coupons (materials obtained from a railcar) and placing the
coupons in 20 locations inside and outside the railcar before fumigation, followed by laboratory
analysis of spore viability after the fumigation.
1.4.4 Objective 4
This objective required evaluating the effectiveness of activated carbon for capturing the MB fumigant
during the aeration portion of the fumigation cycle and monitoring MB breakthrough status of the
activated carbon during aeration of the railcar.
1.4.5 Objective 5
The objective was to monitor the effectiveness of MB containment and provide for the health and
safety of workers during the entire fumigation process. The HASP, and AAMP, provide detailed
6
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procedures for air monitoring and for handling elevated levels (exceeding 0.5 ppm) of MB in ambient
air during all aspects of the fumigation process.
2 Study Materials and Methods
This section discusses the study materials and methods, including subway railcar preparation, the MB
fumigation process, temperature and RH monitoring, test coupon preparation and analysis, pre-and
post-fumigation sponge stick sampling, activated carbon scrubber system deployment, ambient air
monitoring, and leak detection.
2.1 Subway Railcar Preparation
A 1980s-era subway car (Figure 1) undergoing a retrofit process was transported to Sandia's campus in
Livermore, California, on a transport trailer, where it was tented and fumigated with MB.
Figure 1. Schematic diagram of subway railcar, with dimensions
As discussed in Section 1,4.2, the MB fumigation parameters were 212 mg/L, 75 °F, greater than 75%
RH, and 36 hours. The railcar site contained a chain-link fence used to cordon off the fumigation area
and keep unauthorized personnel away from the fumigation site. An operations center was located in
a building directly adjacent to the fumigation site, with an on-site operations station located just
outside the fence between the site and the operations center.
The railcar was tented, and circulation fans, heaters, humidifiers, and displacement bladders were
installed in the railcar as discussed below.
2.1.1 Tenting of the Railcar
The railcar and transport trailer were placed on a concrete pad at Sandia's campus in Livermore,
California. Before placement of the trailer and subway car, a 6-mm-thick, high-diffusion-resistant
EVOH tarp with polyester scrim reinforcement (GeoCHEM Inc., Renton, Washington) was placed on the
concrete pad under the chassis of the trailer. On Friday, July 10, 2015, site personnel placed another
section of EVOH tarp over the top of the railcar, and both tarps were joined together. Before the EVOH
tarp was placed over the top of the railcar, 4-inch-diameter, perforated, high-density polyethylene
(HOPE) tubing was draped over the top and sides of the railcar, at multiple location, to provide air
space between the railcar and the tarp. This tented area allowed simultaneous fumigation of the
interior and exterior of the railcar while also reducing the potential for condensation of MB at locations
where the tarp and railcar would be in contact.
7
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The bottom and top tarp layers were joined using spray-on glue and by overlapping and rolling
adjacent edges together and binding them with plastic-tipped, metal-spring fumigation clamps. The
lower edge of the tent envelope was held down on the ground with overlapping 40-pound sandbag
"snakes." This process took approximately 2 hours. Figures 2 and 3 show the tented railcar.
Figure 2. Tented railcar with HOPE tubing draped between the tarp and railcar visible as "ribs" under
the tarp; MB scale and heater unit shown in foreground
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Figure 3. Skirt of EVOH tarp dropped to the ground and weighed down with sandbag "snakes"
Several penetrations into the tented volume were needed to supply electrical power for the fans,
heaters, and humidifiers (see Section 2.1.2) through 4-inch-diameter polyvinyl chloride (PVC) pipes.
Another penetration was necessary for the scrubber duct inlet, and two 4-inch-diameter PVC pipes also
8
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were used for coupon removal at timed intervals. PVC pipes also were used as conduits for MB
introduction from "shooting" hoses (3/4-inch braided, chemical-resistant, high-temperature [149 °C
rating], and high-pressure [greater than 200 pounds per square inch] rating) with MB monitoring lines
(6.4-mm outer diameter, nylon). After the shooting and monitoring lines were routed through the PVC
pipes, voids in the PVC piping and pipe chases were filled and sealed with expanding polyurethane
foam.
Timed-series coupons also were placed inside the fumigation envelope for extraction and analysis to
determine the number of colony-forming spores recovered from these test coupons for comparison to
positive control coupons. The timed-series test coupon holder (PVC-pipe construction) was sealed at
its exterior terminus with threaded PVC caps (Figure 4).
Figure 4. Termini of PVC piping used for timed-series coupon extractions
2.1.2 Circulation Fans, Heaters, Humidifiers, and Displacement Bladders
Fans were strategically placed inside the railcar for mixing and to ensure uniform concentration,
temperature, and RH conditions throughout the railcar. The area inside the tented volume contained
four fans (operating at 3,000 cubic feet per minute [cfm] each), ten 1,500-watt radiant heaters, and
four humidifiers (Delonghi, Model EW7707CM, Woodridge, New Jersey). Figure 5 shows a diagram of
the fans, heaters, and humidifiers located in the railcar.
9
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oq a
no l
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a i
^=- Humidifier WN-
Fan
Figure 5. Schematic diagram of railcar showing locations of fans, heaters, and humidifiers
The fans ran continuously during the fumigation process (including during scrubbing and aeration) to
maintain temperature and RH equilibrium throughout the railcar and to disperse the MB gas when it
was introduced into the fumigation envelope. The power supply for the radiant heaters and
humidifiers was on continuously throughout the fumigation process. The heaters, fans, and
humidifiers were turned on immediately after the tarp was placed over the railcar and allowed to pre-
condition the environment before the introduction of MB. The humidifiers were refilled before the
final sealing of the tarp envelope and before fumigation.
The contents within a volume to be fumigated should be factored into the fumigation decision process
and may adversely impact the efficacy of the fumigation. Specific contents at a significant quantity,
may act as sinks for fumigants, water vapor (humidity), and heat. Fumigant adsorption may be
followed by latent desorption (off-gassing) for extended periods of time after fumigation. For example,
large amounts of foam may act as a sink for a fumigant, requiring the foam to be removed or
additional fumigant to be used to overcome the loss of fumigant to the foam. The interactions
between the contents with the fumigant and fumigation parameters dictate actions that may be
needed. However, interactions are not always known in advance, and fumigation parameters must be
monitored during fumigation to ensure that the parameters necessary for an efficacious
decontamination are met and that safe levels are reached after fumigation before reoccupation of the
railcar.
Three inflatable Mylar® tubes (IMPAK Corp., Los Angeles, California) were installed along the length of
the railcar ceiling (Figure 6) as bladders to displace a portion of the fumigated airspace so that less MB
would be needed to reach the target concentration.
Figure 6. Three displacement bladders suspended from ceiling of the railcar
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The 5.6-mm-thick displacement bladders consisted of four layers (Mylar® film, polyethylene, aluminum
foil, and polyethylene) designed for food packaging. One end of each bladder was sealed with tape
and the other end tape-fitted with a 2-inch-diameter PVC pipe. The pipe was attached to an electric
leaf blower, and each bladder was filled with ambient air to near capacity. The PVC pipes were
immediately capped. The initial volume displaced by the filled bladders was approximately 920 cubic
feet (ft3) at the beginning of the fumigation.
For this study all interior cabinets and panels were left in the closed position to intentionally challenge
the process. However, the standard practice for fumigation is to open as many doors, cabinets,
enclosures, etc., to accelerate fumigant movement into these areas. The fumigation envelope was
sealed up at around 1500 on Friday, July 10, 2015.
2.2 MB Fumigation Process
The MB used in this study (100%, Meth-O-Gas 100®, Great Lakes Chemical Co., West Lafayette,
Indiana) was contained as a liquid in commercial, 100-pound metal cylinders. MB without chloropicrin
was used to avoid potential corrosive damage caused by chloropicrin. Because MB has a boiling point
of 38.5 °F, heat was added during introduction to ensure that only gaseous MB was released from the
end of the shooting hose. Heat was added by using a hose to affix the cylinder valve to a 5-gallon-
capacity heat exchanger. The heat exchanger contained a coiled metal tube through which the MB
passed. The coil was surrounded by a water/radiator coolant mixture (60:40) heated by a propane
burner to 195 °F. The gaseous MB exited the heat exchanger through the shooting hose at about 160
°F and then traveled as a gas through the shooting hose and exited into the shooting bucket inside the
railcar. The certified applicator (Clark Pest Control, Concord, California) placed the MB cylinder on a
balance and donned a full-face-shield and air-purifying respirator before opening the MB cylinder. All
MB released was measured gravimetrically.
The working concentrations of MB during the fumigation were monitored at four locations using a
Fumiscope® thermal conductivity detector as shown in Figure 7 (Key Chemical Co., Clearwater, Florida)
with an accuracy of approximately ±1 gram per cubic meter of MB.
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11
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Key Chemical Co. calibrated the monitor with MB in November 2013. Fumiscope® monitoring locations
included two locations inside the railcar and two outside the railcar (inside the enclosure). The
Fumiscope® was fitted with an air pump to pull the interior MB-laden air through a monitoring line into
the instrument, which then gave a near real-time reading of MB concentration. At the conclusion of
the 36-hour fumigation, the railcar was aerated. During fumigation and aeration, authorized personnel
(licensed California applicators) monitored the MB concentration 24 hours per day.
2.3 Temperature arid Relative Humidity Monitoring
Temperature and RH inside the railcar were monitored in real time during the fumigation process,
including the aeration phase, using a HOBO temperature and RH monitoring system (Model ZW-03,
Onset Computer Corporation, Bourne, Massachusetts). The monitoring system included four wireless
sensor nodes spaced throughout the railcar and a router placed on the outside skin of the railcar under
the tarp. The wireless system transmitted real-time data to the receiving station located
approximately 50 feet from the railcar. Real-time temperature and RH data were collected and
displayed on a laptop computer using HOBOware Pro software (Onset Computer Corporation, Bourne,
Massachusetts). In addition to the four wireless sensors, HOBO temperature and RH loggers (Model
U10, Onset Computer Corporation, Bourne, Massachusetts) were placed adjacent to the 20 test
coupon locations inside the fumigation envelope.
2.4 Test Coupon Preparation and Analysis
Before fumigation, multiple test coupons were inoculated with a known amount (about 106 CFUs) of
surrogate spores (So Sterne strain). The test coupons were placed in various locations throughout the
railcar. The following sections discuss preparation and analysis of the test coupons.
2.4.1 Coupon Preparation
Materials were removed from a subway railcar undergoing renovation. The coupons were cut from
those materials to a 10-mm diameter and included the following materials: nylon loop-pile carpet,
fiberglass wall paneling, aluminum, rubber flooring, Mylar® on polycarbonate, and vinyl seating (Figure
8).
DO *
J
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The coupon materials were sterilized before inoculation using EtO (Andersen Products, Haw River,
North Carolina). Spores of Ba Sterne 34F2, the vaccine strain (Colorado Serum Co., Denver, Colorado),
were selected as inoculation surrogates for fully virulent Ba spores. Spore production procedures were
conducted at Yakibou Labs, Inc. (Apex, North Carolina), using proprietary methods. Negative control
coupons and field blank coupons (although not guaranteed to be sterile after packaging) remained un-
inoculated.
After inoculation, test coupons were allowed to dry at room temperature on a bench and then
packaged into custom-sized Tyvek® pouches (Figure 9).
Location
Place: 2 positive coupons ot each
3 random negative control
Corresponding Coupon ID Numbers
Mylar Carpet Rubber
£ \ jt \ IT
I 7-
Negative Control Blank Material (Check box tor up to i per location)
Mylar Carpet Rubber Seat Material Fiberglass
I 1 I 1 I I -T
i
Scat Material
Fiberglass
Aluminum
3?
/
1!
III
iF
ii
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Figure 9. Tyvek envelopes containing coupons and sample numbers used to track each coupon
location and material type
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The pouches were heat-sealed to prevent infiltration or exfiltration of spores or particulate
contaminants, thereby preventing escape of the spores and maintaining the integrity of the biological
indicators (Bl) from the surrounding environment. Tyvek® pouches were pre-labeled with an identifier
unique to each product type.
Pre- and post-fumigation testing of coupon spore population densities was performed at EPA's NHSRC
Research Triangle Park (RTP) Microbiology Laboratory in accordance with methods of procedure (MOP)
6535a, 6565, and 6566 as summarized in Table 2.
Table 2. Pre- and Post-Fumigation Bl Population Density Testing
Testing Type
Purpose
Frequency
Quantity
Analysis
Coupon
enumeration
pre- and post-
fumigation
To determine
spore population
densities on
coupons pre- and
post-fumigation
one set each
material
before test
and one set
after test
23 total:
5 stainless-steel
coupons and
3 coupons each of 6
materials tested (for
a total of 18)
CFU
enumeration
The testing included non-exposed control coupons. Spores were extracted from the coupons, serially
diluted 10-fold, and then plated onto tryptic soy agar (TSA) plates. After incubation at 35 °C for 18 to
24 hours, the resulting CFUs were enumerated. The CFU abundance was used to estimate the total
spore abundance on the coupons. Triplicate samples of each material type were analyzed for
population density before and after the field fumigation. In addition, 10 replicate stainless-steel
coupons that were inoculated (by Yakibou, Inc.) at the same time as the other coupons were tested for
population density before and after the field fumigation. These stainless-steel coupons were expected
to yield more accurate and repeatable estimates of pre- and post-fumigation viable spore population
densities than other materials (Calfee et al., 2011) because recovery of spores from stainless-steel
surfaces is highly efficient.
2.4.2 Coupon Analysis
Six types of coupons were used during the study to evaluate the efficacy of MB fumigation. These
included two types of test coupons as summarized in Table 3: (1) spatial test coupons deployed
throughout the fumigated area under the tarp to qualitatively assess spatial fumigant efficacy and (2)
temporal (timed-series, collocated) coupons positioned inside the fumigation enclosure (at the
extraction port) and collected at specified time intervals to quantitatively assess temporal fumigant
efficacy.
Table 3. Test Coupon Types Used to Evaluate the Efficacy of MB Fumigation
Coupon Type
Location
Purpose
Frequency
Quantity
Analysis
Spatial Test
Coupons
20 locations
inside the
fumigated area
To qualitatively
assess spatial
fumigant efficacy
Once per study
240 total:
40 of each
material type
Qualitative
(growth or no
growth)
Timed-series
Coupons
Inside the
fumigation
enclosure at
extraction port
To quantitatively
assess temporal
fumigant efficacy
One set of
samples at 6, 12,
18, 24, and 30
hours (five sets
total)
60 total:
2 of each of 6
materials, 5
sets
Enumeration
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In addition, four types of control coupons were used during the study: procedural blank, positive
control, negative control, and laboratory-sterilized negative control coupons as summarized in Table 4.
Table 4. Control Coupon Bl Types Used During the Study
Coupon Type
Location
Purpose
Frequency
Quantity
Analysis
Procedural
Same 20
To undergo fumigation
Once per
60 total:
Qualitative
Blank Coupons
locations as
and the determine
study
3 coupons per
(growth or no
Collocated with
test coupons
extent of cross-
location (20
growth)
Spatial Test
contamination
locations)
Coupons
Procedural
Same
To undergo fumigation
One set of
30 total:
Enumeration
Blank Coupons
locations as
and the determine
samples at 6,
1 of each of six
for Timed-
timed-series
extent of cross-
12, 18, 24, and
materials, 5
Series Coupons
coupons
contamination
30 hours (five
sets total)
sets
Positive Control
Traveled to
To determine the
Once per
39 total:
Qualitative
Coupons
study site but
presence or non-
study
6 Carpet
(growth or no
remained in
presence of viable
7 Fiberglass
growth)
sample coolers
spores on non-
5 Aluminum
and were not
fumigated coupons
7 Rubber
fumigated
7 Mylar®
7 Seating
Negative
Traveled to
To determine the
Once per
31 total:
Qualitative
Control
study site but
presence or non-
study
6 Carpet
(growth or no
Coupons
remained in
sample coolers
and were not
fumigated
presence of viable
spores on non-
fumigated coupons
5 Fiberglass
5 Aluminum
5 Rubber
5 Mylar®
5 Seating
growth)
Laboratory-
Laboratory
To demonstrate sterility
Twice per
23 total:
Qualitative
Sterilized
negative
of coupons and
study
5 stainless-
(growth or no
Negative
control (RTP
extraction materials and
steel coupons
growth)
Control
Microbiology
methods
and
Coupons
Laboratory
only)
3 coupons
each of 6
materials
tested (for a
total of 18)
Procedural blank coupons were not inoculated but were collocated with the test coupons, both spatial
and temporal, during fumigation and were used to determine the extent of cross-contamination from
sample to sample during collection. Positive control coupons were inoculated in the same manner as
the test coupons but were not exposed to MB. Positive control coupons traveled to the study site but
remained in the sample shipment cooler for the duration of the study. Negative control coupons were
not inoculated but were packaged in the same manner as the test coupons, traveled to the study site,
remained in the sample shipment cooler, and were not exposed to MB. Because procedures required
for packaging coupons into envelopes are not strictly aseptic, these coupons were not guaranteed to
be sterile. Accordingly, positive growth results from these control coupons should not be interpreted
to indicate a compromise in sample integrity through contamination. Lastly, laboratory-sterilized
negative control coupons were received from Yakibou, Inc., and autoclaved (1 hour gravity cycle) upon
15
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arrival at the RTP Microbiology Laboratory to sterilize them. These coupons were used to assess the
handling technique of laboratory personnel during culturing procedures. Growth from these coupons
would indicate compromised sample integrity through contamination within the laboratory.
Qualitative testing of the spatial assessment of efficacy and quantitative testing of the temporal
assessment of efficacy are discussed in more detail in the following sections.
2.4.2.1 Spatial Assessment of Efficacy (Qualitative Test)
Two duplicate coupons of each material type (nylon loop pile carpet, fiberglass wall paneling,
aluminum, rubber flooring, Mylar® on polycarbonate, and vinyl seating), along with three procedural
blanks (non-inoculated coupons of three different materials) were positioned at 20 locations
throughout the enclosed fumigation volume before fumigation as shown in Figure 10.
Sample 17, Outside Skin —\
r— Sample 14 Undercarriage AC Duct
/ \ / r— Sample 12, On\S
j— Sample 13, On Floor / ^ Sample 19, Outside Skin q'
Sample 13, Outside Skin
I Sample 7, Inside Panel —v
Sample 12, On\Seat
Sample 5, Return HVAC
~~ mi 1 on
LSampte 1. Inside Panel Sample 9, Inside Panel fl
Sample 4, Inside Panel Sample 8, inside Panel : ;7T*7 ^ . '
aa i I'—j
Sample 2, Inside Panel
Sample 15 Undercarriage AC Duct
I'D /
Computers —'
Sample 3; Inside Panel
Sample 20, Outside Skin
~1
MTA Switch Box
Sample 16 Undercarriage AC Duct Sample 10, InsWe Panel —1
Figure 10. Schematic diagram of railcar showing locations of test coupons
Coupons were placed inside closed panels, outside on the skin of the railcar, and under the railcar.
These coupons remained within the enclosed volume during fumigation and were retrieved after the
MB air concentration within the fumigated volume was less than 1 ppm. After removal from the
fumigated enclosure area, the coupons were aerated, cold-packed, and transported to the RTP
Microbiology Laboratory, where they were qualitatively analyzed for surviving spores accordance with
MOP 6566. Briefly, the coupons were stored in a biological safety cabinet, then carefully and
aseptically removed from Tyvek® envelopes and placed into a bacterial growth medium of 10 milliliters
of TSA. Culture tubes, 18- by 150-mm sterile borosilicate glass tubes (Fisherbrand Cat. No. 14-961-31),
containing broth and the coupon then were incubated at 35 °C for 7 days. Periodically (on days 1, 3,
and 7), the turbidity of the tubes was observed and the results recorded. Turbid media indicated the
presence of bacterial growth and therefore incomplete decontamination. Figure 11 shows
representative turbid and lucid culture tubes.
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Figure 11. Lucid (left) and turbid (right) culture tubes representing negative and positive growth,
respectively
2.4.2.2 Temporal Assessment of Efficacy (Quantitative Test)
To assess fumigation efficacy as a function of time, two replicates of each coupon type (nylon loop pile
carpet, fiberglass wall paneling, aluminum, rubber flooring, Mylar® on polycarbonate, and vinyl
seating), along with six procedural blanks, one of each material type (non-inoculated coupons), were
retrieved from the tented enclosure at 6, 12, 18, 24, and 30 hours into the fumigation process. All
coupons for a particular time-point were attached to a spring that held the set of coupons together.
The spring was pulled from the extraction point using a string. Samples were allowed to aerate, then
they were double-bagged, cold-packed, and transported to the RTP Microbiology Laboratory for
extraction and analysis. The laboratory used an aseptic technique to place the coupons into 18- by
150-mm sterile borosilicate glass tubes containing 10 milliliters of phosphate-buffered saline with
Tween20 (PBST). Each vial then was sonicated for 10 minutes at 42 kilohertz and 135 watts in
accordance with MOP 6566. Then the tubes were continuously vortexed for 2 minutes to further
dislodge spores from the coupons. Immediately before dilution or plating, each vial briefly was re-
vortexed to homogenize the sample. The resulting extracts were subjected to five sequential 10-fold
serial dilutions (MOP 6535a), and 0.1 milliliter of each dilution was inoculated onto TSA plates, spread
with sterile beads (MOP 6555), and incubated at 35 ± 2 °C for 18 to 24 hours. After incubation, the
CFUs were manually enumerated. Figure 12 shows the Ba Sterne strain spore colonies.
Figure 12. Representative dilution plates after incubation containing Ba Sterne strain spore colonies
recovered from coupons
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2.5 Pre- and Post-Fumigation Sponge Stick Sampling
The surrogate spores remained on the test coupons and inside Tyvek® envelops throughout the study
(during transportation to the site; distribution, fumigation, and collection processes in the railcar; and
transportation back to the laboratory). However, sponge stick samples were collected from surfaces in
the railcar before the test coupons were deployed to gain an understanding of background
contamination within the railcar and after the test coupons were retrieved at the end of the fumigation
aeration cycle to determine if the test organism escaped the Tyvek® envelopes or if other
contamination was present on surfaces after the fumigation. Sponge stick sampling was conducted in
accordance with MOP 3144 and based on the Centers for Disease Control and Prevention (CDC)
protocols (CDC, 2012). A total of 11 sponge stick samples were collected, 4 before and 7 after the
fumigation process. Two blank sponge stick samples also were collected.
2.6 Activated Carbon Scrubber System Deployment
An activated carbon scrubber system was leased from General Carbon Corporation (Paterson, New
Jersey) and was delivered to the study site on Monday morning, July 13, 2015. The system was
unloaded from the truck and staged for subsequent placement and installation. Figure 13 shows the
activated carbon scrubber system.
Figure 13. Activated carbon scrubber system installed on the railcar
The scrubber system consisted of two scrubber vessels (General Carbon TV-1000) with each vessel
containing approximately 900 pounds of coconut-shell-based activated carbon (General Carbon 4x8S),
one 2-horsepower centrifugal blower with damper (Model 00156ES1BD56CFL, Weg Electric Corp.,
Duluth, Georgia), 50 feet of 6-inch-inner-diameter (ID) flexible rubber ducting with spring steel
reinforced helix, a PVC exhaust stack (6-inch ID and 8 feet tall), various galvanized metal joint fittings,
and a plastic ball valve. One extra vessel containing 700 pounds of activated carbon was ordered and
placed on site in case of carbon breakthrough of the two vessels. However, the extra vessel never was
18
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used. A WhisperWatt (MQ Power, Carson, California) 60-kilowatt diesel generator provided electrical
power to the blower as well as other equipment at the site.
The inlet to the scrubber system was anchored to the floor near the railcar's rear door. The flexible
duct dropped down to the concrete pad, where it penetrated the EVOH tarp. This open piece of
flexible duct was connected to a ball valve operating in the closed position during fumigation and then
opened during scrubbing. Approximately 10 feet of the flexible duct was used to connect the gate
valve to the first scrubber, and then an additional 10 feet of flexible duct connected the two scrubbers.
In addition, 10 feet of flexible duct connected the outlet of the second scrubber to the inlet of the
blower. After traveling through both vessels, the scrubbed gas was exhausted to the atmosphere
through an 8-foot-tall stack located on the positive side of the blower. The system air flow rate was
285 cfm. The entire system took two people approximately 6 hours to assemble and shakedown. A
similar higher-capacity scrubber used by Serre et al. (2016) was shown to capture more than 99% of
MB during aeration (Wood et al., 2015).
2.7 Ambient Air Monitoring
The study team monitored ambient conditions using both wireless air monitoring units and a weather
station. Before fumigation began, personnel from the EPAERT and the Scientific, Engineering, Response
& Analytical Services (SERAS) contractor deployed four ambient air monitoring stations strategically around
the railcar enclosure. Each station included a RAE System MultiRAE Pro, ERT's VIPER Data Management
System for real-time access and analysis, and a SNAPPER air sampling collection system that included a
sampling pump, Tedlar® bag, and software that can trigger air sample collection. The MultiRAE Pro
used a 10.6-electrovolt lamp photoionization detector (PID) and a wireless radio frequency modem.
The PID was calibrated to be responsive to MB using a 1.7 conversion factor2 (additional information can
be found at http://www.raesystems.com/products/multirae-family). The SNAPPER system, upon
triggering by the operator, took a 1-minute Tedlar® bag sample. The Tedlar® bag sample then was
retrieved and taken to EPA's on-site mobile laboratory, the Portable High-throughput Integrated
Laboratory Identification System (PHILIS) laboratory, for MB analysis.
After deployment, the air monitoring units were calibrated at the study site. SERAS calibrated the
MultiRAE Pro units using zero air and volatile organic chemical (VOC) standards, (isobutylene at 100
ppm). After unit calibration to the VOC standard, a bump test was conducted using MB gas at 5 ppm to
ensure that the units were detecting MB in the 3- to 5-ppm range. If any drift occurred, the units were
re-calibrated to ensure accuracy.
2.8 Leak Detection
In addition to the MultiRAE Pro units at the four stationary positions, another two MultiRAE Pro units
were used as hand-held detectors for leak testing near the tented enclosure. A team of two or more
walked the perimeter of the cordoned-off area around the railcar at least once per hour with a
MultiRAE Pro and noted any non-zero readings. When the perimeter readings were below the action
level of 0.5 ppm, the team entered the cordoned-off zone (15 feet around the perimeter of the railcar)
and approached the enclosure while noting any non-zero readings. When a reading exceeded the
action level (0.5 ppm) in the breathing zone of any team member, the team exited the area. To
address leaks, SCBAs were donned and leak survey and leak mitigation activities were conducted by
2 See RAE Systems TN-106 for the proper way to implement a conversion factor. For high concentration initial
doses, it may be desirable to use a dilution fitting. See RAE Systems Technical Note TN-167.
19
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personnel wearing appropriate PPE. Readings were taken all the way around the enclosure, including
immediately adjacent to the tarp and at tarp penetrations at multiple locations. Elevated readings
were reported to the tenting and fumigation contractor for potential leak mitigation.
3 Study Results
This section discusses the study results, including the results for the release and monitoring of MB,
railcar temperature and RH, test coupons, sponge stick sampling, the activated carbon scrubber
system, ambient air monitoring, leak detection, post-aeration air sampling, and displacement bladder
observations.
3.1 Results from Release and Monitoring of the MB
The time and amount of MB released into the railcar is provided in Table 5. Initially, 150 lbs. of MB was
introduced into the railcar over one and one-half hours. Two additional increments of MB were added,
20 lbs. (at 2.9-hours) and 15 lbs. (at 23-hours) after the fumigant initially reached the target MB
concentration. The concentrations of MB in each of the four locations inside the railcar were
monitored at different times and concentration results are shown in Figure 14.
Table 5. Time of MB Releases (lbs.) and Measured Concentrations in Rail Car
Date
Time (hr.)
Elapsed Time
(hr.)
Inside Cone,
(mg/l)
Lbs. MB
07/10/2015
1630
-1.5
26
20
07/10/2015
1720
-0.7
133
79
07/10/2015
1800
0.0
212
51
07/10/2015
2055
2.9
200
20
07/11/2015
1700
23.0
170
15
Methyl Bromide Concentration (mg/l)
ml MB/I iter 1 v b/ '
350
snn
jUU
s
ZDU
200 ^
4
1 qn
to ^ ^
•
•
i
•
150#
10(f
•
5*
•
—m—
i
t
• Top East site
• Top west
site
/est
t
•-
• Bottom East
Bottom m
ft
-5 0 5 10 15 20 25 30 35 40 45
Hours
Figure 14. Concentration of MB (mg/l) inside the tented enclosure during fumigation.
20
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3.2 Railcar Temperature and Relative Humidity Results
Radiant heaters and household humidifiers were used to raise the temperature and humidity in the
railcar. Table 6 summarizes the average temperature and RH at each coupon location inside the
railcar. The average temperature inside the railcar during fumigation was 75.4 °F, and the RH was
82.9%. These values slightly exceed the desired fumigation conditions of 75 °F and 75% RH.
Table 6. Average Temperature and RH at Designated Coupon Locations
Location ID
HOBO ID
Location
Temperature
(°F)
RH
(%)
1
34
Inside closed panel box, right rear of car
74.2
82.7
2
31
Inside closed panel box, left rear of car
74.0
85.6
3
10
Inside closed panel box, right side of car
73.7
83.2
4
49
Inside closed panel box, left side of car
75.3
83.1
5
20
In return HVAC duct under seat
76.2
82.2
6
11
Inside closed panel box, left above side door
71.8
84.2
7
22
Inside closed panel box, right front of car
76.8
81.3
8
55
Inside closed panel box, right front of car
76.7
80.1
9
47
Inside closed panel box, over front door
76.8
81.8
10
18
Inside closed panel box, conductors room left front
75.4
84.9
11
17
Inside closed panel box, conductors room left back
76.7
78.5
12
57
On seat in car
76.4
82.2
13
24
On floor between seats
74.5
86.0
14
19
Under car in HVAC duct right center of car
75.0
86.5
15
54
Under car in HVAC duct left center of car
74.9
84.9
16
29
Under car in HVAC red duct at center of car
76.4
82.2
17
48
Outside car but inside panel #372 right side of car
75.8
76.3
18
40
Outside car but inside panel #372 right side of car
76.9
78.8
19
3
Outside skin of right side of car
74.7
87.5
20
42
Outside skin of left side of car
75.1
86.7
Mean
75.4
82.9
Note: HVAC = Heating, ventilation, and air conditioning
3.3 Test Coupon Results
This section discusses the pre- and post-fumigation coupon population comparison, spatial assessment
of efficacy (qualitative test) results, and temporal assessment of efficacy (quantitative test) results.
3.3.1 Pre-and Post-Fumigation Coupon Population Comparison
The spore population densities before and after fumigation for the non-exposed test coupons were
compared. As shown in Table 7, no significant differences were detected in the population densities.
Table 7. Spore Population Densities on Pre- and Post-Fumigation Control (Non-Exposed) Coupons
BlCoupon Type
Mean Pre-Fumigation
Mean Post-Fumigation
No. Before and
Population
Population
After Fumigation
Stainless steel
2.5 x 10s
Not determined
5 before
Nylon carpet
2.0 x 10s
1.8 x 10s
3 before, 6 after
Fiberglass wall
1.3 x 10s
1.4 x 10s
3 before, 7 after
paneling
Aluminum
2.4 x 10s
2.0 x 10s
3 before, 5 after
21
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Rubber flooring
2.4 x 10s
2.0 x 10s
3 before, 7 after
Mylar®
2.3 x 10s
1.6 x 10s
3 before, 7 after
Vinyl seating
1.2 x 10s
1.4 x 10s
3 before, 7 after
The abundance of viable spores on non-exposed coupons was similar before and after the field
fumigation, indicating that time in storage did not significantly affect the spore titer on the coupons.
Recoveries from stainless steel, aluminum, and rubber flooring were within the targeted range (2.0 to
5.0 x 106). However, recoveries from nylon carpet, fiberglass wall paneling, Mylar®, and vinyl seating
coupons were lower than the amount inoculated onto these coupons but still resulted in the over 6-log
detection capability needed to evaluate the efficacy of the fumigation. These results were expected
because recoveries from steel typically are between 75 and 95% of the inoculum, while recoveries
from more porous materials historically have been between 1 and 25% of the inoculum. All coupons
were inoculated with a population density (as determined by the Bl supplier) of 4.2 x 106 CFUs per
carrier. Accordingly, the mean recovery efficiencies from stainless steel and other materials
were around 60%. The lowest recovery was 29%.
3.3.2 Spatial Assessment of Efficacy (Qualitative Test) Results
Table 8 summarizes the spatial assessment of efficacy results for all 20 coupon locations.
Table 8. Bl Results from Spatial Assessment of MB Fumigation Efficacy
Location
Material
Procedural Blanks
Bis/Total Bis
Carpet
Fiberglass
Aluminum
Rubber
Mylar"
Vinyl
Procedural Blanks (growth-positive Bis/total Bis)
1
0/2
0/2
0/2
0/2
0/2
0/2
0/3
2
1/2
0/2
0/2
0/2
0/2
1/2
0/3
3
0/2
0/2
0/2
0/2
0/2
0/2
0/3
4
0/2
0/2
0/2
0/2
0/2
0/2
0/3
5
0/2
0/2
0/2
0/2
0/2
0/2
0/3
6
0/2
0/2
0/2
0/2
0/2
1/2
0/3
7
0/2
0/2
0/2
0/2
0/2
1/2
0/3
8
0/2
0/2
0/2
0/2
0/2
1/2
0/3
9
0/2
0/2
0/2
0/2
0/2
0/2
0/3
10
0/2
0/2
0/2
1/2
0/2
2/2
0/3
11
0/2
0/2
0/2
0/2
0/2
0/2
0/3
12
0/2
0/2
0/2
0/2
0/2
0/2
0/3
13
0/2
0/2
0/2
0/2
0/2
0/2
0/3
14
0/2
0/2
0/2
0/2
0/2
0/2
0/3
15
0/2
0/2
0/2
0/2
0/2
1/2
0/3
16
0/2
0/2
0/2
0/2
0/2
0/2
0/3
17
0/2
0/2
0/2
0/2
0/2
0/2
0/3
18
1/2
0/2
0/2
0/2
0/2
0/2
0/3
19
0/2
0/2
0/2
0/2
1/2
0/2
0/3
20
0/2
0/2
0/2
0/2
0/2
1/2
0/3
Total
2/40
0/40
0/40
1/40
1/40
8/40
0/60
Switchbox
0/2
Positive Controls
growth-positive Bis/total Bis)
Not exposed
6/6
7/7
5/5
7/7
7/7
7/7
Not applicable
Negative Controls (growth-positive Bis/total Bis)
Not exposed
0/6
0/5
0/5
0/5
0/5
0/5
Not applicable
22
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As the table shows, none of the 40 fiberglass or 40 aluminum test coupons contained viable spores
after fumigation. Out of the 40 coupons of each material type, the following numbers of coupons were
positive after fumigation: 2 nylon carpet coupons, 1 rubber flooring coupon, 1 Mylar® coupon, and 8
vinyl seating coupons. No growth on any of the procedural blank (60 total) coupons suggests that
contamination did not occur during field or laboratory procedures. All 39 positive-control coupons
(inoculated but not exposed) were positive for growth. None of the 31 negative control coupons (not
inoculated and not exposed) were positive for growth. The two aluminum coupons inside the New
York City switchbox were negative for growth after fumigation.
3.3.3 Temporal Assessment of Efficacy (Quantitative Test) Results
Table 9 summarizes the temporal assessment of efficacy results for the quantitative test of spore
survival.
Table 9. Results from Temporal Assessment of MB Fumigation Efficacy
Time
Point
(hours)
Test
No.
Test Coupons and Procedural Blanks
(total CFUs recovered)
Carpet
Fiberglass
Aluminum
Rubber
Mylar"1
Vinyl
6
Test 6
603,500
532,500
588,500
721,000
240,000
611,000
12
Test 12
494,000
347,000
539,000
425,000
543,500
510,500
18
Test 18
186,000
164,500
133,000
184,500
183,850
146,000
24
Test 24
5,300
230
485
186
1,620
97
30
Test 30
0
5
0
0
0
0
Analysis of the time-series coupons showed viable spores (10 CFUs) were recovered during filter
plating from only one of the two replicate fiberglass coupons exposed for 30 hours, resulting in an
average recovery of 5 CFUs. The remaining 11 coupons of various material types showed zero
recovered viable spores. Log reductions (LR) for all Bis during the quantitative temporal assessment
portion at 30 hours after exposure were greater than or equal to 6 LR for all coupons except for the
fiberglass coupon, which had an LR value of 5.5. At the 24-hour exposure time, efficacy was greater
than or equal to 2.5 LR for all coupons.
3.4 Sponge Stick Sampling Results
Table 10 summarizes the results from the surface sponge stick wipe samples.
Table 10. Sponge Stick Sample Recovery Results
Sample
Sample ID
Location
Pre- or Post-
Recovery of Target
No.
Fumigation
Organism (CFUs)
Swabl
S-BCKl
Floor, rear of railcar
Pre
0
Swab2
S-BCK2
Floor, center of railcar
Pre
0
Swab3
S-BCK3
Seating
Pre
0
Swab4
S-BCK4
Ceiling
Pre
0
Swab5
S-BCK5 (blank)
Blank
Pre
0
Swab6
S-P3
Inside panel
Post
0
Swab7
S-P4
Inside panel
Post
0
Swab8
S-P5
Inside panel
Post
0
Swab9
S-P6
Inside panel
Post
0
Swab 10
S-P7
Inside panel
Post
0
Swabll
S-P10
Inside panel
Post
0
Swab 12
S-Pll
Inside panel
Post
0
Swab 13
S-P30 Blank
Blank
Post
0
23
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Four pre-fumigation and seven post-fumigation surface wipe samples were collected. An abundance of
background organisms were found. However, Ba Sterne strain spores were not found on pre- or post-
fumigation sponge stick surface wipe samples. The two blank surface samples collected showed no
growth based on microbiological analysis.
3.5 Activated Carbon Scrubber System Results
Three activated carbon samples were placed on the inlet side of the first scrubber. Each of the three
activated carbon samples was contained in a nylon mesh sock that allowed MB and all other potential
contaminants to adsorb into the carbon. One of these carbon samples subsequently was analyzed to
verify that the carbon met the regeneration acceptance criteria, which it did.
Once the 36-hour fumigation time had been achieved, the activated carbon scrubber system was used
to capture MB from the tented area. MB levels were measured between the carbon vessels and at the
exit of the second carbon vessel. This procedure allowed personnel to monitor breakthrough of the
carbon beds and connect a third vessel into series, if necessary. Measurements were taken using a
MultiRAE Pro Handheld PID (RAE Systems, Santa Clara, California). Figure 15 shows the results.
MultiRAE Pro Scrubber Monitoring: MB Cone, (ppm)
Figure 15. MB concentration between scrubbers and in-stack carbon breakthrough results
Scrubbing was initiated at 0600 on July 12, 2015, with breakthrough on the first scrubber occurring at
0630. The MB concentration in the outlet from the first scrubber was monitored until 0650, when the
monitor read 10 ppm (Figure 15). At this time, the monitoring point was changed to the exit stream
from the second scrubber. Breakthrough from the second scrubber occurred at approximately 0940.
The scrubber operation continued until 1100, when the monitor readout from behind the second
scrubber approached 10 ppm.
At the end of active aeration with the scrubber, the air inside the tented area was monitored using the
MultiRAE Pro and read 20 ppm. The fumigation contractor pulled the tarp from the railcar at 1200,
and the railcar was allowed to aerate for the rest of the day.
24
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3.6 Ambient Air Monitoring Results
Outdoor ambient air was monitored throughout the fumigation process. Perimeter monitoring was
continuously conducted during fumigation using four MultiRAE Pro units. The study team used the
readings to determine compliance with the 0.5-ppm MB action level during fumigation operations
developed for this study. Any readings exceeding the action level triggered the SNAPPER system, which
collected a grab sample for analysis by the PHILIS mobile laboratory. The MultiRAE Pro unit readings
exceeded 0.5 ppm nine times during the fumigation process, and each time, the SNAPPER system
activated the sampling pump to fill a Tedlar® bag. In addition, the SNAPPER system was activated eight
other times during the fumigation process to collect background samples. (During background
sampling, the MultiRAE Pro units did not exceed 0.5 ppm). After a bag was filled at any of the
stationary monitoring locations, it was transported to the on-site PHILIS mobile laboratory for analysis.
Table 11 summarizes the PHILIS laboratory results.
Table 11. MB Concentration Results from Tedlar® Bag Air Samples Analyzed by PHILIS Laboratory
Sample ID
Sampling Location and Time
Result
Reporting
Limit
Unit of
Measure
09851
Location 1 Background SNAPPER 12, 07/10/15, 1325
u2
0.500
ppm v/v3
09852
Location 2 Background SNAPPER 15, 07/10/15, 1326
u
0.500
ppm v/v
09853
Location 3 Background SNAPPER 22, 07/10/15, 1327
u
0.500
ppm v/v
09854
Location 4 Background SNAPPER 24, 07/10/15, 1328
u
0.500
ppm v/v
09855
Location 1 Hit Line 40, 440-ppb SNAPPER 12, 07/10/15,
1641
u
0.500
ppm v/v
09856
Location 4 Hit Line 39, 310-ppb SNAPPER 24, 07/10/15,
1809
u
0.500
ppm v/v
09857
Location 4 Sample Line 39, 420-ppb SNAPPER 24,
07/10/15, 1910
u
0.500
ppm v/v
09858
Location 1 Sample Line 12, 300-ppb SNAPPER 12,
07/10/15, 2004
0.79
0.500
ppm v/v
09858
Location 1 Sample 300-ppb SNAPPER (repeat),
07/10/15, 2004
0.71
0.500
ppm v/v
09859
Location 2, 300-ppb Box 15, Line 133, 07/11/15, 0001
U
0.500
ppm v/v
09860
Location 4, 300-ppb Box 24, Line 39, 07/11/15, 1208
U
0.500
ppm v/v
09841
Location 1, Box 12 sample, Line 40, 07/11/15, 1400
U
0.500
ppm v/v
09842
Location 2, Box 15 sample, Line 133, 07/11/15, 1400
0.79
0.500
ppm v/v
09843
Location 3, Box 22 sample, Line 127, 07/11/15, 1400
U
0.500
ppm v/v
09844
Location 4, Box 24 sample, Line 39, 07/11/15, 1400
U
0.500
ppm v/v
09845
Location 1, Box 15, 460-ppb Line 40, 07/11/15, 1701
0.52
0.500
ppm v/v
09846
Location 1, Box 15, 690-ppb Line 40, 07/11/15, 1806
U
0.500
ppm v/v
09850
Location 2 SNAPPER 15, 300+ ppb grab, 07/12/15, 1115
U
0.500
ppm v/v
Notes:
U = below reporting limit
ppb = part per billion
ppm v/v = part per million, volume/volume
In addition to the SNAPPER samples triggered by MultiRAE Pro unit readings and the background
samples collected, five other samples were analyzed using the PHILIS laboratory. The SNAPPER and
background samples were collected in Tedlar® bags and taken to the PHILIS laboratory, where the MB
in the bag was collected on carbon, followed by desorption and analysis. The five additional samples
were not collected using this conventional method. Instead, they were collected by pulling air directly
25
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into the carbon tube, followed by desorption and analysis of the MB on carbon. Table 12 summarizes
the PHI LIS laboratory results for these five samples.
Table 12. MB Concentration Results from Additional Samples Analyzed by PHILIS Laboratory
Sample ID
Sampling Location and Time
Result
Reporting
Limit
Unit of
Measure
09847
Between scrubber and 1 and 2 grab Pump 40,
07/12/15, 0725
3,100
100
ppm v/v
09848
Between scrubber and 1 and 2 grab Pump 40,
07/12/15, 0847
4,200
1,000
ppm v/v
09849
Between scrubber and stack grab 50-ppb Pump 40,
07/12/15, 0940
15
0.500
ppm v/v
09861
Off railcar seats, 07/12/15, 1304
140
5
ppm v/v
09862
Railcar air after fumigation, 07/12/15, 1304
36
5
ppm v/v
Notes:
ppb = Part per billion
ppm v/v = part per million, volume/volume
Three samples were taken from the scrubber air stream, and two samples were taken inside the railcar
during aeration. Two of the scrubber samples were pulled well after the MultiRAE Pro registered
breakthrough of the first carbon scrubber bed. MB concentration values were 3,100 and 4,200 ppm
for these two samples. One scrubber sample was taken in the stack after the second scrubber bed.
The time stamp on these samples (Table 12) can be compared to the time stamps on the MultiRAE Pro
raw data (no correction factor used) shown in Figure 11. The sample taken in the stack had a reading
of 15 ppm and was collected close to the breakthrough time given by the MultiRAE Pro unit at 0940
hours. Results for the two samples taken during aeration are discussed below in Section 3.7.
3.7 Post-Aeration Air Sampling Results
After initial active aeration through the activated carbon, the traps were opened and the railcar was
aerated naturally, with the assistance of fans, for 19 hours. Personnel then entered the railcar with a
MultiRAE Pro hand-held detector to verify that the MB concentration was below 1 ppm so that
personnel could safely enter the railcar to collect the coupons. Subsequently, MultiRAE Pro sampling
of locations near the rubber flooring (right at the floor, not near the breathing zone) resulted in
readings up to 1 ppm. When the MultiRAE Pro was placed in an opening in the seat cushion fabric (not
in the breathing zone), it had a reading above 10 ppm. Additionally, two samples were analyzed by the
PHILIS Laboratory as summarized in Table 11. The PHILIS air sample result taken on charcoal carbon
from under the seat cover correlates with the elevated MultiRAE reading taken at the same location.
However, the result for the railcar air sample analyzed by the PHILIS laboratory did not correlate with
the MultiRAE Pro monitor reading of zero throughout the railcar at that same time (see final entry in
Table 12).
3.8 Displacement Bladder Observations
After railcar aeration, the Mylar® tubes were observed to have deflated during fumigation and
contained some MB. This situation probably resulted from multiple tape-seal leaks that were
exacerbated by the turbulent air flow from the circulating fans. The air leaking from the tubes diluted
the MB-laden air and thus reduced the working MB concentration during the latter part of the
fumigation process. In the future, the Mylar® displacement tubes should be heat-sealed with a "Hot
26
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Jaw" sealer available from IMPAK Corp., and a valve should be used to fill the tubes before they are
placed in the area being fumigated.
4 Conclusions and Recommendations
The main objective of this study was to evaluate the operational aspects and the efficacy of MB for
inactivating surrogate Ba Sterne strain spores on a subway railcar. The study was conducted in an
effort to gain large-scale information on the use of MB for the decontamination of Ba spores and to
develop site-specific plans and guidance that could be modified and used for a real-world incident. At
the conclusion of the 36-hour fumigation, the railcar was aerated and test coupons were collected and
sent to a laboratory for analysis.
Study results showed that none of the 40 fiberglass or 40 aluminum test coupons contained viable
spores after fumigation. Out of the 40 coupons of each material type, the following numbers of
coupons were positive after fumigation: 2 nylon carpet coupons, 1 rubber flooring coupon, 1 Mylar®
coupon, and 8 vinyl seating coupons. No growth on any of the procedural blank (60 total) coupons
suggests that contamination did not occur during field or laboratory procedures. All 39 positive-
control coupons (inoculated but not exposed) were positive for growth. None of the 31 negative
control coupons (not inoculated and not exposed) were positive for growth.
Timed-series coupons removed from the fumigation envelope at 6, 12, 18, and 24 hours after the start
of fumigation all contained viable spores on some materials. LRs from the quantitative temporal
assessment portion at 30 hours after exposure were greater than or equal to 6 LR for all coupons
except for the fiberglass coupon, which had an LR value of 5.5. At the 24-hour exposure time, efficacy
was greater than or equal to 2.5 LR for all coupons.
The sections below discuss conclusions based on study findings for each study objective and presents
recommendations based on the study findings.
4.1 Objective 1, Conclusion
Under this objective, a QAPP was developed for the fumigation of a subway railcar using MB for
inactivating the chosen non-pathogenic surrogate spores. The QAPP was developed before the July
2015 field study and included a detailed HASP and AAMP. The SAP was incorporated into the QAPP
and was not a stand-alone document for this study because most of the sampling was covered by using
coupons made from railcar materials designed for this specific study. The HASP and AAMP are
included in Appendices B and C, respectively, for modification and use during future incidents.
4.2 Objective 2, Conclusion
This objective was to conduct the fumigation process safely, economically, and effectively. The
operational fumigation was conducted safely during July 2015. During the week of July 6, 2015, the
activated carbon scrubber was set up, the subway railcar was covered with an EVOH tarp, and
fumigation began. To prepare the railcar for this study, humidifiers, heaters, and fumigation
equipment were installed. Coupons were placed throughout the railcar on July 10. Fumigation began
that afternoon, and MB concentration inside the railcar reached the target concentration at 1800
hours that evening. MB concentration, temperature, and RH were monitored and maintained inside
the railcar throughout the 36-hour fumigation period.
27
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4.3 Objective 3, Conclusion
Under this objective, the efficacy of the fumigation was evaluated by measuring the post-fumigation
viability of Ba Sterne strain spores. To achieve this objective, 40 test coupons were made of each of
the following railcar materials: nylon loop-pile carpet, fiberglass wall paneling, aluminum, rubber
flooring, Mylar® on polycarbonate, and vinyl seat covering. The coupons were cut into 10-mm-
diameter discs and inoculated with approximately 106 CFUs per coupon using non-pathogenic Ba
Sterne strain spores and placed in sterilized Tyvek® envelopes. The coupons were placed in 20
separate locations throughout the railcar before fumigation. Three negative procedural blanks were
included at each location. Positive and negative controls of all materials also were taken to the site but
did not undergo the fumigation process.
The evaluation of efficacy of the fumigation as measured by the deployment of coupons was
successful. Contamination by non-target bacteria was not detected on any of the procedural blank
coupons. For this study all interior cabinets and panels were left in the closed position to intentionally
challenge the process. However, the standard practice for fumigation is to open as many doors,
cabinets, enclosures, etc., to accelerate fumigant movement into these areas. Spatial assessment
results show that 228 (95%) of 240 test coupons were completely negative for growth of Ba Sterne
spores at the end of the 36-hour fumigation period. Based on the temporal assessment, at the 30-hour
exposure time point, results show that on 11 of the 12 coupons, the spores were completely
inactivated, resulting in a 6-LR efficacy for five of the six materials tested. Overall, the MB treatment
was efficacious.
4.4 Objective 4, Conclusion
This objective required evaluating the effectiveness of activated carbon for capturing the MB fumigant
during the aeration portion of the fumigation cycle and monitoring MB breakthrough status of the
activated carbon during aeration of the railcar and when the railcar MB concentration fell below 0.5
ppm. An activated carbon scrubber system was used at the conclusion of the 36-hour fumigation
period and monitored for breakthrough. The scrubber was effectively deployed and used to reduce
the MB concentration inside the railcar from approximately 55,000 to 20 ppm in 5 hours.
Breakthrough was monitored for both carbon beds set up in series using a MultiRAE Pro instrument.
4.5 Objective 5, Conclusion
This objective was to monitor the effectiveness of MB containment and provide for the health and
safety of workers during the entire fumigation process. Ambient air monitoring was conducted by
placing PIDs at four stationary locations around the perimeter of the cordoned-off study area. In
addition, hand-held monitors with the same technology were used to leak test the tenting materials
and to monitor locations not covered by the four stationary monitors. This MB monitoring method
was effective and provided a successful health protection measure. MB monitors detected small leaks
near the tented area, and leak reduction measures were deployed as needed. Monitoring of the
aerated railcar effectively provided health protection for re-entry. However, one PHI LIS laboratory air
sample reading did not correlate with the MultiRAE Pro unit. This discrepancy requires further
investigation. In addition, when the MultiRAE Pro and the PHILIS sampled the seat cushion fabric (not
in the breathing zone), reading were above 10 ppm. This result also requires further investigation
related to aeration time, reoccupation, and reuse.
28
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4.6 Recommendations
Based on several positive test coupon results from this study, it is recommended that the fumigation of
a railcar for Ba be extended from 36 to 48 hours and that the temperature, RH, and MB concentration
be maintained above the set points of 75 °F, 75% RH, and 212 mg/L, respectively, during the 48-hour
fumigation period. In addition, based on the result of eight positive results for the vinyl seat covering
coupons, it is recommended that railcar seating material be sprayed down with pH-adjusted bleach
before fumigation to aid in the inactivation of So spores.
After the aeration phase, additional air samples were collected from surfaces in the railcar, and small
amounts of MB appeared to be desorbing from some surfaces. Additional investigation is needed to
characterize MB desorption from surfaces after fumigation.
This operational study and update of the operational documents improves the capacity of U.S.
agencies to respond to and recover from a biological incident in a subway system.
5 References
Calfee, M.W., Y. Choi, J. Rogers, T. Kelly, Z. Willenberg, and K. Riggs. 2011. Lab-Scale Assessment to
Support Remediation of Outdoor Surfaces Contaminated with Bacillus anthracis Spores. Journal of
Bioterrorism and Biodefense 2, 1-8.
Centers for Disease Control and Prevention (CDC). 2012. Surface sampling procedures for Bacillus
anthracis spores from smooth, non-porous surfaces. Revised April 26, 2012. On-line Address:
http://www.cdc.gov/niosh/topics/emres/surface-sampling-bacillus-anthracis.html
Corsi, R. L., M.B. Walker, H.M. Liljestrand, H.F. Hubbard, and D.G. Poppendieck. 2007. Methyl bromide
as a building disinfectant: interaction with indoor materials and resulting byproduct formation. Journal
of the Air & Waste Management Association, 57(5), 576-585.
Hezemans-Boer, M., J. Toonstra, J. Meulenbelt, J.H. Zwaveling, B. Sangster, and W.A. van Vloten. 1988.
Skin lesions due to exposure to methyl bromide. Archives of Dermatology 124 (6): 917-921. June
International Agency for Research on Cancer. 1986. IARC Monographs on the Evaluation of the
Carcinogenic Risk of Chemicals to Humans: Some Halogenated Hydrocarbons and Pesticide Exposures.
Volume 41. World Health Organization, Lyon.
Jordi, A.U. 1953. Absorption of methyl bromide through the intact skin: A report of one fatal and two
non-fatal cases. Journal of Aviation Medicine 24, 536-539
Juergensmeyer, M.A., B.A. Gingras, R.H. Scheffrahn, and M.J. Weinberg. 2007. Methyl Bromide
Fumigant Lethal to Bacillus anthracis Spores. Journal of Environmental Health 69, 24-26, 46, 50.
National Institute for Occupational Safety and Health (NIOSH). 2012. Pocket Guide to Chemical
Hazards. Department of Health and Human Services, CDC, and NIOSH.
National Toxicology Program. 1992. Toxicology and Carcinogenesis Studies of Methyl Bromide (CAS
No. 74-83-9) in B6C3F1 Mice (Inhalation Studies). Technical Report No. TR-385.
Serre, S., L. Mickelsen, M.W. Calfee, J.P. Wood, M.S. Gray, R.H. Scheffrahn, R. Perez, W.H. Kern, and N.
Daniell. 2016. Whole-building decontamination of Bacillus anthracis Sterne spores by methyl bromide
fumigation. Journal of Applied Microbiology 120: 80-89. doi:10.1111/jam.12974
29
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United States Environmental Protection Agency (EPA). 1988. Health Effects Assessment for
Bromomethane. EPA/600/8-88/022. Environmental Criteria and Assessment Office, Office of Health
and Environmental Assessment, Office of Research and Development, Cincinnati, OH.
EPA. 2006. Report of Food Quality Protection Act (FQPA) Tolerance Reassessment and Risk
Management Decision (TRED) for Methyl Bromide and Reregistration Eligibility Decision (RED) for
Methyl Bromide's Commodity Uses. Case No. 0355. EPA 738-R-06-026. August.
EPA. 2011. Systematic Investigation of Liquid and Fumigant Decontamination Efficacy against
Biological Agents Deposited on Test Coupons of Common Indoor Materials. EPA 600-R-076. August.
EPA. 2012. Compatibility of Material and Electronic Equipment with Methyl Bromide and Chlorine
Dioxide Fumigation. EPA 600-R-12-664. October.
EPA. 2013. Material Effects of Fumigants on Irreplaceable Objects, Short- and Long-term Effects. EPA
600-R-13-216. September.
EPA. 2014. Methyl Bromide Decontamination of Indoor and Outdoor Materials Contaminated with
Bacillus anthracis Spores. EPA/600/R-14/170.
EPA. 2015. Methyl Bromide Field Operation Guidance (MB FOG) Report. Consequence Management
and Advisory Division. April 13.
Weinberg, M.F., R.H. Scheffrahn, and M.A. Juergensmeyer. 2004a. PART 1: Efficacy of Methyl Bromide
Gas against Bacillus anthracis and Allied Bacterial Spores in Final Report: Whole-Structure
Decontamination of Bacillus Spores by Methyl Bromide Fumigation. EPA, Small Business Innovation
Research Phase II.
Weinberg, M.J., and R.H. Scheffrahn. 2004b. PART 2: Whole-Structure Decontamination of Bacterial
Spores by Methyl Bromide Fumigation in Final Report: Whole-Structure Decontamination of Bacillus
Spores by Methyl Bromide Fumigation. EPA, Small Business Innovation Research Phase II.
Wood, J.PV M.J. Clayton, T. McArthur, S.D. Serre, L. Mickelsen, and A. Touati. 2015. Capture of methyl
bromide emissions with activated carbon following the fumigation of a small building contaminated
with a Bacillus anthracis spore simulant. Journal of the Air & Waste Management Association 65, 145-
153.
Yamomoto O, H. Hori, I. Tanaka, M. Asahi, and M. Koga. 2000. Experimental exposure of rat skin to
methyl bromide: a toxicokinetic and histopathological study. Archives of Toxicology Feb 73 (12): 641-8.
30
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Appendix A. Lessons Learned
As part of the Department of Homeland Security's (DHS) Underground Transport Restoration (UTR)
project, several federal agencies conducted a scientific study to evaluate methyl bromide (MB) as a
fumigant for decontaminating subway railcars contaminated with Bacillus anthracis (Ba) using non-
pathogenic Ba Sterne strain spores. At the conclusion of the project, important lessons were learned.
One of the project goals was to document on-site observations and identify areas for potential
improvement. These important findings are summarized below.
• When power is not available, redundant emergency power systems are essential. One on-site
generator failed before the fumigation began and was replaced before the MB was added to
the fumigation envelope.
• Samples should be aerated before shipment to the laboratory for analysis. Low concentrations
of MB were desorbing from the Tyvek envelopes after removal from the fumigation zone.
• Most leaks around the system correlated with the removal of the timed-series sample from the
fumigation envelope. During an actual event, this leaking may not occur, h However, the time
for removing samples should be minimized to reduce the amount of fumigant that escapes the
fumigation envelope.
• Adequate make-up air during the scrubbing phase may help expedite the scrubbing. This
make-up air should be balanced with the desired space velocity through the carbon. Fresh air
pathways are needed to flush out any remaining MB.
• Personnel blood samples should be collected after the fumigation to verify that personnel have
not been exposed to MB. Individual air monitors also can be used on personnel entering the
hot (exclusion) zone to monitor exposure to MB.
• Additional MB gas monitors are beneficial for multiple railcars. Redundant systems are needed
in case a fumiscope fails. Non-dispersive infrared (NDIR) systems are available that are more
accurate and less susceptible to positive and negative interferantsinterferents than
fumiscopes.
• Additional work is required to study the desorption of MB from materials, especially for
materialsfor materials containing closed cell foam.
• Fall protection should be considered for contractors personnel working at heights and/or in
areasthat work where falls could occur.
For this study, all interior cabinets and panels were left in the closed position to challenge the
process. However, the standard practice for fumigation is to leave open as many door,
1
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APPENDIX B
U.S. ENVIRONMENTAL PROTECTION AGENCY
CBRNE CONSEQUENCE MANAGEMENT ADVISORY DIVISION
& NATIONAL HOMELAND SECURITY RESEARCH CENTER
SAFETY, HEALTH, AND ENVIRONMENTAL MANAGEMENT PROTOCOL
FOR FIELD ACTIVITIES
referred to as
Health and Safety Plan (HASP)
for
The Field Trial Evaluation of Methyl Bromide Fumigation of a Biological
Agent Surrogate in a Rail Car
Livermore, CA
6-15 July, 2015
(Fumigation 11-12 July 15)
Version 1.0
22 June 2015
1
-------
Revision Date: 6/26/15
Protocol No.
SAFETY, HEALTH, AND ENVIRONMENTAL MANAGEMENT PROTOCOL
FOR FIELD ACTIVITIES
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina
PURPOSE
To identify site/project specific safety and health hazards related to the proposed methyl bromide (MB) fumigation
test of a rail car as part of an underground transit restoration project. Additionally, this plan outlines emergency
and environmental management and procedures.
All personnel involved in the project on site, regardless of employer, must read, understand, and acknowledge the
contents of this plan.
SCOPE
The project will occur on the US Government property under control of the Department of Energy (DOE), Sandia
and Lawrence Livermore National Laboratories. Site specific environmental health and safety requirements under
the DOE will have overall precedence. Approval to allow Sterne strain (34F2) on site is authorized in Sandia
document IBCPR #:2016-04-29-TW
PARTI. PROJECT INFORMATION
Project Title: Methyl Bromide Fumigation of Surrogate Spores (B. anthracis Sterne) in a Rail Car
Dates/Duration of Field Activity: 6-15 July, 2015 (Fumigation 11-12 July)
Principal Investigator (PI): Shannon Serre (OEM); Leroy Mickelsen (OEM)
Laboratory, Division, Branch: Office of Emergency Management (OEM)/Chemical, Biological, Radiological, and
Nuclear (CBRN) Consequence Management Advisory Division (CMAT); with safety support from Office of
Research and Development (ORD) National Homeland Security Research Center (NHSRC)
Site (or Cell): Leroy Mickelsen: 919-937-7011
Field Site Name/Address:
Sandia National Laboratory
Livermore, CA
Site Type:
Federal government facility, national laboratory
National Environmental Policy Act (NEPA) Requirements
Will the project encounter / impact endangered species (plants / animals)? No
Will the project encounter / impact any historic sites (burial grounds, monuments, etc.)? No
Will the project involve drilling, soil samples, or any soil impact? No
Will the project involve any potential uncontrolled impacts to water / air and/or discharges approaching regulatory
limits? None anticipated
NOTE: If YES to any of the above, the NEPA process must be completed prior to execution of field study.
ADDITIONAL NOTES:
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(1) Structural fumigations using MB has been phased out under the Montreal Protocol and the Clean Air Act
because it has been recognized as a stratospheric ozone depleting substance. Critical use exemptions
(CUEs) are permitted under Section 604(d) of the Clean Air Act and the Montreal Protocol on Substances
that Deplete the Ozone Layer (Protocol). The CUE must be obtained from EPA prior to use of the
product. The MB will be contained within the structure during fumigation and scrubbed via a charcoal bed
to eliminate intentional discharge to the environment.
(2) This is a joint project, with primary funding from the Department of Homeland Security, Science and
Technology Directorate. The NEPA review specific to California requirements has been conducted by
Sandia National Laboratories (SNL). SNL is in contact with all state and local authorities and has
received appropriate approvals prior to start work.
SUBMITTED BY
PI Signature: Date:
(Principal Investigator must be an EPA employee)
REVIEW:
NHSRC SHEM: Date:
APPROVALS
NHSRC: Date:
(Obtain signatures above prior to sending to the ORD SHEM Office (MD-D343-02 or
archer.john@epa.gov)
ORD SHEM Office: Date:
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Acknowledgement:
Required by ALL personnel on site, including visitors, associated with this field study.
(1) I have read, understand, and will comply with the requirements of this site specific HASP;
(2) I will report all accidents, injuries, illnesses, exposures, and/or near misses immediately to the EPA
Incident Commander;
(3) I possess current training (including daily safety briefings as required), medical surveillance, and
clearances to perform the tasks assigned to me on site;
(4) I will at all times don the appropriate personal protective equipment (PPE) and following appropriate
safety protocols/requirements for the tasks engaged in;
(5) I will comply with all Federal, State, Local regulations and site specific policy related to this activity.
NAME (PRINT)
EMPLOYER
SIGNATURE
DATE
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PART II. PROJECT INFORMATION
A. Detailed Study Description (Research or Monitoring Protocol should be attached if applicable):
The United States Environmental Protection Agency (EPA) is conducting a project to evaluate methyl
bromide (MB) as decontamination tool for mitigating Bacillus anthracis (Ba) contamination. This work is a
component of the Department of Homeland Security (DHS) led and funded Underground Transit
Restorations (UTR) program. Lawrence Livermore (LLNL) and Sandia National (SNL) Laboratories have
been contracted by DHS to implement a rail car fumigation. EPA is the interagency lead for such activities
and will be providing oversight and guidance, and much of the execution. The fumigation contractor will be
hired by LLNL. SNL will obtain all required NEPA and state and local environmental permits, as well as
provide a site for the fumigation, including site security. The Methyl Bromide Application Services
Provider will fumigate a rail car mounted on a flatbed trailer, using MB at 200 - 300 milligrams per liter
(mg/L) (51,279 - 77,291 parts per million {ppm}) for 48 hours as described in their Statement of Work. The
fumigated rail car will contain surrogate spores that are enclosed in a Tyvek envelope and distributed
throughout the structure. Samples of the surrogate spores will be collected at specified time intervals via a
collection system outside of the rail car. Upon completion of the 48-hour contact time, the MB will be
exhausted through carbon filtration and collected for recycling.
Direct reading, "real time" site monitoring (zone and perimeter) will be conducted by EPA Office of
Emergency Management.
The site, although containing elements of Hazardous Waste and Emergency Response Operations
(HAZWOPER) practices, is a field research evaluation and not subject HAZWOPER requirements specific
to site clean-up.
The site will be attended during 24 hour/day during all active phases of fumigation (generation, contact
time, scrubbing) by a minimum of an IC, SO, and monitoring staff.
In addition to EPA/RTP approval for use of Ba Sterne as a biosafety level 2 agent, the SNL, California
Institutional Biosafety Committee has approved the use for this project under Project Title: Operational
Testing Demonstration for Decontamination of a Railcar, Expiration date: 2016-04-29 (See attachment 1,
OUO)
The conditions that will be evaluated for the study will be ambient temperature, relative humidity, elevated
MB concentrations during fumigation, and increased time as compared to pest control structural
fumigations.
The objective of the project is to:
• Conduct the MB fumigation process safely, economically and effectively.
• Monitoring MB concentrations inside the structure during fumigation to assure concentration-time
(CT) requirements have been reached and maintained.
• Monitoring temperature (T) and relative humidity (RH) inside and outside the structure.
• Evaluate the efficacy of the fumigation by measuring the viability of surrogate spores placed on
throughout the structure to be fumigated.
• Operationalize the use of activated carbon for the capture of the MB fumigant during the aeration
cycle of the fumigation and evaluate its effectiveness at this field scale.
• Monitor to ensure the containment of MB and to ensure the safety of workers during the entire
fumigation process.
• Assess the breakthrough status of the activated carbon and determine an estimate of fumigant off-
gassing for re-entry time calculations.
This project is currently being planned by an interagency planning team and testing is expected to be
conducted in mid July 2015 at Sandia National Laboratory outdoor campus, CA.
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B. Personnel (List EPA personnel only)
See Attachment 1. EPA Personnel Qualifications
C. Medical Monitoring.
1) All personnel entering the contamination reduction zone (warm zone) or must have received medical
clearance to don respiratory protection, up to SCBA, within one year prior to the study.
2) EPA staff likely to enter the contamination reduction zone must receive baseline bromide in urine (or
equivalent as directed by board certified occupational and environmental medicine (OEM) physician)
evaluation prior to site visitation. Any EPA personnel with likely exposure (even with respiratory
protection) must receive post exposure bromide in urine and/or blood follow-up as directed by the site SO
or OEM physician. Non EPA staff must be medically monitored in accordance with their employer's
occupational health requirements.
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D. Location(s) where work will be conducted (include site name and address)
Site Name: Sandia National Laboratory
Address: 7011 East Ave, Livermore, CA 94550
Is this site a remote iocation or an urban setting X_ ?
Will the project require overnight operations? Yes _X_ No
Site map identified below.
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Will research equipment or other materials be decontaminated in the field?
If yes, describe decontamination procedures and waste generated.
Yes X No
V1.0 26Junl5
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MB fumigation of the rail car. Residual MB after fumigation will be scrubbed through carbon bed filters.
Waste materials will include disinfected test surfaces (coupons) with indicator strips (Bacillus spores),
PPE (non-contaminated), gas cylinders to be returned to vendor, and carbon contained in filtration
unit(s) will be returned to vendor for recycling.
E. Contact Personnel for Field Site
Contact Name: Mark Tucker
Title: Program Manager
Phone #: (c) 505-235-6782
F. Transportation
Will a Government vehicle to be taken? _ Yes _X_ No
If yes, has the most suitable and fuel efficient vehicle for the task been chosen? _ Yes No: NA
Please describe.
If yes, is a first aid kit available? _X_Yes No
If yes, is a fire extinguisher available ? _X_Yes No
If yes, please list other supplies that will be available.
G. Copies of Forms (Motor Vehicle Accident, Injury/Illness) Available? Yes
H . Identify All Parties Involved in the Field Study:
ORGANIZATION
Federal / Contractor
ROLE
Est Personnel on Site
EPA
Federal
PI, PM, Safety
8
Sandia
Federal/GOCO
Logistics, Security,
2
LLNL
Federal/GOCO
Logistics, Security,
1
University of FL - Davie
State Govt
Fumigation Consultant
3
Clark Pest Control
Contractor
Fumigator
4
Dynamac
Contractor
Support to EPA
1
DHS
Federal
Oversight observation
2
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PART III. HAZARD INFORMATION
A. Potential Hazards Encountered during Field Study
Task
Hazard Category
Hazard
Controls
PPE
Site Preparation
Physical
Physical - Climbing/Falling
Training &
Education
Leather Gloves
Hard hat
Tarping rail car
Fall Protection
Fall Harness
Reflective Vest
Site Preparation
Physical
Physical - Heat Cold
Monitoring
Sunscreen / clothing
Slips, trips, falls
Site maintenance
Fumigation
Chemical
Chemical - Gases
Process Isolation
Self-Contained Breathing
Apparatus (SCBA)
Loose clothing, long
sleeve shirt,
socks, shoes
Methyl bromide
exposure
Occupy Cold Zone
as identified by
Monitoring (Default,
50')
Fumigation
Chemical
Chemical - Gases
Other - List Below
Fire/Explosion
Methyl Bromide
interaction with
incompatible materials
Distance / Initiate
911
Site Ambient Air
Monitoring
(within exclusion
zone)
Chemical
Chemical - Gases
PPE
SCBA
Loose clothing, long
pants, socks,
shoes.
Use of instruments to
detect gas leaks, potential exposure to
concentrations above Threshold
Limit Value (TLV)
PPE
Handling Surrogate
Materials
Biological
B. Anthracis Sterne (vaccine
strain) BSL-2 practices
Other - List Below
Containment
N-95 (in event of spill)
Nitrile Gloves, Tyvek suit
(optional)
Handling
Compressed Gas
Cylinder
Physical
Physical - Impact
Other - List Below
Secure Cylinder,
cap on when not in
use
Leather gloves
Steel toe boots
Leak/"bubble" test
Safety glasses
Sample collection
Chemical/
Biological
Methyl bromide
exposure/ biological
surrogate exposure
PPE/ Monitoring
SCBA
Tyvek (optional) , Nitrile
gloves
Project Oversight
Physical
Physical - Sunburn
Guarding
Sunscreen
Scrubber Operation
Chemical
Gasses, breakthrough
of filter
Activated Carbon
filtration; monitoring
SCBA
(in emergency), loose
clothing, long
pants, socks,
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Task
Hazard Category
Hazard
Controls
PPE
shoes
Physical
Noise (diesel generator)
Distance
Ear plugs or muffs
* When respirator is checked, personnel using respirators must have been properly trained and fitted for the
respirator within the past twelve months. Individuals using a respirator must be enrolled in the Respiratory
Protection Program to remain eligible to wear respiratory protection equipment of any kind.
See attachment 2 for Site Specific PPE Requirements Summary Table
1. Identify any locations on the site that EPA personnel are restricted from entering. (Note: Employees are
not authorized to enter confined spaces.)
Rail car while under fumigation conditions. Hot (Exclusion) zone and warm zone are restricted to
personnel with direct task in those areas (i.e., ambient air monitoring, fumigation operations).
Approval from Incident Commander is required for any entry.
2. Identify any pre-field visit vaccinations that are necessary.
Tetanus
Hepatitis A (wastewater)
Hepatitis B (blood, body fluids)
Other
X None required
NOTE: Pre visit baseline bromide in urine/blood is required for EPA staff who may enter the
contamination reduction (warm) or exclusion zone. If any probability of exposure, post visit
bromide in urine/blood will be required as an element of occupational exposure assessment.
3. Describe the level of physical exertion required:
Low (Office work)
X Moderate (Frequent walking)
High (Frequent climbing, lifting)
B. Toxicity of Materials to be Used
1. Will any chemical materials be used that are considered hazardous agents by the ORD Safety, Health,
and Emergency Management (SHEM) Office?
A hazardous agent, as defined by the ORD SHEM Office, exhibits one or more of these characteristics:
Has a lethal dose 50 (LD50) (oral, rat) < 50 mg/kg
body weight
Has an inhalation lethal concentration 50 toxicity
(rat) < 2 mg/liter or < 200 ppm
Has a dermal LD50 toxicity (rabbit) < 200 mg/kg
Has an occupational exposure limit (Occupational
Safety and Health Administration {OSHA},
National Institute for Occupational Safety and
Health {NIOSH} or American Conference of
• Is an infectious biological agent (as defined by
Centers for Disease Control and Prevention
{CDC} and/or National Institutes of Health {NIH})
• Is an explosive or violently reactive agent (shock
sensitive, peroxide forming, and/or incompatible
with moisture/air)
• Is a sensitizing agent.
• Nanoparticle research involving the use or
manufacture of particles (Bucky balls, nano
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Governmental Industrial Hygienists {ACGIH}) < 1
PPm
• Causes teratogenic or mutagenic effects (in
humans or animals)
tubes, quantum dots, etc.) that is not contained in
solution and/or with the possibility of airborne
exposure.
• Is an agent whose toxicological characteristics are
unknown, but it is suspected of meeting one of
the above criteria
*EXCEPTION: Standards ordered from vendors in sealed vials or ampoules that are used directly in laboratory
instrumentation are exempt even if they meet the above criteria.
X_ Yes No If yes, List in the table below:
C. Hazardous Agent(s):
Provide the following information for any hazardous agent that will be taken into the field by EPA personnel. -
Note: Methyl Bromide will be delivered to the site by vendor in compressed gas cylinders and any
remaining will be picked up by vendor at completion of study.
Material Name
CAS
No.
Physical
Form
Quantity
Taken in
Field
Condition /
Method of
Storage and
Transport
DOT Labeling
Requirements
Methyl Bromide
(100%)
74-83-9
Gas
200 lbs
Compressed
Gas Cylinder
UN 1062; Methyl
bromide
Division 2.3 - Gases,
toxic/poisonous
Bacillus
anthracis Sterne
(BSL-2)
Solid
1 mg
Sealed, Tyvek
envelopes
NA
Choose an
item.
Choose an
item.
Choose an
item.
Choose an
item.
Choose an
item.
Choose an
item.
Choose an
item.
Choose an
item.
*Attach a copy of Material Safety Data Sheet (MSDS) for each chemical listed above, or a copy of
information found in NIOSH Registry of Toxic Effects of Chemical Substances
Note: Ba Sterne will be handled as a Biosafety Level 2 agent. All Sterne will be delivered to the site in sealed
Tyvek coupons, and stored in zip-lock bags prior to placement. Upon sample retrieval coupons will be
stored in secondary and/or tertiary containment (zip lock bags inside of sealed container, or secondary
container). At no time shall the Sterne be out of controlled custody of EPA staff.
D. Hazardous Waste Disposal
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(Fill out the following information only if you are taking materials into the field and anticipate generating waste
materials that must be returned to an EPA facility.)
Note: No hazardous wastes are anticipated to be generated. The activated carbon filters will be regenerated and
the methyl bromide adsorbed within collected and re-used. Any residual gas in the cylinders will be returned to
the vendor for continued use.
Type of Waste
Generated
Waste
Volume
Time Period (e.g.,
weekly solvent
waste)
Any unused
stock?
(yes or no)
If unused stock,
will it be kept on
site or disposed
of?
Non-regulated PPE
<1 Cubic yard
N/A
No
Kept
E. Occupational Exposure Limits
Agent
8 Hr Time
Weighted
Average
(TWA)
ppm
Short Term
Exposure
Limit (STEL)
(15 Min) ppm
Ceiling
ppm
Immediately
Dangers to
Life or
Health (IDLH)
ppm
Notations
Action Levels
(based on
ambient air
monitoring)
Methyl
Bromide
TLV=1
NIOSH =
As low as
reasonably
achievable
(ALARA)
Excursion* - 3
ppm(ACGIH)
20
OSHA
250
NIOSH
Skin (Liquid
absorbs through
skin)
NIOSH considers
MB a potential
occupational
carcinogen;
ACGIH does
not*; see
International
Agency for
Research on
Cancer (IARC)
citation**
0.5 ppm,
relocate work
area or don
SCBA,
designate as
"Hot Zone";
> 1 ppm, take
action to
control any
leaks, fugitive
emissions;
Cold & Warm
Zone shall be
maintained at
background or
less than
detect
Hydrogen
Bromide
(decomposition
product)
3 ppm
OSHA
2 ppm
(ceiling)
TLV
3 ppm (ceiling)
NIOS
2 & 3
30
By product
Ba Sterne
Not
app
lica
ble
* - Excursion Limit Recommendation: Excursions in worker exposure levels may exceed 3 times the TLV-TWA for
no more than a total of 30 minutes during a work day, and under no circumstances should they exceed 5 times
V 1.0 26Junl5
12
-------
the TLV-TWA, provided that the TLV-TWA is not exceeded.
[American Conference of Governmental Industrial Hygienists. Threshold Limit Values for Chemical Substances
and Physical Agents and Biological Exposure Indices. ACGIH, Cincinnati, OH 2012, p. 5] **PEER REVIEWED**
** - Evaluation: There is inadequate evidence in humans for the carcinogenicity of methyl bromide. There is
limited evidence in experimental animals for the carcinogenicity of methyl bromide. Overall evaluation: Methyl
bromide is not classifiable as to its carcinogenicity in humans (Group 3).
[IARC. Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Man. Geneva: World Health
Organization, International Agency for Research on Cancer, 1972-PRESENT. (Multi-volume work). Available at:
http://monoaraphs.iarc.fr/index.php p. V71 731 (1999)] **PEER REVIEWED**
Note: NIOSH Pocket Guide reports methyl bromide as a potential occupational carcinogen (in conflict with IARC)
and thereby established exposure limits as low as reasonably achievable.
F. Symptoms of Exposure
Methyl Bromide
Skin, Eye and Respiratory Irritations:
Contact of the skin with high concentrations of vapor or with liquid methyl bromide produces a tingling & burning
sensation.
[Braker W, Mossman A; Matheson Gas Data Book 6th ED p.457 (1980)] **PEER REVIEWED**
Liquid can cause eye and skin burns.
[Tomlin, C.D.S. (ed.). The Pesticide Manual - World Compendium. 10th ed. Surrey, UK: The British Crop
Protection Council, 1994., p. 686] **PEER REVIEWED**
Methyl bromide irritates the respiratory tract and in the eye, can cause irritation, tearing, reddening or burning
pain.
[Pohanish, R.P. (ed). Sittig's Handbook of Toxic and Hazardous Chemical Carcinogens 5th Edition Volume 1: A-
H,Volume 2: l-Z. William Andrew, Norwich, NY 2008, p. 1671] **PEER REVIEWED**
G. Warning Properties
Methyl Bromide:
Usually odorless, sweetish, chloroform-like odor at high concentrations.
[O'Neil, M.J. (ed.). The Merck Index-An Encyclopedia of Chemicals, Drugs, and Biologicals. Whitehouse Station,
NJ: Merck and Co., Inc., 2006., p. 1041] **PEER REVIEWED**
Methyl bromide has practically no odor or irritating effects in low concentration and therefore does not provide any
warning of physiologically dangerous concentrations.
[Braker W, Mossman A; Matheson Gas Data Book 6th ED p.457 (1980)] **PEER REVIEWED**
Burning taste.
[O'Neil, M.J. (ed.). The Merck Index-An Encyclopedia of Chemicals, Drugs, and Biologicals. Whitehouse Station,
NJ: Merck and Co., Inc., 2006., p. 1041] **PEER REVIEWED**
H. Fire and Explosion
Material
Lower Explosive Limit
(LEL)
Upper Explosive Limit
(UEL)
Incompatibilities
Methyl Bromide
10%
15%
Aluminum, magnesium,
strong oxidizers. [Note:
Attacks aluminum to form
aluminum trimethyl which
is SPONTANEOUSLY
flammable.]
Hydrogen Bromide
(decomposition product)
N/A
N/A
V 1.0 26Junl5
13
-------
1. Prior to the start of the field tests with methyl bromide, the local Fire Department (FD) shall be contacted by the
Incident Commander or his/her designee to conduct a pre-fire walk-through and inform the local FD of the site
hazards.
2. A pre-fumigation inspection must occur prior to the fumigation to remove any oxidizers, aluminum zinc,
magnesium products. Information could not be found in the literature identifying the airborne concentrations
necessary to initiate spontaneously flammable products. To that end, all preventive precautions must be taken.
3. Local fire and rescue must be readily available during the fumigation in the event of fire, explosion, or
catastrophic release.
Fire Potential (MB):
Non-flammable in air, but burns in oxygen.
[O'Neil, M.J. (ed.). The Merck Index-An Encyclopedia of Chemicals, Drugs, and Biologicals. Whitehouse Station,
NJ: Merck and Co., Inc., 2006., p. 1041] **PEER REVIEWED**
Flame propagation is narrow range of 13.5-14.5% by volume in air.
[Clayton, G.D., F.E. Clayton (eds.) Patty's Industrial Hygiene and Toxicology. Volumes 2A, 2B, 2C, 2D, 2E, 2F:
Toxicology. 4th ed. New York, NY: John Wiley & Sons Inc., 1993-1994., p. 4023] **PEER REVIEWED**
Not ordinarily combustible except in the presence of high heat or strong oxidizers.
[National Fire Protection Association; Fire Protection Guide to Hazardous Materials. 14TH Edition, Quincy, MA
2010, p. 49-97] **PEER REVIEWED**
Mixtures of 10-15% with air may be ignited with difficulty.
[Lewis, R.J. Sr. (ed) Sax's Dangerous Properties of Industrial Materials. 11th Edition. Wiley-lnterscience, Wiley &
Sons, Inc. Hoboken, NJ. 2004., p. 2397] **PEER REVIEWED**
Hazardous Reactivities & Incompatibilities (MB): Note: Issues with aluminum related to liquid MB stored
in aluminum cylinders (per discussion with manufacturer)
Risk of fire and explosion on contact with aluminium, zinc, magnesium or oxygen.
[International Program on Chemical Safety/Commission of the European Union; International Chemical Safety
Card on Methyl Bromide (November 25, 2009). Available as of October 16, 2012:
http://www.incheni.org/paaes/icsc.htni **PEER REVIEWED**
Aluminum, magnesium, strong oxidizers. [Note: Attacks aluminum to form aluminum trimethyl which is
SPONTANEOUSLY flammable.]
[NIOSH. NIOSH Pocket Guide to Chemical Hazards. Department of Health & Human Services, Centers for
Disease Control & Prevention. National Institute for Occupational Safety & Health. DHHS (NIOSH) Publication
No. 2010-168 (2010). Available from: http://www.cdc.gov/niosh/npg **PEER REVIEWED**
Metallic components of zinc, aluminum and magnesium (or their alloys) are unsuitable with bromomethane
because of the formation of pyrophoric Grignard-type compounds. A severe explosion is attributed to ignition of a
bromomethane-air mixture by pyrophoric methylaluminum bromides produced by corrosion of an aluminum
component.
[Bretherick, L. Handbook of Reactive Chemical Hazards. 4th ed. Boston, MA: Butterworth-Heinemann Ltd., 1990,
p. 155] **PEER REVIEWED**
Forms explosive mixtures with air within narrow limits at atmospheric pressure, but wider at higher pressure.
[Lewis, R.J. Sr. (ed) Sax's Dangerous Properties of Industrial Materials. 11th Edition. Wiley-lnterscience, Wiley &
Sons, Inc. Hoboken, NJ. 2004., p. 2397] **PEER REVIEWED**
Attacks aluminum to form spontaneously flammable aluminum trimethyl. Incompatible with strong oxidizers,
aluminum, dimethylsulfoxide, ethylene oxide, and water. Attacks zinc, magnesium, alkali metals and their alloys.
Attacks some rubbers and coatings.
[Pohanish, R.P. (ed). Sittig's Handbook of Toxic and Hazardous Chemical Carcinogens 5th Edition Volume 1: A-
H,Volume 2: l-Z. William Andrew, Norwich, NY 2008, p. 1670] **PEER REVIEWED**
PART IV. EMERGENCY PROCEDURES
V 1.0 26Junl5
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-------
This information must be coordinated with representatives from the field site. This refers to the emergency
procedures dictated by the site personnel.
A. In the event of an accident or chemical/biological spill:
1. Describe procedures in event of personal exposure (inhalation, ingestion, inoculation, asphyxiates,
flammables, corrosives, etc.):
MB or Hydrogen Bromide (HBr) exposure - remove to cold zone for fresh air. Document with IC
and follow-up with medical treatment as necessary.
In event of tear or leakage from Ba Sterne coupon, evacuate area and don N-95, Tyvek coveralls,
eye protection to prepare for decontamination.
2. Describe plans for containment to prevent spread of the agent from the immediate area, decontamination
procedures and monitoring methods to assure decontamination.
MB will be contained in compressed gas cylinders and building "tented" during fumigation. Effluent
from fumigation will be subjected to scrubbing via charcoal filtration. Area ambient air monitoring will
be conducted throughout the fumigation and any leaks immediately addressed.
In event of accidental release of Sterne, don PPE (above) and decontaminate with 1/10 hypochlorite
solution.
3. Describe the procedures for emergency evacuation of the facility.
The Incident Commander (IC) or Safety Officer (SO) will activate an alarm by producing three blast
from an air horn. All personnel MUST evacuate upwind of the site to the pre-designated
assembly area.
A. Activate 911, all personnel evacuate downwind to the emergency evacuation assembly point for
individual accountability check.
B. Assembly points will be designated daily (based on wind conditions), posted on-site, and
discussed during daily safety briefings.
B. In the event of a medical emergency:
1. Emergency phone number (Is 911 available or does facility have its own medical emergency number)?
Yes
2. Is response by EMS available? Yes
3. Include the hospital name, address, phone number and location relative to the site if EMS crew will not
be available to provide emergency transportation.
Hospital: ValleyCare Hospital
Address: 5555 W. Los Positas Blvd, Pleasanton, CA 94588
Phone#: 929-847-3000
*Please attach (copy and paste) map or directions for first response hospital closest to site:
V 1.0 26Junl5
15
-------
Iriving directions
- | X
£3 a 1-580 W
16 mm without traffic Show t
Sandia National Labs - CRF
18 min
12.1 miles
Round Valley
Regional Preserve
Kg
Mottjjn Territory
Regional Preserve
Los Vaqurros
Reservoir & Watershed
f Head west on East Ave toward S Gate Dr
Ta&sajara
I* Turn right onto S Vasco Rd
X Slight nght onto the ramp to Oakland
^ Merge onto 1-580 W
f Take the Tassajara Rd ex
-------
B. Personnel monitoring is the responsibility of the individual's employer. EPA with the potential to exposure at
or above 0.5 ppm MB will be required to be monitored at the discretion of the site Industrial Hygienist.
PART VI. SITE MANAGEMENT/Security
A. The general site shall be controlled at all times during fumigation and until such time as the facility is cleared
for re-entry at post fumigation. NO ENTRY shall be permitted into the test house at any time while under
containment for fumigation.
1. Entry post fumigation may occur when monitoring demonstrates a concentration at 5 ppm or less. The
minimum PPE for entry into the no entry zone after fumigation (when concentrations below 5 ppm MB)
shall be SCBA, loose fitting clothing, long pants, socks, no jewelry. No PPE is required when airborne
concentrations are below 0.5 ppm.
2. Approval to enter must be granted by the site incident commander or his/her designee.
NOTE: In the event of unanticipated emergencies such as detached delivery systems, etc. that
operationally necessitate entry:
a. Approval must be granted by the site safety officer for any entry above 5 ppm.
b. Level A shall be used, including a buddy system, back-up responders, and continuous
communications.
c. The level A ensemble must be rated for Methyl Bromide (breakthrough time greater than 480 mins).
B. The EXCLUSION ZONE (Hot Zone) is the area with actual or potential contamination and the highest
potential for exposure to hazardous substances.
1. The exclusion zone shall be established in areas where MB concentrations may reach or exceed 0.5
ppm.
2. The minimum PPE for entry into the exclusion zone is: SCBA, loose fitting clothing, long pants, socks, no
jewelry.
3. Approval to enter the exclusion zone must be granted by the site incident commander or his/her
designee.
4. Either visual observation, a buddy system, or communications must be maintained at all times when in
the exclusion zone.
C. The CONTAMINATION REDUCTION ZONE (Warm Zone) is the transition area between the exclusion and
support zones. This area is where responders enter and exit the exclusion zone and where decontamination
activities take place.
1. Airborne concentrations of MB must be less than 0.5 ppm at all times in this zone.
D. The SUPPORT ZONE (Cold Zone) is the area of the site that is free from contamination and that may be
safely used as a planning and staging area, including incident command.
1. This area shall be established upwind of the operations.
2. Continuous monitoring shall be conducted in accordance with the AAMP and the site relocated if
contaminant levels above background are repeatedly detected.
3. Airborne concentrations should be maintained at background, or less than detect at this site.
4. In the event of wind change, or contaminants entering the support zone, the support zone location will be
moved to an area free of contaminants.
E. Restriction of Personnel shall be limited to only those individuals involved in the project, providing project
support, or approved by the Incident Commander.
F. Visitor's access shall be limited to the support zone unless approved by the incident commander and Safety
Officer. Visitors entering the Contaminant Reduction Zone or Exclusion Zone must demonstrate a bona fide
need to enter, along with SCBA training and medical monitoring.
PART VII. MANAGEMENT OF SPILLS OR LEAKS
A. Small scale - the highest probability of small scale leaks involve joints/ connections in the compressed gas
delivery system, as well as any leaks from the containment tent.
V 1.0 26Junl5
17
-------
1. Prior to initiating fumigation with MB, the compressed gas distribution system must be pressure tested
using an inert gas (N, He, Compressed Air). Each pipe joint must be "soap tested" to identify and stop
any leaks prior to fumigation.
2. If leaks occur during fumigation, staff must don SCBA, as PPE during abatement actions. A "buddy
system" must be used by providing visual back-up, ready for SCBA entry, as needed (one person in
exclusion zone, one visual back-up ready to enter with SCBA).
B. Moderate scale leaks - include breakthrough in the carbon filtration system.
1. Leaks producing uncontrolled discharge of greater than 5 ppm MB shall initiate system shutdown and
abatement action as appropriate.
2. Abatement must include two personnel in SCBA, loose fitting clothing, including long sleeve, long pants,
and nitrile gloves with two personnel assigned as back-up in the same level of PPE.
C. Uncontrolled, Catastrophic Release
1. Level 1 - Broken distribution line in fumigation delivery system.
a. Shut down system
b. Concurrently notify Incident Commander to determine whether site evacuation is necessary.
2. Large scale uncontrolled release, fire or explosion, loss of containment.
a. Shut down system if possible.
b. Initiate emergency evacuation of site.
c. Concurrently notify 911 for emergency response and possible community evacuation.
PART VIII. EMERGENCY EVACUATION
See also Part IV above, Emergency Procedures
Evacuation assembly areas will be established and posted on site based on wind and other site specific
conditions. Assembly areas will be discussed during daily safety briefings. Evacuation drill will be conducted at
the discretion of the IC and/or SO.
Evacuation procedures are as follows:
1. An "air horn" will be activated by the Incident Commander or his/her designee. The evacuation alarm shall be
three, one second audible blasts, at one second intervals. There shall be a five second delay, and the alarm
repeated.
2. Staff must secure operations as necessary, without putting themselves at risk, and immediately report to the
evacuation assembly area.
3. A "by name" head count shall be conducted by the Incident Commander or his/her designee. If staff are not
present or accounted for, the information must be conveyed to local emergency response to determine if
rescue is necessary.
ATTACHMENTS
1) SNL CA Institutional Biosafety Committee Approval Cover Page
2) EPA Personnel Qualifications Table
3) Site Specific PPE Requirements Summary Table
3) IPCS Methyl Bromide Data Sheet
4) Hazardous Substance Data Bank Methyl Bromide document
5) Hazardous Substance Data Bank Hydrogen Bromide document
6) Centers for Disease Control and Prevention, Anthrax Sterne information document
V 1.0 26Junl5
18
-------
LIST OF ACRONYMS
ACGIH American Conference of Governmental Industrial Hygienists
ALARA As Low As Reasonably Achievable
Ba Bacillus anthracis
CDC Centers for Disease Control and Prevention
CMAT CBRN Consequence Management Advisory Team
CUE Critical use exemption
CT Concentration-time
DATS Decontamination Analytical and Technical Services
FD Fire Department
ft Feet
HASP Health and Safety Plan
HBr Hydrogen Bromide
IARC International Agency for Research on Cancer (World Health Organization)
IDLH Immediately Dangerous to Life or Health
lbs Pounds
LD Lethal Dose
LEL Lower Explosive Limit
MB Methyl Bromide
mg/L Milligrams per liter
MSDS Material Safety Data Sheet
NEPA National Environmental Policy Act
NHSRC National Homeland Security Research Center
NIH National Institutes of Health (US)
NIOSH National Institute for Occupational Safety and Health
OEM Office of Emergency Management (EPA)
ORD Office of Research and Development
OSHA Occupational Safety and Health Administration
PPE Personal Protective Equipment
ppm Parts per million
RH Relative Humidity
SCBA Self Contained Breathing Apparatus
SHEM Safety, Health, and Emergency Management
STEL Short Term Exposure Limit
T Temperature
TBD To be determined
TLV Threshold Limit Value
TWA Time Weighted Average
UEL Upper Explosive Limit
V 1.0 26Junl5
19
-------
USEPA United States Environmental Protection Agency
Attachment 1, SNL CA Institutional Biosafety Committee Approval Cover Page
WMUAC. L1UC CJM.V
Mi/ ft: oiutf luu nHk rtkuruaiJa' !i : Frrtt so u-r
Wnrfe-i.taf l".&£ iJJf
n»anr rcriev rtrthcrt tcfcitpMI: rcteMr
MtxoC^ ii*j<'icriiiTe-iu mic 4mini»
-------
Attachment 2, EPA Personnel Qualifications Table
NOTE: Each signatory certifies the statement below:
"/ have reviewed this Safety Health and Environmental Management Protocol for Field Activities and agree to
comply with all procedures and protective measures outlined in the protocol."
Name
*Medical
Monitoring
Respirator
*Field
Activity
Training
*First
Aid
*AED/
CPR
*HAZWOPER
Biosafety
Training
Shannon Serre
7/2014
4/2013
4/2013
6/2015
4/2015
Leroy Mickelsen
11/2014
6/2015
4/2015
Elise Jakabhazy
Mike Nalipinski
4/2015
Larry Kaelin
Chris Gallo
5/2015
2/2015
2/2015
2/2015
2/2015
Marshall Gray
6/2015
11/2014
11/2013
6/2014
6/2014
6/2015
4/2015
John Archer
2/2015
10/2014
7/2013
6/2015
2/2015
Francisco Cruz
07/2014
09/2014
01/2015
01/2015
08/2014
indicate if personnel are: 1) Participants in the Occupational Medical Surveillance (Medical Monitoring) Program
and 2) Up-to-date in Field Activity Safety Training and/or any other training.
(1) Non RTP, EPA OEM Employees
If no, provide explanation in Comments section below.
Comments
1) Site specific training will be provided by Safety Officer for HAZWOPER only trained personnel.
2) Bios safety training required for staff handling Ba Sterne coupons
V 1.0 26Junl5
21
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ATTACHMENT 3 Site Specific PPE Requirements Table
PERSONAL PROTECTIVE EQUIPMENT REQUIREMENTS FOR UTR FUMIGATION PROJECT
6-15 JULY 2015, LLNL/SNL, CA
Handling
Site Set-up
Ambient Air
Ba Sterne
Near Filter In direct
Entry under
Cylinders or
items over 50
Monitoring
Coupon
Placement/
Fan/Noise sunlight
Haz Areas
Fumigation
Conditions-*
lbs
Retrieval
above 85dBA
Foot Protection
X
X
Hard Hat
If overhead
hazards on site
Eye Protection
Face Shield
X
Safety glasses
Hearing Protection
Nitrile Gloves
X (double)
Leather Gloves
X
As applicable
N-95
X (If spill/leak)
Tyvek Coveralls
SCBA
If
concentration
> 0.5ppm MB
X
Level A Suit
Rated for MB
Sun Screen/Covered Skin
X
X
*- Entry into the rail car under fumigation conditions is not planned or anticipated. However, if real-time situation
mandates an entry for some reason it must be at "level A", approved by the safety officer and IC under stringent
condition (2 enter, 2 back-up, constant communications, limited time, etc.).
X
X
1
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL HOMELAND SECURITY RESEARCH CENTER
AND CBRNE CONSEQUENCE MANAGEMENT TEAM
Ambient Air Monitoring Plan
For the Field Study of Methyl Bromide Rail Car Fumigation
June 26, 2015
V1.0 26Junl5
2
Appendix C
-------
LIST OF ABBREVIATIONS AND ACRONYMS
AAMP
Ambient Air Monitoring Plan
ACGIH
American Conference of Governmental Industrial Hygienists
Ba
Bacillus anthracis
BI(s)
Biological Indicator(s)
CDC
Centers for Disease Control and Prevention
CFM
Cubic Feet per Minute
CMAD
CBRN Consequence Management Advisory Division
CT
Concentration x Time
°C
Degrees Celsius
EPA
United State Environmental Protection Agency
ERT
Environmental Response Team
ERT
Environmental Response Team
ft
HBr
Hydrogen Bromide
HSAP
Health, Safety, and Emergency Response Plan
HVAC
Heating, Ventilation, and Air Conditioning
IDLH
Immediately Dangerous to Life or Health
in.
Inch
lbs/hr
Pounds Per Hour
m
Meter(s)
MB
Methyl Bromide
mg/L
Milligrams per liter
mg-hr/L
Milligrams-hour per liter
MSDS
Material Safety Data Sheet
NHSRC
National Homeland Security Research Center
NIOSH
National Institute for Occupational Safety and Health
OSHA
Occupational Safety and Health Administration
PEL
Permissible Exposure Level
PHILIS
Portable High Throughput Integrated Laboratory Identification Systems
ppb
Parts per billion by volume
ppm
Parts per million by volume
QA/QC
Quality Assurance/Quality Control
QAPP
Quality Assurance Project Plan
RAP
Remedial Action Plan
RH
Relative Humidity
SAP
Sampling and Analysis Plan
SOP
Standard Operating Procedure
STEL
Short Term Exposure Limit
TLV
Threshold Limit Value
TWA
Time Weighted Average
V 1.0 26Junl5
3
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Table of C ontents
1 Introduction 5
2 Site History and Background 5
3 Potential Compounds of Concern 6
4 Air Monitoring Objectives 9
4.1 Data Quality Control Procedures 10
4.2 Background Data Collection 10
5 Description of the Fumigation Process 11
6 Implementation Schedule 12
7 Monitoring Equipment 12
7.1 RAE System AreaRAE 12
7.2 RAE System MulitRAE 13
7.3 Field Portable Gas Chromatograph (GO 13
7.4 Key Chemical and Equipment RDA Fumiscope 14
7.5 Colorimetric Tubes 14
8 Monitoring Program Description 14
8.1 Work Zone Monitoring 15
8.2 Perimeter Monitoring 15
8.3 Scrubber Monitoring 15
9 Assessment and Response 16
10 Air Monitoring/Sampling Plan with SNAPPER and PHILIS 19
11 Modifications to the AAMP 20
12 References 20
V 1.0 26Junl5
4
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1 Introduction
This Ambient Air Monitoring Plan (AAMP) describes the air monitoring procedures that will be
employed during a rail car methyl bromide (MB) fumigation study. Ambient air will be
monitored for potential MB emissions, and to assess ambient MB concentrations at the site and in
the surrounding community. Although the fumigation process has been designed to contain MB
within the tented area, the proactive measures described here will be taken to protect public
safety should a release occur.
2 Site History and Background
In 2001, a series of letters containing Bacillus anthracis (Ba) were mailed to various locations
throughout the United States. It was determined that initial and residual contamination from Ba
spores was difficult to detect, identify, and decontaminate in an efficient and expeditious manner.
Additionally, significant costs were incurred during decontamination of buildings and equipment
that had been suspected of having been contaminated.
Comments from government reports and congressional inquiries pointed out that sampling and
decontamination methods were not standardized or validated. Deficiencies were observed when
attempts were made to locate, characterize and remediate Ba contamination. Recommendations
were made by these agencies to standardize and validate procedures that could be used to
characterize biological agent contamination and follow on with efficient decontamination
measures that would effectively clear buildings and associated areas. The latter part of these
recommendations will be addressed, in part, within the scope of this fumigation study and are
described in the project Quality Assurance Project Plan (QAPP).
Environmental decontamination and clearance are critical components of the comprehensive
public health and environmental recovery strategy employed in the aftermath of a biological
agent release. Capacity to decontaminate structures plays a critical role in the nation's resiliency.
Currently, there is limited capacity to decontaminate biological agents from structures and
outdoor areas. Fumigation with a sporicidal gas may be the most thorough method for structural
disinfection. For over 60 years, MB has been used as a pesticide for soil, foodstuffs, and
structures. Studies have shown the MB is efficacious in inactivating Ba spores and other
microorganisms (Weinberg, 2004; Part I and Part II). In addition, the technology and skilled
labor force currently used in the commercial fumigation industry can be used in a cost-effective
manner for deployment of MB in response to a biological incident. MB has been banned from
structural fumigations and is now used under exemptions to fumigate mostly agricultural imports
and exports. However, in the event of a national emergency resulting from a Ba incident, MB
V 1.0 26Junl5
5
-------
may be a game changer, adding significantly to our resiliency by increasing our capacity to
respond.
The site will be located at Sandia National Laboratory in Livermore, California.
Figure 1. Location of MB fumigation site shown by X in above photo.
3 Potential Compounds of Concern
The primary objecti ve of the AAMP is to protect human health and the environment during the
fumigation process. According to the MB label, the lower explosive limit can vary from 10-15
percent. The National Institute for Occupational Safety and Health (NIOSH) lists MB as a
potential occupational carcinogen and recommends lowest feasible exposures and an
immediately dangerous to life or health (IDLH) value of 250 ppm. OSHA's permissible
V1.0 26J u n 15
6
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exposure level (PEL) is 20 ppm (80 mg/m3) with a skin notation and the American Conference of
Governmental Industrial Hygienists (ACGIH) threshold limit value (TLV) is 1 ppm (3.9 mg/m3)
with a skin notation. (NIOSH, 2010) (http://www.cdc.gov/niosh/npg/npgd0400.htmn (OSHA,
2004) (https://www.osha.gov/dts/chemicalsampling/data/CH 251900.html). Basic properties of
MB are shown in Figure 2.
V 1.0 26Junl5
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Methyl bromide
Synonyms & Trade Names Bromomethane, Monobromomethane
CAS No. 74-83-9
RTECS No. PA4900000
DOT ID 6 Guide 1062 123
S
Formula CHjBr
Conversion 1 ppm =
3.89 mg.'m3
IDLH Ca[250 ppm]
See: 74839
Exposure Limits
NIOSH REL : Ca See Aocendix A
OSHA PEL C 20 ppm (80 mg/m3) [skin]
Measurement Methods
NIOSH 2520
OSHA 3^/2040 iC
See: NMAM or OSHA
Methods 10
Physical Description Colorless gas with a chloroform-like odor at high concentrations,
[Note: A liquid below 38eF. Shipped as a liquefied compressed gas.]
MW: 95.0
BP: 38«F
FRZ:
Sol: 2%
VP: 1.9 atm
IP: 10.54
-137eF
eV
Sp.Gr: 1,73 (Liquid
Fl.P: NA
UEL:
LEL:
RGasD:
at 32'P)
(Gas)
16.0%
10%
3.36
Flammable Gas. but only in presence of s high energy ignition source.
Incompatibilities & Reactivities Aluminum, magnesium, strong oxidizers [Note: Attacks
aluminum to form aluminum trimethyl, which is SPONTANEOUSLY flammable.]
Exposure Routes inhalation, skin absorption (liquid), skin and/or eye contact (liquid}
Symptoms irritation eyes, skin, respiratory system; muscle weak, incoordination, visual
disturbance, dizziness: nausea, vomiting, headache; malaise (vague feeling of discomfort);
hand tremor; convulsions; dyspnea (breathing difficulty); skin vesiculation; liquid: frostbite;
[potential occupational carcinogen]
Target Organs Eyes, skin, respiratory system, central nervous system
Cancer Site [in animals: lung, kidney &forestomach tumors]
Personal Protection/Sanitation fSee protection coeesl
Skin: Prevent skin contact (liquid)
Eyes: Prevent eye contact (liquid)
Wash skin: When contaminated (liquid)
Remove: When wet (flammable)
Change: Ne recommendation
Provide: Quick drench (liquid)
Respirator Recommendations
NIOSH
At concentrations above the NIOSH REU or where there is no REL, at any detectable
concentration:
(APF = 10,000) Any self-contained breaching apparatus that has a full facepiece and Is
operated in a pressure-demand or other positive-pressure mode
(APF = 10,000) Any supplied-air respirator that has a full facepiece and is operated in a
pressure-demand or other positive-pressure mode in combination with an auxiliary self-
centainec positive-pressure breathing apparatus
Escape:
(APF = 50) Any air-purifying, full-facepiece respirator (gas mask) with a chin-style, front-
or back-mounted organic vapor canister
Any appropriate escape-type, self-contained breathing apparatus
Important additional information about rescirator selection
See also: INTRODUCTION See ICSC CARD: 0109 See MEDICAL TESTS: 0138
4 Figure 2. Basic chemical, physical, and health data for methyl bromide (NIOSH, 2010).
V1.0 26Junl5
First Aid fSee procedures^
Eye: Irrigate immediately
(liquid)
Skin: Water flush
immediately (liquid)
Breathing: Respiratory
support
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The risk of exposure to MB without warning is significant because MB is a colorless and
odorless gas with a chloroform-like odor at very high concentrations. To address this significant
risk, the AAMP details a MB monitoring plan with multiple and redundant measures.
5 Air Monitoring Objectives
For purposes of this monitoring program, ambient air is defined as air outside of the tented rail
car being fumigated. In particular, the objectives of the AAMP are to:
1. Measure concentrations of MB in ambient air surrounding the fumigated rail car.
2. Compare atmospheric concentrations with site specific Action Levels developed during
MB fumigation operations. The OSHA PEL ceiling3 of 20 ppm of MB is dated and the
ACGIH TLV of 1 ppm will be used, since no short-term exposure limit (STEL) values
for MB are published.
3. Describe operational response measures that will be taken in the event atmospheric
concentrations of MB exceed established Action Levels during the fumigation period.
In order to achieve the program objectives MB gas concentrations in ambient air will be
continuously monitored around the fumigated rail car and in the surrounding area. Air
monitoring will begin during the set-up of the fumigation equipment. Air monitoring will be
completed when the following conditions have been satisfied:
a) All fumigation activities have been completed.
b) The post-fumigation concentration of MB in the rail car is below the ACGIH's 8-hour
Time Weighted Average value (TWA) of 1.0 part per million (ppmv).
c) All tenting materials are removed from the rail car.
3
Ceiling limit is an airborne concentration of a toxic substance in the work environment, which should not be
exceeded. If instantaneous monitoring is not feasible, then the ceiling is a 15-minute time-weighted average
exposure not to be exceeded at any time during the working day.
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During the fumigation process, weather conditions will be continuously monitored in order
to assess the direction of potential migration routes for MB detected in ambient air. The
monitoring data will be used to relocate mobile gas monitoring units and/or implement
corrective actions.
5,1 Da alty Control Procedures
Information regarding the instruments is provided in Section 7.0. In order to collect accurate
and usable measurements, data quality procedures will be implemented, including:
Calibrating all instruments according to manufacturer's instructions;
Verifying instrument calibrations and responses during monitoring events by using clean
filtered air;
Documenting all calibration activities; and
Reporting and documenting all QC results.
In addition, United States Environmental Protection Agency (EPA) will utilize a tiered approach
to monitoring. Multiple instruments will be used to measure MB in ambient air. These
instruments will improve the data quality by increasing the ability to detect MB. They also
utilize different monitoring techniques, thus increasing the likelihood that detections are accurate.
Instruments to be utilized by EPA and its contractors include:
• RAE Systems AreaRAE and MultiRAE
• Portable gas chromatograph with MB compatible column and conditions
• Key Chemical and Equipment Remote Data Acquisition (RDA) Fumiscopes
• Colorimetric tubes (Draeger MB tubes, etc.)
5,2 Background Data Collection
Prior to the start of fumigation, ambient monitoring for MB will commence. Ambient air
monitoring will be conducted during setup of fumigation equipment to establish baseline
readings and to assess the effects of potential interferences from other compounds. These
data will be recorded in an ambient air monitoring log.
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6 Description of the Fumigation Process
The fumigation process will involve exposing the interior and exterior of the rail car to a target
MB concentration for a set amount of time. Process parameters such as MB concentration,
temperature and relative humidity will be monitored and controlled inside the tented rail car
during the fumigation by subcontractor. The overall process will consist of the following
steps:
1. The rail car will be fully encapsulated in a tarp to prevent leakage of MB gas to the
atmosphere.
2. The rail car will be conditioned to maintain desired relative humidity/temperature
levels as described in the MB Fumigation Guidance.
3. MB gas will be released into the tented area.
4. While MB is being released, the temperature will be maintained at or above 75 °F and the
RH will be maintained at or above 75 percent.
5. MB concentration will be kept at or above 212 mg/L for 36-hours.
6. The 36-hour concentration-time (CT) clock will start once the temperature, RH, and MB
concentration reach the desired levels.
7. The CT clock will be paused any time the temperature, RH, or MB concentration goes
below one of these operational limits. It will restart once the limits are obtained again.
8. If MB concentration at or beyond the warning tape (30' from tented rail car) rises above a
warning level, then checks will be made for leaks and corrective actions will be taken to
mitigate them.
9. When fumigation reaches the desired 36-hour CT, the MB gas inside the tented area
will be removed by scrubbing the exhaust flow with a series of activated carbon beds.
10. When the activated carbon bed scrubber system has reached its maximum effectiveness
(scrubber stack concentration is equal to or greater than the concentration under the
tented area), then workers in appropriate PPE will open the tarps and place fans to
assist the final aeration.
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11. The process will be concluded after MB levels inside the rail car decline to acceptable
levels for site workers to re-occupy.
Any changes to the AAMP will be documented in section 10.0 - Modifications to the AAMP.
7 Implementation Schedule
Air monitoring will be started before any fumigant is released and continue until all fumigation
activities have been completed, including aeration. The process will be concluded after MB
levels inside the rail car decline to acceptable levels for site workers to re-occupy in Level D
protection.
To ensure proper placement of ambient air monitoring units, a site specific weather station will
be deployed during initial operations so that meteorological data can be continuously collected
during the fumigation process.
8 Monitoring Equipment
As previously described, several tiers of ambient air monitoring instruments will be utilized
during the fumigation. The purpose of this approach is to provide additional health and safety
precautions, because a detector agent (chloropicrin) will not be utilized and MB at the levels
used for fumigation does not have sufficient odor warning properties. The monitoring
equipment will be co-located as much as possible so that multiple sensors are providing near-
real time conditions for MB. The following subsections outline the various pieces of
equipment and how they will be utilized for this project.
System AreaRAE
EPA will deploy an interconnected system of four AreaRAE gas detectors as the primary means
to assess MB concentrations around the structure. RAE Systems AreaRAE is a one- to five-sensor
gas detector with a photo-ionization detector (P1D) installed. The PID provides real-time
monitoring capabilities in the range of 0 to 10 ppm as volatile organics. The detector is
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responsive to MB and a 1.7 conversion factor4 (RAE Systems, 2005) will be employed to correct
its gross PID response readings to MB concentrations. The lowest reliable PID reading is
approximately 0.1 ppm which is below the 0.5 ppm threshold for the A AMP air monitoring
objectives. The AreaRAE can provide both time-weighted average (TWA) and STEL readings.
Each AreaRAE will be equipped with a 10.6 eV lamp and a wireless RF (radio frequency) modem.
A RDK Host Controller or a personal computer will be used as a base station to continuously
monitor each wireless AreaRAE deployed during the fumigation process. The controller will
also allow for remote data logging conditions at each locality.
The AreaRAEs will be deployed in close proximity (within 30 feet) to the tented rail car and at
selected up and downwind locations. These "selected locations" will include any possible
"sensitive receptors" or "at risk populations" that may be downwind or in close proximity to the
rail car fumigation site.
System MulitRAE
The EPA will deploy two (or more) RAE System MultiRAEs for leak detection and for
personnel monitoring when checking the AreaRAEs or when entering within 30-feet of the rail
car being fumigated. The MultiRAE uses a similar technology to the AreaRAE, but is slightly
more sensitive (lower detection limit). The MultiRAE Pros are light, handheld instruments that
are easy to use.
8.3 Field Portable Gas Chromatograj
The EPA may deploy gas collection bag technology at each stationary monitoring location to
collect samples when high AreaRAE readings are obtained. The sampling bags will be collected
and analyzed on site with the field portable GC (make and model TBD). The GC will be
equipped with an appropriate MB column and operating conditions for optimal resolution of MB.
This result will be our agent-specific analysis for identification and quantification of MB at the
4 See RAE Systems TN-106 for the proper way to implement a conversion factor. For high
concentration initial doses, it may be desirable to use a dilution fitting. See RAE Systems
Technical NoteTN-167.
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time and place where and when the sample was pulled. Although the PID systems are great
detectors for MB without this additional analysis step we could not be sure the PIDs were
reading MB as opposed to some other interfering organic chemical.
8.4 Key Chemical and Equipment miscope
When not monitoring the inside-the-rail car MB concentration, the fumiscopes will be used to
monitor ambient air around the perimeter of the tented rail car. The RDA Fumiscope provides
essentially the same function as the standard fumiscope, such as measuring the thermal
conductivity of various fumigants. The difference is that the RDA model can be left at the rail
car that is being fumigated and remotely accessed via the standard telephone system or cell
phone from a remote computer (called the host computer). In addition the RDA model can
sample and test four independent test points as opposed to the standard model's single test point.
The sampling ports of the RDA will be located approximately 30 feet from the rail car similar to
the AreaRAE sampling locations. Exhaust from the fumiscope will be routed back to the tented
area.
8.5 Colorimetric Tubes
Colorimetric tubes are a good means of detecting MB. Draeger colorimetric tubes are glass
vials, filled with a chemical reagent that reacts to a specific chemical or family of chemicals. A
calibrated 100ml sample of air is drawn through the tube with a Draeger Accuro bellows pump.
If the targeted chemical(s) is present, the reagent in the tube changes color and the length of the
color change typically indicates the measured concentration.
Draeger MB tubes will be collected every six hours from four perimeter AAMP sampling
locations. As much as possible, the tubes will be collected near AreaRAE locations. However, it
may be necessary to collect samples along seams in the tarps or at downwind locations based on
current site conditions. Personnel will utilize Draeger tube model CH27301, MB tube 5/B, 5-50
ppm. The tube has some sensitivity to HBr and other halogenated hydrocarbons.
9 Monitoring Program Description
The Site AAMP will provide ambient air monitoring for MB. The Site AAMP utilizes a
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combination of stationary monitors and portable equipment, including PID based
sensors (AreaRAEs and MultiRAE Pros), chromatography and colorimetric indicators.
Their use will be orchestrated to yield an orthogonal approach to detection, increasing
the safety for workers and the public.
: Zone Monitoring
Multiple MultiRAE Pros will be deployed with workers entering the designated work zone near
the fumigated rail car. MultiRAEs will be equipped with PID sensors corrected for MB
response. Several MultiRAEs will be deployed for use by project personnel for leak detection
and for personnel protection when near the fumigated rail car. The e xact monitoring
locations will be determined based on where workers are working.
Initial data from the instruments will be used to identify potential leakages of MB from the
tented rair car, so that repairs and/or modifications can be made. Once these are corrected, the
data will also be used to assist personnel with proper positioning of the instruments downwind
to quantify MB concentrations at the property perimeter.
9.2 Perimeter Monitoring
Perimeter monitoring will be conducted using groups of AreaRAEs. Perimeter monitoring
locations during fumigation will be approximately 30-feet from the rail car and based on
meteorological data. The AreaRAEs will monitor MB continuously and provide readings on a
real-time basis. Readings will be used to determine compliance with ambient concentration
Action Levels developed by EPA for MB during fumigation operations.
Approximately four AreaRAEs will be setup at the perimeter and one unit will be in the
support zone (additional monitors can be added if the structure is large, greater than 100,000
cubic feet). Generally, the locations will be downwind of the fumigation site or near a
sensitive receptor populations, if any.
;rubber Monitoring
Scrubber monitoring will be conducted using a MultiRAE (Plus or Pro model). Monitoring
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will be done initially between the two carbon beds to determine breakthrough of the first bed.
After breakthrough of the first bed has been reached the monitor will be moved to the stack
that follows the second bed. When concentrations at the scrubber stack reach the concentration
inside the rail car (as determined by the fumiscopes) then the scrubbing process will be
discontinued, blower shut down, duct to the beds will be disconnected, carbon samples
removed, and each bed will be capped off.
10 Assessment and Response
1. Air monitoring for purposes of comparison to established ambient concentration
threshold Action Levels for MB will be conducted using AreaRAEs and other
monitoring equipment, bag samples followed by gas chromatography, will be used to
verify MB concentrations. If the ambient concentrations of each compound remain
below their respective Action Level thresholds, the fumigation will proceed as planned.
If confirmed MB concentrations exceed any of their respective ambient threshold levels,
the EPA Principle Investigator will be immediately notified. Operational responses will
be implemented in accordance with a series of proportionate measures that have been
developed by EPA for the various Action Levels.
In general, the ambient Action Level for MB has been designed to serve the following purposes:
• Action Level 1 (0.5 ppm) provides an early warning that ambient concentrations of MB
have exceeded an established threshold level for an extended period of time and staff
should be alerted.
• Action Level 2 indicates that ambient concentrations of MB have remained above an
established threshold for an extended period of time despite troubleshooting and
corrective action, and that additional MB should not be added to the rail car until
ambient concentrations again fall below the threshold. At this point staff should be
notified of a possible evacuation.
• Action Level 3 indicates that: (1) ambient concentrations of MB have remained above an
established threshold for an extended period of time despite troubleshooting, corrective
action and cessation of MB addition to the rail car. If this level is achieved, the
fumigation operation should be terminated until the source of emissions can be
identified and corrected. At this level, the local fire department may notify nearby
residents to evacuate or shelter in place as detailed in the HASP Evacuation Plan.
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The respective ambient threshold Action Level for MB are shown in Table 9-1, along with a
summary of the operational response measures that will be taken with respect to the fumigation
in the event that any of the Action Levels are exceeded at any point during the operation. If the
Action Level 3 threshold for evacuation for non-essential personnel is reached, then evacuation
of these personnel will be conducted as described in the Health, Safety and Emergency
Response Plan and the Evacuation Plan. If residential evacuations are necessary, the local
authorities will coordinate the evacuations.
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Table 9-1 Ambient Action Levels and Response Actions
Constituent
of Concern
Monitoring
Location
Action Level Definition / Response
EPA
Limit
Action
MB
Perimeter
0.5 ppmy
15-min TWA
Action level 1: if the AreaRAEs 15-min rolling average is
0.5 ppmv, then staff will be alerted.
Action level 2: if a second consecutive 15-min rolling
average is 0.5 ppmv, then troubleshooting and corrective
action will be implemented. Staff will be notified of
possible evacuation.
Action level 3: if a third consecutive SPM 15-min average is >
0.5 ppmv, then MB additions will be ceased, and the tented
area will be actively scrubbed. Non-essential staff will be
evacuated.
MB
Work Zone
0.5 ppmy
Peak
Action level 1: if the AreaRAE Peak is > 0.5 PPmv MB. l'1cn
the staff will be alerted.
Action level 2: if the AreaRAE Peak remains at > 0.5 ppmy
MB, then troubleshooting and corrective action will be
implemented. Staff will be notified of possible evacuation.
MB
Work Zone
1.0ppmv
Peak
Action level 3: if the AreaRAE Peak continues to be
>1.0 ppmy MB despite corrective actions, MB
introduction into the tented area will be ceased and the
tented area will be actively scrubbed. Non-essential staff
will be evacuated.
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11 \Ir Monitoring/Sampling Plan with \mi\ ui;i W IS
This section describes the air monitoring and sampling plan that will utilize the SNAPPER system and
Portable High-throughput Integrated Laboratory Identification System (PHILIS) Mobile Laboratory Bus
with Gas Chromatograph-Time of Flight Mass spectrometry (GC/TOF).
ERT/SERAS will be providing RAE System's AreaRAEs and/or MultiRAE Pros to perform air
monitoring for VOCs equipped with ERT's VIPER Data Management System for real time analysis and
data interpretation. ERT/SERAS will also be providing their SNAPPER air sampling collection software
that can trigger an air sample to be collected either manually or placed on a timed collection protocol.
The sample can be collected on a tedlar bag, SUMMA canister, and/or any media (filter, tube) that is
designated. CBRN CMAD will be providing their PHILIS Laboratory to analyze the collected samples
for Methyl Bromide.
Equipment:
1. 4 - RAE Systems AreaRAE Monitors and/or MultiRAE Pros with Photoionization Detectors
(PIDs) for Volatile Organic Compounds (VOCs)
2. 4 - SNAPPER set ups with the ability to sample a tedlar bag, SUMMA canister, and/or any
media (filter, tube) that is designated upon being triggered manually or by a timed collection
protocol.
3. 1 - Host Computer that will run both the VIPER and SNAPPER Systems.
The perimeter AreaRAEs will be set up to monitor for VOCs while the decontamination operations are
being conducted. VIPER will be collecting the data every second and pushing the data up to
ERT.VIPER.ORG every minute. SNAPPER and VIPER are not fully integrated as of this time so the
computer will not manually take a sample when an action level is reached. In lieu of that, the operator
will monitor the computer in real time and take a sample if one-half the action level is reached. Methyl
Bromide has 1.7:1 ratio for a PID reading so at the action level of lppm (ACGIH TLV) for worker
exposure to Methyl Bromide there would be a 588ppb reading on the PID. The operator will trigger
SNAPPER if the PID reads 300ppb. In addition to any samples taken at the one-half action level,
samples will be taken before decontamination operations, after decontamination operations and every 3
hours during the decontamination operations even if the one-half action level is not reached. The
sampling will continue at the 3 hour intervals during time the PHILIS laboratory is staffed to accept
samples; overnight hours are not currently scheduled to be staffed in the PHILIS laboratory.
The air samples will be taken and analyzed by the CBRN CMAD PHILS Mobile Laboratory for Methly
Bromide. This laboratory analysis would confirm the presence of Methyl Bromide and rule out any other
contaminants that could be contributing the elevated VOC levels seen by the monitoring
instrumentation. Detection limits and methods will be determined by PHILIS laboratory personnel. Any
media specific, volume dependent requirements must be discussed prior to project mobilization.
The analytical instruments in PHILIS will only be used to confirm the presence of MB in collected
samples down to a concentration of 1 ppm.
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12 Modifications to the AA.YIP
If any modifications are made to the AAMP following approval, they will be documented in writing
and attached to the original AAMP. Changes to the AAMP must be approved by the Unified
Command.
13 References
NIOSH. National Institute for Occupational Safety and Health, Education and Information Division,
NIOSH Pocket Guide to Chemical Hazards and Other Databases 22-0256. Methyl Bromide. NIOSH
Pub. 2010-168c. 2010. (http://www.cdc.gov/niosh/npg/npgd0400.htmn
NIOSH. National Institute for Occupational Safety and Health, Education and Information Division,
NIOSH Pocket Guide to Chemical Hazards and Other Databases 22-0256. Hydrogen Bromide. NIOSH
Pub. 2010-168c. 2010. (http://www.cdc.gov/niosh/npg/npgd0331 .htmO
OSHA. Occupational Safety and Health Administration. Chemical Sampling Information for
Bromomethane. 2004. (https://www.osha.gov/dts/chemicalsampling/data/CH 251900.html
OSHA. Occupational Safety and Health Administration. Chemical Sampling Information for Hydrogen
Bromide. 2004. (https://www.osha.gov/dts/chemicalsampling/data/CH 246200.htmO
USEPA, Information on PHILIS, http://www.epa.gov/swercepp/web/docs/misc/PHILIS.pdf.
RAE Systems. AP-218: Measurement of Fumigants in the Food Storage Industry. 2005.
(http://www.raesvstems.com/sites/default/files/downloads/FeedsEnclosure-AP-218 Fumigants Food Ind.pdf)
RAE Systems. TN-106: Correction Factors, Ionization Energies, and Calibration Characteristics 2010.
(http://www.raesvstems.com/sites/default/files/downloads/FeedsEnclosure-TN-106 Correction Factors.pdf)
RAE Systems. TN-167: Proper Use of Dilution Fittings. 2005.
(http://www.raesvstems.com/sites/default/files/downloads/FeedsEnclosure-TN-
167 Proper Use of Dilution Fittings.pdf
USEPA, Information on VIPER, http://www.epaosc.org/site/site profile.aspx?site id=5033.
Weinberg, M.F., R.H. Scheffrahn, and M.A. Juergensmeyer, PART 1: Efficacy of Methyl Bromide Gas
against Bacillus anthracis and Allied Bacterial Spores in Final Report: Whole-Structure
Decontamination of Bacillus Spores by Methyl Bromide Fumigation, U.S. Environmental Protection
Agency, Small Business Innovation Research Phase II. 2004.
Weinberg, M.J. and R.H. Scheffrahn, PART 2: Whole-Structure Decontamination of Bacterial Spores by
Methyl Bromide Fumigation in Final Report: Whole-Structure Decontamination of Bacillus Spores by
Methyl Bromide Fumigation. 13 2 2004, U.S. Environmental Protection Agency, Small Business
Innovation Research Phase II.
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