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Bennett's Quarry
AIR MONITORING PLAN

Monroe County, Indiana
August 6, 1999


1.0 INTRODUCTION

This Air Monitoring Plan (AMP) sets forth the procedures that will be used to conduct airmonitoring and air sampling during the excavation, loading, and consolidation of contaminated material at the Bennett's Quarry site in Monroe County, Indiana. The AMP is to be implemented under the direction of the site Health and Safety Coordinator (HSC) with approval from the CBS Project Manager. This plan describes procedures for perimeter air sampling for polychlorinated Biphenyls (PCBs), personnel exposure sampling for PCBs, asbestos, lead, and volatile organic compounds (VOCs), and inspection and real-time monitoring for dust, methane, and organic vapor emissions. It also discusses sample custody, laboratory analytical methods, and data reporting. Additional air monitoring requirements associated with the safety of remediation personnel at the site are included in the Health and Safety Plan dated August 6, 1999.

2.0 PERIMETER AIR SAMPLING

2.1 PURPOSE

Perimeter air sampling will be performed to ensure that excavation and materials handling operations do not result in excessive airborne PCB emissions from the site. Air samples will be collected and analyzed to determine the concentrations of PCBs at the perimeter of the Bennett's Quarry site.

CBS will be proactive in minimizing the generation of dust by implementing control procedures at first visible signs of dust, including regular covering of stockpiles, and spraying and misting of the work face, haul roads, and material handling stations.

2.2 METHOD OF MONITORING

Perimeter samples will be collected in accordance with U.S. EPA Method T-04. This method uses a modified polyurethane foam (P'UF) sampler to sample ambient air at a flow rate of approximately 200 to 280 liters per minute for a duration of approximately 24 hours. Airborne PCBs are collected on a PUF cartridge preceded by a quartz fiber filter. Both the cartridge and the filter are submitted for laboratory analysis. Airborne PCB concentrations will be reported as mass per unit volume of air. A copy of the ambient air sampling method is included in Appendix A.

2.3 MONITORING LOCATIONS

2.3.1 PUP Samplers

Air samples will be collected at four air monitoring locations prior to remediation for background and during remediation activities as follows. The anticipated initial placement of the samplers around the main area is presented on Figure 1. Actual placement of the samplers in the field may differ slightly in order to place the units in clear, unobstructed locations that do not interfere with project operations. Each sampler will be placed on an elevated platform, as needed, such that the inlet to the sampler is at an unobstructed location.

The "north" sampler will be placed in the field just east of the existing fence line on the north side of the property.

The "south" sampler will be placed on the south side of the gravel road near the old site entrance at the south end of the property.

The "west" sampler will be placed on the west side of the west fence line between the former Monon railroad line and Stout Creek.

The "east" sampler will be placed along the existing access road near the main entrance.

Placement of the samplers during excavation of the satellite area will be determined in the field.

2.3.2 Meteorological Station

A meteorological station equipped with a printer and battery-powered backup will be installed and operated at the site. The location of the meteorological station will be determined in the field at the time of installation. This station will measure and record wind speed, wind direction, temperature, rainfall, and barometric pressure and will be capable of automatically determining average wind speed, average wind direction, and maximum and minimum temperatures on a daily basis. Data from this unit will be used to determine prevailing wind direction and weather information, as discussed in the paragraphs that follow.

2.3.3 Prevailing Wind Direction

Initially, CBS will analyze each of the four PUP samples each day to demonstrate a trend in prevailing wind directions and airborne PCB emissions. Once this trend is established, CBS will analyze one PUF sample each day representing the prevailing wind direction. If the analyzed sample does not exceed the set action level, all other samples will be archived for 14 days and will then be disposed.

The prevailing wind sample will be determined by using the average wind direction information from the meteorological station. The meteorological station automatically reduces wind direction to an average bearing every 5 minutes. The prevailing wind for the day is defined as the quadrant with the highest incident frequency during the work shift. The prevailing wind direction will be reported as a prevailing quadrant and will correlate to the air sampler locations as follows:

3.0 PERSONNEL MONITORING

3.1 PURPOSE

Personnel monitoring will be performed to measure the exposures of the site workers to PCBs, VOCs, asbestos, and lead and to ensure that these exposures do not approach the threshold limit values (TLVs) or permissible exposure limits (PELs) for each.

3.2 METHOD OF MONITORING

Personnel exposures will be evaluated by sampling in accordance with NIOSH Method 5503 for PCBs, NIOSH Method 1501 for aromatic hydrocarbons (additional VOC methods may be selected based on visible contamination, e.g., paint), NIOSH Method 7400 for asbestos, and NIOSH Method 7300 for lead using personnel sampling pumps. These methods use small, portable air sampling pumps that are worn by workers. Polychlorinated biphenyl samples are collected on a Florisil-containing sampling medium preceded in line by a glass fiber filter. Both the Florisil tube and the filter are submitted for laboratory analysis. Samples for VOC analysis are collected in a solid sorbent (charcoal) tube. Samples for asbestos and lead analysis are collected on a cellulose ester membrane filter. To quantify worker exposures, the samples are collected in the personal breathing zone of workers for a duration of at least 7 hours. A copy of the sampling methods are included in Appendix B.

3.3 MONITORING LOCATIONS

The HSC will designate one crew member in an active work area to wear the sampling device. In general, samples will be collected from those workers and site conditions representing the highest potential for exposure.

3.4 FREQUENCY OF MONITORING

Initially, one worker will be monitored each day in each applicable work area for a specific constituent (i.e., PCBs, lead, asbestos, or VOCs). Initially, enough crew members will be selected to monitor for each constituent of concern. If sampling results are consistently below 0.01 mg/m3 for PCBs ( I percent of the PEL), 0.1 fiber/cm for asbestos, 0.030 mg/m for lead, and the applicable OSHA PEL for specific VOCs, daily sampling may be reduced as long as sufficient representative samples are collected to provide historical data documenting that workers are not exposed above the PEL. This reduction in sampling frequency will be determined at the discretion of the HSC.

3.5 ACTION LEVEES AND ACTIONS TO BE TAKEN

The action level for airborne PCB concentrations in the personal breathing zone will be 0.125 mg/m3. This action level represents 25 percent of the TLV for PCB Aroclors 1254 and higher, and 12.5 percent of the TLV for Aroclors below 1254. The action level for airborne VOCs, lead, and asbestos will be as described in Section 3.4. If a personnel sample exceeds the action level, emissions controls will be upgraded. If engineering controls cannot reduce airborne concentrations, all workers in that area shall be required to use Level C protection, including air-purifying respirators, until one of the following conditions is met: The HSC determines the source of the high exposure, and the source is eliminated from the work area.

At least 2 consecutive days of personnel sampling in the work area show exposure levels substantially below the action level, and the HSC determines that the source of the elevated exposure is no longer present.

3.6 QUALITY CONTROL SAMPLES

Quality control samples for personnel monitoring will consist of trip blanks. One blank sample per lo actual samples will be submitted to the laboratory for analysis along with the samples; for batches smaller than 10 samples, one trip blank will be submitted every third sampling event. Blank samples will be numbered, logged, and labeled in the same manner as actual personnel samples, and no information will be provided to the laboratory that distinguishes them as blanks.

4.0 REAL-TIME MONITORING

4.1 PURPOSE

Visual inspections in conjunction with real-time monitoring will be performed to quantify dust levels and to ensure that excavation, materials handling, and consolidation operations do not result in excessive dust or vapor emissions from the site.

4.2 METHOD OF MONITORING

Visual inspection will be the primary method for evaluating the effectiveness of dust control during this project. To supplement these inspections, real-time measurements for total dust and aerosols may be collected using a portable MiniRAM (miniature real-time aerosol monitor) or equivalent instrument. Although other sampling methods are more appropriate for determining actual airborne PCB concentrations, they require laboratory analyses. Because of time constraints, real-time monitoring may be used to quantify total dust levels and to determine if immediate corrective actions need to be implemented.

Organic vapors in the breathing zone will be monitored during excavation and material handling operations using a photoionization detector (PID). The PID provides real-time screening of total VOC levels. Methane and potentially explosive atmospheres will be monitored using an OgLEL meter. Neither instrument will identify discrete contaminants; however, because of time constraints, real-time monitoring may be used to determine if immediate corrective actions need to be implemented. The PID and O2/LEL meter will be calibrated daily in accordance with the manufacturer's specifications. Calibration and maintenance records will be kept on file at the site.

4.3 MONITORING LOCATIONS

Inspections for visible airborne dust and screening for organic vapors and methane will occur at the working face of the excavation area, at stockpile staging areas, and at the downwind site perimeter. Real-time monitoring may also be conducted at locations selected by the EiSC downwind of dust-generating activities (e.g., handling of contaminated soils and capacitors), where appropriate, to ensure minimal impact to site workers and offside residents.

4.4 FREQUENCY OF MONITORING

Inspections for visible airborne dust will be conducted continuously. Real-time dust monitoring and organic vapor screening may also be conducted periodically during excavation and material handling operations to determine airborne emissions. Monitoring cannot be conducted during rain snow, or heavy fog conditions due to limitations of the instruments. These weather conditions, however, substantially reduce the potential for heavy dust or vapor emissions. .

4.5 ACTION LEVEES AND ACTIONS TO BE TAKEN

Visible airborne dust will be used as the site action level. If dust is visible, dust suppression methods will be implemented by the remediation contractor. If visible dust is present at the site boundary, work will be stopped until engineering controls or alternate methods are initiated to reduce the levels of visible airborne dust.

In addition, PID levels greater than 5 ppm above background and O2/LEL meter readings registering 5 percent of the LEL at the work face or in material handling areas will be used as site action levels for organic vapors. Under these conditions, work will be stopped until the contaminant(s) of concern have been identified and the risks associated with the identified contaminants have been determined. Appropriate engineering controls and personal protective equipment will be utilized, as needed.

5.0 SAMPLE CUSTODY

5.1 SAMPLE IDENTIFICATION

Each sample, including quality control samples, will be identified with a unique sample number. This number will provide easy identification of the sample in field logs, field data sheets, analytical reports, chain-of-custody forms, and project reports. The sample numbering system for air samples under this project is divided into three parts. A typical air sample for this project will have the following nomenclature:
PN-PUF-XXX
where:
P N      This identifier represents PSARA's site-specific project number.

PUF     This acronym will be used to identify the PUF sampling effort. For personnel (or employee) monitoring, the acronym "EM" will be used.

X X X     Three-digit numerical identifier representing the next available consecutive number starting at 001.

The objective of this system is to provide a unique numbering system that is clearly understandable to project personnel. Sample number and corresponding sample information such as site name, sampling date, and sample location will be kept in a sample log.

5.2 FIELD DOCUMENTATION

Field documentation for this project will include field log books, air sampling and air monitoring data sheets, computer sample logs, and sample labels.

The HSC will maintain a field log book at all times during the project. This log book will be used to record (in a chronological manner) all sampling activities, project meetings, field decisions, and other events that may impact the air monitoring data.

All field data collected with respect to air monitoring or sampling will be recorded on air monitoring and air sampling data sheets. Appendix C contains the data sheets that will be used to record personnel and perimeter air sampling information as well as an air monitoring form for recording total dust concentrations from the MiniRAM.

All air sample cartridges and tubes will be labeled in the field prior to collection of the actual sample. Each label will include the following information:

5.3 SAMPLE HANDLING, PACKAGING, AND SHIPMENT

Upon completion of each sampling event, the samples collected (plus any quality control samples) will be packaged in a cooler for overnight shipment to the analytical laboratory. Personnel samples will be capped at both ends, labeled, and folded into cardboard to prevent damage during shipment. PUF cartridges will be labeled, wrapped in aluminum foil, placed in padded sample bottles, and carefully packaged in the sample cooler to minimize jostling.

The sample cooler will then be filled completely with packing material such as Styrofoam peanuts to prevent shifting and damage during shipment. The signed chain-of-custody documents (discussed in the following subsection) will be placed in a large zip-lock bag and affixed to the inside of the cooler lid. The cooler will then be sealed with packing tape, and custody seals will be affixed to ensure the integrity of the chain of custody.

5.4 CHAIN-OF-CUSTODY PROCEDURES

Strict chain-of-custody procedures will be followed for all air sampling under this project. Appendix D presents an example of the chain-of-custody document that will be used to track sample custody.

It is anticipated that all air samples will be shipped by overnight carrier. In this event, the sample custody form will be signed as relinquished by the person shipping the samples when the cooler is sealed. The custody document will then be sealed in the sample cooler with the samples. Upon receipt of the sealed sample cooler, the laboratory sample custodian will acknowledge receipt using the overnight carrier's document and will retain a copy for the custody record. The custodian will then open the cooler, inventory the samples, acknowledge receipt of the samples using the chain-of-custody document, and log the samples into the lab.

6.0 LABORATORY ANALYSIS

The PUF cartridges and glass fiber filters collected as part of the perimeter air monitoring program will be analyzed for PCBs in accordance with U.S. EPA Method T-04. Analytical results will be reported in nanograms per cubic meter (ng/m3).

The Florisil tubes and glass fiber filters (PCBs), cellulose ester membrane filters (lead and asbestos), and solid sorbent tubes (VOCs) collected for analysis as part of the personnel monitoring program will be analyzed for PCBs in accordance with NIOSH Method 5503, lead using NIOSH Method 7300, asbestos using NIOSH Method 7400, and aromatic hydrocarbons in accordance with NIOSH Method 1501 (additional VOC methods may be selected based on visible contamination, e.g., paint). Analytical results will be reported in micrograms per cubic meter (pg/m3). Copies of these methods are presented in Appendices A and B. respectively. .

7.0 DATA REPORTING

The results of perimeter air sampling will be reviewed by the HSC upon receipt from the laboratory. If airborne PCB concentrations at the site perimeter exceed the action level of 1g/m3 above background, the measures indicated in Section 2.5 will be taken.

Similarly, the results of personnel monitoring will be reviewed, and if constituent (i.e., PCBs, lead, asbestos, and VOCs) concentrations greater than their individual action levels are obtained, actions will be taken as necessary. A copy of each individual's results will be provided to the employee in accordance with 29 CFR 1910.20. Employees will be required to sign a form indicating they were provided with and understand their sample results. The HSC will retain the original personnel monitoring records in the project office. A copy of the personnel notification form is included in Appendix All perimeter and personnel monitoring results will be recorded on the appropriate sample logs. A weekly summary of monitoring results will be submitted to the U.S. Environmental Protection Agency, the Indiana Department of Environmental Management, the City of Bloomington, and the Monroe County Health Department.

Field monitoring logs will be maintained on site for real-time dust-level monitoring and organic vapor screening. If airborne dust concentrations greater than the action level of 10 mg/m3 above background are obtained, the actions indicated will be taken. Similarly, if volatile organic vapor concentrations are greater than 5 ppm above background or if 5 percent of the LEL is achieved, the actions described previously will be taken.


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