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
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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
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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
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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
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Revision No 1
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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
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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
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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
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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.
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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
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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.
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Potential corrective actions include
Additional watenng
Saturation watering
Modification of construction activities
Suspension of construction activities
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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.
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5.3 Reporting
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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.
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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.
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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
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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
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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
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7.2 Dioxin /Furan Monitoring
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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
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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
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ring
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7 7 Polychlorinated Biphenyl Monitoring
Reserved
7 8 Volatile Organic Carbon Monitoring
Reserved
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8 0 Meteorological Monitoring
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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.
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90 REFERENCES
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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
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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
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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.
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Each of these steps are discussed in detail below
A.1 1 Identification of Land Use and Potentially Exposed Populations
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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.
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A.1.3 Quantifying Exposure
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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
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(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
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A.2 Toxicity Assessment
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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.
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A.2.1 Toxicity Assessment for Non Carcinogenic Effects
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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.
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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
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APPENDIX A
DAILY SUMMARY OF METEOROLOGICAL DATA
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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
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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
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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
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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
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APPENDIX B
Note These raw data are available for review at Port Angeles Public
Library Under Separate Cover
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