NCD003200383_19930801_Koppers Co. Inc._FRBCERCLA SPD_Treatability Study-OCR

E PA .ite~·.s;,,';~~>-~ .... ~ ., .• •-·. -~. ·:;:;ffi. Solid Waste and Emergency Respo,,se
, Environmental Protection Office---:f Research and Development
Agency Washington, DC 20460
.t.a;;ust i 993 ---~~..-1; PROGRAMFACT SHEET ------! .
Demonstration of the Base-Catalyzed Decomposition Technology
and SAREX® THERM-0-DETOX™ S:,-stem
··· Koppers Company Superfund Site
Morrisville, North Carolina
THIS FACT SHEET TELLS YOU ABOUT ...
EPA's Superfur.d Innovative Technology Evaluation (SITE)
Program
A technology dcmon5tration to be pe:formed at the Koppers
. Company Superfund site, located in Morrisville, North Carolina
A Vi,;itors' Day to be held on August 31, 1993 at the Koppers
Company site
INTRODUCTION
_The U.S. Er.viconmental Protection Agency (EPA) identifies new
· methods for hazardous wa,1c cleanup through its SITE Program.
Under this progr=, created in 1986, innovative treatment tech-
nDlogies that IT'.ay sigr.ificantly reduce the toxicity, mobility, or
· volwne ofhaz.ardous waste are demonstrated and evaluated. 1he
SITE Program also generates reliable performance and cost
information on the technologies for use in evaluating cleanup
alternatives for similarly contaminated sites.
The technology proposed for demonstration is the Base-Catalyzed
Decomposition (BCD) technology developed by EPA's Risk
Reduction Engineering Laboratory in Cincinnati, Ohio, using the
SAREX® TIITRM-O-DETOX™ system developed by ETG
Environmental, Inc. (ETG), and Separation and Recovery Sys-
tems, Inc. (SRS). The purpose of this demonstration is to assess
how well the technology removes pentachlorophenol (PCP) and
dioxins from the soil at the Koppers Company Superfund site in
Morrisville, North Carolina.
EPA'S SITE PROGRAM
Each year, EPA solicits proposals from priva((; tc.:hnology devel-
opers to demonstrate innovative technologies under the SITE
Prc>gran1. Technology developers can submit dcm0nstratiou
proposals any time throughout the year. For each technology
sekx,1Cd, EPA, often "ith input from state and regional ag~ncies .
dc,e;:.thc following:
Identifies a site ,,;ith wastes suitable for treatment
• Prepares a technology demonstration plan
Notifies appropriate agcn:ies for intergov,,mn :,~,,ta! and
-~ conun~ty revit:ws
Pr~pares a fact shcct for the public, proposing the ,ite and
technology match
Prepares the demonstration site
Conducts and audits field sampling and laboratory analyses
Organizes a Visitors' Daytoviewthetechuologydemonstra-
tion
Evaluates technology performance
Prepares an Applications Analysis Report and a Technology
Evaluation _Report summarizing the demonstration results,
as well as several other informational items such as bulletins,
swnmaries, and a video
CONTAMINATED
MATERIALS ·----·
OR SCREENED SOILS
SCREW CONVEYOR
MEOUIM TEMP. THERMAi.
DESORPTION UNIT
(MTTD)
COOLING WATER
VAPOR DISCHARGES
WATER SPRAY
COOLING SCREW
CONVEYOR
ON-SITE BACKFILL
~-------'V~A~POR RECOVERY SYSTEacM"------,
TO
ATMOSPHERE
CARBON
POLISHER
CONDENSOR
UNIT
DECHLORINATION
r--"--, __ _.__--"OIL ADDITIVE REAGENTS
AQUEOUS
CONDENSATE
STORAG~
CARBON
ADSORPTIO
OILY
CONDENSATE>---~
STORAGE
TREATED
WATER
LIQUID
TANK
REACTOR
(LTR)
OR . ------<,
OFF-SITE DISPOSAL 'R'"="""''+i'
DECONJAMINATED SOLIDS
CONTAINER OIUHC
Figure I: BCD Technology and SAREX" THERM-0°DEfOX'" System
TECHNOLOGY DESCRIPTION
The BCD technology is an EPA ,patented process to remediate soil
. and sludge contaminated with chlorinated organic compounds .
Based on the process requirements of the BCD technology, ETG
and SRS have developed the SAREX" IBERM-O-DETOX™
system in cooperation with EPA to evaluate the effectiveness of
this process under real-time conditions in the field.
TheSAREX"lHERM-O-DETOX™systemisbasedonaproven
indirect-heat medium temperature them,al desorption (MTTD)
unit. The unit is equipped with a multiple-shaft agitator for high
heat transfer efficiency and excellent local mixing action.
The BCD physicaVchemical process detoxifies and chemically
· decomposes contaminants by removing chlorine atoms. Com-
pounds that the BCD process can decompose include polychlori-
nated biphenyls (PCB), PCP, chlorinated dibenzodioxins and
furans, insecticides, and herbicides.
The pr~s begins by mixing an inorganic reagent with the
contaminated soil, sediment, or sludge. The mixture is heated in
the MTTD unit for about 1 hour at 6.50 °F to 800 °F. Some of the
chlorinated contaminants are decomposed during this step. The
remaining organic contaminants are thermally desorbed and re-
moved \\ith the off-gas.
Clean soil exiting the solid reactor can be returned to the site. The
remaining contaminants from the vapor condensate and residual
dust are captured and treated for 2 to 4 hours at approximately
650 °F in a liquid-tank reactor (L TR). The L TR uses a high-
. boiling-point hydrocarbon, a proprietary catalyst, and sodium
hydroxide. Nitrogen is purged through the L TR to control oxygen
levels, preventing the tank contents from oxidizing or igniting. ·
Oily residuals remaining in the L TR contain dust and sludge and
are combustible. They can be burned in an oil-fired power plant,
a cement kiln, or treated and reclaimed by waste oil recyclers. The
aqueous condensate from the process can be discharged to a
publicly·<l\vned treatment works after being polished through an
activated carbon treatment process. Decontaminated sludge can
be disposed of in the same manner as municipal sludge. Spent
carbon from the water polishing can also be treated in this process.
The only by-products produced by the BCD process are biphenyl,
low-boiling olefinics, and sodium chloride.
SITE DESCRIPTION
The Koppers Company site is located in the Shiloh community,
several miles north ofMorrisville, North Carolina. The site covers
approxin1ately 52 acres at the intersection of Highway 54 and
Koppers Road (see Figure 2).
The southeastern section of the sll: the CELLON processing
· area and former lagoon area. The CELLON process involved
pressure-treating wood with PCP and then steaming it The water
generated from this process, called rinsate, was collected, pro-
cessed to remove the PCP by flocculation, and placed in two
lagoons at the site for further treatment The rinsate did however
contain PCP: The CELLON process was used at the site from .
:. !968to 1975. Thetwolagoonswereclosedandemptiedin 1976.
-: Water from the lagoons was sprayed onto the ground at the north
··· endofthesite,andthebottomsludgesfromthelagoonswerespread
to dry.
In 1980, high levels of PCP were found in the soils in the former
lagoon area and CELLON processing area. PCP was alsodeiected
in the groundwater. In I 989 thesitev.'aS added toEPA's National
Priorities List (NPL). A remedial investigation (RI) V.'aS con-
ducted, identifying the primary contaminants at the site as PCP,
polychlorinated dibenzo-p-<lioxins (PCDD), polychlorinated
dibenzofurans (PCDF), and isopropyl . ether (IPE). The RI
indicated that the CELLON processing area and lagoon area
served as sources for the migration of contaminants into the
ground:-,,ater.
TECHNOLIY DEMONSTRATION
The BCD technology and SAREX® THERM-0-DETO)I."™ sys-
tem demonstration at the Koppers Company site is scheduled to
occur during August 1993. The primary objectives of this
demonstration are to:
• Determine how efficiently the BCD process removes PCP,
dioxins, and furans from the contaminated soil
Determine whether treatment residuals (air, water, oil) meet
cleanup levels
Evaluate the potential for the BCD process to form additional ·
volatile organic compounds when heated to high tempera-·
tures
Obtain information required to estimate treatment cost.s,
including capital and operating expenses, for future S uperfund
decision-making purposes
CHURCH ROAD
LEGEND
• EXISTING WELLS
· -PROPERTY BOUNDARY
UNIT STRUCTURES/
KOPPERS SITE
PROPERTY LINE
> t; ..
FIRE POND
Figure 2: Kopper's Company, Inc. Superfund Site
EPA has prepared a detailed qu assurance project plan
outlining the methods and procedures for testing and evaluating the
technology. When the demonstration is complete, EPA will
compile and analyze the findings in an Applications Analysis
Report and a Technology Evaluation Report. These reports will
be_used to.evaluate alternatives for cleaning up similar sites across
the country.
.. ADDITIONAL INFORMATION
Questions or comments about the SITE Program or the proposed
de_monstration should be made by August 25, 1993 to:
Terry Lyons
U.S. EPA SITE Project Manager
26 West Martin Luther King Drive
Ci..,cinnati, Ohio 45268
[phone]
Specific questi
directed to:
egarding the demonstration site should be
Beverly Hudson or Diane Barrett
North Supetfund Remedial Branch
Waste Management Division
U.S. EPA, Region 4
345 Courtland Street, NE
Atlanta, Georgia 30365
[phone] or [phone]
Specific questions regarding the BCD technology or SAREX®
THERM-O-DETOX™ system should be directed to:
Dr. Y ei-Shong Shieh
ETG Environmental, Inc.
660 Sentry Parkway
Blue Bell, Pennsylvania 19422
(2 I 5) 832-0700
E PA . U.S. Emironmciltal Protection Agency
26 West Martin Luther King Drive.
Cincinnati, Ohio 45268 . . . . .
Attention: Terry Lyons .
@ Photocopied on Recycled Paper
u
Fax Transmittal
Transmitted Fronu
Risk Reduction Eng1neer1ng Laboratory ·
Superfund Technology Demonstration Division
Techn1ca1 Supp~rt Branch
Cincinnati, Ohio 45268
Phone:· [phone]
Fax: [phone]
DATE: ~ PAGES (1Tc~~~~!:1ED: ---~--
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July 20, l 993
Mr, Tel'T}' Lyona
Tochnlcal Project Manager .
U, S. Environmental Protection Aaency
Office of Research 1111d Developmont
26 W. Manin Luther Kiili Drive
Cincinnati, Ohio 45U8
Subject: Contract No. 68-C:0-0047
•
MC
Work A.alpmenl No. 0-t 1 ,
Site Preparation Activities tor the Sarn 'l'HERM,O,DETOX SITE Danom&tjatlon
Dear Mr. Lyons:
Enclosed plwe find attached one copy of tho Sit~ Preparation Activities fior tho Sarex. THERM-O-
DETOX SITE.Demonstration. •Activities dlacuued Include soil conta/Dlnatkm dellnoatlon, acavatlon,
.feed preparation, assembly of the Sarex THERM-0-DETOX containment pad; cowlnmeDt of tl'Ntod
residues generstcd frorn the procei;s, and schedulllli of site actlvltln. TIit allacbnwt dlacua181 act!vltillll
not covered In the drat\ quallty ·as~urance proj~t plan tor the demonairailon. Optc-atlon of the SU6l
THERM•O-DETOX system will he covered In a work plan byETG Envlronmelltll, ~c., which wUI be
completed by July 26, 1993.
If you have any QUC$tlons or comments concern Ina 1lte preparation actlvltlet dll<IIAHd In the attachmellt,
please call me at (404) 522·2867,
Sincerely,
µ;,~
Roben Hutcheson
Project Manaaer
11nachmen1
cc: Beverly Hudson, !PA Region 4 Ru.-nedlJ Project M1naaer
Bruce Nlchol1on, North Carolina Division of Solid Wute, Superfvnd Branch
Mitchell Moss, ETG Environmental Project Mana1er
Shannon CralJ, Boazer Envlrtinmcntal, Inc,
• •
· SITE PREPARATIONS ACTIVITIES
Site preparation activities for the Sarex THERM•O-DETOX SITS DmnP111tratlon Include aoll
contamination delineation; excavation; feed preparation;, UMmbly of the proc.a equipment COllt•lnJNQt
pad; containment and 11oraae of treated residues; site utility and facility requirements; a!ld tho CWTent
~chedule fur slle prepara1lon demonstration activities. Then Items are dlaeuaaed bdow.
I. SOIL CONTAMINATION DELINEATION, EXCAVATION, AND PEEi> PREPARATION
Solla to be treated ualllll tho BCD teohnolol)' will bt obtalnlld trom th• area north of tho formw
Cellon process bulldlni, Surface eoll sampllna conducted durln, lh, remedial lnvatlgatlon
indicated PCP concentratlonK areater rhan 1,000 part per mllllon In this area, and dloxlna/furans
concentrations 1rea1er than 270 part per billion. Activities to be performed In this area, whlell
Include contaminant dellnlllltlon, soil excavation, and ~oil feed preparadon, art dllCIIUtd below,
a. Soll Cgnramiaarlon Polioent!on
Surface soils to be e~cavated for treatmMt ualna the Sarex THERM•O-DETOX 1y1tem
will be dellneated during the t'!rat week on 1lte ualns the field analftlcal and 1amplillJ
service provided by PRC. The 111rfaco solla w111 be anllyild for PCP, 2,3,7,B•
tetrachlor!nated, d!hcnzo-p-d!vxln, 2,3, 7, 8-teuachlor!nated ·dlbelllloflaran, tolal dloxl11.1 1
and total furans. A portahlc aas chromatoaraph will be u,od l>r tho lll&lyala.
Approxlm111ely 50 surface soil samplea will be collected for anaiytl1. Th• samples wUI
· be co!lectod from a arid, with sampllna poln!A bti111 separated approximately 10 feet by
10 feet from eaeh other, The grid will be located In th• vlcink)' afloll borlnp X-26 and
X-28, which wer~ In.stalled durlna the romedlaJ lnveatlaatlon. All1110ll aamplill& locaelona
wlll be m11tked by a pin flaa and clearly ldentlfled with the c:orreapondin& aoll aampl•
number. This will aid loi:&tlon and Identification durlna t\lQln IIOil ooollmlnatlon
lnve,t11ations to be conducted d11rin1 the remedial doal1n,
b. son Excavation 10<1 Screening
Approximately 10 to 15 tona of soil will be ex.cavated for trelhnent. The aolla wlll
excavated w an approximate deprh of 0.5 foot below land 1urface ualna a tront eDd
loader, The area of excavation wUI moaaure approidmately 25 teet b~ l5 feet cootlnaent
upon one ati\a contalnln1 soils contaminated wlui hlah concentrations of PCP, dlodns,
and furans. High variability Ill surface soil contamination may requiro oxcavatlon of 10ll1
from more than one area to obtain the n.cessary volume for troatment.
The sons will be excavated uslna a backhoe and placed Into 55·&allon druma. The 10111
will he acreened manually to remove M>il p&r1lcles laraer lhan 0,5 Inch prior to placement
In druma. Drums containin1: acreencd soils will bt ataaod near dli feed preparation area,
the location or which Is undet.ermined at thla time.
•••r--
. I
• •
Facility requlrem1111u for the demonstration Include I worlt trallor, badlroom, and pboat MNICI,
The work trailer currently on 1lte l1 belnr provided by Bwtt But, Ille, for 11M durlq Ille
demonstration. Portable toll\!11 wlll be brousht to th• alt, If th, Btaslt tralJtr do• not contain
toilet facilitle«. Phone Kervlce will be provided by ponable telephona brou1bt to the 1lte.
Eh,ctrlcal and water utility service and and ponable toilet facUltlea provided for the demonstration
will be bllled 10 PRC Environmental Managtm811t, Inc. for payment Ulldet EPA Work
Asslanmant No. 0-1 I, as Kpeclfled 1n the work plan for the project,
5, SCHEDULE
The demonstration currently Is scheduled to ,tart durlna lhe .woek ot Auau,t l, 1993 and bt
completed b,Y Augu11 25, 1993.
Activities scheduled fo~ the w~ck of AuguRt 2 Include moblllzatloa of equipment to the site,
a,sembly of the prefabrlcuted containment pad, and delineation; e,;cavatlon, 1111d mbdnJ of foed
10ll1.
Activltle& scheduled for tho week of Auaust 9 Include shake-down teatln, of the Sarer. THERM-
O-DETOX system in Jlreparatlon for treatment of contaminated aoUa, pteparatlom for th• alt
quality te-,tins of the process equipment by Radian Corporation, and.tho Vlslton' Day actlvltlea.
Activities scheduled for the week of Auaust 16 lncludo demonstration 111d teetlna of the SlllllJt
THERM-0-DETOX system through the·processln1 of contamhiattd 10D1.
' Acthoitles 8cheduled for the week of Auaust 23 Include demobULlatlon of demo11&tr11tlon
equipment and petl(mnel.
------
c;,
• •
Feed PtlPVltiPD
Soils to be treated need to be prepared prior to foodln& llltQ die Sara THERM-O-
DETOX system i,rocesslns tqulpmont, Feed proparatlon will corillai or mh~ aoll, with
sodium bicarbonate powdered reagent In a pu1 mill. The foed preparation area wUI be
lined with plutlc to contain spilled aoll and reaaent,
The contaminated 1olls will be transferred from !he 5S•&•llon dnama 1tqod near the foed
preparation ares Into the pua mlil by use of a front•end loader, Soils mixed with the
sodium bicarbonate reasent wlll bo placed back lnto 55•&1111011 d!'llmf 1111d 1ca,ed naar the
cont~lnmant pad to be built for the demonatratloa proces1 eqvlpmMlt,
2. CONTAINMENT PAD
A pr~fabrlcated containment pad for tho Sarex THERM..Q.DETOX l)'llelll will be conatructocl
adjac:ent to the on-site concrete decontamination pad. The pad 11 belns 00111tnic:tm to c:ontaln the
possible spllla1e of feted snil, treated soil, and coolln11 water. The liner of the contalnmeat ped
will conslst of a aeo•textile base overlain by a hl&h denalty plastic llnw and plywood. Tho wall1
of the containment pad will b~ constructod of metal to provlde support for the plutlc liner.
Soils that are spilled within the cuntalnment pad wlll be colll!Cttd daily and stored In 55-&allon
dnims, The stored aoils will be fed Into the THERM-0-DETOX l)'ltelll for lreatment.
At the end of lh• demon5tration, the containment pad will be dluuembled. The liner a)'ltem wlll
bo drummed .a.nd prepared for off11ite diRpc,1al, The rernalnder ot oontalnment pad wUI be
prepared for shipment to EPA.
3. TREATED RESIDUES
· Reslduea generated by the Sarex THERM,O•DETOX system will coultt ot treated 10ll1, water,
and oll. Reald11H produced by the 1ystem will be stored ln 55•iallon dnuna 8Dd are andclpllted
to contaln conoen1ratlons of pentachlorophonol, dioxins, and furans at aipi.ltlcantl)' rtduced levels,
The aoaJ of the system Is to produce treated aoila that can be dlspONd of on site, treeted w&att
water that can bo dlacharged to the local treatment works, and wuto oU wblch can be dl1poltd
of as non-hwrdous oil. Analytical te11tina of all reslduos wlll bl perlonnod prior to 4ewmlnlna
the method of disposal.
4. lrrlLmES AND FACILITY REQUIREMENTS
Utlllty requlrementa for the demoostratlon Include water and eltctrlclty.
Electrical servlcc for the Sarex THERM-0-DETOX syatem wUI r~lrt uparlldlfli tbe curreot
on site power supply. Electrlcal service lmprovementa to the alte wm be provided by Carotl.Da
Power & Light and a local ~ubcontractor,
Water requirement~ for tho demonstration wlll require leas Ina water tanker tr\lckl to1provld• ill•
nece11sary dally volume requirlll.1 for the Sarex THERM-0-DB'TOX 1yne111.
','
• •
UNITED STATES
ENVIRONMENTAL PROTECTION.
AGENCY
Demonstration of the
Base-Catalyzed Decomposition
Technology and the SAREX®
THERM-0-DETOX™ System
Koppers Company Superfund Site
EPA Region 4
August 31, 1993
Visitors' Day Packet
SUPERFUND INNOVATIVE
TECHNOLOGY £VALUATION
OFFICE OF RESEARCH AND DEVELOPMENT
OFFICE OF SOLID WASTE AND EMERGENCY
RESPONSE
_c:_:
'.'.'.:::,:, Photocooied on Recycled Paper
• • TABLE OF CONTENTS
SECTION PAGE
Foreword .........................................
Visitors' Day Agenda ........................ .
EPA SITE Program .................................................. 2
Demonstration Site ................................................... 6
Technology ........................................................ · 9
Demonstration Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Notes ........................................................... 18
SITE Document Order Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
SITE Videotape Request Form ........................................... 25
FIGURES PAGE
Figure I: Types of Technologies in the Demonstration Program ............... 3
Figure 2: Site 2 Location Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............. 7
Figure 3: BCD Technology and the SAREX® THERM-0-DETOX"' System ............. 10
Figure 4: BCD Technology and the SAREX® THERM-0-DETOX'" System Sampling Locations . 16
TABLES PAGE
Table I: Sampling Locations and Descriptions ,-.......... 1)
I
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Foreword
TI1e U.S. Environmental Protection Agency's (EPA) Office of Research and Development
(ORD), EPA Region 4. and the North Carolina Department of Environment. Health. and Natural
Resources (NC-DEHNR) is sponsoring a Visitors' Day for the Superfund Innovative Technology
Evaluation (SITE) demonstration of ETG Environmental. Inc. ·s. (ETG) Base-Catalyzed
Decomposition (BCD) technology and the SAREX"' THERM-0-DETOX" system. This Visitors' Day
packet contains information about the SITE Program. the treatment process. Koppers Company
Superfund site. and the criteria and methods for evaluating the technology. Contacts are listed at the
end of each section. In addition. this packet includes a section for notes and order forms for SITE
Program publications and videos.
Visitors' Day Agenda
10:00 -10: 15 a.m.
10:15 -· 10:45 a.m.
10:45 -11: 15 a.m.
I 1:15 - I 1:45 a.m.
il:45 a.m. -12:15 p.m.
12:15 -12:30 p.m.
12:30 -I: 15 p.m.
1:15 -1:30 p.m.
2:00 -2:45 p.m.
Registration
Welcome
SITE Program Overview
History and Description of the
Demonstration Site
Technology Description
Technology Demonstration and
Evaluation Approach
General Question anti Answer
Period
Lunch
(CJvailable in cafeteria at visimrs'
own expense)
Board Bus to Koppers Site
Viewing of T t!chnology
Demonstration
Cindy Loney
PRC Environmental
Management, Inc.
Terry Lyons
EPA SITE Project Manager
Beverly Hudson
EPA Region 4
Remedial Project Manager
Dr. Yei-Shong Shieh
ETG Environmental. Inc.
Robert Hutcheson
PRC Environmental
Management. Inc.
Terry Lyons -Moderator
EPA SITE Project Manager
' I,
• • EPA SITE Program
■ The Supertund Amendments and Reauthorization Act of 1986 (SARA) directed EPA to
develop a program that promotes alternative ur innovative technologies for remediating
hazardous waste sites.
11 In response. EPA ORD established the SITE Program. which has four components:
II
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• Demonstration Program -Conducts and evaluates demonstrations of promising
innovative technologies to provide reliable performance. cost. and applicability
information for site cleanup decision-making
• Emerging Technology Program -Providt!S funding to developers to continue
research efforts at the bench-and pilot-scale levels to promote the
development of innovativt! tt!chnnlogii:s
• Monitoring and i'vleasurement Technologies Program -Develops technologies
that detect. monitor. and measure hazardous and toxic substances to provide
better. faster. and more cost-effective methods for producing real-time data
during site characterization and.remediation
• Technology Transfer Program -Disseminates technical information on
innovative technologies to remove impediments for using these technologies
,The evaluation of the BCD technology and the SAREX® THERM-0-DETOX" system is part of the SITE Demonstration Program. This program focuses on evaluating a full-scale
technology to:
•
•
Develop credible. objective data on a technology's performance. operation .
and cost
Publicize these tindings to EPA regions. remediation tirms. responsible
parties. and other interested parties. through publications and conferences
• Encourage aJvam:ement of technologies for commt!rcial use
Each year. EPA ORD solicits proposals frnm technolngy deveinpers for the Demnnstration
Program. Since the tirst solicitation in 1987. EPA ORD has accepted 94 technolngies into the
Demonstration Program and has demonstrated 46 nf these technologies. Figure I shows the
types of technologies currently participating in the Demnnstration Program.
For each technology accepted into the program. EPA ORD selects a hazardous waste site
where the technoingy will he demonstrated. Technology-site matches are made through EPA
regional nominations. developer nominations. other agency nominations. and database searches.
l
J
l
l
I
I
• EPA SITE Program
T'·pes o r.· re 1 -:,,..' igu .,
Solidifica~ion/
Stabilization
11
•
Materials
Handling
3
Radioactive
2
Thermal Desorption
16
. Program . in the Demonstrauon -t. Technologies
J
• • EPA SITE Program
■ Technology demonstration activities generally fall into three categories: pre-demonstration. demonstration. and post-demonstration. These activities are listed by c:uegory below:
Pre-demons! rat ion:
Activities
• Site selection
• \Vaste characterization
• Treatability testing
• Demonstration Plan preparation
• Sik preparation
• E4uipment mobilization
Demonstration:
Activities
• Equipment operation
• Process monitoring an<l
measurement. an<l sample
collection and analysis
• Fid<l audit
• Visitors· Day
Post-demonstration:
Activities
• Equipment demobilization
• Site restoration
• Laboratory audit
• Technology evaluation
• Technology transfer
(bulletins .. reports.
\'ic.leotape, anJ con1'cn:nces)
Rcsponsihle Organizations
EPA ORD, EPA regions. state agencies. and devdoper
EPA ORD. EPA regions. and stale ,1gencies
EPA ORD anJ. Llevelopa
EPA ORD
EPA ORD
Devdopc:r
__ -.Responsible Or~aniz:itions
Developc:r
EPA ORD
EPA ORD
EPA ORD, EPA regions, state agencies. developer, and
other intc:rested parties
Responsihle Or~anizations
Developer
EPA ORD
EPA ORD
EPA ORD
EPA ORD
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• •
EPA SITE Program
SITE Program Contact
For more information on this technology demonstration of the SITE Program, please contact:
Terry Lyons
U.S. EPA SITE Project Manager
Risk Reduction Engineering Laboratory
26 West Martin Luther King Drive
Cincinnati. Ohio 45268
[phone]
5
• • Demonstration Site
Description
•
•
•
The Koppers Company site is located in the Shiloh community. several miles north of Morrisville. in Wake County, North Carolina.
The site covers approximately 52 acres at the intersection or' Highway 54 and Koppers Road . (see Figure 2).
ETG's BCD technology and the SAREX"' THERM-0-DETOX'" system are heing demonstrated at the Koppers Company site in August 1993.
Historv
•
II
a
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"
The Koppers Company site is a former wood treating facility. In 1961 the site was sold hy Cary Lumher Company to Unit Structures. Inc. and again sold in 1962 to Koppers Company. In 1986. the majority of the site was sold to Unit Structures (unrelated to the previously mentioned.Unit Structures. Inc.). In 1988 Koppers Company was bought hy Beazer East. Inc. (Beazer).
Between 1968 until 1975 a process called CELLON was used to treat wood in the southeastern section of the site. The area is called the CELLON proce,sing area and the · former lagoon area on Figure 2. The treatment consisted of steaming the wood after pentachlorophenol (PCP) had heen·pressure-applied to the wood. Water generated from the steam. known as rinsate. was collected and processed to remove the PCP hy means of flocculation. The rinsate was then placed in two lagoons on the site for further treatment; however. the rinal rinsate did contain amounts of PCP.
In I 976. the two lagoons at the site were closed. The water from the lagoons was sprayed onto the ground at the north end of the site. and the lagoon hottom sludges were mixed with surrounding soil anti spread to dry in the former lagoon area. Both areas were fertilized and seeded.
In I 980. high levels of PCP were found in the soils of the former lagoon area and the CELLON processing area. PCP was also detected in the groundwater.
During several separate actions hetween 1980 and 1986. llver 1.710 cuhic yards of contaminated soil was removed from the area hy Koppers Companv. Contaminated soil was reportedly hauled to a permitted facilitv for proper disposal.
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Demonstration Site
CHURCH ROAD
OW-2 • • ... W-12
,c:t> \
RUCTURES PROPERTY ' :-:-·· .,,.,, \ KOPPERS
.......S ' . COMPAN
LEGEND
Cl EXISTING WELLS
-PROPERTY BOUNDARY
--UNIT STRUCTURES/
KOPPERS SITE
PROPERTY LINE
~ \ \PROPER
STRUCTURES 1
~-..:o.-.i=RO~ ..• •., /
FIRE POND
Figure 2 Site Location iVIap
> tJ ...
• • Demonstration Site
■
■ ,
■
In June 1980, the NC-DEHNR conducted an inspection of the site, Seven monitoring wells were installed around the plant by Koppers Company in July l 980,
NC-DEHNR recommended in June 1988 that the site he included on EPA's National
Priorities List (NPL). This was finalized in March 1989.
In December 1992 the Record of Decision (ROD) was signed. A primary and contingency
remedy was selected for soils. The primary remedy cnnsists of soil excavation and off site incineration. The contingency remedy consists of using the BCD technology. For
groundwater at the site. carbon adsorption was selected. For surface water at the site. pond dt!watering was chosen.
■ Treatability studies of the BCD process will he conducted on soils at the site. Based on the
results from these studies. the BCD technology may be selected to remediate the site.
Waste Characteristics
■ Through a remedial investigation. contaminants identified at the site include PCP.
polychlorinated dihe~zo-p-dioxins (PCDD). polychlorinated dihenzofurans (PCDF). and isopropvl ether (!PE). . '
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Demonstration Contact for the Koppers Comp:mv Superfund Site
For additional infonjation about the site. please contact: ' !
B~verlv Hudson. Remedial Project M:ma~er nr
Diarie Ba;rett. NC Community R~lations C~ordinarnr
North Superfund Remedial Branch
Waste /vtanagement Division
U.S. Envrionmemal Protection Agern:y~ Region 4
345 Courtland Street. NE
Atlanta. Gerogia 30365
[phone]
Fur written information concerning site activities and documents developed during the
Superfund process. visit the information repository located at:
Wake County Puhl ic Library
Cary Branch
310 South Academy Street
Carv. North Carolina 27511
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Technology
Background
■ EPA's Risk Reduction Engineering Laboratory (RREL) in Cincinnati. Ohio developed and
patented the BCD technology. ETG and Separation and Recovery Systems, Inc. (SRS)
developed the SAREX"' THERM-0-DETOX" system to be used with the BCD technology.
• Through a cooperative effort between the EPA SITE Program. EPA Region 4. the
NC-DEHNR. the BCD technology will he evaluated at the Koppers Company Superfund site
in Morrisville. North Carolina. The technology demonstration will determine how d'fectively
the BCD technology, in conjunction with the SAREX"' THERM-0-DETOX" system. removes
PCP and furans from the soil at the site.
Prnce.~s Description
" The BCD physical/chemical process detoxifies and chemically decomposes contaminants by
removing chlorine atoms. The BCD process can decompose polychlorinated biphenyls (PCB).
PCP. chlorinated dibenzodioxins and furans. insecticides. and herbicides.
" The SAREX"' THERM-0-DETOX" system is based on indirect-heat t,y low and medium
temperature thermal desorption (L TTD and MTTD) units. The units are equipped with a
multiple-shaft agitator for high heat transfer efficiency, excellent local mixing action. and
retention-time variability (see Figure 3).
• The process tiegins tiy mixing an inorganic dechlorination reagent with the contaminated soil.
sediment. or sludge. The mixture is heated in the MTTD unit for about I hour at 650 °F to
800 °F. Some ot' the chlorinated contaminants are decomposed during this step. The
remaining organic contaminants are thermally desorhed and removed with the off-gas.
"' Clean soil exiting the MTTD can he returned to the site. The remaining contaminants from
the vapor condensate and residual dust are captured and treated for 2 to 4 hours at about 650
°F in a liquid-tank reactor (L TR). The LTR uses a high-boiling-point hydrocarbon. a
proprietary catalyst. and sodium hydroxide. Nitrogen is purged through the LTR to control
oxygen levels. preventing thl! tank contents from oxidizing or igniting.
9
Technology
CONTAMINATED
MATERIALS
OR SCREENED SOILS
• •
VAPOR RECOVERY SYSTEM ~----------,
FEED J--, DE';,HLO'l:~t•ON
VAPOR DISCHARGES
HOPPER ~ EAG S
I/-Z:/"-/"-d
LOW TEMP. THERMAL I DESORPTION UNIT
(LTTO)
~-'~--_J.-~
a o c::: 1 0 V V
MEDIUM.TEMP. THERMAi, · WATER SPRAY DESORPTION UNIT r-I (MTTO) I . ;:::j/\/"-/VI
COOLING SCREW j CONVEYOR
ON-SITE BACKFILL
OR
OFF.SITE DISPOSAL V V
CAAl!ON i '"'°""""
DECONTAMINATED SCUDS
CONTAINER TI1E.\TED ~UHC
CONDENSATE
TANK
Figure 3 -The BCD Technology and the SAR.EX® TI·IER.!\J-0-DETOXT" System.
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Technology
■ Oily residuals remaining in the L TR contain dust and sludge and are combustible. They can
be burned in an oil-tired power plant. a cement kiln. or treated and reclaimed by waste oil
recyclers. The aqueous condensate from the process can be discharged to a publicly-owned
treatment works after being pumped through an activated carbon treatment process.
Decontaminated sludge can he Jisposed of in the same manner as municipal sludge. Spent carbon from the water pDlishing can also be treated in this process.
■ The only by-products produced hy the BCD process are nonchlorinated hydrocarbons. low-boiling olefinics. and sodium chloride.
BCD Chemistry
The base-catalyzed reaction to dehalogenate halogenated compounds can he generalized as follows:
R-(Cl)x + R' R -

H

+ NaCl R"
•
•
•
catalyst
R-(CI). represents halogenated compounds such as PCP. PCBs .
2.4-dichlorophenoxyactic or 2_4.5-trichlorophenol. and dioxins.
R' represents the hydrogen donor.
Chloride on R-(CI\ is replaced by H to produce R-H. R' donates hydrogen and becomes R'' with the formation of sodium chloride (NaCl).
This reaction completely clehalogenates halogenated rnmpounds .
11
• • Technology
Equipment
II The system includes the following components: (I) a medium-temperature thermal desorption (MTID) unit. (2) a vapor recovery system. and (3) a liquid-tank reactor (L TR). (see Figure 3).
11 Off-gas emissions are extremely low. and organic vapors are condensed and removed. The technology has minimum environmental impact and few permitting requirements.
II The treated soil discharged from the MTID unit is free of organic rnntaminants. maintains its physical characteristics. and is suitable for on-site hackiill.
" The system can he installed on two to three trailers for ease of mobilization.
Operation
■ The system will be demonstrated over a period of 3 weeks. Because this is a pilot-scale remediation. ETG will vary the operating parameters during the technology demonstration to determine optimal conditions for the project.
■ Operating temperature. teed rate. reagents. and off-gas !low rate will he predetermined for each of the six test runs.
Factors Affecting Performance
11 System performance could be affected hy the following iacrors:
• Ot!gree of mixing
• Heat transfer
• Material temperature
• Retention time • Reagent types and quantities
ETG Technolouv Contact
For more information on the system. please wnract:
Dr. Yei-Shong Shieh
ETG Envirnnmental. Inc.
660 Sentry Parkway
Blue Bell. Pennsylvania 19422
215-832-0700
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Demonstration Approach
Technology Demonstration Ohjectives
• The following objectives have been identified by the EPA SITE Program. EPA Region 4.
NC-DEHNR. the technology developers (ETG and SRS), and Beazer (Koppers Company's
owner).
• Assess the technology's ability to treat contaminated soil to levels determined in the
site's ROD
• Determine whether process eftluents meet applicable local. state. and federal standards
for disposal or discharge
• Evaluate potential effects on PCP and t't,rans. such as formation of other hazardous
by-products resulting from the thermal reactions of chemicals in the BCD process.
• Develop capital and operating cost estimates
• Identify specific operating and maintenance concerns .that may affect the system's
long-term reliability
Demonstration Prouram Test Runs
■ A total of eight test runs will he conducted to attain the above objectives. six runs using the
solids reactor and two runs using the liquid reactor.
11 Operating conditions for the first four solids runs will he varied slightly to determine which
exhibit the greatest contaminant reduction and meet cleanup levels. The last two solids runs
will use the optimum operating conditions determined during the first four solids runs.
Sampling and Analvsis Program
11 The overall sampling objective is to produce well-documented. defensible data that are of
known quality and are reproducible. Fnr this reason. EPA prepared a Category II quality
assurance project plan (QAPP) that details sampling. analytical. quality assurance. and quality
control procedures. Speciti.: sampling objectives are as follows:
• Collect samples that are representative of the sampled media
• Collect and analyze samples for target compounds necessary to determine the BCD
system's performance
• Verify the reproducibility of the treatment system's performance
• Demonstration Approach
Sampling and Measurement Locations
•
II
•
Locations at which samples will be collected are discribed in Table-I and shown in Figure 4 . These samples will be analyzed for the target compounds and physical characteristics (for example moisture content I needed to document the system's performance.
Various process measurements will be recorded on log sheets to document the operating
conditions during each run. Examples of these measurements include waste ieed rate and
reactor temperature.
The process conditions to he varied include the temperature settings of the solids reactors and
the addition of the catalyst. The low temperature and medium temperature thermal desorption
units will operate at the same temperature. During test run I :ind 2 they will be Dperated at
800 "F. and during test runs 3 and 4 they will operate at 650 "F. The catalyst will be added during runs I and 3.
Oualitv Assurance Ohjectives and Audits
• The quality assurance objective for this demonstration is to produce well-documented data of .known quality. Quality is measured by the data's.prec:ision.,accuracy, completeness.
representativeness. and comparability.
EPA will audit both the field demonstration and the laboratory analvsis to verifv the following: · · -
The sampling. analytical. quality assurance. and quality control procedures from the
·approved quality assurance proje·~t plan (QAPP) are properly implemented
Modifications to the approved field or laboratory procedures are appropriate
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Demonstration Approach
Table 1 -Sampling Locations and Descriptions
Sampling De."icription
Location
I Comaminatt'd soil afler si:.e rt>d11c1ion. The 1,:ont.:iminatcd soil will be excavated, screened to less than
1/2-inch, and contained in 55-p.llon drums. R:i.ndom grab samples will be t::i.kcn· from the 55-gallon
drums before and after the addition of the cata.lyst. One composite s.:i.mpk: per two drums will be
generated from the grab samples and submiucd for analysis.
' Trealt!d soil. Treated soil will be sampled as it is Jischargcd from the MTTD unit alter cooling water is -
added in the cooling screw l"nm·cyor. One l'ompositc samplr.: per two drums will be generated from the
grab samples and submiH1.:d ftlr an:.dysis.
3 Reactor o.ffgas. The n.:actor nff-~J.s will bi..: sampkd from ports in lite pipe exiting the re!l.ctor before
discll!l.rgc.
4 Stack gas. Gases from the L TTD and MTTD oi!lwali.:r s,:rubbcr system :i.nd from the L TR will be
sampled after discharge from the carbon polishers.
5 LTR injl11t1nl. The L TR in!lw.:nt will consist of 40 to 60 gallons oi' oil collectcd from the soil scrubber
systcm. The scrubber system oil in the L TR will be sampk:d before the addition of re:i.gents.
6 LTR t!.Ol1unr. After the L TR batch test is complete !l.nd allowed to cool. the n:o.ctor effluent will be
s!1.mpkd from the reactor tank.
i LTR o{f-gos. The L TR off-gas will be sampled at two st:i.ges of each batch test. The first reactor off-g.:J.s
.sample will be colh:ch:d a1icr the initial ri.:actor bc::n-up. The second reactor off-gas sample will be
collectcd bcfore completion o( Lhe batch test. The sampli.: will be collected ·before condensing off-gas.
s Cundt!nsare water. Cundl!nsatc w:Hcr will be c:olh:ctcd from the con<li.:nsatc storage tank before treatment
in the carbon unit.
9 Treated 1,·astt!wata. Thi! tn::i.ted wastewater will be sampled from the treated wastewater stor.igc t:i.nk.
15
• Demonstration Approach
CONTAMINATED
MATERIALS
OR SCREENED SOILS
•
I
,-----'-'A_POR RECOVERY SYST;;EM;;_ ___ _,
DECHLORINATION
REAGENTS
VAPOR DISCHARGES
TO ATMOSPHERE
FEED 0
HOPPER~
~l/J."'c/:;:;::"'=/:::;:;:"'=21::::.,
LOW TEMP. THERMAL I DESORPTION UNIT
(LTTD)
0 0 0 c-
l O CJ V
CARBON
POLISHER
. '------.,---.J 0,,----~--,
MEDIUM TEMP. THERMA~ WATER SPRAY
DESORPllON UNIT : I
(MTTDJ • L
AOOEOl,IS l:Oi.DENSU'E STOIV.G[
.::1·~v-"'-/"'"'""'_/...,.,~-/__,1
. COOLING SCREW j ~ COfNEYOA
:.,.11-~
ON.SITE BACKFILL . 1 ?!???:
OR ---7!#·~§!!!!!!!!!!!!~ OFF-SITE DISPOSAL v u
DECONTAMINATED SCUDS .
CONTAINER .
0
_lj
OIL WATER RUBBERS
CONDENSER
UNIT
TREA.l"EO WATER
0
'
CONDENSATE
TANK
Figure 4 -The BCD Technoiogy and the SAREX® THERJVl-0-DETOX'" System
Sampling Locations
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Demonstration Approach
Documentation or Demonstration Results
• EPA will publish the following reports documenting the technology demonstration results:
• Demonstration Bulletin
• Project Summary
• Technology Evaluation Report
• Applications Analysis Report ,
These reports for the BCD technology and the SA REX® THERM-0-DETOX'" system
demonstration will he availahle in 1994. EPA will also produce a technology demonstration
video documenting the demonstration activities. Order forms listing all documents and videos
availahle under the SITE Program are located at the end of this document.
Demonstration Activitie8 Contact
For further information ahout the demonstration approach and activities. please contact:
. Roh·:rt Hutcheson
PRC 0 :oject Manager
285 -Peachtree Center Avenue. Suite 900
. Atlanta. Georgia 30303
[phone]
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oEPA • Documents Available from-e
U.S. EPA Risk Reduction Engineering Laboratory
Superfund Technology Demonstration Division*
General Publications
0 SITE Program: Progress and Accomplishments for FY91-
A Fifth Repon to Congress (EPN540/R-92/076)
0 SITE Profiles, Fifth Edition (EPN540/R-92/077)
0 Survey of Materials Handling Technologies Used at Hazardous Waste
Sites (EPN540/2-91/0IO)
Demonstration Project Results
American Combustion-
Oxygen Enhanced Incineration
0 Technology Evaluation (EPN540/5-89/008)
0 Applications Analysis (EPN540/A5-89/008)
0 Technology Demo. Summary (EP N540/S5-89/008)
0 Demonstration Bulletin (EP N540/M5-89/008)
A WD Technologies, lnc.-
Jntegraud Vapor Extraction and Steam Vacuum Stripping
0 Applications Analysis (EPN540/A5-91/()()2)
0 Demonstration Bulletin (EPN540/M5-91/()()2)
Babcock and Wilcox-Cyclone Furnace Vitrifu:aJion
0 Technology Evaluation Vo!. I (EPN540/R-92'U17A)
0 Technology Evaluation Vol. Il (EP N540/R-92/017B)
0 Applications Analysis (EPN540/AR-92/017)
0 Technology Demo. Summary (EPN540/SR-92/017)
0 Demonstration Bulletin (EPN540/MR-92/01 I)
Bergmann USA-Soil/Sediment Washing System
0 Demonstration Bulletin (EP N540/MR-92/075)
Biotrol-/Jiotreahrunt of GroundwDllr
0 Technology Evaluation (EPA/540/5-91/001)
PB92-110048••
0 Applications Analysis (EPN540/A5-91/00I)
0 Technology. Demo. Summary (EP N540/S5-91/001)
0 Demonstration Bulletin (EPN540/M5-9!/001)
BUJtrol-SoU Washing System
0 Technology Evaluation Vo!. I (EPN540/5-9!/003a)
PB92-1153!0
0 Technology Evaluation Vol. Il Part A
(EP N540/5-91/003b)
PB92-115328
• Order documents free of charge by calling EPA's
Center for Environmental Research Information
(CERI) at 513-569-7562.
□ Technology Evaluation Vol. II Part B
(EP N540/5-91/003c)
PB92-115336
0 Applications Analysis (EPN540/A5-91/003)
PB92-115245
0 Technology Demo. Summary (EPN540/S5-9!/003)
0 Demonstration Bulletin (EPN540/M5-9!/003)
CF Systems Corp.-Solvent Extraction
0 Technology Evaluation Vo!. I (EPN540/5-90/002)
0 Technology Evaluation Vo!. II (EPN540/5-90/002a)
PB90-!86503
0 Applications Analysis (EPN540/A5-90/002)
0 Technology Demo. Summary (EPN540/S5-90/002)
0 Demonstration Bulletin (EP N540/M5-90/002)
Chtmfix Technologies, lnc.-
Chtmical Fixation!StabiliUJJion
0 Technology Evaluation Vo!. I (EPN540/5-89/01 la)
0 Technology Evaluation Vol. Il (EPN540/5-89/0l lb)
0 Applications Analysis (EPN540/A5-89/011)
0 Technology Demo. Summary (EPN540/S5-89/011)
. 0 Demonstration Bulletin (EP N540/M5-89/01 I)
Dehydro--Tech-Carver-Greenfield
0 Technology Evaluation (EP N540/R-92/002)
0 Applications Analysis (EPN540/AR-92/002)
0 Technology Demo. Summary (EPN540/SR-92/002)
0 Demonstration Bulletin (EPN540/MR-92/002)
PB92-217462
DuponJ!Oberlin-MU:rofulralWn SysJem
0 Technology Evaluation (EPN540/5-90/007)
PB92-J53410
0 Applications Analysis (EPN540/A5-90/007)
0 Technology Demo. Summary (EP N540/S5-90/007)
0 Demonstration B~lletin (EPN540/M5-90/007)
•• Documents with a PB nwnbcr must be ordered by that number ai
cost from
National Technical Information Service
5285 Pon Royal Road
Springfield VA 22161
Telephone [phone].
• ' ' • Demonstration Project Results (continued)
EPA-Design and Developmtnl of a Pilot-Scak Debris
Deconlaminotion System ·
0 Technical Evaluation (EPN540/5-91/006a)
0 Technical Evaluation Vol. Il (EPN540/5-91/006b)
PB91-231464
0 Technology Demo. Swnmary (EPN540/S5-91/006)
Hazcon-Solidifi.calion
0 Technology Evaluation_ Vol. I (EPN540/5-89/00la)
0 Technology Evaluation Vol. Il EPN540/5-89/00lb)
PB89-J58828
0 Applications Analysis (EPN540/A5-89/001)
0 Technology Demo. Swnmary (EP N540/S5-89/001)
0 Demonstration Bulletin (EP N540/M5-_89/001)
Horsehead Resource Devtlopmtnl
0 Technology Evaluation Vol I (EPN540/5-9J,005)
PB92-205855
0 Applications Analysis (EPN540/A5-9J/005)
0 Technology Demo. Swnmary (EP N540/S5-91/005)
0 Demonstration Bulletin (EPN540/M5-91/005)
International Technology Corporation--Slu"y Biodegradation
0 · ·Demonstration Bulletin (EPN540/M5-9JA)()9)
JWT/GeoCon Jn.SiJu Stabilization
0-Technology Evaluation Vol. I (EPN540/5-89/004a)
0 Technology Evaluation Vol. Il (EPN540/5-89/004b)
0 , Technology Evaluation Vol. ill (EPN540/5-89/004c)
PB90-269069
0 Technology Evaluation Vol. IV (EPN540/5-89/004d)
PB90-269077
0 Applications Analysis (EPN540/A5-89/004)
0 Technology Demo. Swnmary (EPN540/S5-89/004)
0 Technology Demo, Swnmary., Update Report
(EP N540/S5-89/004a)
0 Demonstration Bulletin (EPN540/M5-89/004)
McCoU Superfund Sil~Demonstrali.on of a Trial Excavation
0 Technology Evaluation (EPN540/R-92/015)
PB92-226448 .
0 Applications Analysis (EPN540/AR-92/015)
0 Technology Demo. Swnmary (EP N540/SR-92/015)
Ogden Circulating Bed Combustor-McCoU S~perftmd Sile
0 Technology Evaluation (EPN540/R-92/00I)
0. Demonstration Bulletin (EPN540/MR-92/001)
• Order documents free of charge by calling EPA's
Center for Environmental Research Information
(CERI) al 513-569-7562.
Ou.tboard Marine Corporation Sile-Soilluh Anaerobic Thermal
Processor
0 Demonstration Bulletin (EPN540/MR-92/078)
Retech Plasma Centrifugal Furnace
0 Technology Evaluation Vol. I (EPN540/5-91/007a)
PB 92-216035
0 Technology Evaluation Vol. Il (EPN540/5-91/007b)
PB92-216043
0 Applications Analysis (EPN540/A5-9J,007)
0 Technology Demo. Swnmary (EPN540/S5-91/007)
0 Demonstration Bulletin (EPN540/M5-91/007)
Resources Conservation Compan~The Bll;Sic Extractive Sludge
Treatment (B.A.SJ.C)
0 Demonstration Bulletin (EPN540/MR-92/079)
Roy F. Weston, lnc.-Low Temperature Thermal Trralment
(LTJ) System
0 Demonstration Bulletin (EPN540/MR-92/019)
SBP TeChno'logies-Memhrane Filtration
0 · ,Demonstration Bulletin (EPN540/MR-92/014)
Shirco-lnfrand Incineration
0 Technology Evaluation-Peake Oil
(EP N540/5-88/002a)
,
0 Technology Evaluation-Rose Township
(EP N540/5-89/007a)
0 Technology Evaluation-Rose Township Vol. Il
(EP N540/5-89/007b)
PB89-J67910
0 Applications Analysis (EPN540/A5-89/0J0)
0 Technology Demo. Summary (EPN540/S5-89/007)
0 Demonstration Bulletin (EPN540/M5-88/002)
Silicate Tuhnology Corporation-Solidij,cation/Stabilization of
Organid/norganic Contaminants
0 Demonstration Bulletin (EPN540/MR-92/0J0)
Soiltech ATP Syslems-Aostra.Soi/.Tech Anaerobic Thermal
Process
0 Demonstration Bulletin (EP N540/MR-92/008)
•• Documents with a PB nwnber must be ordered by that number at
cost from
National Technical lnformation'Service
5285 Port Royal Road
Springfield VA 22161
Telephone [phone].
I
I
I
.emonstration Project Results -tinued)
Solidiuch, lnc.-Solidif,eation
0 Technology Evaluation Vol. I (EPA/540/5-89/005a)
0 Technology Evaluation Vol. II (EPN540/5-89,005b)
PB90-191768
0 Applications Analysis (EPA/540/A5-89,005)
0 Technology Demo. Summary (EPN540/S5-89/005)
0 Demonstration Bulletin (EPA/540/M5-89,005)
Te"a Voe-Vacuum Extraction
0 Technology Evaluation Vol. I (EPN540/5-89/003a)
0 Technology Evaluation Vol. II (EPN540/5-89,003b)
PB89-192033
0 Applications Analysis (EPA/540/A5-89,003)
0 Technology Demo. Summary (EPN540/S5-89/003)
0 Demonstration Bulletin (EPN540/M5-89,003)
• Order documents free of charge by calling EPA's
Center for Environmental Research lnfonnation
(CERI) at 513-569-7562.
Thomeco, lnc.-Enzyme.Actimud Cellulose Technology
0 Trcatability Study Bulletin (EPN540/MR-92/0l8)
Toronto Harbour Commissi.oners-Soil Recycling Tnatnunt
Train
0 Demonstration Bulletin (EPN540/MR-92/015)
Toxic Tr,atments (USA}-ln-Silu Steam/Hot Air Stripping
0 Applications Analysis (EP N540/A5-90,008)
0 . Demonstration Bulletin (EPN540/M5-90,003)
Ultrox lnternational-VV Oz.one T'natmentfor LUJuids
0 Technology Evaluation (EPN540/5-89/0l2)
0 Applications Analysis (EPN540/A5-89/012)
0 Technology Demo. Summary (EPN540/S5-89/012)
0 Demonstration Bulletin (EPN5.40/M5-89/0l2)
j
•• Docwnents with a PB number must be ordered by that number at
cost from
National Technical Information Service
5285 Pon Royal Road
Springfield VA 22161
Telephone [phone].
• • ·1
I
Emerging Technologies Program Reports
Atomic Energy of Canada Limiud--Chemu:al Tnalment and
U/Jrafutration
0 Emerging Tech. Bulletin (EP A/540/F-92/00'l)
Babcock and Wilcox-Cyclone Furnace SoU Vilrification
0 Emerging Tech. Bulletin (EPA/540/F-92/010)
Batt elk Memorial lnstitute-DevelopNUnJ of Electro-Acoustic
Soil Decontamination (ESD) Process/or In Situ Applications
0 Emerging Technology (EPN540/5-90,u()4)
PB90-204728
0 Emerging Tech. Summary (EPN540/S5-90/004)
Bio-Recovery Systems-Removal and Recovery of Metal Ions
from Groundwaier
0 Emerging Technology (EPN540/5-90,005a)
0 Emerging Tech.-Appcndiccs (EPN540/5-90/005b)
PB90-252602
0 Emerging Tech. Summary (EPN540/S5-90/005)
0 Emerging Tech. Bulletin (EPN540/F-92/003)
• Order documents free of charge by calling EPA's
Center for Environmental Research Information (CERI) at 513-569-7562.
Colorado School of Mines-Constructed Wetlands Treatment/or
Toxic Metal ConJaminaled Waters
0 Emerging Tech. Bulletin (EPN540/F-92/00J)
Electro-Pure Systems-Alternaling Current Electrocoagulation
0 Emerging Tech. Bulletin (EPA/540/F-92/011)
Energy and EnvironmenJal Enginuring-Laser-lnduced
Photochemical Oxidatfre Destruction
0 Emerging Tech. Bulletin (EPA/540/F-92/004)
Florida lntt!rnational Unh1ersity-Electron Beam Treatmenlfor
the Trichloretechylene and Tetrach/oroethylene from Aqueous
Stream
0 Emerging Tech. Bulletin (EPN540/F-92/009)
SITE Emerging Technologies-lA.ser-Induced Photochemical
Oxidative DestructWn of Toxic Organics in Uachates and
Groundwater
0 Emergini:Tech. Bulletin (EPA/540/SR-92/080
I
University of Washington-Metals Treatment al Superfund Sites ·.· .. ·1 by Adsorptive FillratWn
0 Emerging Tech. Bulletin (EPN540/F-92/008)
•• Documents with a PB number must be ordered by that_ number at cost from
National Technical Information Service
5285 Port Royal Road
Springfield VA 22161
Telephone [phone].
I
• VIDEOTAPE REQUEST F-
----~1992
Foster Wheeler Enviresponse, Inc.
Attn: Ms. Marilyn Avery
8 Peach Tree Hill Road
· Livingston, NJ 07039
Dear Ms. Avery,
Please send us the following USEPA-produced videotapes. I have completed the address
information below and enclosed a check in the amount of $. __ made payable to "Foster
Wheeler Enviresponse· ($35.00 per tape, plus $10.00 additional per tape for international
shipments).
Copies Number Videotape Title
S1 SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION (SITE}
PROGRAM (6 technology demonstrations)
S2 SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION (SITE)
PROGRAM (4 technology demonstrations)
S3 SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION (SITE)
PROGRAM (4 technology demonstrations)
S4 SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION (SITE)
PROGRAM (4 technology demonstrations)
R1 RREURCB RESEARCH PROGRAM (5 programs)
(Contents of each tape are listed on the reverse side of this sheet.)
(Signed) __________ _
Title
Tapes should be sent to the following (Please Print):
NAME:
COMPANY:
ADDRESS:
CITY: STATE ---------ZIP -------
(NO REQUESTS WILL BE HONORED WITHOUT PREPAYMENT BY
PERSONAL OR COMPANY CHECK.)
ECOVA (SHIRCO)
INFRARED
INCINERATION
SYSTEM
Brandon, FL -8/87
ULTROX
ULTRAVIOLET
RADIATION AND
OXIDATION
San Jose, CA -3/89
SOLIDITECH
SOLIDIFICATION AND
STABILIZATION
ECOVA (SHIRCO)
INFRARED
INCINERATION
SYSTEM
Rose Twp., Ml -11/87
BIOTROL
BIOLOGICAL
AQUEOUS
TREATMENT
EMTECH (HAZCON)
SOLIDIFICATION
PROCESS
Douglassville, PA -10/87
BIOTROL
SOIL WASHING
SYSTEM
New Brighton, MN · 9/89 New Brighton, MN · 9/89
CHEMFIX
SOLIDIFICATION AND IN SITU STEAM AND
STABILIZATION AIR STRIPPING
Morganville, NJ -12/88 Clackamas, OR • 3/89 San Pedro, CA • 9/89
E.I. DUPONT/
OBERLIN FILTER
MEMBRANE
MICROFILTRATION
HORSEHEAD
FLAME
REACTOR
RETE<:;H PLASMA
CENTRIFUGAL
FURNACE
Palmerton, PA• 5/90 Atlanta, GA -3/91 Bune, MT -7/91
SYNTHETIC SOILS
MATRIX (SSM)
PROGRAM
DIOXIN AND THE
MOBILE
INCINERATION
SYSTEM
MOBILE CARBON
REGENERATION
SYSTEM
IWT/GEO-CON
IN SITIJ
STABILIZATION/
SOLIDIFICATION
Hialeah, FL -4/88
IT/AREL
DEBRIS WASHING
SYSTEM
BABCOCK & WILCOX
CYCLONE
FURNACE
Alliance, OH -11 /91
MOBILE SOILS
WASHING
SYSTEM
·-·····",, :_·,.,._
TERRAVAC
VACUUM
EXTRACTION
SYSTEM
Groveland , MA· 1 /88
MOBILE IN SITIJ
CONTAINMENT/
TREATMENT UNIT
~ ·::c.. . •
CF SYSTEMS • SOLVENT
EXTRACTION UNIT
New Bedford, MA -3/89
Videotape Order
Form Ill,
November, 1992
_ _j
• •
REVIEWS AND APPROVALS !Nt«.;tnntu
AUG l 2 l~~J
SUPERF/INOSfCTION
CLIENT NAME: U.S. ENVIRONMENTAL PROTECTION AGENCY
RISK REDUCTION ENGINEERING LABORATORY
CONTRACT NO.: 68-C0-0047
\ KOPPERS COMPANY, INC.
MORRISVILLE, NORTH CAROLINA
We, the undersigned, have read and approve of the health and safety guidelines presented in this
', Healih and Safety Plan for on-site work activities at Koppers Company, Inc.
Kurt A. Sorensen
PRC Environmental Management,
Inc. (PRC),
Health and Safety Director
Robert Hutcheson
PRC Project Manager
Terry Lyons
EPA Technical Project Manager
Signature Date
• •
1.0 INTRODUCTION
PRC Environmental Management, Inc. (PRC), received Work Assignment No. 0-11 from the United
States Environmental Protection Agency (EPA) under Contract No. 68-C0-0047 to conduct sampling
activities during the Base-Catalyzed Decomposition (BCD) process demonstration at the Koppers site in
Morrisville, North Carolina. The following site-specific health and safety provisions have been developed
· for use during the Koppers site Superfund Innovative Technology Evaluation (SITE) BCD demonstration.
This document addresses those items specified under Occupational Health and Safety Administration
(OSHA) 29 Code of Federal Regulations (CFR) 1910.120 (b) Final Rule. This document will be
provided to all PRC on-site personnel, subcontractors, and site visitors who may be exposed to hazardous
conditions during the SITE BCD demonstration.
The purpose of the health and safety plan (HSP) is to define requirements and designate the protocols to
be followed during the SITE BCD demonstration at the Koppers site. All PRC personnel on site,
including PRC employees, subcontractor employees, and site visitors must be informed of site emergency
response procedures and any potential fire, explosion, health, or safety hazards of on-site activities. This
HSP summarizes potential hazards and defines protective measures planned for site activities. A separate
SITE demonstration, to be performed simultaneously with the BCD demonstration, will also be conducted
at the Koppers site. This HSP only applies to the SITE BCD demonstration to be conducted at the
Koppers site.
This plan must be reviewed and approved by the PRC health and safety director (HSD), the PRC project
manager, and the EPA Technical Project Manager (TPM). The compliance agreement form in
Attachment A must be signed by all field personnel before they enter the site. Any revisions to this plan
must be reviewed by the EPA TPM and approved by the PRC HSD.
2.0 HEALTH AND SAFETY PLAN ENFORCEMENT
This section describes the responsibilities of project personnel and summarizes requirements for
subcontractors and visitors who wish to enter the Koppers site.
1
• •
2.1 PROJECT PERSONNEL
The PRC project manager, field site manager, HSD, and site health and safety officer (SHSO) will be
responsible for implementation and enforcement of the health and safety provisions of this HSP. Their
duties are described in the following sections.
2.1.1 Project Manager and Field Site Manager
The PRC project manager, Robert Hutcheson, is ultimately responsible for ensuring that all project
participants abide by the requirements set forth in this plan. The PRC field site manager, Gary Benfield,
will oversee and direct field activities, including subcontractor activities. He also is responsible for
ensuring compliance with this plan.
2.1.2 Health and Safety Director
The PRC HSD, Kurt Sorensen, will be responsible for providing technical coordination for the health and
safety program. The HSD will act in an advisory capacity to the SHSO, and will report to the PRC
project manager. Liaison with officers and representatives of EPA on matters relating to health and
safety will be handled by the HSD or SHSO. The HSD is responsible for maintaining up-to-date records
of HSP-rel;ited documentation and HSP participants. HSP-related documentation will be maintained at
PRC's Chicago office. This documentation includes the following:
• Documentation of the physician's examination of each project worker (Section 7.0,
Medical Surveillance).
• The training record for each worker who has completed the training necessary to perform
his or her job.
• Documentation of a fit test for workers required to wear respiratory protection equipment
meeting the requirements of OSHA CFR 1910.134 and American National Standards
Institute (ANSI) Z88.2-1980.
• Task-specific air monitoring information (regarding drumming of waste, reactor
emissions, and other activities)
Project employees who do not meet HSP requirements will not be allowed to conduct field work.
2
• •
2.1.3 Site Health and Safety Officer
The PRC SHSO, Tracy Poole, will be responsible for field implementation and enforcement of this HSP.
The SHSO will have advanced field work experience and will be familiar with health and safety
requirements specific to the project. The SHSO will ensure that the Safety Meeting Sign-off Sheet
(Attachment B) will be signed by all personnel who are to perform field work. The SHSO must also
ensure that each field worker completes a Daily Site Log (Attachment C) before leaving the site.
2.2 SUBCONTRACTORS
Subcontractor personnel participating in the SITE demonstration will be required to read and comply with
all sections of this plan. All subcontractor personnel entering the site must sign the compliance agreement
form. Subcontractor personnel must comply with all applicable OSHA CPR 1910.120 training, fit
testing, and medical surveillance requirements. Subcontractors are responsible for providing personal
protective equipment (PPE) required by this plan for their personnel (see Section 6.2, Protective
Equipment and Clothing), and are ultimately responsible for the health and safety of their employees.
2.3 VISITORS
Any visitor to PRC operations at the site will be required to read the PRC HSP and sign the compliance
agreement form. Each visitor will be expected to comply with relevant OSHA requirements. Each
visitor will also be expected to provide their own personal protection equipment (PPE) required by the
HSP. Any visitor who does not adhere to the provisions of the HSP will be ordered to leave the work
area. Any visitor who has not met OSHA training and medical surveillance requirements will not be
permitted to enter areas where exposure to hazardous materials is possible. Exceptions will be strongly
discouraged, but they can be made on a case-by-case basis under the following conditions: (1) respirators
are not required, (2) the visitors' time on site is limited, (3) each visitor is given a pre-entry briefing, (4)
each visitor is accompanied by trained personnel at all times, and (5) SHSO approval is obtained.
3
•
3.0 SITE BACKGROUND
Past investigations have determined that wood treating processes conducted at the Koppers site from 1968
to 1975 contaminated site groundwater, surface water, and soil with pentachlorophenol (PCP), 2,4-
dichlorophenol, isopropyl ether (IPE), and other organic contaminants. The following sections describe
the Koppers site and its history.
3.1 SITE DESCRIPTION
The Koppers site (Figure 3-1) is located in Morrisville, North Carolina, at the intersection of Highway
54 and Koppers Road. The site property currently is owned by two companies, Beazer East Inc. (Beazer)
and Unit Structures Inc. (USI). The portion of the site owned by Beazer is inactive. The portion of the
site owned by USI currently is used as a wood laminating facility. The site occupies approximately 52
acres and includes the wood laminating facility, an office, and several warehouses (Figure 3-2).
Surrounding land is used for a mixture of commercial, light industrial, and rural residential purposes.
3.2 SITE msTORY
From 1896 to 1961, the site property was owned by the Cary Lumber Company. In 1961, the site
property was sold to USI. The company operations, however, were different than those of US! today.
In 1962, the site property· was sold to Koppers. In 1968, Koppers began treating wood using the
CELLON® process. This process consisted of injecting PCP into the wood. Butane was used as the
carrier solvent. IPE was used as a co-solvent to increase the solubility of the PCP in butane. After
application, the butane carrier was evaporated under reduced pressure, leaving a dry, crystalline salt
residual of PCP. After the butane carrier was removed, a vacuum was pulled on the cylinder and the
IPE and dissolved PCP were sent to a blowdown pit. The PCP residual on the treated wood was
removed by steaming. Then the steam condensate was pumped to an aboveground flocculation tanks
where flocculent was added to remove the PCP. After flocculation, the condensate passed through a sand
filter before emptying into two unlined lagoons located on the property. The CELLON® process was
discontinued in 1975, when Koppers began using pre-treated wood for their operations.
4
• •
Some time after 1975, the name of the facility was changed from Koppers to Beazer. In 1986, Beazer
sold a portion of the site property to US!. USI sold certain portions of the site back to Beazer in 1992.
In 1976, Beazer began conducting environmental investigations of the CELLON® process area and the
two lagoons. In 1977, as part of their reclamation project, the liquid contents of the two lagoons were
pumped out and sprayed on the northern portion of the site. Fertilizer was added to the soils in this area
and the soils were plowed. This area is now referred to as the land farm area.
The bottom sludges in the lagoons were mixed with the soil surrounding the lagoons and spread out to
dry. This area was fertilized and seeded. It is now referred to as the former lagoon area.
Beginning in 1980, Beazer began conducting additional environmental investigations at the site. These
investigations focused on both soil and groundwater. As a result of the investigations, Beazer removed
about 220 cubic yards of soil from the former lagoon area in the spring of 1980. Later that year,
Koppers removed an additional 240 cubic yards of soil from the former lagoon area. In 1986, soil was
removed from the following areas: 1100 cubic yards from the former lagoon area, 50 cubic yards from
the filter bed area, and 100 cubic yards from the blowdown pit area. According to Beazer, the removed
soils were disposed of at permitted disposal facilities.
In 1986, Beazer began sampling nearby residential wells to determine if the PCP had migrated off site.
Also in 1986, the North Carolina Division of Health Services' (NCDOH), Superfund Branch, began to
investigate the groundwater in the vicinity of the site. Some of the nearby residential wells showed
detectable amounts of PCP and !PE. Beazer provided bottled water to residents whose wells showed
detectable levels. Later, Beazer connected most of the residents to the city water system. Beazer and
NCDOH, under a cooperative agreement, have continued to sample off-site residential wells on a
quarterly basis.
The NCDOH Superfund Branch developed a Hazard Ranking System (HRS) package of the site. On June
24, 1988, the site, based largely on its groundwater contamination, was proposed for inclusion on the
National Priority List (NPL). The final rule and inclusion of the Koppers site on the NPL list occurred
on March 31, 1989.
7
I
•
In March of 1989, EPA and Beazer signed an Administrative Order on Consent, which permitted Beazer
to conduct its own Remedial Investigation/Feasibility Study (RI/FS) on the site. The RI/FS work plan
was approved in November 1989 and the field work was started in 1990. The RI/FS field work covered
site soils, groundwater, drainage pathways, and ponds.
4.0 SITE-SPECIFIC HAZARD EVALUATION
PCP, 2,4-dichlorophenol, isopropyl ether, and 2,3, 7,8-tetrachlorodibenzo-p-dioxin (TCDD) and 2,3, 7 ,8-
tetrachlorodibenzofuran (TCDF), commonly referred to as dioxins, are the potential chemical
contaminants expected to be encountered during field activities. Field activities to be performed during
the SITE demonstration consist of soil sampling and sampling of oil and water from the treatment unit
air scrubber system. In addition, sodium hydroxide and sodium bicarbonate, reagents which will be
mixed with the soil prior to treatment, may be encountered during soil sampling. Hazardous materials
expected to be encountered and a work task hazard analysis are provided in Tables 4-1 and 4-2,
respectively. Table 4-3 presents additional hazards that may or may not be encountered during site
activities. The material safety data sheets (MSDS) and Registry of Toxic Effects of Chemical Substances
(RTECS) information included in Attachment D summarize toxicological, human health, and safety
information for the expected contaminants. The following sections describe the possible exposure
pathways and health effects of PCP and dioxins.
4.1 EXPOSURE PATHWAYS
Exposure to on-site contaminants during field activities may occur through inhalation due to airborne
contaminated dust and organic vapors, dermal contact, or ingestion. Descriptions of these exposure
pathways are provided below. Exposure to sodium bicarbonate and sodium hydroxide may occur through
inhalation and dermal contact during sampling of the soil-reagent mixture.
4.1.1 Inhalation
A principal pathway of exposure to PCP, 2 ,4-dichlorophenol, and dioxins during this SITE demonstration
is through inhalation of airborne dust contaminated with these compounds. PCP, 2,4-dichlorophenol, and
dioxin concentrations in contaminated soil are known to be as high as 3,220 milligrams per kilogram
8
Substance
PCP
TCDD/TCDF
2,4-dichlorophenol
Sodium
Hydroxide
0 •
TABLE 4-1
HAZARDOUS MATERIALS POTENTIALLY PRESENT
AT KOPPERS SITE
Environmental
Media•
Soil
Soil
Soil
Soil
Exposure
Pathways
Inhalation
Skin Contact
Ingestion
Inhalation
Skin Contact
Ingestion
Inhalation
Skin Contact
Ingestion
Ingestion
Skin Contact
Inhalation
9
Toxic
Characteristics"
Eye, skin, and throat irritation,
nausea, dizziness, loss of weight,
chloracne, bronchitis
Chloracne, hepatotoxicity, weight
loss, thymic atrophy, suppression
of cellular immunity, death,
probable human carcinogens
Mucous membrane and respiratory
tract irritation, severe burns
Edematous lips, chin, tongue,
necrosis of mucous membranes,
pneumonia, burns, tissue
corrosion, ulcerations,
pulmonary edema, squamous cell
carcinoma, death due to shock,
asphyxia
Substance
Sodium
Bicarbonate
Isopropyl ether
Notes:
• •
TABLE 4-1 ( continued)
HAZARDOUS MATERIALS POTENTIALLY PRESENT
AT KOPPERS SITE
Environmental
Media'
Soil
Soil
. Exposure
Pathways
Ingestion
Skin Contact
Inhalation
Inhalation
Skin Contact
Ingestion
Toxic
Characteristics•
Irritation and burns of the skin, eyes,
and mucous membranes.
Drowsiness, dizziness, nausea,
vomiting, narcosis, dermatitis,
intoxication and depression,
and weight loss
Environmental media where on-site contaminants may be encountered.
b Acute and chronic physiological symptoms resulting from exposure to the hazardous materials
potentially on site.
10
Task
Task 1
Soil Sampling
Task 2
Scrubber Oil
Sampling
Task 3
Scrubber Water
Sampling
Notes:
•
TABLE 4-2
WORK TASK HAZARD ANALYSIS
Potential
Hazard
Chemical
Physical
Chemical
Physical
Chemical
Physical
Anticipated
Level of
Protection
Level D'·b
Level D'
Level D'
' Levels of protection are discussed in detail in Section 6. 1
Upgraded
Level of
Protection
Level C'
Level C'
Level C'
b Soil sampling activities initially will be conducted in Level C. The level of protection will be
downgraded to Level D if air monitoring indicates ambient airborne dust concentrations are less
than 5.0 milligrams per cubic meter (mg/m3) of air. Air monitoring parameters are discussed in
more detail in Section 8. 3.
11
• •
TABLE 4-3
POTENTIAL HAZARD EVALUATION
Potential Hazard Yes No Unknown
Airborne Particulate Matter: __x_
Toxic Vapors and Gases: __x_
Explosivity: __x_
Radioactivity: __x_
0 2 Depletion: __x_
Buried Utilities: __x_
Physical Hazards: __x_
Confined Spaces: __x_
Trenching: __x_
Noise: __x_
I
12
• •
(mg/kg), 1.120 mg/kg, and 0.270 mg/kg, respectively. Inhalation of dust will be of concern on a windy
day when dust is likely to be created. The potential for inhalation of organic vapors also exists. PRC
personnel will monitor the concentration of dust and organic vapors with real-time field survey
instrumentation. When appropriate, personal protection will be upgraded to Level C.
4.1.2 Denna! Contact
Dermal contact with either contaminated soil or water and oil from the scrubber unit may occur during
on-site sampling activities. Dermal contact will be prevented with the use of the proper PPE, such as
inner and outer gloves. Safe operating procedures for PPE are described in Section 6.3.
4.1.3 Ingestion
Ingestion of hazardous materials, although unlikely, may occur due to lack of proper hygiene or
decontamination procedures. Section 9.2 discusses safe work practices that may prevent ingestion of
hazardous materials.
4.2 HEALTH EFFECTS
The following sections describe the health effects of PCP, 2,4-dichlorophenol, dioxins, !PE, sodium
hydroxi\Je, and sodium bicarbonate. Health effect information is taken from the National Institute for
Occupational Health and Safety (NIOSH, 1990) handbook and MSDSs. Table 4-4 presents permissible
exposure levels (PEL) for chemical exposures to be potentially encountered on site, in accordance with
OSHA 29 CFR 1910. Low, medium, or high levels of these contaminants may be encountered during
sampling activities at the Koppers site. Potential exposure to contaminated soil or air scrubber water and
oil may be through inhalation, skin contact, or ingestion.
Effects of acute exposure to PCP include irritation of the eyes, skin, throat, and lungs, rapid heartbeat
and breathing, fever, muscle weakness, loss of appetite, sweating, dizziness, and nausea. Very high
doses may cause unconsciousness, seizures, and death due to cardiac arrest. Hot weather may increase
the risk of acute poisoning. The effects of chronic exposure to PCP may include chloracne, bronchitis,
and weight loss.
13
• •
TABLE 4-4
PERMISSIBLE EXPOSURE LEVELS FOR ON-SITE CHEMICALS
On-Site Chemical PEL
Pentachlorophenol (PCP) 0.5 mg/m3
2,3, 7 ,8-tetrachlorodibenzo-p-dioxin (TCDD) None established
2,3, 7,8-tetrachlorodibenzofuran (TCDF) None established
2,4-dichlorophenol None established
sodium hydroxide (NaOH) 2.0 mg/m3
sodium bicarbonate (NaHCO3) None established
On-Site Chemical TLV
isopropyl ether 1,050 mg/m3
14
• •
Acute exposure to 2,4-dichlorophenol may result in irritation of the mucous membranes and upper
respiratory tract. Prolonged contact may produce severe skin irritation or burns. No chronic symptoms
are known to date.
Exposure to high concentrations of isopropyl ether vapor may cause drowsiness, dizziness, nausea,
vomiting, narcosis, and irritation of the eyes and nose. Repeated or prolonged exposure to the skin may
result in drying and irritation of the skin. Ingestion of isopropyl ether causes symptoms similar to those
for overexposure to vapor. Chronic exposure may cause headaches, dizziness, weight loss, and
intoxication and depression.
Acute and chronic effects of 2,3,7,8-TCDD exposure include chloracne, hepatotoxicity, psychological
alterations, weight loss, thymic atrophy, gastric ulcers, peripheral neuropathy, thrombocytopenia,
suppression of cellular immunity, and death. The liver appears to be the target organ following acute
exposure. It should be noted that 2,3,7,8-TCDD is a probable human carcinogen.
Ingestion of sodium hydroxide may cause: immediate burning of the mouth, esophagus, and stomach;
edematous lips, chin, and tongue; painful swallowing; necrosis of the mucous membranes; vomiting; and
a rapid, faint pulse. Death usually results from shock, asphyxia, or pneumonia two or three days after
ingestion. Skin contact may not be painful for up to three minutes after contact; however, skin damage
begins immediately. Damage may progress to severe burns, tissue corrosion, ulcerations, and permanent
scarring if not immediately washed off. Inhalation may cause burns and pulmonary edema. Chronic
effects may include squamous cell carcinoma of the esophagus years after ingestion and dermatitis due
to repeated exposure.
Acute exposure to sodium bicarbonate may result in irritation, and possible chemical burns, of the skin,
eyes, and mucous membranes of the respiratory tract. No effects from chronic exposure to sodium
bicarbonate have been reported.
Worker exposure to on-site contaminated soil will be controlled through proper use of PPE and real-time
air monitoring for dust. The need for respiratory protection (powered air purifying respirators) will be
based on real-time air monitoring results. Initially, soil samples will be collected in Level C. If the
concentration of the dust measured on the monitoring instrument is less than 5 mg/m3, the level of
15
•
protection will be downgraded from Level C to Level D. The allowable particulate concentration (APC)
was calculated for PCP based on the highest recorded soil concentration of PCP found on site which was
found to be approximately 155 mg/m3• The PEL value for PCP is 0.5 mg/m3. PELs for 2,4-
dichlorophenol and dioxins have not been established.
4.3 PHYSICAL HAZARDS
Physical hazards associated with sampling and other activities present a potential threat to on-site
personnel. Dangers are posed by underground utility lines, unseen obstacles, noise, heat, and poor
illumination.
Injuries may result from the following:
• Accidents due to slipping, tripping, or falling
• Improper lifting techniques
• Moving or rotating equipment
• Equipment mobilization and operation (for example, electrocution from contact
with underground power lines)
• Improperly maintained equipment
Injuries resulting from physical hazards can be avoided by adopting safe work practices (SWP) and by
using caution when working with machinery. SWPs to be used during on-site sampling are described in
Section 9.2. To ensure a safe work place, the SHSO will conduct and document regular safety
inspections and will ensure that site workers are informed of potential physical hazards related to the site.
5.0 TRAINING REQUIREMENTS
All on-site PRC personnel, subcontractors, and site visitors who may be exposed to hazardous on-site
conditions will be required to meet the training requirements outlined in OSHA 29 CFR 1910. 120, which
covers hazardous waste operations and emergency response. All PRC personnel and each visitor entering
the site will be required to read this HSP and sign the compliance agreement form, and site workers will
be required to sign the Safety Meeting Sign-off Sheet.
16
•
Before on-site activities begin, a briefing will be presented by the SHSO for all personnel who will
participate in on-site activities. The following topics will be addressed during the briefing:
• Names of the SHSO and the designated alternate
• Site history
• Hazardous chemicals that may be encountered during on-site activities
• Physical hazards that may be encountered on site
• Training requirements
• Levels of protection to be used for specific work tasks
• Work tasks
• Environmental surveillance equipment use and maintenance
• Action levels (Section 8.3, Monitoring Parameters) and identification of situations
requiring an upgrade or downgrade in levels of protection
• Site control measures, including site control zones, communications, and safe work
practices (Sections 9.0, Site Control)
• Emergency communication signals and codes
• Decontamination procedures
• Environmental accident emergency procedures (in case contamination spreads outside the
exclusion zone)
• Personnel exposure and accident emergency procedures (in case of exposure to hazardous
substances, falls, and other hazardous situations)
• Fire and explosion emergency procedures
• Emergency telephone numbers
• Emergency routes
Other health and safety related topics that may arise before on-site activities begin also will be discussed
at the briefing.
17
•
Issues that arise during implementation of on-site activities will be addressed during "tailgate" safety
meetings to be held daily before the shift begins. Any changes in procedures or site-specific health and
safety related matters will be addressed during these meetings.
6.0 PERSONAL PROTECTION REQUIREMENTS
PPE will be worn to protect field personnel from known or suspected physical hazards, air-, and soil-
borne contamination. The levels of personal protection to be used for work tasks have been selected
based on known or anticipated physical hazards, concentrations of contaminants that may be encountered
on site, their chemical properties, toxicity, exposure routes, and contaminant matrices. The following
sections describe levels of protection, limitations of protective clothing, the duration of work tasks, and
respirator selection, use, and maintenance.
6.1 LEVELS OF PROTECTION
Personnel will wear personal protective equipment when site activities involve known or suspected
atmospheric contamination such as when airborne dust is generated by site activities or accidental direct
dermal contact occurs. Full-face powered air purifying respirators will be used to protect the lungs, the
gastrointestinal tract, and eyes against airborne contaminants. Chemical-resistant clothing will be used
to protect the skin and body parts from direct contact.
Levels of protection and their respective components are classified under four categories according to the
degrees of protection:
Level D:
Level C:
This level provides minimal protection against chemical hazards. Worn
only as a work uniform, worn in areas posing no respiratory or skin
hazards.
Worn when the criteria described for Level C protection in Section 8. 3
for using air-purifying respirators are met, and a lesser level of skin
protection is needed.
18
•
Level B:
Level A:
•
Worn when the highest level of respiratory protection is needed, but a
lesser level of skin protection is required. Level B is the primary level
of choice for unknown environments.
PRC does not conduct site activities that require Level A protection.
6.2 PROTECTIVE EQUIPMENT AND CLOTHING
The following general levels of protection and the associated PPE ensembles have been selected for use
by field personnel during sampling activities (see Table 4-2, Work Task Hazard Analysis). Because the
anticipated hazard level is medium, sampling will be performed using Level C protection. If site
conditions or the results of air monitoring performed during on-site activities do not warrant Level C
protection, all field personnel will downgrade to Level D protection. Descriptions of equipment and
clothing required for Levels D and C protection are provided below. It is not anticipated that site
activities will warrant Level A or Level B protection.
• Level D
Coveralls or work clothes, if applicable
Steel-toed boots with shanks
Hard hat (face shield optional)
Disposable outer gloves (latex or nitrile), if applicable
Safety glasses or goggles
Chemical-resistant clothing (Tyvek® or Saranex®), if applicable
Disposable boot covers (when entering wet or muddy areas with known
elevated contamination levels, such as previously excavated waste areas)
Hearing protection (for areas with a noise level exceeding 85 decibels on
the A-weighted scale)
• Level C
Coveralls or work clothes, if applicable
Chemical-resistant clothing (Tyvek® or Saranex®), if applicable
19
• •
Outer gloves (neoprene or nitrile}, if applicable
Inner gloves (latex or polyvinyl chloride)
Steel-toed boots with shanks
Disposable boot covers or chemical-resistant outer boots
Full-face, air-purifying or powered air-purifying respirator with NIOSH-
or Mine Safety and Health Administration (MSHA)-approved cartridges
to protect against organic vapors, dust, fumes, and mists (cartridges will
be changed at the end of each shift, with increased breathing resistance,
or at breakthrough, whichever occurs first)
Safety glasses or goggles (with half-face respirator only)
Hard hat (face shield optional)
Hearing protection (for areas with a noise level exceeding 85 decibels on
the A-weighted scale)
6.3 LIMITATIONS OF PROTECTIVE CLOTIIlNG
PPE clothing ensembles designated for use during site activities have been selected to provide adequate
protection against contaminants at known or anticipated concentrations in soil matrices and ambient air.
However, no protective garment, glove, or boot is entirely chemical-resistant, nor does any protective
clothing provide protection against all chemicals. Permeation of a given chemical through PPE depends
on contaminant concentrations, environmental conditions, the physical condition of the protective
garment, and the resistance of the garment to the specific contaminant. Chemical permeation may
continue even after the source of contamination has been removed from the garment.
To obtain optimum use from PPE, the following procedures will be followed by all site personnel:
• When using Tyvek® or Saranex® coveralls, don a new, clean garment after each
rest break or at the beginning of each shift.
• Inspect all clothing, gloves, and boots both before and during use for the
following:
--Imperfect seams
--Nonuniform coatings
--Tears
20
• •
--Poorly functioning closures
• Inspect reusable garments, boots, and gloves both before and during use for
visible signs of chemical permeation such as the following:
--Swelling
--Discoloration
--Stiffness
--Brittleness
--Cracks
--Any sign of puncture
--Any sign of abrasion
Reusable gloves, boots, or coveralls exhibiting any of the characteristics listed above must be discarded.
PPE clothing used in areas with known or suspected elevated concentrations of contaminants should not
be reused. Reusable PPE will be decontaminated in accordance with procedures described in Section IO. I
and will be neatly stored in the support zone, away from work zones.
6.4 DURATION OF WORK TASKS
The duration of site activities involving use of PPE will be established by the SHSO or a designee and
will be based on ambient temperature and weather conditions, the capacity of personnel to work in the
designated level of PPE (taking into account such conditions as heat stress), and the limitations of the
protective equipment. All rest breaks will be taken in the support zone after decontamination and
removal of PPE.
6.5 RESPIRATOR SELECTION, USE, AND MAINTENANCE
All PRC personnel and subcontractors taking part in site activities must fulfill worker provisions outlined
in OSHA 29 CFR 1910.134. PRC and subcontractor personnel will be informed of the proper use,
maintenance, and limitations of air-purifying respirators during the daily safety briefing, if applicable.
All site personnel must complete a qualitative fit test for the respirator to be used on site.
Respirator use is anticipated for the site. If necessary, a full-face, powered air-purifying respirator
equipped with NIOSH-or MS HA-approved cartridges will be selected for use to protect against dusts and
vapors. Respirators will be selected by the SHSO based on knowledge of the substances that may be
21
•
present and the concentrations of compounds previously encountered at the site. Air-purifying respirators
will be used only in conjunction with breathing-space air monitoring, which must be conducted in
adherence to the action limits outlined in Section 8.1. Air-purifying respirators will be used only when
the devices can provide protection against the substances encountered on site.
Factors precluding the use of air-purifying respirators are as follows:
• Concentrations of substances that may be immediately dangerous to life and
health, as defined in the MSDS
• High relative humidity (which reduces the sorbent life of the cartridges)
• Identified substances with inadequate warning properties (for example, they are
tasteless, odorless, and invisible), and respirator cartridges with an unknown
sorbent service life, and respirator units with no end-of-service-life indicator
Respirators will be inspected daily, and any necessary repairs will be made during the time of inspection.
Damaged respirators will be properly disposed of. Respirators issued to individuals will be cleaned and
disinfected in the support zone at least weekly. When a respirator is used by more than one person, the
respirator will be.cleaned and disinfected after each use. After being cleaned, respirators will be placed
in clean plastic bags and stored in the support zone. The following respirator inspection and cleaning
procedures will be followed whenever respirator protection is used:
• Daily Inspection and Checkout Procedures:
Visually inspect the entire unit for obvious damage and deteriorated
rubber.
Inspect the face-piece harness for damage.
Inspect the lens for damage and make sure the face piece has the proper
seal.
Pull the plastic cover off the exhalation valve and check the valve for
debris and tears in the neoprene that could cause leakage.
Unscrew the cartridges of both inhalation valves and visually inspect the
neoprene valves for tears. Make sure the inhalation valves and cartridge
receptacle gaskets are in place.
22
• •
Make sure a protective cover is attached to the lens.
Make sure the speaking diaphragm retainer ring is hand-tight.
Don the respirator, and perform the negative pressure test.
• Weekly Cleaning Procedures:
Disassemble the respirator in the support zone by removing the
cartridges, damaging them to prevent accidental reuse, and discarding
them. To clean the respirator thoroughly, remove the inhalation and
exhalation valves, speaking diaphragm, and any hoses.
To clean the respirator, dissolve cleaning and disinfecting solution
(usually provided by the manufacturer) in warm water in an appropriate
tub. With gloved hands, swirl the respirator in the tub for at least 1
minute. A soft brush may be used to facilitate cleaning.
Rinse the cleaned and disinfected respirator thoroughly with potable
water to remove all traces of detergent and disinfectant. This step is
very important in preventing dermatitis.
Air dry the respirator on a clean surface. The respirator may also be
hung upside-down, but care must be taken not to damage or distort the
face piece.
Reassemble the clean, dry, respirator and inspect it in an area separate
from the disassembly area to avoid contamination. Inspect the respirator
carefully for detergent or soap residue left by inadequate rinsing.
Residue appears most often under the seat of the exhalation valve and
can cause valve leakage or sticking.
• Procedures to Follow after Routine Use in the Exclusion Zone:
Wash and rinse the respirator in the support zone with soap and warm
water.
At a minimum, wipe the respirator with disinfectant wipes that have been
soaked in benzoalkaloid or isopropyl alcohol. Allow the respirator to air
dry in the support zone.
The effectiveness of the respiratory protection program will be monitored continuously by the SHSO or
the SHSO's designee. Monitoring of worker stress levels during activities that require respiratory
protection will also be performed by the SHSO or the designee (Section 8.0, Environmental Surveillance).
23
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7.0 MEDICAL SURVEILLANCE
The following section describes the PRC medical surveillance program, including health
monitoring, documentation, record keeping, medical support, and follow-up procedures. This program
will be followed for all activities at the Koppers site.
7.1 HEALTH MONITORING REQUlREMENTS
All PRC and subcontractor personnel involved in on-site activities at the Koppers site must
participate in a medical surveillance program, as required by OSHA 29 CFR 1910.120(1). PRC has
established a medical surveillance program with Environmental Medicine Resources, Inc., of Atlanta,
Georgia. Under this program, PRC personnel receive annual or biennial physical examinations consisting
of the following:
• A baseline medical examination that includes the following:
Completion of a personal, family, and environmental history
questionnaire
Physical examination
Vision screening
Laboratory test
Audiometric screening
Pulmonary function test
Resting electrocardiogram
Chest x-ray (required once every 3 years)
• A complete blood count that includes the following:
White blood count
Red blood count
Hemoglobin test
24
•
Hematocrit test
Liver function test
Kidney function test
Lipid metabolism test
Carbohydrate metabolism test
• A urinalysis that includes the following:
Sugar content test
Albumin content test
Specific gravity test
• Laboratory chemistries for the following:
Cholinesterase
•
Coproporphyrin and uroporphyrin
Arsenic
Cadmium
Iron
PRC receives a copy of the examining physician's written opinion after post-examination laboratory tests
have been completed; PRC employees also receive a copy of the written opinion. This opinion includes
the following information (in accordance with 29 CFR 1910.120(!)(7)):
• The results of the medical examination and tests.
• The physician's opinion as to whether or not the employee has any medical
conditions that would place the employee at an increased risk of health
impairment from work in hazardous waste operations or during an emergency
response.
25
• •
• The physician's recommended limitations, if any, on the employee's assigned
work. Special emphasis is placed on fitness for duty, including the ability to
wear any required PPE under conditions expected on site (for example,
temperature extremes).
• A statement that the employee has been informed by the physician of the medical
examination results and of any medical conditions that require further
examination or treatment.
7.2 DOCUMENTATION AND RECORDKEEPING REQUIREMENTS
The PRC Chicago office will maintain medical surveillance records for each PRC employee performing
hazardous waste site activities. These records will be in compliance with 29 OSHA CFR 1910.120(!).
The records will also be maintained at Environmental Medicine Resources in Atlanta, Georgia. Any
visitor or observer at the site will be required to provide documentation of compliance with OSHA 29
CFR 1910.120(!) before entering the site. In addition, PRC will be responsible for recording and
reporting accidents, illnesses, and injuries involving PRC employees in accordance with OSHA 29 CFR
1910 and 1926 and EPA requirements. An accident report form, to be completed by the SHSO, is
provided in Attachment F. A copy of this completed report will be added to PRC's medical surveillance
records in the event of a reportable accident, illness, or injury.
7.3 MEDICAL SUPPORT AND FOLLOW-UP REQUIREMENTS
PRC personnel will be required to seek medical attention and physical testing in the event of injury or
possible exposure above established exposure limits. Depending upon the type of injury or exposure,
follow-up testing, if required, must be performed within 24 to 48 hours of this incident. The type of test
to be performed to monitor exposure effects will be based on the circumstances involved and will be
selected by a qualified health professional from Environmental Medicine Resources.
8.0 ENVIRONMENTAL SURVEILLANCE
Radian Corporation will be on site during the BCD demonstration to conduct air monitoring activities.
Radian will monitor gases generated in the reactor at several points in the reactor system.
26
• •
Off-gases that have been treated in the reactor unit scrubber system also will be monitored to ensure that
the offgas treatment process is effective and toxic gases are not released. Radian will not perform
personal air monitoring for workers on site.
Air monitoring will be performed by PRC during designated sampling and other on-site activities to
protect field personnel against exposure to airborne hazardous substances and to determine appropriate
levels of PPE for work tasks. The following sections discuss initial air monitoring, periodic air
monitoring, monitoring parameters, use and maintenance of survey equipment, and heat stress
monitoring.
8.1 INITIAL AIR MONITORING
Initial air monitoring of the work area will be performed before and during the sampling activity. This
monitoring activity will be performed using real-time field survey instrumentation, such as a Miniram
Model PDM-3 and a Photovac Microtip HL200, to determine the airborne concentrations of site derived
dust and organic vapors, respectively. These airborne concentrations will also be monitored at the
beginning of each work day to identify background contaminant concentrations and to detect any
potentially hazardous situations that might have developed during off-shift periods.
8.2 PERIODIC AIR MONITORING
Periodic air monitoring will be performed during all site activities. This type of monitoring will be
performed as a minimum requirement when the following situations arise:
• Work begins on a different portion of the site.
• Workers experience physical difficulties.
Required survey instrumentation, sampling procedures, and monitoring procedures are specified in
Section 8.3. Sampling methods will be subject to review by the SHSO.
27
• •
8.3 MONITORING PARAMETERS
Air monitoring for ambient airborne dust and organic vapors will be performed at shoulder height (in the
breathing zone) on workers most likely to be exposed to potentially hazardous concentrations of
contaminants. Situations that will require air monitoring, monitoring parameters, detection devices, and
action levels are discussed below.
8.3.1 Ambient Airborne Dust
The following instrument and monitoring frequency will be used to monitor for airborne dust during site
activities.
• Instrument:
• Activity:
• Monitoring Frequency:
Miniram® Model PDM-3
Direct Real-Time Air Monitoring
Monitoring will be performed continuously during on-site
activities. Initially, Miniram® readings will be recorded in
the field logbook every hour. If continued monitoring does
not indicate the presence of airborne dust at or above 5
mglm', readings may be recorded every two hours or
longer, based on the SHSO's review of the monitoring data
collected.
The PEL value of PCP is 0.5 mg/m3• No PEL values for 2,4-dichlorophenol or dioxin have been
established. If the dust concentration does not exceed 5.0 mg/m3, the protection level will be downgraded
from Level C to Level D. Action levels for on-site dust contaminants are detailed below.
• General Action Levels
Situation: Concentration of airborne dust are below 5 mg/m3
Action: Continue investigation without respiratory protection at
Level D, continue monitoring
Situation: Concentration of dust at or above 5 mg/m3
Action: Notify SHSO; upgrade to Level C protection and continue
work unless otherwise specified
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• •
8.3.2 Organic Vapors
The following instrument and monitoring frequency will be used to monitor for organic vapors during
site activities.
• Instrument:
• Activity:
• Monitoring Frequency:
Photovac Microtip HL-200 equipped with a 10.6
electron voltage lamp
Direct Real-Time Air Monitoring
Monitoring will be performed continuously
during on-site activities. Initially, Microtip
readings will be recorded in the field logbook
every 30 minutes. If continued monitoring does
not indicate the presence of organic vapors,
readings may be recorded every hour or longer
based on the SHSO's review of the monitoring
data collected.
Individual concentrations of organic vapors of concern will not be determined by field instruments
because mixtures of organic vapors may be encountered and real-time field survey instrumentation may
react to the total organic vapor mixture (by measuring positive interference, or giving a false-positive
reading). Action levels for organic vapors are detailed below.
• General Action Levels
.Situation: Concentration at background concentration to 5 parts per
million (ppm) above background concentration
Action: Continue investigation without respiratory protection at
Level D; continue monitoring
Situation: Concentration 5 ppm to 25 ppm above background
concentration
Action: Notify SHSO; upgrade to Level C protection and continue
work unless otherwise specified
Situation: Concentration 25 ppm to 500 ppm above background
concentration
Action: Notify SHSO; evacuate exclusion zone; consult HSD about
whether or not to continue site activities
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• •
8.4 USE AND MAINTENANCE OF SURVEY EQUIPMENT
All personnel using field survey equipment will be briefed by the SHSO on its operation, limitations, and
maintenance. Maintenance and calibration will be performed in accordance with manufacturer guidelines
by a designated individual familiar with the devices. Repairs, maintenance, and routine calibration of
these devices will be recorded in an equipment maintenance logbook that will be signed by the service
technician. The equipment maintenance logbook for each instrument will be kept in that instrument's
case.
Air monitoring equipment (such as the Miniram®) will be calibrated before work begins and at the end
of the work day. Only routine maintenance (such as changing batteries and fans) will be performed by
on-site personnel. Any additional maintenance will be performed by a trained service technician.
8.5 HEAT STRESS MONITORING
Heat stress is a common and serious illness at hazardous waste sites. Occurrence of heat stress depends
on such factors as environmental conditions, clothing, workload, an on-site worker's physical condition
and characteristics, and the type of PPE required for the work task. Some types of PPE are water
impermeable and heavy and may lead to potential heat stress conditions. Under heat stress conditions,
the body's expenditure of energy increases and reduces the efficiency of the body's normal heat exchange
mechanisms.
Heat stress may be of particular concern when the dry-bulb air temperature exceeds 70°F. Depending
on the degree and nature of possible heat stress to be encountered on site, the SHSO will choose from
the following heat stress control actions:
• Provide adequate liquids to replace lost body fluids. These liquids may be water,
commercial mixes combined with potable water, or commercial liquids (such as
Gatorade®).
• Establish a work regimen that will provide adequate rest periods for cooling
down. This action may require additional shifts for workers or earlier or later
work schedules.
30
• •
• Provide cooling devices, such as vortex tubes or cooling vests, to be worn
beneath protective garments.
• Require removal of impermeable protective garments during rest periods.
• Ensure that all rest periods are taken in a shaded rest area, if possible.
• Regulate rest periods, and ensure that workers will not be assigned other tasks
during rest periods.
• Notify all workers of health hazards and the importance of adequate rest,
acclimatization, and proper diet; teach workers to recognize heat stress and to
conduct first aid to prevent heat stress.
The following chart contains general guidelines that can be used to pace hot-weather field work:
Continuous Work
75 percent work and
25 percent rest each hour
50 percent work and
50 percent rest each hour
25 percent work and
75 percent rest each hour
Light
Work
82.4
83.5
84.9
86.4
Wet Bulb Globe Temperature'
Degrees Fahrenheit {°F)
Moderate
Work
76.5
78.8
81.4
84.4
Heavy
Work
73.4
75.0
78.6
82.4
' Temperature adjusted for worker wearing coveralls. Subtract 5 degrees for water impervious clothing.
Source: Modified from ACGIH 1990.
Higher heat exposures than those shown above are permitted if workers have undergone medical
surveillance and if it has been established that they are more tolerant of hot-weather work than an average
worker. Workers will not be permitted to continue work when deep body temperatures exceed 100 .4 "F.
If the SHSO determines that heat stress is a potential problem, body temperatures will be monitored
periodically to ensure that overheating does not occur.
31
• •
9.0 SITE CONTROL
Work areas on or near the site will, depending on environmental monitoring, be divided into an exclusion
zone, a contamination reduction zone (CRZ), also known as decontamination zone, and a support zone.
Generally, the exclusion zone will be designated by barricade tape or traffic cones. Access to a
contaminated exclusion zone will be restricted to authorized personnel. A daily roster with the date of
each person's entrance into the contaminated zone; the person's name, signature, and organization; the
time of entry; and the time of exit will be kept for all personnel working in such an area. Any visitors
to the area must present proper identification and be authorized for site entry. Visitors must comply with
all provisions of this HSP. The SHSO will identify work areas that visitors or personnel are authorized
to enter and will enforce site control measures. The following sections discuss site SWPs, HSP
enforcement, and complaints.
9.1 COMMUNICATIONS
The following hand signals will be employed by site personnel in emergency situations or when verbal
communication is difficult.
Signal
Hands clutching throat
Hands on top of head
Thumbs up
Thumbs down
Arms waving upright
Gripping partner's wrist
9.2 SAFE WORK PRACTICES
Definition
Out of air or cannot breathe
Need assistance
Okay, I am all right, or I understand
No or negative
Send backup support
Exit area immediately
Safe Work Practices (SWP) requirements for site activities include the following:
32
• •
• All site personnel will enter a designated exclusion zone only through the
contamination reduction corridor (CRC). All personnel leaving an exclusion
zone must exit through the CRC and undergo the CRZ decontamination
procedure.
• Only equipment necessary to complete sampling will be permitted within an
exclusion zone. All nonessential equipment will remain within the support zone.
• All personnel will avoid contact with potentially contaminated substances.
Walking through puddles or mud and kneeling on the ground will be avoided
whenever possible.
• Equipment will not be placed on potentially contaminated surfaces.
• Food and beverages will not be permitted in the exclusion zone or CRZ.
Possession or use of tobacco products and application of cosmetics are also
prohibited in these areas.
• Matches and lighters will not be permitted in the exclusion zone or CRZ.
• During rest periods, all personnel will be required to observe each other for signs
of toxic exposure and heat stress. Indications of adverse effects include, but are
not limited to, the following:
Changes in complexion and skin discoloration
Changes in coordination
Changes in demeanor
Excessive salivation and pupillary response
Changes in speech patterns
• Site personnel will inform each other of nonvisual effects of illness, such as the
following:
Headache
Dizziness
Nausea
Blurred vision
Cramps
Irritation of eyes, skin, or the respiratory tract
The following sections describe safe work practices regarding sampling in trenches and confined spaces,
avoidance of trip and fall hazards, site activities near utility and power Jines, avoidance of excessive noise
exposure, ilJumination, sanitation, and site housekeeping.
33
•
9.2.1 Sampling in Trenches and Confined Spaces
Sampling in trenches and excavations may pose physical hazards to personnel. The following precautions
will be taken when sampling is conducted in excavations or trenches.
• Trenches will be inspected by a competent person before workers enter them.
A confined space entry permit system will be used to prevent workers from
entering unsafe trenches.
• Workers will not enter trenches alone. Standby personnel will always be present
to respond in the event of an emergency.
• The level of protection for entry personnel will be based on the results of air
monitoring.
• If the depth of the water present in trenches and excavations is 3 feet or above,
sampling will not be conducted in those areas.
All site personnel entering confined spaces will observe requirements specified in ANSI Z 117 .1-1977 (or
the latest version). Each worker must complete a Confined Space Entry Permit for each confined space
to be entered. This form (Attachment E), must be approved by the SHSO before work in the confined
space begins. Before entry, a worker must have satisfactorily completed a confined space training
program and a Confined Space Entry Permit. It is not anticipated that site activities will require confined
space entry.
9.2.2 Avoidance of Trips and Falls
Workers will be informed of any potential trip and fall hazards during regular health and safety meetings.
Whenever possible, trip and fall hazards will be eliminated or clearly identified with yellow caution tape.
9.2.3 Site Activities Near Utility and Power Lines
Site activities will proceed with caution in any area where historical data or instrument surveys indicate
the presence of utility lines (such as gas, telephone, and other lines). All site activity locations will be
coordinated by the PRC project manager.
34
• •
9.2.4 Avoidance of Excessive Noise Exposure
Workers will be protected from excessive noise exposure by means of equipment maintenance, noise
monitoring, and hearing conservation programs that comply with OSHA 29 CFR 1910.95. Hearing
protection will be required if the sound level continuously equals or exceeds 85 decibels on the A-
weighted scale or if the sound level exceeds 140 decibels regardless of the duration of exposure. Sound
level will be measured with a sound level meter during site activities. The decibel level will be measured
using a slow response setting on the A-weighted scale.
Ear inserts with a noise reduction rating of at least 26 decibels on the A-weighted scale or similar
equipment will be provided to PRC personnel. Such equipment will be worn during work tasks involving
heavy equipment, internal combustion engines, or other sources of elevated noise levels.
9.2.5 Illumination
Outdoor work will not be performed after sunset or when a lack of artificial or natural illumination makes
outdoor work difficult.
9.2.6 Sanitation
Potable water, drinking cups, nonpotable water, toilet facilities, washing facilities, and other sanitation
requirements will be provided in compliance with specifications of OSHA 29 CFR 1910.120(n).
9.2. 7 Site Housekeeping
Potentially hazardous wastes generated during site activities will be double bagged and drummed, if
necessary, and handled in accordance with Resource Conservation and Recovery Act (RCRA)
requirements. Nonhazardous waste and debris will be disposed of as standard municipal waste.
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• •
9.3 HEALTH AND SAFETY PLAN ENFORCEMENT
The SHSO will be responsible for enforcement of the HSP during on-site sampling activities. Personnel
who fail to follow HSP procedures will face disciplinary action that may, at a maximum, include
dismissal from the site.
At least one copy of this HSP will be available to all site personnel at all times. Any necessary changes
in HSP procedures will be made at the beginning of each work day by the SHSO.
9.4 COMPLAINTS
Personnel will be encouraged to report to the SHSO any conditions or practices that they consider
detrimental to their health or safety or that they believe are in violation of applicable health and safety
standards. Such complaints may be made orally or in writing. Personnel who believe that an imminent
danger threatens human health or the environment will be encouraged to bring the matter to the
immediate attention of the SHSO for resolution.
10.0 DECONTAMINATION
Decontamination is the process of removing or neutralizing contaminants from personnel or equipment.
When properly conducted, decontamination procedures protect the worker from contaminants that may
have accumulated on PPE, tools, and other equipment. Proper decontamination also prevents transport
of potentially harmful materials to unaffected areas. Personnel and equipment decontamination
procedures are described in the following sections.
10.1 PERSONNEL DECONTAMINATION
Minimal personnel decontamination is anticipated for the Koppers site because disposable PPE will be
used. If necessary, personnel decontamination will be completed according to the guidance given in the
"Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities" (NIOSH 1985).
Personnel and PPE will be decontaminated with potable water or a mixture of detergent and water.
Liquid and solid wastes produced during decontamination will be collected, drummed, and disposed of
36
• •
pending on-site analysis. If accepted, decontamination wastes will be disposed at the POTW. If
decontamination wastes are not accepted at the POTW, a licensed disposal contractor will be hired for
decontamination waste removal.
The following decontamination procedures will be conducted if personnel decontamination is required:
• Wash neoprene boots ( or disposable booties) with a Liquinox® or Alconox®
solution, and rinse them with water. Remove and retain neoprene boots for
reuse, if possible. Place disposable booties in plastic bags for disposal.
• Wash outer gloves in a Liquinox® or Alconox® solution and rinse them in water.
Remove outer gloves and place them in a plastic bag for disposal.
• Remove the Tyvek® or Saranex® suit and place it in a plastic bag for disposal.
• Remove the air-purifying respirator, if used, and place the spent filter in a plastic
bag for disposal. The filter may be changed daily or at longer intervals,
depending on the use and application. Clean and disinfect the respirator with
towelettes or a non-phosphate cleaning solution. Place it in a plastic bag for
storage.
• Remove inner gloves and place them in a plastic bag for disposal.
• Thoroughly wash hands and face with water and soap.
Used, disposable PPE will be collected in 55-gallon drums and disposed of as municipal waste, unless
otherwise specified. Further personnel decontamination procedures may be established as needed.
10.2 EQUIPMENT DECONTAMINATION
Decontamination of all nondisposable sampling and field monitoring equipment used during site activities
will be required. The equipment decontamination procedures described in the following sections are
based on guidelines appropriate for low-level contamination. When appropriate, Liquinox® or Alconox®
cleaning solutions and deionized water rinses will be used to decontaminate equipment. Wastewater from
equipment decontamination activities will be disposed of in the same manner as personnel decontamination
wastes, as discussed in Section IO. I.
37
• •
10.2.1 Sampling Equipment
Sampling equipment such as stainless steel spades, spoons, soil and groundwater samplers, and stainless
steel or aluminum pans will be decontaminated before and after each use. Distilled water will be used
for the following sampling equipment decontamination procedures:
• Scrub the equipment with a brush in a bucket containing Liquinox® or Alconox®
solution and potable, distilled water.
• Triple-rinse the equipment with distilled water, and allow it to air dry.
• Reassemble the equipment and 'place it in a clean area on plastic or aluminum
foil. If aluminum foil is used, wrap the equipment with the dull side of the
aluminum foil toward the equipment.
10.2.2 Field Monitoring Equipment
The Miniram® Model PDM-3 will be used for monitoring concentrations of dust in the atmosphere. This
equipment will be cleaned daily by wiping it with isopropyl alcohol wipe. Also, the equipment will be
stored in a bag to minimize the exposure to the dust.
11.0 EMERGENCY CONTINGENCY PLANNING
The SHSO will be notified of any on-site emergencies and will be responsible for ensuring that
appropriate emergency procedures are followed. Standard emergency procedures to be used by site
personnel are described in the following sections.
11.1 INJURY IN THE EXCLUSION OR THE CONTAMINATION REDUCTION ZONE
In the event of an injury in the exclusion zone or CRZ, all personnel will exit the exclusion zone and
assemble at the decontamination line, and the SHSO will be immediately notified of the event if
necessary. The SHSO will contact the HSD, and together they will evaluate the nature and extent of the
injury. The affected person will be decontaminated to the extent practical before being moved to the
support zone. Appropriate first aid procedures will be performed, an immediate request for an ambulance
38
• •
will be made (if necessary), and the designated medical facility will be notified (if necessary). Emergency
numbers for reaching an ambulance and the designated medical facility are provided in Section 11.5. No
personnel will re-enter the exclusion zone until the cause of injury or illness is determined and re-entry
is considered safe. In case of severe injury, the SHSO will implement procedures to minimize the
possibility of further injury. If the need to transport the patient to the medical facility supersedes the need
to decontaminate the patient, the medical facility will be notified that the patient has not been
decontaminated before the patient arrives. Documentation requirements are outlined in Section 7 .2.
11,2 INJURY IN THE SUPPORT ZONE
If an injury occurs in the support zone, the SHSO will be notified immediately. Appropriate first aid will
be administered and, if necessary, the injured individual will be transported to the designated medical
facility. If the injury does not affect the safety or performance of site personnel, operations will continue.
I
Documentation requirements are outlined in Section 7.2.
1L3 FIRE OR EXPLOSION
In the event of a fire or explosion at the site, the Morrisville Fire Department will be contacted at (919)
469-2156 as soon as possible, and evacuation of the site will begin immediately.
11.4 PROTECTIVE EQUIPMENT FAILURE
If any worker in the exclusion zone experiences a failure of protective equipment that affects his or her
personal protection, the worker and all coworkers will immediately leave the exclusion zone. Re-entry
to the exclusion zone will not be permitted until the protective equipment has been repaired or replaced
and the cause of equipment failure has been determined and is no longer considered a threat.
39
• •
11.5 EMERGENCY INFORMATION TELEPHONE NUMBERS
PRC will have a mobile telephone on site. Emergency telephone numbers not presented below can be
obtained by calling Kathy Schuessler of PRC at [phone].
11.6
Emergency Service
Morrisville Police Department:
Morrisville Fire Department:
Local Hospital:
Rex Hospital
4420 Lake Boone Terrace
Raleigh, NC 27607
Local Ambulance Service:
Poison Control Center:
National Response Center:
CHEMTREC Chemical Transportation
Emergency Center:
PRC (Atlanta office):
Robert Hutcheson. Project Manager:
Kurt Sorensen, HSD:
EPA Risk Reduction Engineering
Laboratory (RREL)
Terry Lyons, EPA TPM:
HOSPITAL ROUTE DIRECTIONS
Telephone Number
911 or [phone]
911 or [phone]
[phone]
911
1-[phone]
1-[phone]
1-[phone]
[phone]
[phone]
[phone]
[phone]
Before performing any site activities, PRC personnel will conduct a pre-emergency hospital run from the
site to the hospital. A map showing the hospital is provided in Figure 11-1. Directions to the hospital
are as follows: turn left out of the plant and go to Highway 54; turn right onto Route 54 to Airport
40
• •
Boulevard to 1-40; turn right onto 1-40 to Blue Ridge Road; turn left onto Blue Ridge Road and go to
Lake Boone Terrace. The hospital is located at 442 Lake Boone Terrace.
41
• •
REFERENCES
American Conference of Governmental Industrial Hygienists (ACGIH) 1993. "Threshold Limit Values
for Chemical Substances and Physical Agents and Biological Exposure Indices for 1992-1993."
National Institute for Occupational Safety and Health (NIOSH) and others. 1985. "Occupational Safety
and Health Guidance Manual for Hazardous Waste Site Activities."
NIOSH, 1990. "Pocket Guide to Chemical Hazards." U.S. Department of Health and Human Services.
U.S. Government Printing Office. Washington, D.C. June.
43
• •
CONTENTS
Section
1.0 INTRODUCTION
2.0 HEAL TH AND SAFETY PLAN ENFORCEMENT ...................... .
2.1 PROJECT PERSONNEL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2.1.1 Project Manager and Field Site Manager . . . . . . . . . . . . . . . . . . . . . 2
2.1.2 Health and Safety Director . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2.1.3 Site Health and Safety Officer . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2.2 SUBCONTRACTORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2.3 VISITORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
3.0 SITE BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.1 SITE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.2 SITE HISTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
4.0 SITE-SPECIFIC HAZARD EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
4.1 EXPOSURE PATHWAYS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
4.1.1 Inhalation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
4.1.2 Dermal Contact . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
4.1.3 Ingestion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
4.2 HEALTH EFFECTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
4.3 PHYSICAL HAZARDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
5.0 TRAINING REQUIREMENTS 16
6.0 PERSONAL PROTECTION REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . 18
6.1 LEVELS OF PROTECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
6.2 PROTECTIVE EQUIPMENT AND CLOTHING . . . . . . . . . . . . . . . . . . . . 19
6.3 LIMITATIONS OF PROTECTIVE CLOTHING . . . . . . . . . . . . . . . . . . . . 20
6.4 DURATION OF WORK TASKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
6.5 RESPIRATOR SELECTION, USE, AND MAINTENANCE . . . . . . . . . . . . . 21
7.0 MEDICAL SURVEILLANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
7.1 HEALTH MONITORING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . 24
7.2 DOCUMENTATION AND RECORDKEEPING REQUIREMENTS . . . . . . . . 26
7.3 MEDICAL SUPPORT AND FOLLOW-UP REQUIREMENTS 26
• •
CONTENTS (Continued)
8.0 ENVIRONMENT AL SURVEILLANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
8.1 INITIAL AIR MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
8.2 PERIODIC AIR MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
8.3 MONITORING PARAMETERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
8. 3. I Ambient Airborne Dust . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
8.3.2 Organic Vapors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
8.4 USE AND MAINTENANCE OF SURVEY EQUIPMENT . . . . . . . . . . . . . . 30
8.5 HEAT STRESS MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
9.0 SITE CONTROL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
10.0
9.1 COMMUNICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
9.2 SAFE WORK PRACTICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
9. 2. I Sampling in Trenches and Confined Spaces . . . . . . . . . . . . . . . . . . . 34
9.2.2 Avoidance of Trips and Falls . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
9.2.3 Site Activities Near Utility and Power Lines . . . . . . . . . . . . . . . . . . 34
9.2.4 Avoidance of Excessive Noise Exposure . . . . . . . . . . . . . . . . . . . . . 35
9.2.5 Illumination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
9.2.6 Sanitation . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . 35
9.2.7 Site Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
9.3 HEALTH AND SAFETY PLAN ENFORCEMENT . . . . . . . . . . . . . . . . . . 36
9.4 COMPLAINTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
DECONTAMINATION 36
10.1 PERSONNEL DECONTAMINATION........................... 36
10.2 EQUIPMENT DECONTAMINATION. . . . . . . . . . . . . . . . . . . . . . . . . . . 37
10.2.1 Sampling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
10.2.2 Field Monitoring Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
11.0 EMERGENCY CONTINGENCY PLANNING . . . . . . . . . . . . . . . . . . . . . . . . . . 38
II.I INJURY IN THE EXCLUSION OR THE CONTAMINATION REDUCTION
ZONE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
11.2 INJURY IN THE SUPPORT ZONE . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
11.3 FIRE OR EXPLOSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
11.4 PROTECTIVE EQUIPMENT FAILURE . . . . . . . . . . . . . . . . . . . . . . . . . 39
11.5 EMERGENCY INFORMATION TELEPHONE NUMBERS . . . . . . . . . . . . . 40
11.6 HOSPITAL ROUTE DIRECTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
II
• •
CONTENTS (Continued)
FIGURES
Figure
SITE LOCATION 5 3-1
3-2
11-1
SITE LAYOUT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
HOSPITAL LOCATION MAP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
TABLES
4-1 HAZARDOUS MATERIALS POTENTIALLY PRESENT AT KOPPERS SITE ....... 9
4-2 WORK TASK HAZARD ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
4-3 POTENTIAL HAZARD EVALUATION ............................... 12
4-4 PERMISSIBLE EXPOSURE LEVELS FOR ON-SITE CHEMICALS . . . . . . . . . . . . 14
ATTACHMENTS
Attachment
A COMPLIANCE AGREEMENT FORM
B SAFETY MEETING SIGN-OFF SHEET
C DAILY SITE LOG
D MATERIAL SAFETY DATA SHEETS
E CONFINED SPACE ENTRY PERMIT
F ACCIDENT REPORT FORM
Ill
ACGIH
ANSI
APC
BCD
CFR
CRC
CRZ
EPA
HSP
HRS
HSD
!PE
mg/kg
MSDS
MSHA
NaOH
NCDOH
NIOSH
NPL
OSHA
PCP
PEL
POTW
• •
LIST OF ACRONYMS
American Conference of Governmental Industrial Hygienists
American National Standards Institute
Allowable Particulate Concentration
Base Catalyzed Decomposition Process
Code of Federal Regulations
Contamination Reduction Corridor
Contamination Reduction Zone
U.S. Environmental Protection Agency
Health and Safety Plan
Hazard Ranking System
Health and Safety Director
Isopropyl ether
milligrams per kilogram
Material Safety Data Sheet
Mine Safety and Health Administration'
Sodium hydroxide
North Carolina Division of Health Services
National Institute for Occupational Safety and Health
National Priority List
Occupational Safety and Health Administration
Pentachlorophenol
Permissible Exposure Level
Publicly Owned Treatment Works
IV
PPE
PPM
PRC
RCRA
RJ/FS
RREL
SHSO
SITE
SWP
TCDD
TCDF
TLV
TPM
US!
• •
LIST OF ACRONYMS (continued)
Personal Protective Equipment
parts per million
PRC Enviromnental Management, Inc.
Resource Conservation and Recovery Act
Remedial Investigation and Feasibility Study ·
Risk Reduction Engineering Laboratory
Site Health and Safety Officer
Superfund Innovative Technology Evaluation
Safe Work Practice
2,3, 7 ,8-tetrachlorodibenzo-p-dioxin
2,3, 7 ,8-tetrachlorodibenzofuran
Threshold Limit Value
Technical Project Manager
Unit Structures, Inc.
V
• •
s1wrnrnw·, sEUiON.
SITE DEMONSTRATION OF
THE BASE-CATALYZED DE.COMPOSITION (BCD) TECHNOLOGY
. AT THE
,KOPPERS COMPANY, INC. SITE
MORRISVILLE, NORTH CAROLINA
,-RESPONSE TO QUALITY ASSURA.i'ICE COMMENTS " ~ . .
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Cincinnati, Ohio 45268
~ork Assignment No.
Date Prepared
EPA Contract No.
PRC-EMI No.
PRC Project Manager
Telephone No.
EPA Project Manager
Telephone No.
0-11
August 5, 1993
68-C0-0047
047-1100
Robert Hutcheson
[phone]
Terry Lyons
[phone]
•
TABLE OF CONTENTS
Section
1.0 RESPONSE TO CONCERNS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I ·
2.0 RESPONSE TO MINOR ISSUES .....•........................ ·. . . . . . . . . . . . 8
3.0 CHANGES RECOMMENDED BY SITE TEAM MEMBERS ....................... 16
3.1 CHANGES RECOMMENDED BY RADIAN CORPORATION ................. 16
3.2 CHANGES RECOMMENDED BY VERSAR, INC ......................... 19
3.3 CHANGES RECOMMENDED BY INTERNATIONAL TECHNOLOGY
CORPORATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
ATTACHMENTS
Attachment
A REVISED SAMPLE LOCATION MAP
B STANDARD OPERATING PROCEDURE FOR THE GAS CHROMATOGRAPHY/MASS
SPECTROMETRY ANALYSIS OF AIR TOXICS CANISTER SAMPLES USING METHOD TO-14
•
• •
1.0 RESPONSE TO COi\l.MENTS
The Quality Assurance (QA) manager for the Risk Reduction Engineering Laboratory (RREL)
identified four concerns regarding the Quality Assurance Project Plan (QAPP) for the Base-Catalyzed
Decomposition Technology SITE demonstration at the Koppers Company, Inc. site in Morrisville,
North Carolina. The PRC SITE team's responses to concerns follow.
la. For sample point~ 2 and 3 (untreated and treated soil), Table 4-3 specifies 12 composite
samples per run, while Table 4-1 specifies four 2.5-hour composite samples. The
associated texi states that each of the 2.5-hour composites will consist of at least four
grab samples. Please clarify the number of samples that will be collected, and explain
the timing and procedures for collecting the subsamples.
Response: Four composite samples will be collected per test run at sample locations 2 and 3.
One composite sample will be collected from each sample location every 2 hours per 8-hour
test run. A composite sample will consist of four grab samples with one grab sample
collected every 30 minutes. Each grab sample will be contained within a compositing jar
which will be covered with a Teflon®-lined lid and placed in a cooler in between collection of
each grab sample. Originally, 12 composite samples were·to be collected per test run from
each sample location (four samples every 2.5 hours for a total of 12 samples per sample
location).
lb. In Table 4-3 under sample location 2, there is an entry·labeled "sodium carbonate
•reagent""with·zero samples.and one blank. What is meant by this entry?
Response: One composite sample of.the sodium bicarbonate reagent will be collected during
mixing of the contaminated soil.-with·-the reagent'." The·composite,sample will consist"of at
least 4 grab samples and will be analyzed for PCDDs/PCDFs, SVOCs, VOCs, and metals.
The QAPP will be revised to de_signate the sodium bicarbonate sample as sample location 11.
The original entry was meant to refer to sampling of a "reagent blank" to assure that the
reagent contains no contaminants of concern.
le. Table 4-3 provides for matrix spike samples for PCP for contaminated soils, while the
text explains that these samples are too concentrated for matrLx spiking. Consistency is
needed.
Response: Matrix spike samples will be collected for SVOCs analysis as outlined in Table 4-
3. The text of the QAPP will be revised for consistency.
Id. Table 4-1 and Section 4.4.1 list six composite samples for sample location 1 for the TCLP
procedure, while Table 4-3 lists only three samples and one field duplicate. How many
samples are intended.
Response: The collection of TCLP samples at sample location I has been canceled. TCLP
samples (I per test run) will only be collected at sample location 3.
• •
le. Table 4-3 lists oil and grease (O&G) for sample location 1 while O&G is not listed for
this stream in Table 4-1. Please clarify.
Response: Analyses for oil and grease (O&G) will be conducted on samples collected from
sample location I. Table 4-1 will be revised to correspond with Table 4-3.
lf. Table 4-3 lists pH for sample location 2 while pH is not listed for this stream in Table 4-
1. Please clarify.
Response: Samples will be collected for pH determination al sample location 2. Table 4-1
will be revised to indicate the collection of pH samples at sample location 2.
lg. Table 4-1 lists moisture for san1ple location 2 for the purpose of converting data to a
dry-weight basis to calculate the efficiency of the BCD process. This seems to be
inconsistent with the discussion concerning equation 1-1, which calculates removal based
on the total mass of contan1ii:tant. Please clarify.
Response: The determination of moisture content will be used for the purpose of converting
data to a dry-weight basis only. Table 4-1 of the QAPP will be revised to indicate the change
in rationale for collection of moisture content at sample location 2. Since data from both
locations 2 and 3 will be converted to a dry weight basis, the contaminant removal efficiency
of the .BCD process will .be determined by contaminant·concemration as opposed to mass of
contaminant.
lh. • Table 4-3 lists metals, O&G, and bulk density for sample location 3 while these
paran1eters·are not listed for this stream in Table 4-1. Please clarify. Is bulk density
. needed to calculate the total.mass of treated soil? If so,.it should also be included for
untreated soil (Sample Point No. 1)). ' ·
Response: The analysis of metals, O&G, and bulk density will be'conducted for samples
collected at sample location 3. Also, bulk density will be determined for sojl at sample
location I as indicated in Table 4-3. Table 4-1 of the QAPP will be revised for consistency.
Bulk density is a non-critical parameter and will be used to determine soil property changes
resulting from the L TTR/MTTR. Soil mass will be determined by weighing drums of soil
entering the LTTR/MTTR units.
li. Table 4-3 lists three time-integrated samples per test run for each of the gaseous streams
while footnote "d" states one composite sample per run. Please clarify the number of
samples per run for the gaseous streams in Table 4-3.
Response: One time-integrated sample per test run will be collected for each gas stream
sample location. Table 4-3 will be revised accordingly.
lj. Table 4-3 lists metals analysis for sample location 6 while metals analysis is not listed for
this stream in Table 4-1. Please clarify. Sodium hydroxide reagent is listed as a
parameter for sample location 6 in Table 4-3 with zero samples and 1 blank to be taken.
This entry is not understood. Please explain.
2
• •
Response: Metals analysis will be conducted on samples collected from sample location 6 as
indicated in Table 4-3. Table 4-1 will be revised to correspond with Table 4-3.
'
Also, a separate sample of the sodium hydroxide reagent will be collected per test run of the
LTR. The sample will be analyzed for PCDDs/PCDFs, SYOCs, VOCs, and metals. The
QAPP will be revised to designate the sodium hydroxide reagent sample as sample location
12.
lk. Sample locations 6 and 7 are described as solid samples in Table 4-3. These are oil
samples, Please revise,
Response: Sample locations 6 and 7 are the L TR influent and efflue_nt which consists
primarily of LW I 10 oil from the LTTR/MTTR oil scrubber system. The QAPP will be
revised to indicate sample locations 6 and 7 as being oil samples.
11, Table 4-3 lists particulate loading and moisture content for sample location 8 while these
are omitted from Table 4-1; on the other hand, Table 4-1 lists O&G and pH for this
sample point, both of which are inappropriate for gas san1ples, Please clarify,
Response: Particulate loading and moisture content samples will be collected for analysis at
sample location 8 as indicated in Table 4-3. Table 4-1 of the QAPP will be revised
accordingly. Also, oil and grease (O&G) samples and pH samples will be removed from
sample location 8 in Table 4-1.
lm,. -Table 4-3 lists three time-integrated.samples per run for.sample.location 8. Footnote "d"
.states that there is 1 composite. (integrated) sample ·per run. Please:clarify the number of
.-samples per-run for sample-location 8 in Table 4-3,
, ·Response: As stated in'Response Ii, onetime-integrated·sample·per test run will be collected
from each gas stream location. Table 4-3 of the QAPP will be revised for consistency.
ln. For sample location 9 in Table 4-3, seven samples are listed per test run. Footnote "r'
states that there is 1 san1ple for each thermal desorber run and L TR run, Please correct
the number of samples per run for sample location 9 in Table 4-3,
Response: One time-integrated gas sample will be collected from the stack gas sample
location (designated as sample location 5 in the revised QAPP) during six runs of the
L TTR/MTTR and two runs of the L TR. Table 4-3 of the QAPP will be revised to indicate
the changes.
lo. Three samples per test run are listed for sample locations 10 and 11 while footnote "c"
lists four composites for each five runs, Please clarify the number· of samples per run
for these streams,
Response: The condensate water will be stored in the condensate storage tank for use in the
L TTR/MTTR water scrubber system during the course of the demonstration. The condensate
water will be treated at the end of the demonstration, prior to demobilization. Three grab
samples will be collected from the condensate storage tank (designated as sample location 9 in
3
• •
the revised QAPP) prior to treatment. The treated condensate (wastewater) will be placed
into a treated wastewater storage tank. Three grab samples (designated as sample location 10
in the revised QAPP) will be collected at the end of wastewater treatment. Tables 4-1 and 4-
3 in the QAPP will be revised to indicate the change in sample frequency. Also a sample of
the scrubber water/cooling water supply source will be collected to assure that no
contaminants of concern are detected with the water supply.
lp. Preliminary samples will be analyzed on site with a portable gas chromatograph. Which
samples will be used. for this purpose?
Response: Preliminary samples will be analyzed on site for all sample locations (primarily
for sample locations I and 3) except gas sample locations. Data will be used for process
control only and is considered non-critical. ·
lq. For most analyses at sample point 1, three composite samples will be collected over the
entire project. Section 3.3.1 explains the compositing procedure once subsantples have
been collected. However, there is no explanation regarding how the initial subsamples
will be collected. These should be tinted to be representative of the entire mass of soil
that is treated.
Response: The text describes collection of grab samples in paragraph 3 of Section 4.4.1. A
determination of collection times. for grab samples will·be;estimated during manual screening
of the soils based on the time necessary to screen approximately 0.5 ton. Screening of soils
for the demonstration will be completed.prior to the start.of the.BCD process demonstration.
The text of the QAPP .will be revised to ,indicate. the method for determining the grab sample.
collection time interval.
lr. .According.to page 4.0-3_, san1ples of treated soil will be,collected before it is cooled \\ith
process water. This approach raises.two co~cerns. ;First,,this approach will overlook
any addition of contaminants from the process cooling water. Second, volatiles would
likely be lost during the sampling procedure. Is the description of this sampling point in
the tex1 correct, or will the soils actually be sampled once they have cooled to room
temperature, as is suggested in Figure 4-1?
Response: Treated soils (sample location 3) will be collected after it is cooled with process
water .. The text of the QAPP will be revised to indicate the point of collection for soils at
sample location 3.
The cooling water will consist of either tap water obtained from the local municipal water
supply system, or treated condensate water from the BCD process. Samples of the cooling
water will be collected to assure no contaminants of concern are detected in the cooling water
supply source.
ls. Approximately 10 percent of the samples in Table 4-3 are field duplicates. However,
there is no indication of how such duplicates will be collected. Please provide procedures
for collecting field duplicates. How will the data from such duplicates be treated?
4
•
Response: Field duplicate samples will be generated by collecting twice the necessary volume
for a designated sample. Double volume samples will be composited and quartered prior to
containerization. The data for duplicate samples will be used to assess sample variability.
The duplicate results will be averaged for the sampling event that was duplicated. The text of
the QAPP will be revised to indicate the collection method and use of duplicate sample data.
lt. Volatile organics will collected with methanol extraction procedure. Please note that this
approach will result in poorer detection lin1its for the VOCs than are listed in Table 3-4.
Please revise this table accordingly to be sure· that all parties are in agreement regarding
this detem1ination. Also note that this procedure will require that the mass of soil and
the volume of methanol be recorded to permit a calculation of the final concentrations in
the soil.
Response: Volatile organic samples will be collected as individual grab samples and analyzed
by Method 8240. The methanol extraction method will not be used. The text of the QAPP
will be revised to indicate the change in the volatile organic sample collection procedure.
2. How will the mass of treated and untreated soil be detemtined? lb.is information is
needed to estimate treatment cost (objective 4) and for calculating removal efficiencies.
Will the soil be weighed in some manner, or will soil mass be estimated from volume
and bulk density measurements?
It is unclear whether soil mass should be considered.as critical or-noncritical. Section
1.5 discusses calculation of the removal efficiency based on the total amount of
contaminant rather than the contaminant concentration. These procedures will require
that the mass of material used and recovered for each run be measured in a traceable
manner. -However; the mass of feed material or product has not been designated as a
critical paran1eter, and no QA objectives been set for mass.determinations. If the data
for this·project will be analyzed according to equation 1-1, the mass detem1inatious will
be critical and QA objectives must be set. Appropriate calibration and QC procedures
will also have to specified. Please make appropriate revisions.
Response: The soil mass is considered a critical measurement for determining treated cost.
and will be determined by weighing feed soil entering the L TTR and MTTR. Drummed
contaminated soils will be emptied into the L TTR/MTTR feed hopper. The drums will be
weighed prior to and after emptying the contents: of the drums. The mass of treated soil will
not be measured. As stated in Response lg, removal efficiency will now be determined by
concentration.
3. Section 1.3 lists 5 objectives for this demonstration. There are two concerns related to
these objectives.
3a. The second objective is to "Determine the ability of the process to produce effiuents
(treated soil, oil, water, and gases) that meet applicable local, state, and federal
standards for disposal or discharge." Later in this section (page 24), the measurements
critical to this objective are listed as PCP, PCDDs, and PCDFs in gas, water, and oil, as
well as particulate matter in the stack gas. However, the numerical values for the local,
state, and federal standards are note presented. Without these values, the
5
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appropriateness or the sampling and analysis procedures cannot be evaluated. Please
supply the numerical values for these standards, if possible.
I
Response: The soil residual must be treated. For soil, PCP must be treated to less than 95
ppm and dioxins and furans must be treated to less than 7 ppb.The appropriate re~triction for
disposal of residual wastewater and air are listed below.
Federal Effluent Requirements (40 CFR Part 268)
HXCDD -all Hexachloro-dibenzo-p-dioxins
HXCDF -all Hexachloro-dibenzofurans
PeCDD -all Pentachloro-dibenzo-p-dioxins
PeCDF -all Pentachloro-dibenzofurans
TCDD -all Tetrachloro-dil:ienzo-p-dioxins
TCDF -all Tetrachloro-dibenzofurans
2,4,5-TricWorophenol
2,4,6-Trich!orophenol
2 ,3 ,4 ,6-Tetrachlorophenol
Pentachlorophenol
Phenol
2,4-Dichlorophenol
2,6-Dichlorophenol
. · Hexachlorod ibenzo-p-dioxin
Pentachlorodibenzofurans
Pentachlorodibenzo-p-dioxin
Oil and grease
_Phenols
pH
< I ppb
< I ppb
< I ppb
< i ppb
< I ppb
< I ppb
< I ppb
< 0.05 ppm
< 0.05 ppm
< 0.01 ppm
..::;_ 0.039 mg/1
..::;_ 0.044 mg/1
..::;_ 0.44 mg/I
..::;_ 0.000063 mg/1
..::;_ 0.000063 mg/I
..::;_ 0.000063 mg/I
1.5 lb/1000 cubic feet·of wastewater
0.14 lb/1000 cubic feet·of wastewater
8.0 to 9.0 at all times
State Air Emmission Requirements (NCAC Part 20)
HXCDF
Pentachlorophenol
Phenol
Tetrachlorodibenzo-p-dioxin
Sodium dioxide
Nitrogen dioxide
Particulates
0. 0051 lb/yr
0.063 lb/day
0.0064 lb/hr
0.24 lb/hr
0.00020 lb/day
2.3 lbs/million BTU input
0.6 lb/million BTU input
1.83 lb/hr per 600 lb/hr process material
3b. The third objective is to "Evaluate potential effects or chemical and thermal reactions or
the BCD process on PCP, dioxins, and furans, such as forming other hazardous
compounds." The discussion on page 24 states that for the third objective "the critical
parameters are PCP, PCDDS, and PCDFs in the contaminated feed soil, treated sludge,
treated liquid effiuent, and gas exiting the stack.". The measurement or these paran1eters
6
•
• •
is critical to the first objective; their applicability to the third objective is unclear. If one
objective of this project is actually to identify reaction products, one would expect to
employ analytical methods that are oriented towards the identification of such products.
Rather, this project simply employs EPA method 8270 for standard analyte list. To
identify reaction products, one might concentrate on identifying likely products, such as
cWorinated phenols or partially oxygenated forms of pentacWorophenol. Perhaps
reaction products have been identified from laboratory studies, and these products could
be searched for during the current project. Please clarify this objective, and indicate
which methods are critical to its attainment. Perhaps this objective could be addressed
more easily with .a small scale;laboratory study,
Response: Objective 3 is considered a secondary objective of the demonstration. Page 24 of
the QAPP will be revised.
The primary reason for choosing Method 8270 was the large number of compounds .which can
be analyzed, simultaneously. Many of these compounds may be degradation or breakdown
products of the thermal decomposition of PCP. These compounds include many of the
chlorinated phenols, non-chlorinated phenols, ethers, and phenyl ethers. Another important
reason for choosing Method 8270 is in the qualitative, positive identification of target
compounds. The ability to positively identify compounds is a major advantage of this
method. Another advantage for the use of Method 8270 is that it is possible to identify
,compounds which are no( included: in the target, analyte list. .This is performed through
.'tentatively.identified compounds (TlCs). The 20 TICs,with the highest peaks will be
identified if_possible. The .mass spectrometer software .program includes a 50,000 chemical
,compound·librnry of mass spectra data. This library can be invoked to help in the
identification and quantitation·of.non°identified chemical compounds found in samples. This
may ,be· extremely helpful -when•.searching for PCP degradation products.
4. It is questionable whether the accuracy objective of 50-150 percent recovery can be
achieved for pentacWorophenol (Tables 5-4 and 3-1) without preliminary effort. PCP is
.notorious for poor recoveries. In fact, Table 6 in Method 8270 lists the range of
recoveries for PCP as 14-176 percent. The addition of sodium carbonate may further
stabilize the PCP in the soil matrix and decrease recoveries. It is suggested that
adequate recoveries be demonstrated for PCP before this project is initiated. The
addition of a strong mineral acid to .the soil may be necessary to release the PCP during
extraction.
Response: Tables 3-1 and 5-4 will be changed to indicate that the accuracy objective for PCP
is 14-to 176-percent, as is specified in Table 6 of SW-846 Manual Method 8270. PRC
agrees that the recovery of PCP can be very poor when PCP analysis is performed with
standard EPA SW-846 Manual Method 8270. The poor recoveries of PCP may be
compounded by the addition of sodium carbonate during sample treatment.
To address the concern of low PCP recovery inherent in Method 8270, PRC will be collecting
a sample during the dry-run week (August 16) which has been run through the THERM-O-
DETOX treatment process, and will have had sodium carbonate added to it. This sample will
7
be submitted to Versar before the start of the demonstration activities. Four aliquots of this ·
sample will then be spiked with PCP at each of four levels --10, 100, 1,000, and 2,000 parts
per million, and analyzed using Method 8270. Versar will then perform a statistical analysis
of the matrix spike data including: mean percent recovery, standard deviation, and
determining the 95 percent confidence interval for percent recovery. Versar will transfer this
data to the PRC project manager before the de_monstration activities begin. The 95 percent
confidence interval from this evaluation should.fall within the range of 14-to 176-percent. If
the 95 percent confidence interval exceeds these ranges PRC will contact the EPA TPM to
determine corrective action.
Corrective actions which may be taken includes acidifying samples and analyzing the acidified
sample extracts by Method 8270. This course of action may reduce the number of
compounds which can be reported due to the possibility of acidic breakdown of some Method
8270 analytes. This action may also limit the T!Cs data derived from the sample analysis, for
the same reason. Another corrective action may include analysis of samples with Method
8270 and a separate analysis of samples with EPA SW-846 Manual Methods 8040 or 8151.
These are gas chromatographic methods specifically designed to determine phenols and
chlorinated acids. The main advantage to the use of these methods is that they should provide
better recoveries for PCP and other chlorinated phenols. Another advantage is that the
quantification of PCP may be more accurate with these methods than with Method 8270.
Disadvantages of the use of these.methods are that the;number.ofianalytes reported.is much
-smaller than.with Method 8270, and·the identification of:specific compounds is not as exact as
,with-Method 8270. Method 8040 and 8151 require,second column confirmation, or mass
. spectrometer confirmation using Method 8270, for-positive-identification of compounds.
Corrective actions which will be used will be detem1ined by the EPA TPM and the PRC
project manager.
8
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2.0 RESPONSE TO MINOR ISSUES
RREL's QA Manager identified nine minor issues regarding the subject QAPP. The PRC SITE
team's response follow.
l. There are also some concerns regarding stack sampling procedures.
la. The estimated stack diameter and flow rate of the stack gas is needed to select the proper
sampling equipment. What are the approximate diameters and gas flow rates at the
various stack sampling locations for this process?
Response: Gas samples to be collected during the demonstration include L TTR/MTTR off-
gas, stack gas, and BCD liquid reactor off-gas (designated as sample locations 4, 5, and 8 in
the _revised QAPP). The LTTR/MTTR off-gas· will be collected after the gas stream has
passed through the oil and water scrubbers and condenser, prior to carbon polishing .
. Originally, a separate off-gas sample was to be collected for the L TTR and MTTR
(designated as sample locations 4 and 5 in Draft QAPP; see Attachment A for revised sample
location map). The stack gas sample will be collected after the carbon polishing unit, prior to
release of the gas stream to the atmosphere. The BCD liquid reactor off-gas stream will be
sampled as the gas exits the reactor.
The off-gas·flow rates-of the LTTR/MTTR and the BCD liquid·reactor is estimated at 65
cubic· feet per minute (cfm) and 6 cfm;. respectively. -The diameters of the off-gas/stack gas
pipes are estimated to range between 2 to 4 inches. Radian .will finalize specific sampling
· procedures during the week of the dry-run.
lb. It inmclear whether gas san1ples will be analyzed for PCDDs/PCDFs by Method 23
(HRGC/HRi\1S) or by. Method 8280 (HRGC/LRMS). ·Samples.will be collected by
Method 23, and such samples are normally aiialyzed as well by Method 23. However,
Table 5-3 specifies Method 8280, although Table 3-2 gives detection limits from Method
8290, the SW-846 equivalent to Method 23. Clarification is requested. The primary
difference here is that Method 23, which is based on high resolution mass spectrometry,
gives more definitive identification and frequently better detection limits. If Method
8280 is indeed intended for the air samples, the detection limits in Table 3-2 for
PCDD/PCDFs in air should be adjusted accordingly. The QAPP should also explain
what changes, if any, will be needed to analyze Method 23 samples by Method 8280.
Will labelled surrogates be added to the resin bed_ prior to sample collection?
In Section 4.4.4, page 19, the discussion of the Method 23 train states that separate
trains will be run for PCB, PCDDs, PCDFs, and SVOCs. PCBs have not been
previously identified as part of·this project. Three sampling trains have been discussed,
one for PCDDs/PCDFs, a second for SVOCs including PCP, and a third for particulates.
Please clarify this discussion. Also, there is a typographical error in the description of
the resin in the same paragraph: "SAD" should be XAD-2.
Response: Method 8290 will be used for PCDDs/PCDFs analyses. Table 5-3 of the QAPP
will be changed for consistency with Table 3-2.
9
•
Also, the listing of a PCB gaseous sample train, and the "SAD" designation for "XAD-2" in
Section 4.4.4, page 19, are typographical errors. The text of the QAPP will be revised
appropriately.
le. The minimum sample volume listed for the VOST train (VOCs in gas) is 1.8 liters.
Twenty liters (0.02 dscm) is the typical volume collected and is the volume used to
calculate the detection limits given in Table 3--4. Please clarify.
Response: Samples for VOC analyses will be collected using passivated Summa canisters.
The VOST sample train will not be used to collect a sample for VOC analysis. The text of
the QAPP will be revised to indicate the change in VOC sample collection methods.
Attachment A list the standard operating procedures for the gas chromatography/mass
spectrometry analysis of air toxics canister samples using Method T0--14.
Id. Section 4.7.1 discusses guidelines concerning construction and geometry_of a "standard
pi tot tube." Will a standard pilot tube be used for this project? A type "S" pi tot tube is
usually used for Method 5 sampling unless small ducts or stacks are involved. Please
clarify.
Response: A standard pilot tube will be used for this project. The ducts are too small to a
Type S pitot. Where possible, we will install 4-inch PVC tubing (with no glued joints) with
ports.at•appropriate distances,to.comply with the 8 and 2·diameter rule of EPA Method I.
Gas velocity .and temperature will be measured with a standard pitot and them10couple as
,described in.EPA Method IA and 2C. It may not be feasible to -install a 4-inch diameter
,sample line, in which case the-smallest possible:standard pitot will be used, although the EPA
methods cited do not apply to ducts less than 4-inches in diameter. If this approach is found
to be ineffective, alternate techniques, such as use of a hot wire anemometer or measurement
of total.duct gas. volume over: time, -may be attempted.
le. Will the thermal desorbers and the BCD liquid reactor be operated simultaneously? If
so, how can the gas emission at sample point 9 be apportioned between the various
sources?
Response: The thermal desorbers and the BCD liquid reactor will not be operated
simultaneously. The demonstration schedule presented in the QAPP will be revised to
indicate the days of operation for the respective units.
2. Scheduled QC and calibration
2a. In s~..:tion 3, page 5 of 14, it is stated that untreated soil (before and after the addition of
sodium bicarbonate) will not be spiked for PCP because the expected level of PCP is
greater than 1000 mg/kg. If matrix spiking is not used, how will the accuracy of PCP in
this matrix be determined? Accuracy must be dctern1ined for each critical parameter in
each critical matrix. Please describe the procedure for determining the accuracy of PCP
in the feed soil. The next sentence in the same paragraph states that precision of PCP in
feed soil will be assessed by serial dilution. There is no explanation why this procedure
is being used over the typical laboratory duplicate. Please explain.
10
• •
Response: Matrix spike samples and field duplicates will be collected for sample locations 1
and 2. The text of the QAPP will be revised accordingly.
2b. Table 5-4 specifies a 5% frequency for MS/MSDs. This appears to contradict Table 4-3,
which specifies a definite number of MS/MSDs, typically at a higher frequency than 5%.
It is recommended that Table 5-4 be modified to be consistent with Table 4-3.
Response: Table 5-4 of the QAPP will be modified to be consistent with Table 4-3.
2c. In Table 5-4 corrective action for MS/MSDs is to flag the data. It is recommended that,
at a minimwn, the project manager be notified as soon as possible.
Response: The text of the QAPP will be modified to indicate notification of the PRC and
EPA project managers upon initiation of corrective actions for MS/MSDs.
2d. In Table 5-4 the acceptance criterion for initial calibration for dioxins is RSD < 30%. To
what measurement does this apply? The method requires that the RSD of each standard
injected in triplicate be < 15%. Is the intent of this entry to relax this criterion
somewhat? Or does this criterion apply to the linearity of the calibration curve?
Response: Table 5-4 will be changed to indicate that the acceptance criteria for initial
.calibration for dioxins is .:'o.-15 percent, as is specified in EPA SW-846 Manual Method 8280:
2e. In Table 5-4 there is, no procedure listed to determine accuracy ·for total organic carbon
analysis. , Section 3 mentions matrix spikes .. ·Please resolve this :inconsistency.
Response: Total organic carbon analytical accuracy is assessed ·through the use of matrix
spike san1ples. The matrix spike will be composed of potasium hydrogen phthalate.
Acceptable matrix spike recovery control limits generated by Versar are 80-to 120-percent
recovery. This matrix spike recovery acceptance criteria will be added to Table 5-4.
2f. According the Sections 9.1 and 9.2, accuracy for PCDDs/PCDFs will be determined by
MS/MSDs. This is probably incorrect because later in these subsections and in other
sections of the QAPP, other procedures are specified for accuracy and precision for
PCDD/PCDF analyses. Please resolve these inconsistencies.
Response: Sections 9-1 and 9-2 will be changed to indicate that accuracy for PCDDs/PCDFs
will be_ evaluated through the use of laboratory control standards. The accuracy criteria is 40-
to 120-percent recovery. Accuracy will also be estimated by determining internal standard
recoveries for each congener class.
2g. Page 3.0-4 states that precision for particulate matter will be determined by analyzing
duplicate aliquots of a field sample. A Method 5 sampling train is not appropriate for
aliquoting procedures. Precision of a Method 5 train is not routinely determined. Please
clarify.
Response: Precision for particulate matter will not be determined experimentally during the
demonstration. The reference to particulate matter in the first sentence on page 4 of Section 3
11
• •
should be deleted. Note that footnote "f" to Table 3-1 (relating to particulate matter) says,
("Precision and accuracy are based on EPA collaborative test." The following sentences will
be inserted on page 4 of Section 3 of the QAPP. ·
Precision and accuracy for measuremerits of particulate loading and moisture in gas
streams are not readily measured experimentally in a demonstration test. Adherence
to method protocols, which include performance-related activities such as sampling
equipment calibration, isokinetic sampling, balance calibration, desiccating filters to a
constant weight, etc. is the basis for achieving acceptable method accuracy and
precision.
2h. Footnote "d" to Table 3-1 indicates that the laboratory for gaseous PCDD/PCDF.sample
analyses has not been detennined. This is probably an oversight. Section 2 identifies
three subcontract laboratories; which one will do these analyses?
Response: Gaseous sample analyses for PCDDs/PCDFs will be performed by IT
Corporation. The text of the QAPP will be changed accordingly.
3. Project organization.
3a. According to Figure 2-1, the QA manager is "to be assigned." This person should be
identified in the revised. document to be sure that this .function is covered.
Response: The IT QA.-Coordinator is Mary Tyler. The text of the QAPP will be revised
accordingly.
3b. There is· some ambiguity regarding which laboratories will perform which analysis. Will
Radian ·perfonn all analyses on all gas samples, including .. dioxins and furans? Will all
· dioxin,and.furan determinations be performed by IT?,,Clarification is needed to assure
that samples are sent to the correct laboratory.
Response: All gas sample analysis will be performed by Radian, except those to be analyzed
for PCDDs and PCDFs. IT Corporation will perform PCDD/PCDF analysis on all gas, soil,
water, and oil samples. Versar will perform all listed analysis for soil, water, and oil, except
for samples listed for PCDD/PCDF analysis. Table 3-1 of the QAPP will be revised to
indicate the appropriate lab for each listed analysis.
3c. Figure 2-1 suggests that the QA managers actually report to the project man°agers and
thus lack essential managerial independence. Please clarify.
Response: Figure 2-1 of the QAPP will be modified to indicate managerial independence of
the QA managers.
3d. Who is responsible for the physical measurements such as particle size distribution and
bulk density? Who is responsible for field measurements such as PCP?
Response: Versar is responsible for all physical measurements on soil samples including
particle size distribution and bulk density. As stated in the 3b response, Table 3-1 of the
12
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QAPP will be revised to indicate the appropriate lab for each listed analysis. PRC is
responsible for all field measurements, such as PCP in soil and water. Radian will measure
air flows and ETG will perform all p~ocess measurement. ·
4. Please describe the sample numbering system that will be employed during this project.
Entering this information in the QAPP helps the sampling team to properly id~ntify
samples.
Response: Samples will be labeled according to sample location numbers (SL#), test run
number (TR#), and composite number (C#). For" example, the third composite sample
collected during the fifth test run of the L TTR/MTTR at san1ple location 3 will be labeled
SL3-TR5-C3. The text of the QAPP will be revised to indicate the san1ple numbering system.
5. Table 4-4 should be modified to provide for addition of sulfuric acid to pH < 2 as a
preservative for water samples collected for oil and grease.
Response: Table 4-4 of the QAPP will be revised to indicate the addition of sulfuric acid to
pH < 2 for preservation of water san1ples collected for oil and grease analysis.
6. According to Figure 4-1, the BCD process employs activated carbon beds for cleaning
water and gas before discharge. How will the lifetime of this units be estimated for the
· purpose of calculating operating .costs? How• will;disposal costs for the these systems be
estimated, considering that.they may·be badly:contaminated?
Response: Capacity and cost for granular activated carbon (GAC) units are readily available
· from manufacturers literature. •By .measuring inputs to both water and air GAC during the
demonstration, ·an estimation.of operating and disposal costs will be determined.
7. There are a number of•issues-related to the analytical methods listed in Tables 5-1, 5-2,
and 5-3.
7a. First, Table 5-1 should distinguish between aqueous samples and oil samples. The term
liquid includes both oil and water although different preparation procedures are typically
required. Modified Method 3020 is listed for the preparation of liquid samples for
arsenic, lead, and selenium analyses. Methods 7060 and 7740 have preparation
procedures for aqueous samples contained in them. V.'hy is a modified method being
proposed? Method 3020 is acceptable for preparing aqueous samples for lead analysis.
Why is a modified method being proposed? What preparation method will be used for
oil samples?
Response: Table 5-1 will be changed to indicate three types of matiices: (1) water; (2) solid,
sludge, and oil; and (3) gas. Oil samples are treated differently than water samples, and the
preparation techniques employed for oil samples are usually by solvent dilution for organics,
and by solvent digestion for metals. Oils typically do not have the same density as water (LO
gram per milliliter). For example, a degreasing oil may contain greater than 1,000,000
milligrams per liter of tetracholorethylene. To obtain more realistic and accurate data, oil
samples will be reported on· a weight-to-weight basis.
13
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Table 5-1 will be changed to indicate that water sample preparation methods for arsenic will
be EPA SW-846 Manual Method 7060, and for selenium will be EPA SW-846 Manual
Method 7740. The aqueous sample preparation method used for the analysis of lead will be
EPA SW-846 Manual Method 3020.
Oil samples will be prepared by EPA SW-846 Manual Method 3040 for metals analysis.
7b. Method 3520 is listed in Table 5-2 for preparing solid samples for SVOC analysis. Was
Method 3550 intended?
Response: The preparation methods used for soil and sludge sample preparation will include
both EPA SW-846 Manual Methods 3540 and 3550. The analytical laboratory performing
sample analysis will be given the option of choosing the preparation method, and will be
responsible for verifying the methods applicability to sample matrices encountered during this
demonstration.
7c. Modified Method 3050 is listed for arsenic, lead, and seleniwn. Footnote "d" indicates
that the modification involves the addition of hydrogen peroxide. Method 3050 already
includes the use of peroxide. Please explain. ·
Response: Table 5-2 will be changed to read Method 3050 and footnote "d" will be removed.
7d. Methods 413.2 and 9252 arc listed for preparing solid •san1ples in Table 5-2 for oil and
. grease and chloride analyses. These methods are for water•samples. Please supply
. appropriate methods for ·preparing solid san1ples.
Response: The method used for the analysis of oil and grease in soil, sludge, and oil samples
will follow the same procedures that are listed in·EPA SW-846 Manual Method 9071. This
. method is·applicable to sludge samples,'and-Versar has indicated that,they follow the sample
preparation and analysis procedures for soils, sludge, and oil. Table 5-2 will be changed to
show that Method 9071 will be followed for soil, sludge, and oil analysis of oil and grease.
The method used for the analysis of chloride in soil, sludge, and oil will involve the
separation and transfer of chloride ions from the soil, sludge, and oil into water. Once the
chloride ions have been exchanged to water the remainder of the analysis steps are identical to
those listed in EPA SW-846 Manual Method 9252. PRC and Versar have not been able to
identify a specific EPA-approved method performing soil, sludge, and oil sample analysis for
chloride. The method which Versar will use will be referred to as Modified Method 9252.
The standard operating procedure for Modified Method 9252 will be provided to EPA by
Versar. Table 5-2 will be changed to indicate that Modified Method 9252 will be used for
, preparation and analysis of chloride samples.
8. According to Table 1-9 (schedule) only one week is allowed for shakedown and process
optimization. Will this be enough time for optimization, including completion and
interpretation of analytical results?
14
• •
Response: The schedule of activities to be presented in the revised QAPP is as follows:
Week 6f August 9
Week of August 16
Week of August 23
Week of August 30
Week of September 6
Equipment mobilization and soil
delineation, excavation, and
preparation
Dry run of BCD process equipment
Three test runs using the
LTTR/MTTR, one test run using the
LTR, and the visitors day (tentative)
Three test runs using the
L TTR/MTTR, and one test run using
the LTR
Equipment demobilization
9. Data reduction and reporting. Who will store raw data and samples, and for how long?
Providing a checklist of forms that will be required in the analytical report for each
analysis will expedite the report preparation procedure. Will the investigators require
data-.on magnetic media?
, Response: Samples·will·be stored by the.respective analytical labs for at least 4 weeks after
the submittalof data analysis reports .. -The data analysis reports will be·stored for no less than
I year.
15
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3.0 CHANGES RECOMMENDED BY SITE TEA.i\1 MEMBERS
The SITE team QA managers identified changes to the QAPP that are listed below.
3.1 CHANGES RECOMMENDED BY RADIAN CORPORATION
la. After the first sentence in the second paragraph of Section 3.1, insert:
For gas samples, duplicate media spiked samples (spiked blank sorbent resins), rather than
matrix spiked samples, will be used for semivolatile and volatile organics. Matrix spikes of
impinger solution aliquots will be used for metals and HCI in gas samples.
I b. To the end of the last paragraph on page I of Section 3. I, add:
Precision for PCDD/PCDF analysis in gas samples will be estimated as the relative standard
deviation for recoveries of the pre-sampling surrogate spike in the replicate test runs.
le. Change the first sentence of the last paragraph on page _4 of Section 3.1 to read:
Accuracy for SVOCs, VOCs, metals, chloride, HCl/chlorine, and TOC will be estimated as
percent recovery of the true analyte from matrix spike samples (media spike samples for
SVOC and VOCs in gas.samples.) [Note: the change is shown in parenthesis.]
Id. To the second paragraph on page five of Section 3.1, add:
Accuracy for PCDD/PCOF in gas--samples will be estimated from pre-sampling surrogate
spike recoveries.
2. Change precision objective for metals in gas samples listed in Table 3-1 to 20 RPO and
recovery objective of 75-125%. Also, change precision for HCl/chlorine in gas samples to 20
RPO.
3. Change the precision objective for metals trains in Table 3-6 to 20 RPO.
4. Insert the following to replace Section 4.4.5.
The LTTR/MTTR and LTR will be run separately; thus, the resulting stack gas from each of
these two processes will be sampled separately. The reactor off-gases will be sampled at he
carbon bed siack for PCODs/PCDFS, particulates, moisture, SVOCs, VOCS, and HCI/Cl2•
These samples will be collected through ports installed in the carbon bed exit line. The exit
line from the carbon bed will be modified to accept 4-inch PVC tubing. The tubing will then
be routed to facilitate sampling. Ports will be installed at appropriate distances to comply
with the 8 and 2 diameter rule of EPA Method l. Gas velocity and temperature will be
measured with a standard pitot and thermocouple ·as specified in EPA Method IA. The gas
samples will be collected by either standard U.S. EPA stack sampling methods as published in
40 CFR Part 60 (Standards for Performance for New Stationary Sources, Appendix A,
16
• •
Reference Methods) or methods outlined in the, Methods Ma.nual for Compliance with the BIF
Regulations. The sampling trains to be used during the tesrare briefly described below.
Samples for SVOCs will be collected by a modified Method 5 (MM5) sampling train, Method
0010 in SW-846. Samples for PCDDs/PCDFs will be collected by M23. The MM5 and
M23 train are shown schematically in Figure _. The sampling approach and requirements
for both MM5 and M23 are identical. Differences exist in the preparation and recovery of
the trains. Method 23 has more stringent requirements for preparing the filter and XAD resin
than does Method 0010.
• A heated, three-foot borosilicate glass-lined sampling probe will be insened
into the duct to withdraw the sample. The probe will be equipped with a
stainless steel (316) nozzle, sized to withdraw the sample isokinetically.
• Gas will pass from the probe to a borosilicate filter holder contai.ning a 90
mm Reeves-Angel 934 A-H glass fiber filter (or equivalent). The filter
assembly will be enclosed in a heated chamber capable of maintaining a
temperature of 120 °C.
• The filter will be followed by an impinger train consisting of a spiral-type, ice
water-cooled condenser; an ice water-jacked sorbent module containing
. approximately 20. grams of 30/60 mesh XAD-2 resin (pre-extracted); a
temperature sensor; a I-liter con'densate trap; two standard Greenburg-Smith
• , impingers; 'each containing approximately 100 mis of deionized water and a
final modified Greenburg-Smith impinger containing silica gel plus a
·thermocouple to detect sample gas exit temperatures. The impinger train is
contained within an ice bath.
• A vacuum line will connect·the outlet of the impinger train to a control
module.consisting of a vacuum pump, a calibrated dry gas meter, a calibrated
orifice and an inclined manometer.
For each test run, the following material will be recovered from the MM5 and the M23
sampling trains as described in Method 0010 and M23; rinsate from the sample probe and the
front half of the filter holder, the filter, the XAD-2 resin sorbent module, liquids collected in
the I-liter condensate trap, and rinsate from components between the back half of the filter
holder and the condensate trap. M23 also includes a final toluene rinse. The recovered
material will be extracted and analyzed for SVOCs, or dioxins and furans. Each sampling
train will generate several samples, however, the extracts of each sample will be combined to
produce one final sample per train.
The BIF Method 0050 sampling train will be used to measure particulate HCI/CI, and
moisture content of the gas stream. The BIF Method 0050 train is shown schematically on
Figure_. This sampling· is similar to the MM5/M23 train described above, with the
following exceptions:
• , The water cooled condenser and sorbent module are removed.
17
• •
• The impinger train will consist of five impingers. The first is empty. The
second and third will contain 100 ml of 0.1 N sulfuric acid. The fourth
impinger will contain 100 ml of 0.1 N sodium hydroxide. The last impinger
will contain silica gel as a final ,water trap.
Volatile organic compounds will be collected using passivated Summa canisters for analysis
by GC-MS following the general guidelines of U.S. EPA Compendium Method TO-14.
5. Insert the following changes in Table 4-4.
Dioxins .and Furans, Gas Sample Volume -3 dscm not 10 dscm
HC1/Cl2, Gas Sample Volume -I dscm, not 30 dscm
Semivolatile Organics, Gas Sample Volume -3 dscm, not 10 dscm
Metals, Gas Sample Volume -3 dscm, not 30 dscm
Moisture, Gas Sample Volume -1 dscm, not 20 dscm
Particulate, Gas Sample Volume - 1 dscm, not 3,0 dscm
6a. Modify the first sentence of paragraph one in Section 4. 7.3 as follows:
Incline manometers or magnehelic gauges will be used during this project to measure
differential and static pressures.
6b. Delete the·second sentence ·of the paragraph.
7. In to Section 4.7.6:
• Delete "(NBS Class S·traceable)".
• Last sentence ohection, change "+. 0.1 gram" to± 0.5 gram.
8. Insert the following changes to Table 5-3:
• For PCDDs/PCDFs, change "8280" to "8290".
• For Volatile Organics, change Analysis Method from "5040" to "8240".
• For Metals Analyses, Preparation Methods are as follows:
Arsenic
Barium
Cadmium
Chromium.
Copper
Lead
Mercury
Nickel
Selenium
Silver
SW-846 3020
SW-846 3005
SW-846 3005
SW-846 3005
SW-846 3005
SW-846 7421
SW-846 7470
SW-846 3005
SW-846 3020
SW-846 3005
18
•
Sodium
Zinc
SW-846 3005
SW-846-3005
•
• Preparation and analysis for Chloride (HCI/CI,) in stack gas should be given as BIF
0050.
3.2 CHANGES RECOl'vIMENDED BY VERSAR, INC.
I. Samples for the following parameters may be collected together in the same sample container.
The volume listed is the total amount required for all the parameters. Table 4-4 will be
modified to reflect the combined samples.
• Solids:
•
•
Total metals + TCLP metals
Chloride + moisture + Oil & Grease + pH
PSD + density
Liquids:
Chloride + TSS + pH
Oils:
If oily or sludge-like, treat as solid:
Chloride + Oil & Grease + Moisture <:::ontent. + pH
;If low-viscosity-liquid,-:especially if.aqueous,,treat as a ·liquid sample:
Chloride + pH
Oil. & Grease separate
2. The following sample volume requirements shoul_d be added to Table 4-4.
19
500 ml
1000 ml
1000 ml
500 ml
1000 ml
500 ml
1000 ml
Minimum Sample
Volume
Parameter Media
TCLP (Metals) Solid 500 g
for total & TCLP
metals, collected
together
TCLP (VOCs) 500 g
TCLP (SVOCs) 500 g
Container
Wide Mouth G
Teflon-lined cap
. Teflon-lined cap
•
Maximum
Preservative Holding Time
Cool _:::;_ 4 °C Analyze mercury in
28 days; for other
metals: 6 mos. to
TCLP extraction, 6
mo. to analysis
For VOCs: 14 days
to TCLP extraction;
14 days to analysis
For SVOCs: 7 days
to TCLP extraction;
7 days to
preparation
extraction; 40 days
to analysis
3. The analytical-method for bulk density listed in Table 5-4 will be changed to ASTM 2974.
3.3 CHANGES RECOMMENDED BY INTERNATIONAL TECHNOLOGY
CORPORATION
I. In Table 7-2, the SAL uses "C-1,2,3,6,7,8-HxCDD as an internal standard instead of "C-
1,2,3,4,7,8-HxCDD as ·stated in Table 7-2. Also, "C-OCDF is not used as an internal
standard.
2. The retention time window check solution is analyzed at the beginning and end of each 12
hour shift (Table 5-14).
3. Under acceptance criteria in Table 5-4 for the calibration standard, the term "for native
compounds" will be added.
4. In Table 3-2, the target detection limits for gas samples will be changed to the following:
Compound
2,3,7,8-TCDD
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
OCDD .
Detection Limit (ng/dscm)
0.003
0.003
0.016
0.016
0.016
0.030
20
2.3.7,8-TCDF
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
OCDF
•
0.003
0.003
0.016
0.016
0.016
0.030
•
5. Method SW-846 8290 will be added to Table 5-4. The following changes are listed on the
following page.
21
SUMMARY OF CALIBRATION AND INTER.t"IAL QUALITY REQUIREMENTS
Parameter Analytical Calibration Frequency Acceptance Criteria Corrective Action
Method
PCCDS and PCDFs SW-846-8290 Initial calibration Before sample Relative standard I) Repeat initial calibration
multipoint, 5 levels analysis begins and deviation (RSD) Native 2) If still unacceptable, make
when calibration compounds -20 % necessary adjustments
check standard Labeled cornpounds-30 % 3) Repeat initial calibration • TCDD Beginning of 12 25 % valley between Adjust GC conditions or
chromatography hour shift 2,3,7,8-TCDD anJ replace column
check closest eluting TCDD
isomer
PCDD/PCDF Beginning of 12 MID switch points Rerun retention time
hour shift properly located standard, adjust selected ion
monitoring windows
Calibration check Beginning and end Agreement with 20 % of I) Rerun calibration check
of 12 hour shift predicted value from 2) Repeat initial cahbration
initial calibration for
native compounds, 30%
of predicted value from
initial calibration for
labeled compounds • Method blank 5 % of 1 per batch <I = PQL 1) Reanalysis if blank if
problem still exists flag data
associated with blank
Surrogate spike Every sample 40-135% I) Evaluate system
recovery 2) Flag data
22
•
ATTACHMENT A
REVISED SAMPLE LOCATION MAP
CONT AJJIHA TU>
SOIL
Q)
SCRfD'[D
CONT>.lllHAT'ED
SOil
•
500.
STOO<PIL.£
v""°" ~
V ,'-,/,
LOW TD,,IPE?.,.T\JRE
TlfER\.VJ. O(SM.PllOH
LEGEND
f!ID[R
/' / .....
I 'v►' ',,..,,
0CO S0U0S RU,CTOR
M'EOIVM ITMP. Tl-4ERl,l,,l,L
OCSOR1'TlON
,,.., C:\ \,.) ,.,
'#ATER SPAAl'
COOUNG SCREW
"'""°"" 0
OECOHTAJJlliAlm SO(l. '
COHT,iJNER OR
STOCKPIL.£
@-Sample Location Number
•
0
TO
AT\IOSPHER(
CAAOON
POUSHO!
DCCHLORIN,,1,.TIOH
R(ACD/T"S
/
BCD
LIOUIO
RCACTO<I
,---'-----I, .10, ,l---'-,
CAABON
UNIT TR£ATED
WATIJ!
TO
OISCHAAC(
SU~ENT '-----~
JJ•lO DI.SPQS.A.L
KOPPEQS COMPANY, INC.
MORRISVILLE, NORTH CAROLINA
FIGURE 4-1
BCD PROCESS FLOW DIAGRAM
SAMPLE LOCATIONS
Pile ENVIRONMENTAL MANAGEMENT, INC.
• •
ATTACHMENT B
> STAi'IDARD OPERATING PROCEDURE FOR THE
-·.·.GAS. ;CHROMATOGRAPYtMASS .. SPECTROI\IETRY ANALYSIS
•' OF AIRTOXICS,C:-\J"IISTERSAMPLES USING
'METHOD T0-14
• •
The following ia excerpted from Radian SOP 327-MS-038 which i1 a R&dian Corporation Confidential Reaearch and
Engineering Document.
STANDARD OPERATING PROCEDURE FOR THE GAS CHROMATOGRAPHY/MASS
SPECTROMETRY ANALYSIS OF AIR TOXICS CANISTER SAMPLES
USING METHOD TO-14
1.0 PURPOSE
This standard operating procedure provides a method for the analysis of canister air samples by gas
chromatography, using the.method and analyte list from EPA Compendium Method TO-14 with a
Finnigan 4500 GC/MS/DS in either multiple ion detection (MID) mode or the full scan mode in
conjunction with the sample interface system built by Radian Corporation. This analytical method
can be used to quantify many volatile organic compounds with boiling points less than 200'C.
Analytical properties of polar compounds in canisters are not well defined currently. The GC/MS
analysis of gas samples from·canisters.in restricted t~ use by, or under the supervision of, analysts
experienced in the use of GC/MS systems, and•skilled.in the interpretation of mass spectra and their
use as quantitative tools.
2.0 SCOPE AND APPLICABILITY
This method may be applied to the analysis of air toxics samples which are introduced to the GC/MS
using the Radian sample interface system with the method and analyte list from EPA Compendium
Meihod TO-14. The method is applicable to ambient air, indoor air, to landfill gas, and to any air
samples with volatile organic analytes present below hundreds of ppbv. The method is not applicable
directly to samples from combustion processes. A modification of the method to allow direct gaseous
injection may be performed to analyze air samples which contain high levels of organic compounds.
3.0 METHOD SUMMARY
Field samples are received at the Radian laboratory in canisters. These samples are logged into the
Radian Sample and Analysis Management (SAM) system and scheduled for analysis in the GC/MS
laboratory. An analytical mode, either full scan for maximum nexibility or MID for maximum
sensitivity, is selected and appropriate gaseous calibration standards are prepared. The instrument
is tuned and the range of calibration standards is analyzed. A calibration curve is obtained by linear
• •
regression, with a goal of a correlation coefficient of 0.995 for each analyte. After the calibration
samples have been analyzed, a zero air sample containing pre-purified humidified air is analyzed.
Then, the samples are analyzed. Quantities of the analytes in the sample are calculated from the
linear regression and reported through the SAM system. If qualitative/semi-quantitative analysis of
non-target analytes is desired, enhanced mass spectra obtained in the full scan mode are searched
against the 42,222-compound NIH/EPA reference library, and the data are interpreted by an
experienced mass spectroscopist. Semi-quantitative calculations are performed by comparison of the
signal level for a tentatively identified compound (TIC) to a compound in the sample with a
concentration which is accurately known_.
4.0 INTERFERENCES
This analytical method is based on the identification of mass spectra using the appearance of the
spectra, comparison to reference spectra, and (for the target analytes) comparison to accurately
known retention time. Any elements of the gas matrix which might interfere with the ability to
,identify the mass spectra, obtain accurate-peak areas,·or obtain.an accurate retention time which can
be compared to a reference standard will affect the performance of the analysis. If intense
.,interfering peaks.are encountered, the chromatography will be distorted. The only possible solution
to the problem of.excessive compou·nd ·loading is dilution of the sample or analysis of a smaller
volume. If a coeluting compound is encountered, the mass spectrum generally can be interpreted
unless the coeluting compound is an.isomer of. the compound of interest and the masses·are the same
or approximately the same. In this case, within the limits of the present method, the problem cannot
be resolved. The analysis of blanks will demonstrate that the analytical system is free from
interferences and a field blank can serve as a check on the occurrence on contamination in the
sampling and handling procedures. The laboratory where volatile analysis occurs is completely free
of solvents.
5.0 MATERIALS AND APPARATUS
5.1 Calibration Standards: supplied in a canister ready for use on the
analytical system. Calibration standards are prepared in the Radian
Volatile Organic Compound (VOC) laboratory. Standard canister
numbers, analyte concentrations, source of supply, name of preparer,
date prepared, and date received are supplied to the GC/MS laboratory
with the standards.
2
•
5.2
5.3
5.4
5.4. l
5.4.2
5.4.3
5.4.4
5.4.5
•
Radian Sample Interface System: designed and built by Radian to
interface between ttie sample contained in the canister and the
analytical system.
Bubble Flow Meter
Gas Chromatograph/Mass Spectrometer System
Gas Chromatograph: an analytical system complete with
temperature-programmable gas chromatograph with sub-
ambient capabilities and all required accessories, including
gases, analytical columns, and separator.
Chromatographic Column: DB-624 megabore fused silica
capillary or equivalent, 30 m in length .
.. Mass Spectrometer. capable of scanning from .J 5-350 amu
every l sec or less, using 70 volts (nominal) electron energy in
,the ·electron io~ization mode and producing a mass spectrum
that meets all criteria for the manufacturer's specifications for
-perfluorotributylamine (PITBA) tuning.
Glass Jet Separator. to accept a flow rate of approximately 15
mL/min from the mega bore column and 15 mL/min of makeup
gas while allowing the mass spectrometer to operate at a
vacuum of 10 .. torr or better.
Data System: to allow for the continuous acquisition and
storage on machine-readable media of mass spectra or MID
data obtained throughout the duration of the chromatographic
program, interfaced to the MS. The computer must have
software that allows searching any GC/MS data file for ions
of a specified mass and performing quantitative calculations
against the linear regression generated by the calibration of
the instrument. The software must allow integration of the ion
abundances at a specified mass between a selected time or scan
number limits.· The data system also must include the most
3
6.0
• •
recent version of the EPA/NIH mass spectral reference library
for identification of mass spectra.
CHEMICALS AND REAGENTS
Analytical standards are prepared in the VOC laboratory in canisters at the approximate dilution, so
no chemicals outside the canisters are handled in the MS laboratory.
7.0 SAFETY
Standard safety procedures for the mass spectrometry laboratory require that safety glasses with side
shields be worn at all times. The use of equipment, the canisters, and the interface requires attention
to electrical hazards, as well as sharp, hot surfaces. No analyst is allowed to operate the
instrumentation without appropriate training and an SOP for the use of the Radian interface is
available (Radian SOP 262-A T-00 I).
4
8.0
•
PROCEDURE
8.1 Preparation of the Gas Chromatograph
8.2
8.1.l Install the chromatographic column: DB-624 megabore (0.53
mm) fused silica capillary column or equivalent, 30 min length.
8.1.2
8.1.3
8.1.4
8.1.5
8.1.6
Set the column-helium carrier gas flow to 15 mL/min.
Set the flow of the helium make-up gas into the glass jet
separator at 15 mL/min.
Set the temperature of the separator oven to 220°C.
Set the temperature of the injector port to 105°C.
Set·the program of the GC to hold at l0°C for five min, then
program to 200'.C at 6°C/min, .and hold at 200°C until peak
.elution ceases.
, Preparation of the lnte'rface
, Connect the interface exit fitting directly into the carrier gas inlet to
the chromatographic column after verifying helium flow through the
interface with a bubble flow meter.
5
• •
8.3 Preparation of the Mll5S Spectrometer
8.3.1 . Full Scan Mode -If the full scan mode is selected for analysis,
the optimum sensitivity which can be obtained with MID is
sacrificed but the full potential of the MS as a universal
detector is realized.
8.3.1.1 Zero the MS according to Radian SOP 327-MS-038.
8.3.1.2 Tune the MS according to Radian SOP 327-MS-038.
8.3.1.3 Set scan parameters according to Radian SOP 327-MS-038.
8.3.1.4 Cool the MS according to Radian SOP 327-MS-038.
8.3.1.5 Introduce the sample to the MS according to Radian SOP 327-
MS-038.
8.3.1.6 . · Initiate scan cycle and GC program according to Radian
SOP 327-MS-038.
8.3.2 Multiple Ion Detection (MID) Mode
In the Multiple Ion Detection (MID) mode, the mass
spectrometer is restricted to monitor only previously selected
masses rather than scanning a mass range. Sensitivity is
enhanced over the full scan mode, since no time is spent.
monitoring masses which are not specifically of interest.
However, only information specifically requested is obtained
when the mass spectrometer_ is operated in the MID mode, so
use of the MS as a universal detector is sacrificed for the
additional sensitivity.
8.3.2.1 to 8.3.2.8. of Radian SOP 327-MS-038 detail the set up
procedures for MID mode and should be followed as detailed
there.
6
8.4
• •
Initial Calibration
8.4.1 An initial calibration curve, either three-or five~point, must be
prepared from canister standards provided by the VOC laboratory.
The analyte list currently used in the T0-14 analysis currently includes
the following compounds:
1,3-butadiene
chloromethane
bromomethane
methylene chloride
I, 1-dichloroethane
bromochloromethane
I, I, I-trichloroethane
1,2-dichloroethane
trichloroethene
bromodichloromethane
toluene·
.cis-1,3=.d ichloropropene
.tetrach lo roethene
chlorobenzene
m-xylene
a-xylene
I, 1,2,2-tetrachloroethane
p-dichlorobenzene
I, 1-dichloroethene
cis-1,2-dichloroethene
7
vinyl chloride
propylene.
chloroethane
trans-1,2-dichloroethene
chloroprene
chloroform
carbon tetrachloride
benzene
1,2-dichloropropane
lrans-1,3-dichloropropene
· n°octane
I, 1,2-trichloroethane
.dibromochloromethane
ethyl benzene
p-xylene
bromoform
m-dichlorobenzene
o-dichlorobenzene
1,2-dibromomethane
Halocarbon 11
Halocarbon 113
Halocarbon 12
acrylonitrile
ethyl toluene
1,2,4-trimethylbenzene
hexachloro-1,3-butadiene
Halocarbon I I 4
acetonitrile
chloromethylbenzene
1,2,4-trichlorobenzene
1,3,5-trimethyl benzene
•
8.4.2
8.4.3
8.5 Daily Analysis
•
The data for the calibration samples are
entered into a response factor database, and a
linear regression is performed upon the
calibration data points.
A correlation coefficient of at least 0.995 is the
goal for every compound in the database. If
the correlation coefficient for a given
compound is below this value, additional
samples may be analyzed until the desired
correlation co"efficient is obtained.
The following steps shall be taken in accordance with Radian SOP 327-MS-038 where the
appropriate section of the SOP is indicated in parentheses: daily calibration check (8.5. 1 ), linear
regression (8.5.2), ·calculate percent recoveries (8.5.3), analyze zero air (8.5.4), quantify analytical
sample (8.5.5); optional sample dilution (8.5.6), analyte identification verification (8.5.7). A flow
chart for these steps is given in the cited SOP as Figure 2.
9.0 DAT A HANDLING AND CALCULATIONS
9.1 Preparation of the Project Data File·
All data associated with instrument tuning, calibration, and analyses are compiled into a project
file. The project file included the following information:
l) Canister Information: The chain of custody sheets for the canister and any
other notes or comments relating to the canisters becomes a part of the MS
lab data file.
2) Program Instructions: A copy of the project instructions or QAPjP which
will include any non-routine aspects of the analysis such as analytes which
are not on the method target list and/or use of qualitative or semi-
quantitative analysis for non-t_arget analytes will be a portion of the program
instructions. The program instructions also will describe special analytical
procedures and deliverables.
8
3)
• •
Library and Standards Information: For every analytical procedure, the
GC/MS analyst must create a library. A check of the library against the
target list for the assay will verify that all targets are included in the
automated procedures. Analytical standards are supplied in canisters
prepared by the VOC laboratory. A data sheet is supplied with. each canister
that lists the compounds which are components of the standard, the original
concentrations of all these compounds, and the concentrations of all the
components in the diluted sample, calculated both in the units of ppbv and
ug/m'.
4) Tuning Data: The instrument·is required to demonstrate that tuning criteria
have been met prior to the initiation of any analysis. The tuning data for the
MS include a mass spectrum of PFTBA, the tuning standard, or any other
compound specified as a tuning standard, and a list of the tabulated masses
of this compound.
5) Calibration Data: For each of the analyses. of the three-or· five-point
calibration, a chromatogram and the output of.the data system listing area of
peaks for each of the target analytes are included. The inclusion of the raw
data for the calibration will allow a reviewer or another analyst to reconstruct
the linear regression. An additional component of the calibration data is a
table of the·correlation coefficients .obtained for each of the analytes.
6) Zero Data: For each of the purified, humidified air samples analy.zed, a
chromatogram and the output of the data system are included in the project
file. If any analytes are identified in these zero air samples, a mass spectrum
and a calculated quanti_ty are supplied.
7) Sample Data: For each of the canister samples, an enhanced mass spectrum
is included in the data folder for each analyte identified. A chromatogram
for each sample is also included, and the hardcopy from the data system
which includes quantitation peaks for the analytes identified, a peak area for
the major ion, and a retention time.
8) Calculation Sheet: Quantitative calculations for the target analytes identified
are performed by the computer using the linear regression generated in' the
analysis of the calibration samples. If any additional calculations are
necessary (e.g., unit conversion), a calculation sheet is included to
9
..
9.2
• •
demonstrate how the calculations are performed and the results written
directly onto the computer data sheets.
Preparation of the Project Archive
All data are· archived on streamer tapes in the laboratory for at least five years. The tape numbers
are recorded in the analysis logbook so that the correct streamer tape can be retrieved from the
analysis data and the sample data acquisition file number. The actual files listed on the streamer
tape are recorded in the tape logbook which is maintained for each instrument in the GC/MS
laboratory. An archivial copy of a data package is r·etained for at least five years in the laboratory
data archive.
.. • •
9.3 Analysis Log Book
Each analysis performed on each instrument in the GC/MS laboratory is logged into an analysis
logbook for each instrument which contains the 'following information: file name, date, GC
parameters, GC column, sample identifier, SAM number, method, and analyst. The specifics of the
information to be recorded are listed in Section 10 of Radian SOP 327-MS-038.
10.0 QUALITY CONTROL
I 0.1 Detection Limits
Detection limits for air toxics canister analysis have been experimentally determined using the EPA
method of seven replicates at 99% confidence level. The detection limits, determined according to
Radian SOP 327-MS-027, are listed in Section 11 of Radian SOP 327-MS-038.
Method precision, as.defined by the reproducibility of replicate.measurements has.been determined.
Accuracy as determined by the analysis of. external audit ,samples. has been determined by the
. accumulation of a historical database for ·audit samples .
10.2 . Method Quality Control Checks
The quality control checks listed below are used to assure the production of data of known quality.
10.2.1
10.2.2
10.2.3
Calibration Criteria: A three-or five-point calibration is performed
initially for the method and a linear regression is performed on the
calibration data points. A correlation coefficient of 0.995 or better
must be obtained for each of the target analytes. If the correlation
coefficient is less than 0.995 for the analytes, additional calibration
samples are analyzed until the criterion is met.
Tuning Criteria: The instrument is tuned according to the
manufacturer's criteri~ for perfluorotributylamine, with masses 13 I
and 219 at 30% of mass 69, the base peak. If these criteria are not
met, the instrument is tuned until the criteria are met.
Analysis of Zero Air Samples: No target analytes should be observed
in the zero air samples at levels above the method detection limits. If
11
•
10.2.4
•
target analytes are observed, a new zero air sample is analyzed until
a clean blank is obtained.
Daily Calibration Check: A daily calibration check at the mid-point
of the calibration range is performed prior to the initiation of any
quantitative analysis. The amounts for the calibration check are
generated in the data system by linear regression. Percent recoveries
are calculated for the calibration curve. For the linear regression
obtained from the original calibration data to be valid, the percent
recoveries must be within 30 percent of the initial curve. 1( this
criterion cannot be met, an additional daily calibration check sample
is analyzed. If the criterion still is not met, a new multi-point
calibration is generated.
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••
I 1.0 DOCUMENTATION
The analyst will report the following information .as specified in Section 11 of Radian SOP. 327-
MS-038: canister information, program instructions, library and standards information, sample
dilution, tuning data, calibration data, zero air sample data, sample data, calculation sheets,
reference spectra, appropriate sections of the instrument logbook, and a tabulation of instrument
conditions.
The SAM work order number is used as the data file reference number if the sample is logged into
SAM. All data are recorded on hardcopy from a computer or in black ink. Corrections should be
made by crossing through the original entries with a_single line so the original entry is not obscured,
and initialling the change.
All instrument maintenance is documented in a maintenance log kept next to the instrument. Blank
sample canister numbers are documented in the analysis log and on all chromatograms and
analytical data.
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