Loading...
HomeMy WebLinkAbout700 N Ennis St Technical 1998 Feb - BuildingTECHNIC permit LA 69 (pvoied, cot evmry\rc Address 100 Project descript\i\On t),;syriatAttto at\ s-h-ucAv:res 6Ac, c re' C2 Uc 0 D&te the permit was final technical pages 77o ovi it rev .s01,) it,c Rayonier March 6, 1998 Garin Schneve, P.E. Department of Ecology SW Regional Office PO Box 47775 Olympia, WA 98504 -7706 Re Ambient Air Monitoring Plan Rayomer Mill Site Dismantling Project Enclosed is the final and revised ambient air monitoring plan for the Rayonier Mill Site Dismantling project. This air monitoring plan is a key component of Rayomer's efforts to conduct dismantlirg in a safe and environmentally responsible manner As you know, Rayomer con-miffed to implementing an air monitoring plan at the beginning of the dismantling project last fall. Air momtormg based on that initial plan has been in effect since that time. This revised plan incorporates comments and recommendations made over a three month penod from the citizens of Port Angeles, the Department of Ecology and the U S Environmental Protection Agency and its cooperating agencies. The comments and recommendations were helpful in improving the scope and technical merits of the initial air monitoring plan. We appreciate the assistance from the community and the agencies. Results of air monitoring are )und the perimeter of the work site are being compiled in a report by our consultant, Foster Wheeler Environmental Corp Copies will be sent to you, and one will be placed in the Port Angeles Public Library for public review with the other environmental and cultural documents about the site As additional monitoring ta)Ces place, those results will be forwarded to you and made available to the public through the Port Angeles Public Library Sincerely, Enclosure Paul F Perliwitz Environmental Site Manager Carl Kitz US EPA, Region X 1200 Sixth Avenue (HW -114) Seattle, WA 98101 700 North Ennis Port Angelt, WA 98362 TelkphonL 360) 457 3391 l'a\ (360) 4 2438 Special Pulp Products Port Angeles Mill cc Marc E. Crooks, P.E., Department of Ecology w/o encl. Laurie Davies, Department of Ecology SW Regional Office w/o encl. Joanne LaBaw, US EPA, Region X, w/o encl. Richard Foster, Port Angeles Economic Response Task Force Darlene Schanfald, Olyrhpic Environmental Council Lou Haehnlen, City of Port Angeles Port Angeles Public Lib .ary I RAYONIER, INC. PORT ANGELES SITE 1 AMBIENT F AIR MONITORING PLAN Prepared for RAYONIER, INC Port Angeles, WA Paul Perlwitz, PE, Environmental Manager February -1998 FOSTER WHEELER ENVIRONMENTAL CORPORATION \\BECALVIN\VOL2\WP\ 1834/11934 DOC 3/5/98 AMBIE -1T AIR MONITORING PLAN For the RAYONIER, INC 'ORT ANGELES SITE Prepared for RAYONIER, INC PORT ANGELES, WA Paul Perlyvitz, PE, Environmental Manager Prepared by February 1998 Revision No 1 Revision Date 02/28/98 Page 1 of 42 FOSTER WHEELER ENVIRONMENTAL CORPORATION 1 0 PURPOSE AND OBJECTIVES 4 2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES 5 3 0 SITE INFORMATION 6 3 1 Site Conditions 3.2 Site Activities and Schedule 3.3 Air Emission Contro Methods 4 0 MONITORING PROG RAM DESIGN CONTENTS APPENDIX A DERIVK ION OF RISK BASED ACTION LEVELS \\BECALVIMVOL2\WP \I834 \I I934.DOC .,/5/98 Revision No 1 Revision Date 02/28/98 Page 2 of 42 6 6 8 9 4 1 Air Quality Concerns and Monitoring Approach 9 4.2 Air Quality Action Levels 9 4.3 Onsite Wind Conditions 10 4 4 Sampling Locations 14 4 5 Air Sampling Methods 17 4 6 Quality Assurance Quality Control Sampling 17 4 7 Sampling Schedule 18 5 0 PROGRAM IMPLEMENTATION 20 5 1 Data Assessment anc. Contingency Plans 20 5.2 Data Management 21 5 3 Reporting 22 5 4 Plan Updates /Changes 22 6 0 DATA QUALITY OBJECTIVES 23 7 0 MONITORING PROCEDURES 25 7 1 Total Suspended Particulate Monitoring 25 7.2 Dioxin/Furan Monitoring 26 7 3 Lead Monitoring 27 7 4 Asbestos Monitonng 27 7 5 Other Metals Monitoring 27 7 6 Polycyclic Aromatic Hydrocarbons Monitoring 27 7 7 Polychlorinated Biphenyl Monitoring 28 7 8 Volatile Organic Caibon Monitoring 28 8 0 METEOROLOGICAL MONITORING 29 9 0 REFERENCES 30 Table 1 Potential Air Pollutants, Sources, Transport Mechanisms, and Monitoring Approaches 11 Table 2. Action Levels for Potential Air Pollutants 12 Table 3 Air Sampling and Analysis Methods 19 Table 4 Data Quality Objectives and Analysis Methods 24 TABLES Revision No 1 Revision Date 02/28/98 Page 3 of 42 \\BECALVIMVOL \WP \1834 \I 1934 DOC 3/5/98 FIGURES Figure 1 Mill Site Wind Rose for 1983 through 1989 13 Figure 2. Rayomer Port Angeles Division Mill Vicinity Map 15 1 0 PURPOSE AND OBJECTIVES \\BECALVIN \VOL2 \WP \1834 \I 1934 DOC 3/5/98 Revision No 1 Revision Date 02/28/98 Page 4 of 42 This Ambient Air Monitoring Plan describes the program to be conducted to monitor ambient air quality during dismantling and cleanup activities at the former Rayonier Port Angeles pulp mill site. The, plan describes the basis of design for the momtonng program, general program procedures, air sampling procedures, meteorological monitoring procedures, lat oratory methods, and references. The objectives of the air monitoring plan are to 1) Monitor ambient air quality for potential air pollutants related to onsite activities, 2) Quantify potential offsite transport of project- related emissions, and, 3) Assess the effectiveness of onsite emission control methods used during dismantling and cleanup activities. Rayonier received approval from the City of Port Angeles in July 1997 to dismantle its former pulp mill facility Following this approval, Rayonier voluntarily committed to develop and implement an air monitoring program. Air monitoring commenced in October 1997, and is curre ltly ongoing. The ongoing air monitonng program is consistent with the procedures presented in this plan. Revision No 1 Revision Date 02/28/98 Page 5 of 42 2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES Rayonier is responsible for managing implementation of the ambient air monitoring program. The Environmental Manager provides overall management for implementing the ambient air monitoring program, and coordinates with the dismantling contractor to maintain a current schedule o dismantling work to integrate the ambient air monitoring with dismantling activities. An Environmental Technician coordinates and performs activities associated with the ambient air monitoring program. The mill dismantling contrac:or, ICONCO, is responsible for the facility dismantling work. The dismantling contractor is responsible for implementing and coordinating air emission abatement activities (e g dust control) during dismantling, and also for conducting area and personnel air monitoring during asbestos- and lead containing material dismantling activitis. Quanterra Laboratories provides laboratory services for analysis of air samples. Foster Wheeler Environmental Corporation provides technical support for implementation of the air monitoring program. The Ambient Air Monitoring Plan and the air monitoring data reports are provided to the Washington State Departme of Ecology (Department of Ecology) The US Environmental Protection Agency (EPA) also conducts various air monitoring activities as part of their oversight role for the dismantling work. Rayonier provides frequent opportunity for EPA and the Department of Ecology to observe and monitor onsite air sampling activities \\BECALV(N\VOL2 \WP \1834 \I 1934.DOC 3/5/98 3 0 SITE INFORMATION 3.1 Site Conditions The site is a former pulp mill facility located at 700 North Ennis Street, Port Angeles, WA. The facility was onginally constructed in 1929 and remained in operation until 1997 The site area is approximately 70 acres, and is bordered to the north by the Straight of Juan De Fuca, and to the south by a high bluff leading up to commercial and residential areas. Olympic Memonal Hospital is located on top of the bluff to the southwest of the site To the east of the site, also located on the bluff is a residential area known as the Gale s Addition. The pulp manufacturing buildings and processing units are located directly along the waterfront, and are surrounded by empty former storage areas, parking lots, roadways, and undeveloped wooded areas. The area of the site containing the actual wood chipping, processing, and pulp finishing facilities is approximately 11 acres. The mill used an ammonia -based acid sulfite process for the production of dissolving grade pulps. These pulps were used in specialty manufactured goods such as photographic film, yams, ray and acetate fabrics, high impact plastics, food additives, and as a substrate agent in pliarmaceutical products. Essentially all of the wood utilized in the process was western herr lock. Ammonium bisulfite was used in the digesting process to separate the cellulose from the other water soluble, non cellulose wood residuals. The cellulose was mechanically washed and screened before going through a bleaching process to remove the chem cal impurities. The pulp was then dried and converted in shippable rolls and packages. 3.2 Site Activities and Schedule Revision No 1 Revision Date 02/28/98 Page 6 of 42 Dismantling activities are underway and are planned to last through 1999 Dismantling activities include these elements Removal, sale, onsite staging, and offsite transportation of equipment and materials for reuse or recycling; Dismantling, onsite stockpiling, loading, and offsite transportation of buildings, processing units, and structures, Dismantling, onsite stockpiling, loading, and offsite transportation of selected permanent structures such as concrete tanks and stacks, Asbestos- and lead containing material removal, onsite containerization, and offsite transportation, and \\BECALVIN\VOL2 \WP \1834 \I 1934 DOC 3/5/98 Revision No 1 Revision Date 02/28/98 Page 7 of 42 Major dismantling events (e g. recovery boiler stack dismantling, digester dismantling, hog fuel boiler dismantling), including dismantling, onsite stockpiling, loading, and offsite transportation. Fugitive dust and particulate matter generated during dismantling and material handling activities represents the most probable source of air emissions. Major structure dismantling activities pose the highest single -event potential for fugitive emissions. Dismantling activities that may generate potential worker exposure to elevated levels of asbestos- and lead containing air pollutants are conducted in accordance with State of Washington Department of Labor and Industries, Department of Ecology, and Olympic Air Pollution Control Authority requirements. Specialized air emission abatement methods are implemented dunng these events, and worker personnel and work area air monitoring procedures are performed for these events. Lead containing material removal is ongoing and will continue throughout the duration of the dismantling. Site investigation and cleanup activities are planned to start in 1998 and continuing through 1999 Site investigation activities will consist of installing soil borings, backhoe test pits, and groundwater monitoring wells. Selected interim cleanup actions are also planned for implementation, involving activities such as soil excavation, stockpiling, loading, and offsite transportation activities. Schedules for these activities will be established several months prior to conducting the actions. Rayonier and the dismantling contractor maintain and routinely update a schedule of dismantling activities. This schedule identifies the start and duration of major dismantling activities, itemized by building, area, special events (e.g asbestos- and lead containing material dismantling) and major event (e g. recovery boiler stack dismantling, digester dismantling, hog fuel boiler dismantling) This schedule facilitates conducting air monitoring to coincide with general dismantling activities and also special and major dismantling events. The schedule may be modified depending on the sales of equipment for offsite salvage The EPA is currently conducting an.Expanded Site Investigation (ESI) of the Rayonier Port Angeles site, with scheduled completion in 1998 Numerous soil, groundwater, and sediment samples were collected at the facility for site characterization purposes. The EPA is also currently conducting ongoing oversight of the site dismantling activities, including selected sampling and analysis and air monitoring activities. Data from the ESI is expected to be available in mid -1998 \\BECALVIMVOL2 \WP \1834 \I 1934.DOC 3/5/98 3.3 Air Emission Control Methods Revision No 1 Revision Date 02/28/98 Page 8 of 42 Air emission control methods are implemented during all dismantling activities that have the potential to generate air 'pollutants. The dismantling contractor and Rayonier plan the emission control methods prior to commencing with each element of the dismantling. For general dismantling act! vities, air emission control methods include the use of controlled dismantling meth (mechanical shears, low impact takedown, hand dismantling), frequent wetting prior to and dunng building dismantling; controlled material handling methods, naterial covering, housekeeping; and covering of trucks. Air emission control and monitonng procedures will be identified to augment the general monitoring plan prior to conducting major events (e g. recovery boiler stack dismantling, digester dismantling, hog fu l boiler dismantling) The majority of the dismantling activities are conducted usir g controlled dismantling and low impact takedown methods, high impact dismantling methods (wrecking ball) are used infrequently and are conducted only while using water spray down for emission control. Dismantling activities that have the potential to generate asbestos- and lead containing air pollutants are conducted usi f ig specialized air emission abatement and personnel and area air monitoring procedures. hese methods include tenting, containerizing, negative pressure work spaces, work r decontamination procedures, vacuuming, and use of air filtering equipment in additi 3n to the general methods of controlled dismantling and material handling methods, 'Netting, covering, and housekeeping. These activities are conducted under the direction of the dismantling contractor and are not addressed in this ambient air monitoring plan. Air emission control methoc.s will be implemented during investigation and cleanup activities that have the potential to generate air pollutants. These methods include the use of controlled excavation mei hods, wetting, material covering, housekeeping, vacuuming, and use of covered trucks. Air emission control and monitoring procedures will be identified to augment the gel ieral monitoring plan, if necessary, prior to conducting investigation and cleanup activities \\BECALVM\VOL2 \WP \1834 \I 1934 DOC 3/5/98 4.0 MONITORING PROGRAM DESIGN 4.1 Air Quality Conc 3rns and Monitoring Approach Revision No 1 Revision Date 02/28/98 Page 9 of 42 The Rayonier Port Angeles Mill Site Current Situation/Site Conceptual Model Report (Foster Wheeler 1997) identifies potential air pollutants, sources, and transport mechanisms. This information, along with the air monitoring approaches to be implemented, is presented in Table 1 Fugitive dust and particulate matter generated during dismantling and material handling activities represents the most probable source of air emissions. Most of the dismantling activities are multi -week e'ents, and fugitive emissions from these activities will be more or less similar from day to day Dismantling activities occur on weekdays from 7 a.m. to 5 p.m. Major structure dismantling; activities pose the highest single -event potential for fugitive emissions, and thus will be a focus for emission control and monitoring activities. Boiler ash was handled in specific, limited areas of the site (at and near the vicinity of the hog fuel boiler), and these areas and equipment were cleaned and the ash was disposed offsite prior to shutdown of the fac ility Small amounts of residual ash are located inside equipment or in confined meas. The pulp digesters have internal linings that are lead containing material Focus d emission control and monitoring procedures will be implemented during dismantling of these major structures. The asbestos containing material dismantling work poses a limited potential for fugitive emissions due to the extensive abatement procedures used during these activities. These procedures are implemented by the dismantling contractor, and are not addressed in this air monitoring plan. Lead painted structures have a limited potential as emission sources, as the paint adheres to the dismantled structure Fugitive dust from site cleanup excavation actions also is a potential source of air emissions, with surface soil excavations having the highest potential for fugitive emissions. Subsurface excavations would involve moist subsurface soil with a reduced potential for generating dust. 4.2 Air Quality Action Levels Air quality action levels are identified to use as an indicator of the effectiveness of onsite emission control methods used during dismantling and cleanup activities. In the event that single data point conce ltrations exceed the action limit criteria, the contingency plan \\BECALVIN\VOL2 \WP \1834 \I 1934 DOC 3/5/98 Revision No 1 Revision Date 02/28/98 Page 10 of 42 described in this plan will be implemented. The action levels for the potential air pollutants monitored under this plan, and the method used to establish the action level, are presented in Table 2. Supporting calculations for the nsk -based action levels for dioxins /furans are presented in Appendix A of the plan. As a conservative assessment of particulate matter emissions, sampling will be conducted for total suspended particulate (TSP) for comparison to the PM -10 action level. PM -10 is only a portion of the TSP, so a measurement for TSP will always include a greater range of particulate matter than would a PM -10 measurement. The tetra through hepta isomers of dioxin and furan will be expressed as the equivalent 2,3,7,8- tetrachlorodibenzodioxm (TCDD) concentration. The toxicity equivalent (TEQ) 2,3,7,8 -TCDD concentrations will be calculated by multiplying the measured concentration by the reported 2,3,7,8 -TCDD toxicity equivalency factor (TEF) TEFs currently used by the EPA will be used in this calculation (See Appendix A for TEFs). Lead concentrations will be assessed by collection of particulate matter on TSP filters for total lead analysis. Asbestos air emissions will be conducted in accordance with Olympic Air Pollution Control Authority Regulation 1 Section 14 09, which calls for no visible emissions of asbestos dunng dismantling and demolition activities. 4.3 Onsite Wind Conditions A wind rose figure (Figure 1) for a full calendar year based on data from 1983 -1989 obtained from the 3r and Chestnut (Port Angeles) meteorological station was used to develop sampling station locations (ENSR 1992) The wind rose identifies the predominant flow pattern to be from the south and south southeast (from the site towards the Straight of Juan DeFuca) Secondary flow patterns are from the west northwest and northeast (from the site towards inland areas) Thus, airborne pollutants would primarily affect downwind locations to the north and north- northwest, east southeast, and, to a lesser degree, southwest from the emission sources \\BECALVIMVOL2 \WP \1834 \11934.DOC 3/5/98 Table 1 Potential Air Pollutants, Sources, Transport Mechanisms, and Monitoring Approaches Potential Air Source Pollutant Particulate Dust Matter (total Soil suspended particulate) Dioxins /furans Ash Lead (total) Digester h: ung Soil Asbestos Insulation Galbestos Transite Floor tile Other Asbestos Containing Material (ACM) Other Metals Soil \\BECALVIMVOL2 \WP \1834 \I 1934 DOC 3/5/98 Polycyclic Soil Aromatic Hydrocarbons Polychlorinated SubsurfacT soil Biphenyls Electrical transformers Volatile Organic Subsurfac- soil Compounds Transport Mechanism Fugitive emissions Wind erosion Fugitive emissions Ambient air monitoring Wind erosion Fugitive emissions Ambient air monitoring Fugitive emissions Ambient air visual inspection Fugitive emissions (during excavation only) Fugitive emissions (during excavation only) Fugitive emissions (during excavation only) Fugitive emissions Volatilization (during excavation only) Revision No 1 Revision Date 02/28/98 Page 11 of 42 Air Monitoring Approach Ambient air monitoring To be determined prior to excavation actions To be determined prior to excavation actions To be determined prior to excavation actions To be determined prior to excavation actions Table 2. Action Potential Air Pollutant Total Suspended Particulate Dioxins /furans (2,3 ,7,8-TCDD TEQ) Lead (total) Asbestos Other Metals Polycyclic Aromatic Hydrocarbons Polychlorinated Biphenyls Volatile Organic Compounds \\BECALVIMVOL2 \WP \1834 \I 1934.DOC 3/5/98 Levels for Potential Air Pollutants Action Level 150 µg /m (24 hour average concentration) 17 6 pg/m (24 hour average concentration) 1 5 µg /m (anthmetic mean averaged quarterly) No visible emissions To be determined prior to excavation actions To be determined prior to excavation actions To be determined prior to excavation actions To be determined prior to excavation actions Revision No 1 Revision Date 02/28/98 Page 12 of 42 Method for Developing Action Level State of Washington Administrative Code 173 -470 Risk -based calculation (see Appendix A) US EPA 40 CFR Part 50 Olympic Air Pollution Control Authority Regulation 1, Section 14 09 1 r t 1 I Is' 40 7.5 2 1 24 7 1901 31 WIND SPEED CLASS BOUNDARIES (MILES /HOUR) NOTES DIAGRAM OF THE FREQUENCY OF OCCURRENCE FOR EACH WIND DIRECTION. WIND DIRECTION IS THE DIRECTION FROM WHICH THE WIND IS BLOWING. EXAMPLE WIND IS BLOWING FROM THE NORTH 3.8 PERCENT OF THE TIME. FOSTER WHEELER ENVIRONMENTAL CORPORATION S N WI \IROSE Revision No 1 Revision Date 02/28/98 Page 13 of 42 PERIOD 1983 -1989 Figure 1. Mill Site Wind Rose for 1983 Through 1989 4.4 Sampling Locations Revision No 1 Revision Date 02/28/98 Page 14 of 42 Four sampling stations are located (Figure 2) as close as practical to the site boundaries along the most probable wind flow vectors. These are the sampling station numbers, locations, and sampler types. Station Number Location (direction from primary dismantling area) Sampler Types 1 Southeast TSP, PS -1 2 North TSP, PS -1 3 Southwest TSP, PS -1 4 South TSP Station 2 to the north of the primary dismantling area is located on the Rayonier dock, which is the only available location north of the site Stations 1, 3, and 4 are located to the southeast, southwest, and south, respectively inland from the primary dismantling area. Station 4 is located on top of the bluff above the primary dismantling area, which is in close proximity to nearby residences. Due to limited access and obstruction by nearby trees, Station 4 is located on top of a structure associated with Rayomer's water treatment facility Rayonier also operates an onsite meteorological monitoring station mounted on a tower on the bluff to the south of the dismantling area (Figure 2) Station locations have been selected according to the guidance provided in 40 CFR Part 58, Appendix C The stations are placed so as to avoid obstructions and interference from onsite features, and are a minimum of 6 feet from the closest obstacle to air flow Stations 1, 2, and 3 are located at least 25 feet from roadways, and Station 4 is located approximately 15 feet from an infrequently used side street. Stations 1, 2, and 3 are mounted on stands that elevate the sampler inlets to be about 4 feet high, and Station 4 is located on a structure approximately 15 ft above surface grade. The exhaust hoses for the PS -1 samplers are extended downwind from the sampler inlet. The sampling stations will remain at the locations indicated on Figure 2 for the majority of the dismantling activities. Dismantling of certain areas of the site will necessitate relocating the stations. For example, during dismantling of Rayomer's wastewater treatment facility and other facilities at the eastern portion of the facility, which are scheduled near the end of the dismantling operations, the southeast sampling station will be relocated to be downwind of these dismantling areas. Relocation of the sampling stations will be documented as part of periodic monitoring reports. \\BECALVIN\VOL2 \WP\1834 \I 1934.DOC 3/5/98 i 1 �-.nTER WHEELER ENVIRONMENTAL. CORPORATION Strait of Juan de Fuca KEY ter 1Sp High Volume Air Sampler PS- High Volume Air Sampler a Meteorological Monitoring Station Figure 2. eles Division Mill Vicinity Map Rayonier Port Ang 4.5 Air Sampling Met sods Revision No 1 Revision Date 02/28/98 Page 17 of 42 Air quality sampling will be: conducted according to EPA guidance (EPA 1988, 1994, 1995, 1997), and sample analysis will be conducted in accordance with EPA and standard laboratory protocols. Table 13 lists the sampling techniques and analysis methods for the monitored air pollutants. Each of the four sampling st: :.tions will be equipped with TSP samplers, and Stations 1, 2, and 3 will be equipped with ES -1 samplers. Asbestos monitoring will bei conducted by visually inspecting the ambient air directly around the work area. In the event that air emissions are visible, the dismantling contractor will immediately ie notified to stop work and take corrective actions to stop and prevent the emissions. The meteorological data colt acted by the program will include Wind speed Wind direction Temperature, and Atmospheric pressure The station will calculate the sigma theta (standard deviation) of the wind direction. The meteorological data will be used to characterize transport conditions during periods of sampling. 4.6 Quality Assurance /Quality Control Sampling Quality assurance samples will be part of the sampling program. The monitoring program will incorporate routine quality control (EPA 1993) Trip blanks will identify any sources of contamination unrelated to the sampling program, and will be collected at a frequency of one per sampling event. Trip blanks will accompany the shipment of sampling media but are not exposed to the ambient air The trip blank is subsequently processed and analyzed as a regular sample Laboratory QC checks will involve the analysis of laboratory method blanks and matrix spikes. Method blanks and matrix spikes will be analyzed with each group of samples analyzed, or at a frequency of one in twenty field samples. The method blanks will allow for the detection of contamination from the laboratory procedures, and the matrix spikes will be used to monitor the laboratory's analytical accuracy \\BECALVIMVOL2 \WP \1834 \I 1934. DOC .il5/98 4.7 Sampling Schedule Revision No 1 Revision Date. 02/28/98 Page 18 of 42 During normal dismantling activities, TSP and dioxm/furan monitonng will be conducted on a weekly basis. TSP sampling will be conducted on a once per -week basis, will have a 24 -hour duration, and will occur on Monday of each week. TSP monitonng will be conducted on a 9 a.m. to 9 a.m. schedule. Dioxin/furan sampling will be conducted on a once per -week basis, will have a 30- to 32 -hour duration, and will begin on either Wednesday or Monday Dioxinlfuran monitoring will be conducted on a 6 a.m. (first day) to 2 p.m. (second day) schedule. Meteorological data will be collected on a continuous basis throughout the duration of the air monitonng. Holidays or other non- working days may require adjusting this schedule. Visual inspection for asbestos will be conducted during each day that dismantling of asbestos containing matenal is underway Lead monitoring will be conducted on a once per -week basis during emission generating dismantling activities for structures where elevated levels of lead containing matenals are present. Lead sampling events will have a 24 -hour duration, the day of the week will be determined based on site activities. Following three consecutive months of weekly monitonng results that do not exceed the action levels identified in this plan, the TSP, dioxm/furan, and lead monitonng will change to once every two weeks (bi- weekly) Following three consecutive months of bi- weekly monitonng results that do not exceed the action levels identified in this plan, the TSP, dioxm/furan, and lead monitonng will change to once every month. In the event that bi- weekly or monthly monitonng results for an individual parameter exceeds the established action level, the sampling frequency for that parameter will revert to weekly, and remain at weekly until four consecutive sampling events that do not exceed the action level are recorded. Major structure dismantling activities (e.g. recovery boiler stack dismantling, digester dismantling, hog fuel boiler dismantling) pose the highest single -event potential for fugitive emissions, and thus will be a focus for emission control and monrtonng activities. Momtonng will be conducted on a once per -week throughout the duration of emission generating dismantling activities for each major structure. TSP and dioxin/fivan monrtonng will be conducted, and also lead monrtonng if applicable for the structure. \\BECALVIN\VOL2 \WP\1834 \I 1934.DOC 3/6/98 Table 3. Air Sampling Potential Air Pollutant Particulate Matter (Total Suspended Particulate) Dioxins /furans Lead Asbestos Other Metals Polycyclic Aromatic Hydrocarbons Polychlorinated Biphenyls Volatile Organic Compounds \\DECALVIMVOL2 \WP \1834 \I 1934.DOC 3/5/98 and Analysis Methods Sampling Method High volume TSP air sampler Quartz fiber filter High volume PS -1 sampler Quartz fiber filter PUF Foam Cartridge High Volume Air Sampler EPA 6010, 7000 Quartz Fiber Filter Visual Not Applicable To )e determined prior to exc ivation actions To )e determined prior to exc Ovation actions To )e determined prior to exc ivation actions To determined prior to excavation actions Revision No 1 Revision Date 02/28/98 Page 19 of 42 Analysis Method 40 CFR Part 50 App B EPA TO -9, 8290 5 0 PROGRAM IMPLEMENTATION 5.1 Data Assessment and Contingency Plans Revision No 1 Revision Date 02/28/98 Page 20 of 42 Upon completion of the laboratory analysis, the laboratory will fax the preliminary data to Rayonier for review This preliminary data will be used in conjunction with collected field and meteorological data to conduct a preliminary comparison of the measured pollutant concentrations to the action levels in this plan. The Environmental Manager will review the analytical data in conjunction with the field data to develop preliminary results of the monitoring er ent. The analytical laboratory will promptly commence quality assurance /quality control review of the preliminary data to generate final data. Data validation will commence on a portion of the data following the sampling event, and will be finalized promptly upon receipt of the final analytical data from the laboratory to ensure that only data meeting established criteria for data acceptability is considered for evaluation and reporting. Preliminary data from the total suspended particulate and lead sampling will be available within 10 working days fol owing receipt of the sample by the analytical laboratory, and validated results will be available within 15 working days. Preliminary data from the dioxm/furan sampling will be available within 25 working days following receipt of the sample by the analytical laf oratory and validated results will be available within 45 working days. In the event that the preliminary results of the sampling event indicates an exceedance of the action levels identified in this plan, a thorough review of the available supporting data and laboratory procedures v Till be conducted to confirm the validity of the reported exceedance The laboratory will be contacted to immediately initiate a quality assurance /quality control re view and generation of final data for the sampling event. Single data point concentrations exceeding the action levels identified in the plan will trigger evaluation, and, if warranted, modifications of emission abatement methods as necessary to prevent a repeat of the exceedance Single data point concentrations will require immediate resampling of the pollutant that exceeded its action level Wind conditions during the sampling event will be considered in evaluating the impact, if any of site operations on sample results. Upon venfying that the sampling result exceeded the action limit, the Department of Ecology will be notified. Tie site activities during the monitoring event will be reviewed to evaluate the cause of the xceedance and potential corrective actions. \\BECALVIMVOL2 \WP \1834 \1 I934.DOC 3/5/98 Potential corrective actions include Additional watenng Saturation watering Modification of construction activities Suspension of construction activities Revision No 1 Revision Date 02/28/98 Page 21 of 42 Rayomer will review potential corrective actions and subsequent momtonng requirements with the Department of Ecology before implementing a change to onsite emission control methods. 5.2 Data Management An air monitoring record log of data, reports, and records associated with the air monitonng program will be maintained on site and available for review by the Department of Ecology and EPA. The Environmental Manager will conduct audits of the field activities associated with the program. Upon completion of a sampling event, the Environmental Technician will record the event information into the air monitoring records, including the following information. Sample collection start and end date and time Site activities during sampling event Sample description and identification numbers Field measurements and forms (air flow rates, collected air volumes, elapsed timer reading, magnehelic gage reading) Calibration data and forms Sample field sheets Chain -of- custody copies Equipment maintenance information Meteorological data and windrose Observations and comments Laboratory analytical reports and data validation records will transmitted to the Environmental Manager, to be placed into the air monitoring record log when received from the laboratory Preliminary and final laboratory data will be clearly identified. The results of the data validation process and description of results will be included along with the sample results. Regular reports, correspondence, and other relevant documents will be maintained with the air monitoring records. \\BECALVIMVOL2 \WP \1834 \I 1934 DOC 3/5/98 5.3 Reporting Revision No 1 Revision Date 02/28/98 Page 22 of 42 During the course of the sampling program, monthly data reports will be produced and transmitted to the Department of Ecology The data report will discuss the site activities that occurred and the sampling results that were received dunng the previous month. Each report narrative will summarize the meteorological conditions, sampler locations, analytical procedures, and ambient concentrations for each target analyte Additionally, the report will summarize on -site activities, as well as any changes to the monitoring plan and difficulties encountered during the sampling period that may have impacted the sampling results. All laboratory analytical data, field data sheets, and all sampling train calibration data will be provided as appendices to each sampling event report. All ambient air results will '3e corrected to standard conditions of 25°C (77°F) and one atmosphere (29 92 inches of Hg) The results for each sampling event will be summarized in a tabular format reporting total detected mass quantitation for each analyte in each field blank and sample. The flow calibration data and sampling duration for each sampling train will be used to calculate sample volumes from which the concentration of each target analyte will be calculated. Meteorological data obtained dunng each sampling event will be summarized in the form of a windrose Wind conditions during the sampling event will be considered in evaluating the impact, if an I of site operations on sample results. One report will be generated for every sampling event with a summary of individual event results provided in tabular format, on an as available basis. 5.4 Plan Updates /Changes In the event that this plan re 4uires updating or changes, the Environmental Manager will approve the update or chanes, and will maintain records of the modification, date, and revision number A copy of J revisions will be transmitted to the Department of Ecology as part of the monthly data report. \\BECALVIN\VOL2 \WP \1834 \11934 DOC 3/5/98 6 0 DATA QUALITY OBJECTIVES The data quality objective for this plan is to provide valid data of known and documented quality Specific data quality objectives stipulate the total sampling /analysis detection limits, accuracy, precision, and completeness. Table 4 presents the data quality objectives for this project. Accuracy is defined as the ratio, expressed as a percentage, of a measured value to a true or referenced value, and includes both field and laboratory measurements. Field accuracy will be expressed as the percent difference based on flow monitor rate audits. Sampler flow rates will be audited Using a reference flow device different from the one used to calibrate sampler flow For each flow audit, the percent difference between the known flow rate and the measured flow rate will be calculated. The laboratory component of accuracy will be expressed as percent recovery based on the analysis of a laboratory matrix spike Data completeness is expre ised as the percentage of data generated that is considered valid. Each data package v ill undergo a validation review to determine the completeness of the data and ensure the v- tlidity of the data for use in evaluation and reporting of results. \\BECALVIMVOL2 \WP \1834 \11934 DOC ,/5/98 Revision No 1 Revision Date 02/28/98 Page 23 of 42 Table 4 Data Quality Objectives and Analysis Methods Parameter Matrix Units Practical Accuracy Completeness Method Reference Container Preservative Holding Time Quantitation (Percent (Percent) Limits Recovery) (b) Total Suspended Particulate Particulate µg/m' 2.0 ±10 95 GRAV 40 CFR Part 50 QFF 4 °C 14 days Dioxin/F uran Air /particulate pg/m' 0.1 ±50 95 GC/ EPA TO -9 8290 PUF 4 °C Extract 30 days HRMS Analysis 45 days from extract Lead Particulate µg/m 0.1 ±15 95 ICP EPA 6010, 7000 QFF 4 C 6 months Asbestos Visual inspection Other Metals To be determined Polycyclic Aromatic To be hydrocarbons determined Polychlorinated Biphenyls To be determined Volatile Organic To be Compounds determined (a) Practical Quantitation Limit is matrix dependent (b) Accuracy is calculated by the following formula: recovery (spike sample result sample result) x (100) spike sample result \\BECALVIN \VOL ?1WP 1834 \11934 DOC 3/5/98 Revision No 1 Revision Date 02/28/98 Page 24 of 42 M r— MI NB 1111 ire MI MI M- 111111 rr 211111 11111 UM I 11111 7 0 MONITORING PROCEDURES 7 1 Total Suspended Particulate Monitoring Revision No 1 Revision Date 02/28/98 Page 25 of 42 Total suspended particulate will be sampled by drawing ambient air through a quartz fiber filter in a high- volum; sampler (General Metal Works Hi -Vol), operated and calibrated as outlined in 40 CFR Part 50, Appendix B Reference Method for Determination of Suspended Particulate Matter in the Atmosphere (High Volume Method) Each sampler will be equipped with an electronic mass flow controller and electronic timer The samplers will use clean, preweighed filters mounted in a filter cassette The TSP samplers are designed to operate at a flow rate of 1 1 to 1 7 m /min, with the nominal flow rate set at 1 4 m /min. Each TSP monitor will be subject to a multi -point calibration pnor to and immediately following the sampling program. Calibration data will be recorded on a calibration data sheet. This and other QA Calibrations will be performed according to the procedure presented in EPA 1994 A multi -point calibration of the calibration onfice against a pnmary standard will be cc nducted annually by the equipment manufacturer TSP sampling will follow the procedures outlined by EPA 1994 A single point flow check will also be performed at the start and end of each sampling penod. Any time the difference between the sample flow rate and the one -point flow check deviates more than ±7 the sampler will be recalibrated using the multi -point calibration method. Procedures for this check will follow the guidance provided by EPA 1994 Each unit will be maintained as specified in the instrument instruction manual. The units will be examined for operational integnty during field operations. The Environmental Coordinator will keep a written record of any maintenance requirements. Each TSP Hi -Vol filter will be weighed and visually checked for purity at the laboratory The filters will be placed in to numbered, sealed containers and packaged for shipment to the site. At the end of the sampling penod, the exposed filters will be retneved and returned to the analytical laboratory for gravimetnc analysis promptly following each sample event. Tnp blank samples will be ollected as described in the quality assurance sampling section of the plan. The sample request form, chain of custody, and chain of custody seals will be used for each ample shipment. The samples will be packaged and shipped according to laboratory standard operating procedures and Department of Transportation requirements. Sample preservation requirements are as identified in the data quality BECALVIN\VOL2 \WP\1834 \11934.DOC 316198 7.2 Dioxin /Furan Monitoring Revision No 1 Revision Date 02/28/98 Page 26 of 42 section of this plan. All samples will be shipped by express delivery service for overnight delivery Laboratory analysis will be conducted in accordance with the analytical laboratory's standard operating procedures conforming to 40 CFR Part 50, Appendix B The exposed filters will be retained by the laboratory for a period of at least six months and then disposed of as an environmental sample following all applicable laws and regulations. Dioxm/furan pollutants will be sampled by drawing ambient air through a quartz fiber filter and polyurethane foam (PUF) adsorbent cartridge in a high- volume sampler (General Metal Works Hi -Vol PS -1), operated and calibrated as outlined in EPA Method TO -9 (Method for the Determination of PCDDs in Ambient Air Using HRGC/HRMS The PS -1 samplers will operate at a continuous high flow rate of 0.20 to 0.28 m /min. Each PS -1 monitor will be subject to a multi -point calibration prior to and immediately following the sampling program. This and other QA calibrations will be performed according to the procedure presented in EPA Method TO -9, 1988 A multi -point calibration of the calibration orifice against a primary standard will be conducted annually by the equipment manufacturer Dioxin/furan sampling will follow the procedures outlined in EPA TO -9 A single point flow check will also be performed before and after each sample. Any time the difference between the sample flow rate and the one -point flow check deviates more than ±7 the sampler will be recalibrated using the multi -point calibration method. Procedures for this check will follow the guidance provided by EPA TO -9 Each unit will be maintained as specified in the instrument instruction manual. The units will be examined for operational integrity during field operations. The Environmental Technician will keep a written record of any maintenance requirements. Each filter and PUF cartridge will be weighed and visually checked for purity at the laboratory The filters will be placed into numbered cassettes, sealed, and packaged for shipment to the site. At the end of the sampling period, the exposed filters will be retrieved and returned to the analytical laboratory for analysis promptly following each sample event. Trip blank samples will be collected as described in the quality. assurance sampling section of the plan. The sample request form, chain of custody, and chain of custody seals will be used for each sample shipment. The samples will be packaged and shipped according to laboratory standard operating procedures and Department of Transportation requirements. Sample preservation requirements are as identified m the data quality BECALVIN\VOL2 \WP\1834 \11934.DOC 3/6/98 section of this plan. All samples will be shipped by express delivery service for overnight delivery Laboratory analysis will be conducted in accordance with the analytical laboratory's standard operating procedu es conforming to EPA TO -9 The exposed filters and PUF cartridges will be destroyed dunng the analytical procedure, and will disposed of as an environmental sample following all applicable laws and regulations. 7.3 Lead Monitoring Lead will be sampled by analyzing particulate matter collected by the TSP filters. The filters will be analyzed by inductively coupled argon plasma (ICP), which will determine the concentration of lead. ]'he samplers to be used are General Metal Works high volume samplers. The samplers us clean, preweighed ultra -pure 8 by 10 inch quartz fiber filters mounted on screen supported sample holders. The sampling technique for TSP will be used to collect lead samples (see Section 7 1) As the lead analysis will be performed on the TSP filters, data documentation, and operational protocols for thr lead sampling are identical to those for TSP sampling. 7 4 Asbestos Monito Asbestos momtonng will be, conducted by visually inspecting the ambient air directly around the work area. In the event that air emissions are visible, the dismantling contractor will immediately be notified to stop work and take corrective actions to stop and prevent the emissions. 7 5 Other Metals Monitoring Reserved 7 6 Polycyclic Aromatic Hydrocarbons Monitoring Reserved \\BECALVIN\VOL2 \WP\1834 \1 1934.DOC 3/6/98 ring Revision No 1 Revision Date 02/28/98 Page 27 of 42 7 7 Polychlorinated Biphenyl Monitoring Reserved 7 8 Volatile Organic Carbon Monitoring Reserved \\BECALVIN\VOL2 \WP \1834 \11934 DOC ,/5/98 Revision No 1 Revision Date 02/28/98 Page 28 of 42 8 0 Meteorological Monitoring Revision No 1 Revision Date 02/28/98 Page 29 of 42 Meteorological conditions will be continuously monitored during the air sampling program. Whenever possib e, data collection methods and data analysis will conform the EPA guidance (EPA 1995) The meteorological station is located on a 33 -foot tower installed on top of the bluff to the south of the pulp proces ;mg area of the site. The station will collect wind speed, wind direction, temperature atmospheric pressure, and will derive sigma theta (standard deviation of the wind direct on) The wind speed and wind direction sensors are mounted at the top of the tower The meteorological sensors will be sampled by a datalogger that will convert the signals to engineering units, and av 'rage the data into 10- minute intervals. Wind direction will be sampled at a rate of once per second. Wind direction will be averaged as a unit vector All other parameters will be processed as scalar values. The averaged data will be stored in the datalogger's memory and periodically downloaded to a PC The meteorological system be visually inspected every two weeks. The inspection will look for sensor damage and loose wires. Calibration of the meteorological instruments will be recordec, and copies of the calibration records will be maintained in the program record log. Th instruments will be calibrated once every twelve months. Calibrations will also be performed whenever repairs are made Calibrations are conducted in conformance with the equipment operating manuals. The meteorological data will be used in conjunction with the monitonng data to assess impacts of the meteorology cm the transport and dilution conditions during the site activities. \\BECALVIN\VOL2 \WP \1834 \11934 DOC 3/5/98 90 REFERENCES \\BECALVIMVOL2 \WP \1834 \I 1934.DOC 3/5/98 ATSDR. 1997 Toxicological Profiles on CD -ROM. U S Public Health Service April ENSR (ENSR Consulting and Engineering. 1992. An Air Quality Modeling Analysis for the Port Angeles Mill June 26, 1992. EPA. 1988 Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air, 2 Supplement. EPA/600/4 -89 -017 June 1988 EPA. 1989 Risk Assessment Guidance for Superfund. Volume I —Human Health Evaluation Manual (Part A) EPA/540 /1- 89/002 Interim Final. Office of Emergency and Remedial Response. Washington, DC December 1989 EPA. 1991 Risk Assessment Guidance for Superfund. Volume I —Human Health Evaluation Manual. Supplemental Guidance, Standard Default Exposure Factors. OSWER Directive 285.3 -03 Office of Emergency and Remedial Response Washington, DC March 1991 EPA. 1993 Quality Assurance Handbook for Air Pollution Measurement Systems Volume I A Field Guide to Environmental Quality Assurance EPA/600 /R- 94/038a. 1993 Revision No 1 Revision Date 02/28/98 Page 30 of 42 EPA. 1994 Quality Assurance Handbook for Air Pollution Measurement Systems Volume II Ambient Air Specific Methods. EPA- 600/R -94 -03 8b 1994 EPA. 1994a. Health Assessment Document for 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) and Related Compounds. EPA/600/BP-92/001c External Review Draft, Vols. 1 -3 Office of Research and Development, Washington, DC EPA. 1995 Quality Assurance Handbook for Air Pollution Measurement Systems. Volume IV Meteorological Measurements. EPA- 600/R- 94 -038d. 1995 EPA. 1996 Exposure Factos Handbook. Office of Research and Development, National Center for Environm Assessment, Washington, DC August. EPA. 1997 Compendium o F Methods for the Determination of Toxic Organic Compounds in Ambient Air EPA/600/R- 96 -010a. September 1997 Foster Wheeler 1997 Current Situation/Site Conceptual Model Report. Prepared by Foster Wheeler Environmental Corporation. August, 1997 Washington State Model Toxics Control Act. 1993 Cleanup Regulation. Chapter 173- 340 WAC Publication No 94 -06 January 1996 \\BECALVIMVOL2 \WP \1834 \11.934.DOC 3/5/98 Revision No 1 Revision Date- 02/28/98 Page 31 of 42 Appendix A Derivation of Risk Based Action Levels This appendix describes the, rationale and methodology used to identify an action level for concentrations of dioxir s /furans in air during dismantling activities at the Rayonier Pulp Mill site in Port Ange es, Washington. The objective of the action level derivation process was to determine airborne chemical concentrations of dioxins /furans that represent the upper limit of concentrations posing acceptable risk to the public nearby the mill dunng dismantling act vities. The action levels were developed using a nsk based approach consistent with the methodology noted in EPA Risk Assessment Guidance for Superfund (1989), the exposure levels recommended by the EPA Exposure Factors Handbook (1996), and the tiarget risk levels noted by the Washington State Model Toxics Control Act. Since the guidance documents detail the procedures and parameters used, the following text is meant as a summary of these documents. A.1 Exposure Assessment Exposure is defined as the ontact of an organism with a chemical Exposure assessment is the estimation of the magnitude, frequency duration, and route of exposure. Consistent with EPA (1989), the exposure assessment procedure comprises three basic elements Characterize the Exposure Setting In this step of the exposure assessment, the current and potential fui ure land use at the site and the surrounding property is described. Also, the current or future populations who could be exposed to chemicals at or migrating from the site are identified and the populations selected for exposure in the risk assessment process are described. Identification of Exposzi re Pathways In this step, the pathways by which the populations defined above could be exposed are identified. Each exposure pathway describes a unique mechanism by which a chemical released in the environment can come into contact with human receptor Estimation of Chronic Daily Intake Rates In this step the magnitude, frequency and duration of exposure are quantified for each pathway described above Quantified exposure is expressed a chemical intake averaged over a time period of interest and normalized for body weight. This estimate of exposure adjusted for time and body weight is termed "intake," and is expressed in units of milligram (mg) chemical per kilogram (kg) body weight per day Quantification of exposure is conducted in two stages estimation of exposure point concentrations and calculation of intakes. \\BECALVIN\VOL2 \WP \1834 \11934 DOC .,/5/98 Revision No 1 Revision Date 02/28/98 Page 32 of 42 Each of these steps are discussed in detail below A.1 1 Identification of Land Use and Potentially Exposed Populations Revision No 1 Revision Date 02/28/98 Page 33 of 42 This section summarizes information regarding the physical charactenstics of the site and the characteristics of populations on or near the property This information is used to determine which receptors are potentially at risk from exposure to chemicals at the site. These receptors, known as the potentially exposed populations, are evaluated in the risk assessment. The populations at risk for chemical exposure are determined based on the past, current, and potential future uses of the property Historically, the mill property has been used for industrial purposes. If the property is developed in the future, the risk assessment assumes it will remain under industrial or commercial use. This assumption has little impact on the action levels calculated in this document since the exposure scenario defined below evaluates risks to nearby residents assuming air monitoring stations on site are representative of off site locations. Realistically, the air concentrations more distant from the source would be much less. A.1.2 Identification of Exposure Pathways An exposure pathway describes a chemical's route of transport from its source to the exposed individual. In order for a potential risk to be present, a complete pathway also must be present. According to EPA (1989a), a complete exposure pathway consists of four necessary elements. (1) a source and mechanism of chemical release to the environment, (2) an environmental transport medium (e g air, water) for a released chemical, (3) a point of potential contact with the impacted medium (referred to as the exposure point), and (4) an exposure route (e g inhalation, ingestion) at the contact point. A.1.2.1 Chemical Sources and Release Mechanisms For this evaluation, the sources of chemicals released from the Rayomer Mill during dismantling are (1) chemicals deposited in the soil from past mill operations (See Site Situation Report, Foster Wheeler, 1997), (2) chemicals associated with dust particles present on structures currently existing on site A.1.2.2Exposure Points and Routes People can be directly exposed to chemicals present in surface soils and from dusts associated with the buildings through inhalation of windblown dust generated as a result as a result of dismantling activities. BECALVIN\VOL2 \WP\1834 \11934.DOC 3/6/98 A.1.3 Quantifying Exposure Revision No 1 Revision Date 02/28/98 Page 34 of 42 This section identifies and quantifies the activities of the receptors that affect the amount of chemical exposure they may have. For each activity, specific values are developed as input parameters for the exposure assessment model. Many of the parameters are a combination of reasonable maximum exposure (RME) factors developed by EPA's Superfund program for use in human health risk assessments and are discussed in detail in Washington State Department of Ecology and EPA guidance documents. Thus, the text provided here is a summary of this information. For some parameters, USEFrA RME default values (e.g 90` percentile) are not available because they vary widely depending upon the site location. Therefore, site specific parameters have been developed based on data obtained for the local community, available literature, and data obtained from EPA's Exposure Factors Handbook (EPA, 1996b) Exposure parameters used in the risk assessment for each pathway and each receptor identified above are presented in Tables A -1 and A -2 A.1.3.1 Estimates of Expose tre Duration and Frequency The amount of time that an individual is expected to contact a given toxicant is defined by using three terms Exposure Duration th1? entire time period which a person will be exposed to a chemical This is typicc lly defined in number of years, but for acute exposures can be defined in either month! or days Exposure Frequency the exposure frequency is defined as the number of times an exposure may happen o per the exposure duration. This is typically defined as a number of events per year Averaging Time The averaging time selected is dependent on the type of toxic effect being assessed. When evaluating exposures to developmental toxicants, intakes are calculated by averaging over the exposure event (a day or single exposure incident) When evaluating longer -term exposure to noncarcinogenic toxicants, intakes are calculated by averaging intakes over the period of exposure (e g chronic daily intakes) For carcinogens, intakes are calculated by prorating the total cumulative dose over a lifetime (e g lifetime average daily intake) For individuals working on. or living near the site in the future, exposure duration is related to the length of time a person would be at a specific location. Since the dismantling activities are pl finned for completion in two years, this is defined as the exposure duration. EPA ha; established a an exposure frequency of 250 events per year \\BECAL VIN \VOL2 \WP \1834 \11934 DOC ,15/98 (corresponding to 50, 5 -day work weeks per year) (EPA, 1991a) and an exposure time is assumed to be eight hours per day based on an 8 hour work day (USEPA, 1992b). Averaging time is related to the type of chemical exposure For non carcinogens, assessment is based on a chronic average daily exposure. Therefore, the averaging time is equal to the duration of the exposure or two years. For carcinogens, risk assessment is based on exposure extrapolated over an average 70 -year lifetime. A.1.3.2Inhalation Rates The inhalation rates established for adults are 11 3 and 15.2 m /day for females and males, respectively A median value of 13.3 ug/m was calculated for use in this assessment. A.1.3.3 Quanting Exposure When an exposure assessment will be used as part of a quantitative risk assessment, a numerical estimate of exposure must be calculated. Mathematically, the formula can be shown as Equation A -1 Exposure Calculation Intake_ CAxIRxETxEFxED AT x BW Where CA chemical concentration in air (e g mg /m IR inhalation rate (m ET exposure time (hours /day) EF exposure frequency (days /year) ED exposure duration (years) BW body weight (kg) AT averaging time (period over which exposure is averaged) As discussed, the chemical intake rate expressed by these equations is averaged over a time period of interest. The time period of interest is referred to as the averaging time The averaging time selected depends on the type of toxic effect being assessed. For example, when evaluating exposures to non carcinogenic chronic or developmental toxicants, intakes will be calculated by averaging over the exposure duration. For carcinogens, intakes are calculated by averaging the total cumulative dose over a lifetime The selection of different averaging times relates to the currently held scientific opinion that the mechanism of action for non carcinogens is different than the mechanism for carcinogens. The approach for carcinogens is based on the assumption that a high dose received over a short period of time is the same as a corresponding low dose spread over a lifetime \\BECALVIMVOL2 \WP \1834 \I 1934 DOC 3/5/98 Revision No 1 Revision Date 02/28/98 Page 35 of 42 A.2 Toxicity Assessment Revision No 1 Revision Date 02/28/98 Page 36 of 42 Toxicity assessment is an integral part of the risk assessment process. In general, the toxicity assessment documents and quantifies the relationship between exposures to a COPC and the potentially harmful health effects associated with exposure to that chemical. The first step of a toxicity assessment is to weigh available evidence regarding the potential for contaminants tb cause adverse effects in exposed individuals. This process is called hazard identification. Hazard identification is conducted to determine whether an agent identified at the site is associated with adverse health effect (e g., liver damage) and whether it is possible that the adverse health effect would occur in humans. The second step of the toxicity assessmeint is to provide, where possible, an estimate of the relationship between the extent of exposure to a contaminant and the increased likelihood and /or severity of adverse effects. This step is called a dose response evaluation. A dose response is the process of quantifying the toxicity information and characterizing the relationship between the high dose and low dose, animal and human responses, and one exposure route to another F quantitative dose response relationships, toxicity criteria are derived. Once a chemical is identified as a hazard the EPA gathers evidence and data from a variety of sources regarding the potential for a substance to cause adverse health effects (carcinogenic and non carcinogenic) in humans. EPA then uses this dose response data to determine toxicity criteria fc r a variety of chemicals. In determining toxicity criteria, three kinds of toxicological data, and information are considered. human data, animal data, and other supporting data. The relationship between exposure and response is preferably charactenzed from human epidemiological or occupatu nal data. However, at present definitive data on adverse effects associated with direr: human exposure are limited. Because human data are often insufficient to determine dos response relationships for many chemicals, other supporting data are needed t evaluate potential adverse health effects and to derive toxicity criteria. The most pievalent additional dose response information is drawn from controlled experiments conducted on non -human mammals, such as rats, mice, rabbits, dogs and monkeys. Animal data are used as surrogates to human data based on the assumption that dose- respo+ relationships will be similar However, there are occasions in which humans may respond quite differently than animals to the same toxic chemical To account for these differences when extrapolating dose response data from animals to humans, EPA incorporates uncertainty factors into the derived toxicity criteria. \\BECALVIMVOL2\WP \I834 111934 DOC 3/5/98 A.2.1 Toxicity Assessment for Non Carcinogenic Effects Revision No 1 Revision Date 02/28/98 Page 37 of 42 For the purpose of this nsk assessment, chemicals are considered to have two types of potential effects non carcinogenic and carcinogenic Non carcinogenic effects, such as liver or kidney damage, may be either self repairing once exposure is discontinued, or may be permanent and continue to exist after exposure to the chemical has stopped. For many non carcinogens, protective mechanisms are believed to exist that must be overcome before an adverse effect occurs. In general, exposure concentrations ranging from zero to some finite value can be tolerated without the expression of adverse effects. The toxicity criteria that EPA has developed to quantify the non carcinogenic dose response relationships are called reference doses (RfDs) A.2.2 Toxicity Assessment for Carcinogenic Effects Chemicals termed carcinogens have been shown to produce, or are suspected of producing, tumors in animals and/or humans. Most carcinogens are thought to cause cancer by directly acting on genetic material For carcinogens, EPA generally assumes that a small number of molecular events can evoke changes in a single cell that can lead to uncontrolled cellular proliferation and, likely, a disease (EPA, 1989a) In other words, for a carcinogen, no dose is thought to be risk -free This hypothesized mechanism for carcinogenesis is referred to as "non- threshold." However, scientific evidence suggests a threshold may exist for carcinogens that do not act directly on genetic material. These chemicals are called epigenetic, or non- genotoxic carcinogens. Such chemicals include arsenic and dioxins /furans. The toxicity criteria that the EPA has developed to quantify carcinogenic dose response relationships are called cancer slope factors (CSFs) A CSF is a plausible, upper bound estimate of the probability of developing cancer per unit intake of a chemical over a lifetime A.2.3 Assessing Toxicity for Dioxins/Furans In order to assess potential carcinogenic risk due to exposure to chlorinated dibenzo-p- dioxins (CDDs) and chlorinated dibenzofurans (CDFs), the toxicity equivalence approach, as adopted by EPA (1989b), is used to characterize exposure to the dioxin -like compounds detected at the site In this approach, toxicity equivalence factors (TEFs) have been assigned to all CDDs and CDFs based on their cancer potency relative to 2,3,7,8 tetrachlorodibenzo -p- dioxin (TCDD) While TCDD is the most studied and most toxic of the dioxins, EPA estimates that greater than 90 percent of total body burden dioxin equivalence is due to other dioxin -like compounds (EPA, 1994a). The magnitude of the TEFs are determined primarily by the number and position of the halogen atoms on the dioxin -like compound, and limited in vivo and in vitro toxicity testing. \\BECALVIN\VOL2 \WP \1834 \I 1934.DOC x/5/98 The procedure for estimatir.g the additive toxicity of dioxin -like compounds involves 1) analysis of the individua. dioxin -like compound, 2) multiplication of each compound by its TEF to express its colcentration in terms of TCDD equivalents (TEQs), and 3) summation of the individual TEQs to obtain a total TEQ The procedure used is presented by example in Table A -1 A.3 Calculating Action Levels Because of the different methodology used by EPA to calculate risk for carcinogenic and noncarcinogenic effects, action levels were developed for both and set at the lower limits of the two For non -cancer health threats. risk is typically estimated by comparing the estimated intake with an exposure level at which no adverse health effects are expected to occur for a long penod of exposure (i.e the RfD) ADDS and RfDs are compared by dividing the ADD by the RfD to obtain an ADD- to -RfD ratio, as follows Equation A -2. where ADD= average daily dose (mg /kg -d) RfD reference dose (mg/kg -d) The ADD- to -RfD ratio is kr own as a hazard quotient. If a person's average exposure is less than the RfD (i.e if the hazard quotient is less than one), the chemical is considered unlikely to pose a significant non carcinogenic health hazard to individuals under the given exposure conditions. By combining Equation A 2 and Equation A -1, defining the acceptable risk level, and so .vmg for CA, an action level can be calculated (Table A -2) \\BECALVIMVOL? \WP \I834 \I 1934.DOC 3/5/98 Hazard Quotient ADD RID Revision No 1 Revision Date 02/28/98 Page 38 of 42 Revision No 1 Revision Date 02/28/98 Page 39 of 42 Table A -1 Procedure for Estimating the Additive Toxicity of Dioxin -Like Compounds 1 Identify TEFs for CDDs and CDFs (from EPA, 1994a) Congener TEF 2,3,7,8 -TCDDs 1 2,3 7,8- PentaCDDs 0.5 2,3,7,8 HexaCDDs 0 1 2,3,7,8 HeptaCDDs 0 01 OctaCDDs 0 001 All other CDDs 0 2,3,7,8 -TCDFs 0 1 1,2,3,7,8 PentaCDFs 0 05 2,3,4,7,8 PentaCDFs 0 5 2,3,7,8 HexaCDFs 0 1 2,3,7,8 HeptaCDFs 0 01 OctaCDFs 0 001 All other CDDs 0 2. Multiply concentration of each congener by its respective TEF Concentration (example) TEF TEQ 2,3,7,8 -TCDD 1 0 ng/kg 1 1 ng /kg 2,3,7,8 PentaCDD 1 0 ng/kg 0 5 0 5 ng/kg 2,3,7,8 HexaCDD 1 0 ng/kg 0 1 0 1 ng/kg 2,3,7,8 HeptaCDD 1 0 ng /kg 0 01 0 01 ng /kg OctaCDD 1 0 ng /kg 0 001 0 001 ng/kg All other CDDs 1 0 ng/kg 0 0 ng/kg 2,3 7 8 -TCDF 1 0 ng/kg 0 1 0 1 ng/kg 1,2,3 7,8- PentaCDF 1 0 ng /kg 0 05 0 05 ng /kg 2,3,4 7,8- PentaCDF 1 0 ng /kg 0 5 0 5 ng/kg 2,3,7 8- HexaCDF 1 0 ng/kg 0 1 0 1 ng/kg 2,3,7,8 HeptaCDF 1 0 ng /kg 0 01 0 01 ng/kg OctaCDF 1 0 ng/kg 0 001 0 001 ng/kg All other CDDs 1 0 ng/kg 0 0 ng /kg \\BECALVIN\VOL2 \WP \1834 \I 1934.DOC 3/5/98 Total TCDD TEQ 2.372 ng/kg Carcinogenic nsks are evaluated by multiplying the estimated average exposure rate i e Lifetime Average Daily Dose [LADD]) by the chemical's CSF (Equation A -3) The CSF converts estimated daily intakes averaged over a lifetime to incremental nsk of an individual developing cancer Because cancer risks are averaged over a person's lifetime, longer -term exposure to a carcinogen will result in higher risks than shorter -term exposure to the same carcinogen, if all other exposure assumptions are constant. Equation A -3. where: Risk LADD x CSF LADD= lifetime average daily dose (mg/kg -d) CSF cancer slope factor (mg/kg -d) -1 Revision No 1 Revision Date 02/28/98 Page 40 of 42 By combining Equation A -3 and Equation A -1, defining the acceptable risk level, and solving for CA, an action level can be calculated (Table A -3) The action level for 2,3,7,8 -TCDD (TEQ) was selected based on the lower of the two values calculated for carcinogenic and noncarcinogemc effects. \\BECALVIN\VOL2 \WP \1834 \11934 DOC 3/5/98 Table A -2 Calculation of Action Levels Based on Carcinogenic Risks to Adults on Site Resulting From Inhalation of Particulate Phase Chemicals During Mill Dismantling CA= TRL xBWxAT CSFxIRxETxEFxED Factor Value Units Description Reference CA See below Mg /m Chemical concentration in Air Particulate calculated value TRL 1 0 x 10 -5 Target Risk Level BW 70 AT 25550 CSF IR ET EF 50 ED 2 See below 133 5 Kilograms Days Risk/(mg/kg -day) M /day Days /week Weeks /year Years Chemical CSF 2,3,7,8 -TCDD (TEQ) 1 5 x 10 -5 (a) \\BECALVIMVOL2 \WP \1834 \1 1934.DOC ,/5/98 Body Weight, adult average Averaging Time (70 years x 365 days /year) Carcinogenic Slope Factor, chemical specific Inhalation Rate suggested upper bound estimate Exposure Time Exposure Frequency Exposure Duration Revision No 1 Revision Date 02/28/98 Page 41 of 42 Washington State Department of Ecology Model Toxics Control Act 173 340 -700 3 (b) EPA 1989 EPA 1989 EPA Health Effects Summary Tables EPA 1996 Dismantling Work Schedule EPA 1991 Planned Time Frame for Dismantling Work Schedule CA 1 79 x 10 mg /m or 17 9 pg/m3 Table A -3 Calculation of Action Levels Based on NonCarcinogenic Risks to Adults on Site Resulting From Inhalation of Particulate Phase Chemicals During Mill Dismantling CA TRL x R/D x BW x AT IR x ET x EF x ED Description Reference CA See below Mg /m Chemical concentration in Air Particulate calculated value TRL 1 Target Risk Level Factor Value Units RID See below BW 70 AT 730 IR= 13 3 ET 5 EF 50 ED 2 Chemical 2,3,7,8 -TCDD (TEQ) \\BECALVIN\VOL2 \WP \1834 \I 1934 DOC 3/5/98 Mg/kg body weight Kilograms Days M /day Days /week Week:Iyear Years RP 1 0x 10 -6 (a) Reference Dose, chemical specific Body Weight, adult average Averaging Time (2 years x 365 days /year) Inhalation Rate Exposure Time Exposure Frequency Exposure Duration Washington State Department of Ecology Model Toxics Control Act 173 340 -700 3 (b) See (a) below (a) No RID was available from the EPA. Value obtained was the lowest dose recommended by ATSDR (1997) Revision No 1 Revision Date 02/28/98 Page 42 of 42 EPA 1989 EPA 1989 EPA 1996 Worker Time Onsite Dunng Dismantling Work EPA 1991 Planned Time Frame for Dismantling Activities on the Site CA 7 68 x 10 mg /m or 7,680 pg /m3 RAYONIER PORT ANGELES SITE AMBIENT AIR MONITORING REPORT FOR FEBRUARY 1998 Prepared fOr• RAYONIER Port Angeles, WA Paul Pcrlwitz, PE, Environmental, Manager May 1998 FOSTER 1 WHEELER FOSTER WHEELER ENVIRONMENTAL CORPORATION AMBIENT' AIR MONITORING REPORT FOR FEBRUARY 1998 \\BECALVIN\VOL2 \WP \1 834112133 DOC 5/27/98 for the RAYONIER PORT ANGELES SITE Prepared for RAYONIER PORT ANGELES, WA Paul Perlwitz, PE, Environmental Manager Prepared by Foster Wheeler Environmental Corporation 10900 NE 8th Street Bellevue, WA 98004 -4405 May 1998 CONTENTS 1 INTRODUCTION AND SUMMARY 1 -1 1 1 PURPOSE AND OR ECTIVES 1 -1 1.2 SUMMARY OF RESULTS 1 -2 1 3 PLAN MODIFICATIONS 1 -5 2. RESULTS AND DISCUSSION 2 -1 2.1 CONSTRUCTION ACTIVITIES 2 -1 2.2 METEOROLOGICAL CONDITIONS 2 1 2.3 TOTAL SUSPENDED PARTICULATE CONCENTRATIONS 2 1 2.4 DIOXIN/FURAN CONCENTRATIONS 2 5 2.5 ASBESTOS MONITORING 2 5 2.6 LEAD MONITORING 2 -5 2 7 DEVIATIONS FROM THE MONITORING PLAN 2 -7 3 DATA QUALITY 3 -1 3 1 FLOW CHECKS 3 -1 3.2 TRIP BLANKS 3 -1 3.3 LABORATORY MEI'HOD BLANKS 3 -1 3 4 SURROGATE RECOVERY 3 2 3 5 LABORATORY CONTROL SPIKES 3 2 3 6 DATA COMPLETENESS 3 -2 4 REFERENCES 4 -1 APPENDIX A DAILY SL MMARY OF METEOROLOGICAL DATA APPENDIX B RAW DA IA (AVAILABLE FOR REVIEW AT PORT ANGELES PUBLIC LIBRARY UNDER SEPARATE COVER) \BECALVIN\VOL2 \WP \1834U2133.DOC 5/27/98 111 FIGURES Figure 1 Rayonier Port Angeles Site Air Monitonng Station Location Map 1 -3 TABLES Table 1 Dismantling Activities and Total Suspended Particulate (TSP) Air Monitoring Results 2 -2 Table 2. Dismantling Activities and Dioxin/Furan Air Monitoring Results 2 -4 Table 3 Dismantling Activities and Lead Air Monitoring Results 2 -6 Table 4. Dioxin/Furan Trip Blank Analysis Results 3 1 Table 5. Dioxin/Furan Laboratory Method Blank Analysis Results 3 2 \\BECALVIN\VOL2 \WP \1834 \12133 DOC 5/27/98 1V 1 1 PURPOSE AND OBJECTIVES 1 INTRODUCTION AND SUMMARY Rayomer is implementing an ambient air quality monitoring program during dismantling and cleanup activities at the former Rayonier Port Angeles pulp mill site The monitoring program was conducted as set forth in the Draft Ambient Air Work Plan and Procedures (Rayomer 1997) and the final fimbient Air Monitoring Plan (Foster Wheeler Environmental 1998) This report presents the results of the air monitoring activities for February 1998 \\BECALVIMVOL2 \WP \1834 \12I33.DOC 5/27/98 The objectives of the Ambient Air Monitoring Plan are 1 Monitor ambient air quality for potential air pollutants related to onsite activities, 2 Quantify potential of ['site transport of project- related emissions, and 3 Assess the effectiveness of onsite emission control methods used during dismantling and cleanup activities. The site is a former pulp mill facility located at 700 North Ennis Street, Port Angeles, WA. Rayonier received approval from the City of Port Angeles in July 1997 to dismantle its former pulp mill facility Following this approval, Rayomer voluntarily committed to develop and implement an air monitoring program Air monitoring commenced in October 1997 and is currently ongoing The air momtoring network consists of four sampling stations located as shown on Figure 1 Air monitoring is connducted for potential air pollutants that may be generated by site activities. The specific pollutants to be monitored and the sampling methods to be used are based on the site activities conducted during the monitoring period. Air quality action levels are es in the Ambient Air Monitoring Plan to use as an indicator of the effectiveness of onsite emission control methods used during dismantling and cleanup activities. In the e' Tent that single data point concentrations exceed the action limit criteria, the contingency plan described in the monitoring plan will be implemented. 1 -1 1.2 SUMMARY OF RESULTS The results of the February 1998 air momtoring show that the air emission control methods used during the dismantling work have been effective. The air samples collected around the perimeter of the work site were well below the air quality action levels that are used as indicators of effectiveness of emission controls. Total suspended particulate matter (TSP) monitors were operated at four sampling stations during eight monitoring events, lead samples were collected at four sampling stations during four monitoring events, and dioxin/furan monitors were operated at three sampling stations during four monitoring events. Lead monitoring was performed during this period to establish a baseline for lead concentrations during normal dismantling activities. No major lead containing structure dismantling activities were conducted during this period. The monitoring activities followed the procedures presented in the Ambient Air Monitoring Plan. A summary of the monitoring results follows TSP measurements for the eight monitoring events during February 1998 ranged from 2.8 µg /m to 14 7 µg /m the site action level is 150 gg /m Dioxm/furan measurements for the four monitoring events during February 1998 ranged from 0 0011 to 0 0068 pg /m the site action level is 17 6 pg /m (dioxin/furan concentrations are reported as 2,3,7,8- tetrachlorodibenzo p- dioxin [TCDD] equivalents [TEQs]), No visible emissions of asbestos from dismantling activities were observed during routine inspections, and Lead measurements for the four momtormg events during February 1998 were all below detection limits, the site action level is 1 51.1,g /m Onsite winds were generally light and primarily from the southeast through the southwest. Site activities during this penod included general dismantling, material handling, and asbestos removal The Washington State Department of Ecology, U S Environmental Protection Agency (EPA), and City of Port Angeles conducted several site visits and inspections during this reporting period. No mayor structure dismantling activities (e g recovery boiler stack dismantling, digester dismantling, hog fuel boiler dismantling) or site cleanup excavation activities occurred during February 1998 GAWP \1834 \12133.DOC 5/27/98 1 -2 FOSTER WHEELER ENVIRONMENTAL CORPORATION Strait of Juan de Fuca KEY TSP High Volume Air Sampler PS-1 High Volume Air Sampler Meteorological Monitoring Station :11 -irgiti4 ProlectAreae, Figure 1. Rayonier Port Angeles Site Air Monitoring Station Location Map I I t I 1 I I 1 I I I I I I I 1 I I I 1.3 PLAN MODIFICATIONS There are no plan modifications to be implemented based on the results of the February 1998 monitoring period. \\BECALVIMVOL2 \WP \1834 \I 133 DOC 5/27/98 1 -5 2 RESULTS AND DISCUSSION 1 1 1 2.1 CONSTRUCTION ACTIVITIES General dismantling and asbestos removal activities were underway during February 1998 These activities are presented along with the TSP monitoring data (Table 1) and with dioxin/furan monitoring; data (Table 2) Dismantling of asbestos-con ;wrung materials occurred throughout February 1998 at the Digestor Building, 5 and 6 Boilers and Recovery No major structure dismantling activities (e g recovery boiler stack dismantling, digester dismantling, hog fuel boiler dismantling, major lead containing structure dismantling, or site cleanup excavation activities) occurred during February 1998 2.2 METEOROLOGICAL CONDITIONS Onsite winds were generally light and pnmarily from the south southeast through the west during the February 1998 sampling events. A summary of the meteorological conditions during each samp ting event, in the form of wind rose figures, is presented in Appendix A. The monthly composite wind rose of the wind conditions during the monthly sampling events is also presented in Appendix A. 2.3 TOTAL SUSPENDED PARTICULATE CONCENTRATIONS The TSP monitoring results, along with the site activities on the sampling day are presented in Table 1 TSP monitoring events were conducted for approximately 24 hours starting in the morning on the date noted on Table 1 TSP measurements for the eight monitoring events during February 1998 ranged from 2.8 1.tg /m (Station 2 on February 25) to 14 7 µg /m (Station 4 on February 19) The site action level is 150 µg /m The highest TSP concentratio ns measured during February 1998 was 14 7 µg /m measured on February 19 at tation 4 (located south of the primary dismantling area) This TSP concentration is 10 percent of the 150 µg/m site action level. The three TSP measurements from the other monitors on February 19 were 12.4, 9.3, and 11 7 µg/m at stations 1, 2, and 3, respectively Wind conditions on February 19 were light to moderate and predominantly from the northeast. \BECALVIMVOL2 \WP \1834 \12133.DOC .5/27/98 2 -1 Table 1 Dismantling Activities and Total Suspended Particulate (TSP) Air Monitoring Results Page 1 of 2 Note: Total Suspended Particulate Site Action Level is 150 µg/m TSP Conc TSP Conc TSP•Conc TSP Conc Sample Station 1 Station 2 Station 3 Station 4 Date Dismantling Activities (1.1g /m (µg /m (µg /m (µg /m Feb 2 Salvage at Acid Plant area. Cleanup continues at East Roll 9 7 6 8 9 1 9 8 Storage area. Salvage going on inside Bleach and Purayonier buildings. Feb 4 Cleanup continues at Chip Storage and East Roll Storage areas. 5 9 4 9 7.2 8 6 Salvage work continuing in Acid Plant /Digester area. Truck traffic through the mill kicking up some dust as it was dry for a few days. Some activity with the shears at Beer Keg, located behind electrical shop Feb 9 Cleanup continues at Chip Storage and East Roll Storage areas 11 2 6 8 13 0 12 1 Trucks hauling debris off mill site both days during working hours. Crane using wrecking ball on buildings in Acid t\' Plant/Digester area. Steel being knocked off chemical storage tanks lying in old Hog Fuel area. Some work being done with shears in Woodmill area. Crew began removing metal sheet siding from Recovery Building. Feb 11 Work continuing on Recovery Building siding East Roll Storage 11 0 7 4 8 6 10 9 cleanup Trucks hauling from the area. Continuing work in Acid Plant/Digester area. Building demolition with crane and wrecking ball and shears. Feb 17 Loading steel onto barge west of mill site Cleaning up at East 11 0 6 7 9 9 12 5 N GAWP \1834 \I2I33T DOC •5/28/98 Roll Storage and Chip Storage areas. Removing siding from Recovery Building (north side) Shear working on concrete in Acid Plant area. O IIIII NM OM NM MO MN MI OM MI Table 1 Dismantling Activities and Total Suspended Particulate (TSP) Air Monitoring Results Note: Total Suspended Particulate Site Action Level is 150 µg /m Sample Date Dismantling Activities Feb 19 Crushing concrete at Acid Plant briefly in the morning. Loading steel into barge. Truck traffic to barge from log yard area, as a truck was being loaded with steel and hauling it on the main road through the mill to north of the Woodmill. It would then be dumped and picked up by crane to go into barge Late afternoon on Friday, after the TSP samplers were shut down but the Puf samplers were still running, the shear was taking out of the No 5 and 6 Brinks Filters. Siding being removed from north side of Recovery Building. Equipment removal from Finishing Room. This was just staging; no equipment was removed from the building yet. Feb 23 Hauling debris from Brinks Filter area. Removing siding from 6 9 north side of Recovery Building. Removing equipment from Sludge Building. Feb 25 Hauling wood debris from Woodmill area. Wrecking ball used 6 5 around the Acid Plant area. I.P contractors working in Finishing Room, removing equipment. Marcor removing Galbestos from Recovery Building. G. \WP \1834 \12133T.DOC .5/28/98 TSP Conc TSP Conc TSP Conc Station 1 Station 2 Station 3 (µg /m (1.tg /m (µg /m 124 93 117 40 2.8 81 74 Page 2 of 2 TSP Conc Station 4 (µg /m 147 96 77 N Table 2. Dismantling Activities and Dioxin/Furan Air Monitoring Results Note: Dioxin/Furan Site Action Level —17.6 pg/m TCDD TEQ Sample Dates Dismantling Activities Feb 2 Salvage at Acid Plant area. Cleanup continues at East Roll Storage area. Salvage going on inside Bleach and Purayonier buildings. Feb 9 Cleanup continues at Chip Storage and East Roll Storage areas. Trucks hauling debris off mill site both days during working hours. Crane using wrecking ball on buildings in Acid Plant/Digester area. Steel being knocked off chemical storage tanks lying in old Hog Fuel area. Some work being done with shears in Woodmill area. Crew began removing metal sheet siding from Recovery Building. Feb 19 Crushing concrete at Acid Plant briefly in the morning. Loading steel into barge. Truck traffic to barge from log yard area, as a truck was being loaded with steel and hauling it on the main road through the mill to north of the Woodmill. It would then be dumped and picked up by crane to go into barge. Late afternoon on Friday, after the TSP samplers were shut down but the Puf samplers were still running, the shear was taking out of the No 5 and 6 Brinks Filters. Siding being removed from north side of Recovery Building. Equipment removal from Finishing Room. This was Just staging; no equipment was removed from the building yet. Feb 25 Hauling wood debris from Woodmill area. Wrecking ball used around the Acid Plant area. I P contractors working in Finishing Room, removing equipment. Marcor removing Galbestos from Recovery Building. G: \WP \1834 \12133T.DOC •5/28/98 Dioxin/Furan TEQ Conc Station 1 (pg /m TEQ) 0 0017 0 0065 0 0036 0 0027 Dioxm/Furan TEQ Conc Station 2 (pg /m TEQ) 0 0039 0 0034 0 0045 0 0019 Dioxin/Furan TEQ Cone Station 3 (pg /m TEQ) 0 0025 0 0068 0 0043 0 0011 2.4 DIOXIN/FURAN CONCENTRATIONS The dioxin/furan monitoring results, along with the site activities on the sampling day, are presented in Table 2 Dioxm/furan monitoring events were conducted for approximately 24 hours staring in the morning on the date noted on Table 2 The dioxin/furan toxicity equivalents (TEQs) are calculated and reported using the EPA toxicity equivalence factors (TEFs) for the detected congeners, as described in the Ambient Air Monitoring Phn. The TEQs are calculated using the measured value for each detected congener If a congener was detected in some samples but not in others, a value of one -half the detects Dn limit was used for calculating the TEQs for those non- detected congeners. Dioxin/furan measurements for the four monitoring events during February 1998 ranged from a value of 0 0011 pg /n (Station 3 on February 25) to 0 0068 pg /m (Station 3 on February 9) The site action level is 17 6 pg /m The highest dioxin/furan concentrations measured during February 1998 was 0 0068 pg /m measured on February 9 at Station 3 (located southwest of the primary mill dismantling area) This highest dioxin/furan concentration is approximately four hundredths of one percent o the site action level. The doxm/furan TEQ measurements from the other monitors on ebruary 9 were 0 0065 and 0 0034 pg/m at Stations 1 and 2, respectively Wind conditio as on February 9 were moderate to high, with the highest wind predominantly from the north- northeast through the east. GAWP \1834 \12133.DOC 5/27/98 2.5 ASBESTOS MONITORING Visual inspection was conducted at site locations where asbestos containing material removal occurs, in accordance with the Ambient Air Monitoring Plan. No visible emission of asbestos from dismantling activities was observed based on reports from routine inspections by Rayomer and the dismantling contractor personnel. Asbestos monitoring is conducted to conform to the site action level of no visible emissions of asbestos. 2.6 LEAD MONITORING The lead monitoring results, along with the site activities on the sampling day, are presented in Table 3 Lead monitoring events were conducted concurrent with TSP monitoring events. Lead measurements for the four monitoring events during February 1998 were all below detection limits. The site action level is 1 5 µg/m 2 -5 O\ Table 3 Dismantling Activities and Lead Air Monitoring Results Note: Lead Site Action Level is 1.5 µg /m TSP Conc TSP Conc TSP Conc TSP Conc Sample Station 1 Station 2 Station 3 Station 4 Date Dismantling Activities (µg /m (µg /m (µg /m (µg /m Feb 2 Salvage at Acid Plant area. Cleanup continues at East Roll ND ND ND ND Storage area. Salvage going on inside Bleach and Purayonier buildings Feb 4 Cleanup continues at Chip Storage and East Roll Storage areas. ND ND ND ND Salvage work continuing in Acid Plant /Digester area. Truck traffic through the mill kicking up some dust as it was dry for a few days. Some activity with the shears at Beer Keg, located behind electrical shop Feb 9 Cleanup continues at Chip Storage and East Roll Storage areas. ND ND ND ND Trucks hauling debris off mill site both days during working hours. Crane using wrecking ball on buildings in Acid Plant /Digester area. Steel being knocked off chemical storage tanks lying in old Hog Fuel area. Some work being done with shears in Woodmill area. Crew began removing metal sheet siding from Recovery Building Feb 11 Work continuing on Recovery Building siding. East Roll Storage ND ND ND ND cleanup Trucks hauling from the area. Continuing work in Acid Plant/Digester area. Building demolition with crane and wrecking ball and shears. \\BECAL V I N \VOL2 \W P\ 1834\ 12133T DOC •5/28/98 OM EN NM r— r MI 111111 In OM r 2.7 DEVIATIONS FROM THE MONITORING PLAN 1 The final Ambient Air Monitoring Plan (Foster Wheeler Environmental 1998) was prepared subsequent to the February 1998 monitoring activities. The Draft Ambient Air Work Plan (Rayonier 1997) was prepared in October 1997 to support the initial air monitoring activities at the site The February momtoring program followed the procedures presented in the final Ambient Air Monitoring Plan. \\BECALVIN\VOL2 \WP\1834\12133 DOC 5/27/98 2 -7 1 3.1 FLOW CHECKS One point flow checks on tle air samplers were conducted before and after each dioxm/furan sample was collected, and before each TSP sample was collected. 3.2 TRIP BLANKS 3 DATA QUALITY Trip blanks were analyzed along with the regular TSP and dioxin/furan samples. Trip blanks indicate the level of (ontammation of the sample media during shipping and handling Eight TSP tnp blanks were analyzed during the February 1998 sampling period. The mass of the eight trip blanks ranged from not detected to 0 0007 g /sample Four dioxin/furan trip blanks were analyzed during the February 1998 sampling period. These results are presented on Table 4 Table 4. Dioxm/Furan Trip Blank Analysis Results Sample Date Dioxm/Furan TEQ Mass (pg /sample) February 2 None detected February 9 None detected February 19 None detected February 25 None detected Four lead trip blanks were a ialyzed during the February 1998 sampling period. Each was non detect. 3.3 LABORATORY METHOD BLANKS Four dioxm/furan laboratory method blanks were analyzed along with the field samples. Method blanks are laboratory quality control samples that monitor the concentration of contamination that may be it itroduced into field samples as a result of processing in the laboratory These results arc, presented on Table 5 G \WP \1834 \I2133.DOC 5/27/98 3 -1 Table 5. Dioxin/Furan Laboratory Method Blank Analysis Results Sample Date Dioxin/Furan TEQ Mass (pg /sample) February 2 February 9 February 19 February 25 None detected None detected None detected None detected Four lead method blanks were analyzed during the February 1998 sampling period. Each was non detect. 3 4 SURROGATE RECOVERY Surrogate compounds are also referred to as internal standards and are added to all field and laboratory quality assurance samples (method blanks, laboratory control spikes) A surrogate is a compound that is similar to the compound (or compounds) of interest, but that is not normally found in environmental samples. Surrogates are added to samples to monitor the effects of 1) the environmental matrix, 2) the sample preparation process, and 3) the analytical process on the recovery efficiency of sample contaminants. For February the average surrogate recovery rates were within the acceptable range of 50 to 150 percent. 3.5 LABORATORY CONTROL SPIKES Three laboratory control spikes (LCSs) were analyzed along with the field samples. The LCS is prepared using a "blank" matnx (such as a clean filter) A known quantity of all of the individual dioxin/furan isomers is added to the LCS sample. The LCS is processed through the same laboratory preparation and analysis steps as the field samples, and monitors the accuracy of the laboratory preparation and analysis process. Average February LCS recoveries were within the acceptable range of 50 to 150 percent. 3.6 DATA COMPLETENESS No samples were lost or broken in shipment and all submitted samples were analyzed. All data are considered usable. G \WP \1834 \12133.DOC 5/27/98 3 -2 4. REFERENCES Foster Wheeler Environmental Corporation. 1998 Ambient Air Monitoring Plan, Rayomer Port Angeles Site Prepared by Foster Wheeler Environmental Corporation, Bellevue, Washington. February 1')98 Rayomer 1997 Draft Ambient Air Work Plan and Procedures, Rayomer Port Angeles Facility Prepared by Rayomer, Pc rt Angeles, Washington. October 1997 \\BECALVIN\VOL2 \WP \1834 \I2133.DOC 5/27/98 4 -1 APPENDIX A DAILY SUMMARY OF METEOROLOGICAL DATA \\BECALVIN\VOL2 \WP\1834 \12133 DOC 5/27/98 1 I I I I I I I I I I I I I I I I I I A- G: \WP\1834 \12133.DOC 5/27/98 APPENDIX A DAILY SUMMARY OF METEOROLOGICAL DATA Wind rose figures for each ,sampling event are presented in this appendix (Figures A -1, A -2, and A -3) A wind rose depicts the Joint frequency of occurrence, in percent, of wind speed and wind direction categories for a particular location and time period. The radials of the wind rose indicate the direction from which the wind is blowing. The length of each radial indicates the frequency of occurrence for that direction, and the width of each radial indicates the wind speed cl iss. Each wind rose figure includes the period from when the first sampling monitor was turned on until the last momtor was turned off A composite wind rose of the meteorolo ;ica1 data during each sampling event is also presented. The wind roses are based on 10- minute observations obtained from the on -site meteorological monitoring station. A -1 February 2 N \\BECALVIN VOL2 \WP\1834 \12133.DOC 5/28/98 E WINO SPEED CLASSES (M /S) AVERAGE WIND SPEED (M /S) 0 February 9 N 20% 15%\ 10 S WINO SPEED CLASSES (M /S) O 1 3 3 5 5 7 7 -9 9 AVERAGE WINO SPEED (M /S) 2 33 g FOSTER WHEELER ENVIRONMENTAL CORPORATION A -2 February 4 WINO SPEED CLASSES (M /S) 0 312:1 c AVERAGE WINO SPEED (M /S) 51 February 11 S WIND SPEED CLASSES (M /S) 1 3 3 5 5 7 7 9 9 AVERAGE WIND SPEED (M /S) Figure A -1 Daily Wind Roses Sampled From February 2 to February 11 1998 February 17 N S WINO SPEED CLASSES 0 1 3 3 5 5 7 7 9 (M /S) AVERAGE WINO SPEEO (M /S) —O February 23 N S WIND SPEED CLAS O 1 -3 3 55-7 7 9 20% 15% 10% ES (M /S) >9 AVERAGE WIND SPEED (M /S) 2 0 AVERAGE WIND SPEED (M /S) g FOSTER WHEELER ENVIRONMENTAL CORPORATION BECALVIN\VOL2 \WP\1834 \121 5/28/98 A -3 February 19 N S WINO SPEED CLASSES O 1 3 55 -77 c N S WINO SPEED CLASSES 0 1 -3 3-55 7 7 -9 >9 C 20% 15% 10% AVERAGE WIND SPEED (M /S) February 25 (M /S) 20 15% 10%\ 0A/S) E 3 10 Figure A -2. Daily Wind Roses Sampled From February 17 to February 25 1998 W g FOSTER WHEELER ENVIRONMENTAL CORPORATION BECALVIN\VOL2 \WP\1834 \12133.DOC 5/28/98 February Monthly Composite N S WINO SPEED CLASSES (M /S) 1 -3 3-55-7 7 9 >9 m W AVERAGE WINO SPEEO (M /S) 1 81 A -4 Figure A -3 Daily Wind Roses Composite From February 1998 \BECALVIMVOL2 \WP\1834 \I2133.DOC 5/27/98' 1 1 1 APPENDIX B Note These raw data are available for review at Port Angeles Public Library Under Separate Cover \\BECALV[N\VOL2 \WP \1834 \12133.DOC 5/28/98 B -1