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2.1.1 Narrative
2.1.2 Response Actions to Date
2.1.2.1 Actions During Reporting Period
Over the week beginning the December 7, 2015 work focused
primarily on the following activities:
- Revising
the site health and safety plan
- Finalizing the site air monitoring plan and implementing air monitoring
- Continuing to clear non-hazardous debris from within the building
- Cleaning areas for
dress out and decontamination lines
- Establishing the exclusion
and contamination reduction zones
- Beginning work to stage
containers, sample containers and categorize container contents
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Continuing work to decontaminate building floors
Additionally, the ERRS chemist and three members of the USCG Atlantic Strike Team mobilized to the site this week. The Strike Team is assisting with air monitoring and removal oversight. We also mobilized the EPA air trailer to the site to refill SCBA bottles.
2.1.2.2 Air Monitoring
Every day that cleanup activity work will be ongoing, air monitoring will be conducted to ensure public and worker safety. Chemical hazards due to fugitive emissions from removal activities are anticipated to be low since the crew will employ administrative and engineering controls to minimize fugitive emissions and particulates that migrate off-site.
Meteorological data will be obtained daily from the NWS website that provides current weather conditions and documented in the site logbook.
A website has been established to view the
current and past air monitoring data for the site. To view the data
go to the web address: viper.ert.org. You have to create a login on your first
visit to the site. Once logged in, go to the R05 Hard Chrome Metals Deployment
to view site data.
Particulate Air Monitoring:
Datarams (DR4) are deployed daily at three fixed
locations in each direction along the site perimeter boundaries where off-site
receptors are most at risk to exposure from fugitive emissions, and at one
location within the building in the work zone. Real-time PM-10 particulate data
is transmitted back to the site command post where it is monitored
continuously.
The perimeter action level for PM-10
particulates has been set at 150 micrograms per cubic meter (μg/m3), averaged
over the work day. The work zone action level is 2.5 milligrams per cubic meter
(mg/m3) averaged over the work day. Should a DR4 unit detect sustained
particulate concentrations above the action levels, the source of emissions
will be investigated, and administrative and/or engineering controls will be
initiated to reduce the particulate emissions.
During the week of December 7, 2015, no exceedances of the perimeter or work zone action levels (calculated as work day averages) for particulates were
detected.
MultiGas Air Monitoring:
RAE Systems, Inc. AreaRAE multi-gas
monitors are being deployed in the work zone in the building and at 3
perimeter locations during any chemical handling. The AreaRAE multi-gas
monitors will be used to monitor oxygen (O2) in percent, hydrogen sulfide (H2S)
in ppm, hydrogen cyanide (HCN) in ppm, VOCs (ppm), and percent lower explosive
limit (LEL). Real-time multigas data are transmitted back to the site command
post where they are monitored continuously.
The perimeter action levels are as follows:
·
H2S = 0.5 ppm
%LEL = >5%
VOCs > 5 ppm for 5 minutes
HCN = 2.3 ppm
%O2 – Less than 19.5% or greater than 23.5%
Work zone action levels are available in the Air Monitoring
Plan (see documents section of epaosc.org/hardchromeplating).
Several MultiRAE Plus 5-gas monitors (loaded with
sensors for detection of oxygen, carbon monoxide, hydrogen sulfide, LEL, VOCs, and two with HCN) will be used to monitor for carbon monoxide (CO) in ppm, and periodically
spot check AreaRAE data. Ammonia (NH3) and HCN GasAlert monitors
will also be used continuously in the work zone during chemical handling.
Over this reporting period, we identified a problem with several sensors in the AreaRAEs, which were resulting in readings we were unable substantiate with other equipment. We replaced numerous sensors and modified the calibration methods, and it appears that we have now rectified the problems.
Hydrochloric Acid Monitoring
On December 11, we deployed 4 Honeywell Analytics Single Point Monitors (SPM
Flex) to conduct continuous monitoring of HCL
in the contamination reduction zone and along the site perimeter. Prior to deployment of the SPM Flex units, we conducted regular monitoring of HCL with Draeger Chipsets at the perimeter monitoring stations and in the contamination reduction zone. The crew is also using pH paper for acid monitoring in the work zone. The perimeter action level for HCL = 1.8 ppm. No detections were identified during this monitoring during this reporting period.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
General notice letters were issued to former owners of the property. Investigation is ongoing.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Solid |
Non-Hazardous Debris |
8 Tons |
n/a |
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x |
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