www.haleyaldrich.com COMMUNITY AIR MONITORING PLAN DECOMMISSIONING & DEMOLITION 1 RIVER STREET HASTINGS‐ON‐HUDSON, NEW YORK by Haley & Aldrich, Inc. Rochester, New York for Atlantic Richfield Company File No. 28612‐339 May 2016 Table of Contents Page List of Figures iii 1. Introduction 1 1.1 PROJECT OBJECTIVES 1 1.2 COMMUNITY AIR MONITORING PROGRAM OVERVIEW 1 2. Air Quality Constituents of Interest 4 2.1 SILICON DIOXIDE 4 2.2 POLYCHLORINATED BIPHENYLS (PCBS) 4 2.3 LEAD 4 3. Construction/Demolition Air Monitoring 6 3.1 REVIEW OF ACTION LEVEL EFFECTIVENESS 6 3.2 FIELD SCREENING METHODS 7 3.3 CONSTITUENT‐SPECIFIC MONITORING 8 3.3.1 Sampling Location and Frequency 8 3.3.2 Constituents of Interest 9 3.4 EQUIPMENT AND SAMPLE MEDIA SPECIFICATIONS 9 3.4.1 SKC Leland Legacy Sample Pumps 9 3.4.2 The DataRAM (pDR‐1000AN) 10 3.4.3 Meteorological Station 10 3.5 DOCUMENTATION 10 3.5.1 Sample Custody 11 3.6 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) 11 3.6.1 Particulate Monitors 11 3.6.2 Constituent‐specific Sampling 11 3.6.3 Meteorological Measurement System 13 4. Data Summaries 14 4.1 DATA SUMMARIES 14 4.2 FINAL REPORT 14 5. Corrective Actions 15 References 16 Figures List of Figures Figure No. Title 1 Project Locus 2 Site Plan iii 1. Introduction This Community Air Monitoring Plan (CAMP) describes the perimeter air monitoring that will be conducted during the decommissioning and demolition of Building 52 at the former Anaconda Wire and Cable Plant Site (site) in the Village of Hastings‐on‐Hudson, New York for Atlantic Richfield Company. A Project Locus (Figure 1) and Site Plan (Figure 2) are provided for reference. This plan complies with the regulations set forth in New York State Department of Health (NYSDOH) generic community air monitoring plan (CAMP), NYSDOH CAMP (NYSDOH, June 2000) and Occupational Safety and Health Administration (OSHA) regulations promulgated under 29 CFR 1910.120. During the implementation of this CAMP, steps will be taken to prevent and reduce fugitive dust emissions and to ensure proper precautions are taken to protect human health to the surrounding community during demolition activities at the site. The CAMP addresses silicon dioxide (silica), Polychlorinated Biphenyls (PCBs), lead, and particulate air monitoring to assess if fugitive dust is transported from the site during demolition activities. The details of the dust control and air monitoring program are described in the following sections of this CAMP. 1.1 PROJECT OBJECTIVES There are four primary objectives of this CAMP: Protect human health and the environment; Monitor dust generation using real‐time monitoring in conjunction with worker health and safety programs; Evaluate the effectiveness of dust suppression controls and determine when additional controls are required; and Document air quality during demolition activities. 1.2 COMMUNITY AIR MONITORING PROGRAM OVERVIEW Monitoring conducted as part of this work plan shall be completed as outlined below. The first phase of sampling will establish baseline or background concentrations at the site prior to demolition activities. Baseline conditions will be determined utilizing real‐time data and laboratory data for silica, PCBs and lead that will be collected at least 2 days before the start of work. The second phase of sampling will be conducted during the daily construction/demolition tasks to document ambient air conditions at the site perimeter and to compare these conditions to the established action level criteria determined for the site. This will include real‐time air sample collection for the documentation of conditions at the property boundary during demolition activities. Real‐time particulate matter (dust) data will be collected from one upwind and one downwind location during demolition activities. The location of the monitoring stations may change from day to day depending on site activities and meteorological conditions. Dust monitoring will be conducted utilizing 1 direct reading aerosol (particulate) equipment capable of continuous air flow monitoring. As described herein, ambient air samples will also be collected downwind of demolition activities and analyzed for silicon dioxide, PCBs and lead. Additionally, meteorological parameters consisting of wind speed, wind direction, sigma theta, temperature and relative humidity will be monitored. The Technical Guidance for Site Investigation and Remediation program policy issued by the New York State Department of Environmental Conservation provides guidance regarding fugitive dust and particulate monitoring. The following information is excerpted from that technical guidance regarding the particulate (dust) action levels. “The action level will be established at 150 µg/m3 (15 minutes average). While conservative, this short‐term interval will provide a real‐time assessment of on‐site air quality to assure both health and safety. If particulate levels are detected in excess of 150 µg/m3, the upwind background level must be confirmed immediately. If the working site particulate measurement is greater than 100 µg/m3 greater than the background level, additional dust suppression techniques must be implemented to reduce the generation of fugitive dust and corrective action taken to protect site personnel and reduce the potential for contaminant migration. Corrective measures may include increasing the level of personal protection for on‐site personnel and implementing additional dust suppression techniques (see paragraph 7). Should the action level of 150 µg/m3 continue to be exceeded work must stop and DER [Division of Environmental Remediation] must be notified as provided in the site design or remedial work plan. The notification shall include a description of the control measures implemented to prevent further exceedances.” Based on regulatory guidance and OSHA’s time‐weighted average (TWA) Permissible exposure Limits (PEL), perimeter air quality action levels are summarized in the table below: Particulate matter Silicon dioxide PCBs (per Aroclor) Lead Activity During demolition activities The action level for particulate matter was established to limit 100 µg/m3 greater than TWA exposures to other constituents as follows: background (15 min. avg.) or Action Level Silicon dioxide (respirable crystalline silica) < 250 µg/m3 persistent visible fugitive dust is PCBs < 0.11 µg/m3 leaving the site. Lead < 30 µg/m3 If the action level concentration is reached downwind, confirm background level. If the working site Response particulate exceeds the action level, implement dust suppression techniques. The stop work limit for particulate matter is intended to control 150 µg/m3 greater than other constituents as follows: background for (15 min. avg.) Silicon dioxide < 250 µg/m3 TWA per OSHA’s PEL Stop Work with suppression techniques in PCBs < 500 µg/m3 TWA per OSHA’s PEL Limit place or persistent visible fugitive Lead < 50 µg/m3 TWA per OSHA’s PEL dust is leaving the site. Action level and suppression techniques shall be reviewed if analytical results exceed these levels. 2 Particulate matter Silicon dioxide PCBs (per Aroclor) Lead Sampling 15 minute average 8 hrs minimum Period NIOSH 7500, EPA Method Modified NIOSH using filter TO‐10A using 7300, using filter Sampling Data RAM media inside Sorbent, media inside pre‐ Method pre‐weighted Polyurethane weighted PVC PVC cassettes Foam cassettes Location Upwind & Downwind Downwind Silicon dioxide, PCBs, and lead will be sampled for three days Continuously during all of activity during the beginning of demolition activities and at Frequency demolition activities the onset of each significantly different activity. If results are below the action level, sampling will be suspended. The particulate matter action level was evaluated to determine if this action level was protective for silica, PCBs, and lead in Section 3 of this document. This analysis concluded that this action level for particulate matter at 100 µg/m3 provides appropriate protection for the community. 3 2. Air Quality Constituents of Interest Demolition activities have the potential to generate health risks to nearby and off‐site receptors through inhalation exposures to the Constituents of Interest (COI) in the air‐borne particulates (dust). Constituents of interest specific to the demolition of Building 52 include silicon dioxide (silica), PCBs, and lead, which are discussed below. 2.1 SILICON DIOXIDE Silica is the common name for silicon dioxide, a white or colorless crystalline compound found naturally in sand, granite and many other types of rocks. Concrete and masonry products contain both silica sand and rock containing silica. Crystalline silica is a natural substance found in stone, rocks, sand and clay, as well as products like bricks, tiles, concrete and some plastic composites. When these materials are worked on, for example by cutting or drilling, the crystalline silica is released as a very fine dust which could be inhaled. Silica dust is only harmful when inhaled deep into the lungs, where oxygen is taken up into the blood and only from the respirable fraction typically less than 5 micrometers in size. Due to its crystalline structure, a health concern associated with inhalation of silica is an incurable lung disease called silicosis. Occupational Safety and Health Administration’s (OSHA) permissible exposure limits (PEL) provide protection for workers in certain labor and construction industries including those doing demolition at this site. The PEL for this project is 250 µg/m3. While not required prior to June 23, 2017, OSHA has revised its regulations for silica exposure that take effect on June 23, 2016. The construction industry has one year to comply with these new regulations. The revised PEL, which evaluates the potential risk over a “working life” of 45 years, will be 50 µg/m3 for the respirable portion of silica particulate. This update was to clarify the standard and reflect additional information about the hazards of silica to construction workers. 2.2 POLYCHLORINATED BIPHENYLS (PCBS) Polychlorinated biphenyls (PCBs) are a group of manufactured organic chemicals, with no known natural sources, which contain 209 individual isomers (known as congeners). PCBs are either oily liquids or solids and are colorless to light yellow in color with no known smell or taste. Some commercial PCB mixtures are known in the United States by their industrial trade name, Aroclor. PCBs do not burn easily and are good insulating material. They have been used widely as coolants and lubricants in transformers, capacitors, and other electrical equipment. The manufacture of PCBs ceased in the United States in 1977. Products containing PCBs include old fluorescent lighting fixtures, electrical appliances containing PCB capacitors, old microscope oil, and hydraulic fluids. OSHA limits the concentration of PCBs in workroom air to 1 mg/m3 for PCBs containing 42% Cl and 0.5 mg/m3 for PCBs with 54% Cl. 2.3 LEAD The OSHA limits the concentration of lead in workroom air to 50 µg/m3 for an 8‐hour workday. Lead can affect most organs and systems in the body through ingestion or inhalation. The most sensitive receptor to lead is the central nervous system, particularly in children. Lead also damages kidneys and the 4 immune system. Construction workers are exposed to lead during the removal, renovation, or demolition of structures painted with lead pigments. Workers may also be exposed during installation, maintenance, or demolition of lead pipes and fittings, lead linings in tanks and radiation protection, leaded glass, work involving soldering, and other work involving lead metal or lead alloys. 5 3. Construction/Demolition Air Monitoring The monitoring program for this Site is intended to produce sufficient information in order to control the potential risk associated with fugitive emissions during demolition activities. Site personnel will use particulate monitoring equipment and review results to determine the need to implement dust control measures. Site constituents of interest are not volatile and therefore the predominate pathway for exposure will be inhalation of dust particles to which COIs are attached. The perimeter monitoring program will address potential exposure of the surrounding community to respirable dust generated during site operations through monitoring particulate matter on a continuous real time basis. Air monitoring for particulate matter (fugitive dust) shall comply with NYSDOH CAMP and requirements found in DER‐10. The purpose of the requirement to conduct air monitoring is to reduce the amount of particulate matter entrained in the ambient air as a result of anthropogenic fugitive dust sources by requiring actions to prevent, reduce, or mitigate fugitive dust emissions. Although direct measurement of concentration of site COIs in air cannot be practicably measured in real time, an evaluation of the concentration of dust that would result in an exceedance of COIs in air was completed for each site COI to determine if the particulate matter monitoring and associated action level would provide sufficient protection. 3.1 REVIEW OF ACTION LEVEL EFFECTIVENESS The New York State Depart Department of Environmental Conservation (NYSDEC) guidance regarding fugitive dust and particulate monitoring requires dust suppression techniques be implemented if the working site particulate measurement is greater than 100 µg/m3 greater than the background level. This action level protects receptors and also limits the transport of constituents of interest. The following evaluation considers if the NYSDEC action level is sufficient to limit constituent‐specific concentrations to below their respective desired levels. Institution of Occupational Safety and Health literature provides the approximate ranges for the amount of crystalline silica found in materials such as concrete/mortar and brick. Silica ranges between 25% and 70% in concrete/mortar and up to 30% in brick. Building 52 is primarily constructed with brick and mortar walls. An action level of 100 µg/m3 for particulate matter would be protective for dust with silica content even assuming all dust was from these materials. Based on the highest potential for silica content, the maximum concentration of silica would be up to 70 µg/m3 which is well below the PEL of 250 µg/m3. An action level of 100 µg/m3 can therefore be considered conservative based on the fact that the duration of public exposure would be significantly less than 45 years, the average concentration for all materials would be less than the maximum concentration of silica (70%), and the volume would not be entirely composed of materials containing silica. Site‐specific PCBs are not volatile and therefore would not be airborne unless they are associated with particulate matter. The maximum concentration of PCBs in building materials associated with demolition is approximately 500 PPM (parts per million) which was measured within a coating material at one location on the ceiling. Typical concentrations are less than 500 PPM. Assuming an action level of 100 µg/m3 for particulate matter, an analysis using the maximum concentration for all particulate matter would result in PCB concentrations less than 0.11 µg/m3. 6 Lead is not volatile and therefore would not be observed in air unless it is associated with particulate matter. Based on the pre‐characterization sampling results, the primary source of lead containing particulate matter would be from paint. Prior to demolition activities, loose paint will be scraped to reduce the potential for lead to be present in the air during demolition. Remaining paint is well bonded to the masonry materials or steel beams and therefore has a limited potential for becoming airborne. Some paints used prior to 1955 contained lead concentration of up to 50% by weight. Assuming an action level of 100 µg/m3 for particulate matter, an analysis using the maximum lead concentration for paint and assuming 50% of all particulate matter to be paint would result in concentrations below 30 µg/m3. This approach can be considered conservative based on the fact that pre‐demolition activities will remove loose paint and field observations indicated the paint was well bonded to the building materials and resisted removal during pre‐characterization sampling efforts. Given that the action level for particulate matter is established at 100 µg/m3, it can be concluded that this action level provides adequate protection for the community for all constituents of interest (silica, PCBs, and lead). While the assumptions used for this determination are conservative, verification sampling will also be completed. Verification samples will be collected to determine the concentration of silica, PCBs, and lead in the air for three consecutive days at the beginning of each demolition phase (i.e. brick wall removal, roof demolition, waste management, etc.) or whenever there is a significantly different demolition activity that may increase concentrations of site COIs. These results will be compared to levels established in this CAMP for silica, PCBs, and lead. 3.2 FIELD SCREENING METHODS Particulate monitoring will be conducted at two locations, one upwind and one downwind of the demolition activities. An aerosol meter will be used to provide screening results for particulate matter. This direct reading instrument (the DataRAM, or equivalent) has a measurement range from 0.001 to 400 mg/m3, and provides appropriate sensitivity for site applications. These direct reading instruments will be calibrated on a daily basis and maintained in accordance with the manufacturer’s specifications. All real‐time monitoring data will be logged. Data records will be referenced to site location, time and date of reading, and the initials of the field technician. The monitoring information will be downloaded and reviewed with the documentation package to ensure the airborne levels at the Site perimeter are less than the established Site action levels. Airborne particulate at the upwind and downwind locations will be measured on a continuous basis and reported as 15‐minute averages. An alarm (e.g. audible alarm) would provide notification that the downwind location is measuring concentrations equal to or greater than the particulate matter action level. If the ambient air concentration at the downwind location is 100 µg/m3 greater than background (as measured at the upwind site) for a 15‐minute period, or if airborne dust is observed leaving the work site, dust suppression activities will be employed. Work activities may continue during dust suppression provided that the downwind levels do not continually exceed 150 µg/m3 greater than background and persistent visible dust is not migrating from the work site. If, after implementation of dust suppression techniques, downwind levels are greater than 150 µg/m3 greater than the upwind level, work will cease and a re‐evaluation of activities initiated. Work will 7
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