AIR MONITORING PLANDELATTE METALS SUPERFUND SITE

PONCHATOULA, TANGIPAHOA PARISH, LOUISIANAEPA ID NO. LAD052510344

Prepared for

U.S. ENVIRONMENTAL PROTECTION AGENCY1445 Ross Avenue

Dallas, Texas 75201-2733

Prepared by

Tetra Tech EM Inc.One Dallas Center

350 N. St. Paul Street, Suite 2600Dallas, Texas 75201

Work Assignment No. : 111-RA-RA-06DFEPA Region : 6Date Submitted : November 20, 2002Contract No. : 68-W6-0037Prepared by : Tetra Tech EM Inc.Tetra Tech Project Manager : Mr. Tim StartzTelephone No. : 214-740-2064EPA Work Assignment Manager : Mr. Stephen TzhoneTelephone No. : (214) 665-8409

CONTENTS

Section Page

i

ACRONYMS AND ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2.0 OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

2.1 METEOROLOGICAL CONDITIONS MONITORING . . . . . . . . . . . . . . . . . . . . . . . . 22.2 INTEGRATED AIR MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32.3 REAL-TIME AIR MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

3.0 ACTION LEVELS AND ASSOCIATED RESPONSE ACTIONS . . . . . . . . . . . . . . . . . . . . . . 3

3.1 PARTICULATE MATTER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33.2 LEAD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63.3 HYDROGEN SULFIDE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63.4 SULFUR DIOXIDE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63.5 OTHER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

4.0 MONITORING CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

5.0 INTEGRATED AIR MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

5.1 PARTICULATE MATTER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

5.1.1 Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85.1.2 Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85.1.3 Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85.1.4 Quality Assurance and Quality Control Requirements . . . . . . . . . . . . . . . . . . . . 9

5.2 LEAD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

5.2.1 Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95.2.2 Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105.2.3 Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105.2.4 Quality Assurance and Quality Control Requirements . . . . . . . . . . . . . . . . . . . 11

6.0 REAL-TIME AIR MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

6.1 PARTICULATE MATTER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

6.1.1 Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 126.1.2 Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

CONTENTS (Continued)

Section Page

ii

6.1.3 Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 126.1.4 Quality Assurance and Quality Control Requirements . . . . . . . . . . . . . . . . . . . 13

6.2 HYDROGEN SULFIDE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

6.2.1 Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 136.2.2 Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 136.2.3 Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 146.2.4 Quality Assurance and Quality Control Requirements . . . . . . . . . . . . . . . . . . . 14

6.3 SULFUR DIOXIDE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

6.3.1 Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 156.3.2 Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 156.3.3 Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 156.3.4 Quality Assurance and Quality Control Requirements . . . . . . . . . . . . . . . . . . . 16

6.4 OTHER SOURCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

7.0 PREVENTIVE MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

8.0 HEALTH AND SAFETY PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

9.0 ANALYTICAL ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

10.0 AIR SAMPLING AND MONITORING REPORT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Appendix

A AIR MONITORING DATA SHEETS

Attachment

A ANALYTICAL ANALYSIS METHODS

iii

TABLE

Table Page

1 SITE-SPECIFIC AIR MONITORING REQUIREMENTS AND ACTION LEVELS . . . . . . . . 4

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ACRONYMS AND ABBREVIATIONS

CM Construction managerCO Carbon monoxideDM Delatte MetalsEPA U.S. Environmental Protection AgencyHASP Health and Safety PlanH2S Hydrogen sulfideLEL Lower explosive limitmg/m3 Milligram per cubic meterml/min Milliliters per minuteNIOSH National Institute for Occupational Safety and HealthOSHA Occupational Safety and Health AdministrationO2 OxygenPM Particulate matterPM-10 Particulate matter less than 10 microns but greater than 1.0ppm Parts per millionQA/QC Quality assurance and quality controlRA Remedial actionRD Remedial designRI Remedial investigationS/S Solidification/stabilizationSHSO Site health and safety officerSTART Superfund Technical Assessment and Response TeamTetra Tech Tetra Tech EM Inc.TPSD Tangipahoa Parish Sheriff’s DepartmentTWA Time-weighted average

1

1.0 INTRODUCTION

This plan describes the air monitoring procedures that will be used during the remedial action (RA) at the

Delatte Metals (DM) site. The purpose of this air monitoring plan is to outline the procedures that will

be used to monitor potential air emissions resulting from activities at the site during the RA. Because of

the complexity of the remedial design (RD), these procedures may be modified during the RA to satisfy

unanticipated or changing conditions.

The RA for contaminated soil and sediment is excavation and treatment using on-facility

solidification/stabilization (S/S). The RA for contaminated ground water is treatment through a

permeable reactive barrier wall . The RA for the Delatte Metals site is to be implemented in accordance

with the U.S. Environmental Protection Agency’s (EPA) 2000 Record of Decision and the RD

specifications. Tetra Tech EM Inc. (Tetra Tech) will provide all necessary personnel, services, materials,

and equipment to provide the required management and analytical support.

Extensive air monitoring will be administered and monitored for all RA activities. Based on previous

information from Superfund Technical Assessment and Response Team (START) removal activit ies

(Ecology & Environment, Inc. [E&E 1996]) and the remedial investigation (RI), (Tetra Tech 2000), the

primary concern for workers on site is exposure to soil contaminated with high levels of lead. Previous

START removal activities indicate that exposure to nearby workers may present a safety hazard.

Additionally, exposure to workers associated with the Tangipahoa Parish Sheriff’s Department (TPSD)

vehicle maintenance operations may also present a safety hazard. The TPSD vehicle maintenance

operations currently occupy the former maintenance building located on the south side of the site.

Perimeter monitoring will be conducted during RA activities to ensure that dust generated during RA

activities does not result in off-site migration of contaminants to nearby residential areas and businesses.

This air monitoring plan will be used in conjunction with the site health and safety plan (HASP)

(Tetra Tech 2001). Unforseen gas emissions from soil excavation areas will also be addressed and

monitored with this air monitoring plan. Although it is difficult to quantify the types of potentially harmful

air emissions from soil disturbance areas, the air monitoring plan will be revised, if necessary, based on RA

activities and the HASP (Tetra Tech 2001). These revisions will be based on recommendations by the site

health and safety officer (SHSO) and must meet EPA approval.

2

A majority of RA activities at DM involve soil disturbance activities such as excavating and handling of

contaminated materials. Dust from these activit ies can be minimized using preventive measures, as listed

in Section 7.0. Airborne dust par ticles will be quantified and analyzed to ensure a safe workplace for

workers around these areas. Integra ted air monitoring will be used to monitor the dust levels as well as the

primary contaminant (lead) contained in the dust.

Real-time air monitoring will be conducted around the S/S unit, outside and inside the TPSD vehicle

maintenance operations building, and at other designated perimeter monitoring locations; confirmation

sampling will be conducted around excavated areas and other areas designated by the SHSO. Real-time air

monitoring provides real-time data (data returned by methods such as digital, dial, or calorimetric readings

within a very short time or continuously), which is used to determine if work practices should be changed

or engineering controls can be implemented immediately. The following sections describe the approach and

rationale for conducting air monitoring activities at the DM site.

2.0 OBJECTIVES

The overall objective of the air monitoring effort is to monitor contaminant levels in the ambient air to

determine whether airborne contaminants at the site exceed action level concentrations during RA activities.

Air monitoring will provide data to determine whether work practices must be altered or engineering

controls added to minimize off-site migration of unacceptable levels of airborne contamination.

2.1 METEOROLOGICAL CONDITIONS MONITORING

The objective of monitoring meteorological conditions is to collect sufficient meteorological data to

interpret air sampling data and to document that air was sampled or monitored in accordance with this plan

during the RA. At a minimum, temperature and barometric pressure will be recorded during each day of

on-facility activity. Temperature and barometric pressure will be recorded for use in converting air

volumes to standard temperature and pressure values. A meteorological station will be installed on facility,

and daily meteorological conditions will be recorded and documented.

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2.2 INTEGRATED AIR MONITORING

The objective of integrated air monitoring is to determine whether the RA activities were conducted in

compliance with action levels established herein. Integrated air monitoring will occur over an 8-hour work

period. Based on analytical results, integrated air monitoring samples that exceed an action level could

result in modifications to the work schedule. In addition, integrated air monitoring will be used in

conjunction with the HASP (Tetra Tech 2001).

2.3 REAL-TIME AIR MONITORING

The objective of real-time air monitoring is to determine, in a timely manner, whether unacceptable levels

of airborne contaminants exist at the site, the adjacent TPSD vehicle maintenance operations building, or

designated perimeter monitoring locations. The preferred method of air monitoring for unacceptable levels

of airborne contamination for an RA of relatively short duration is one that provides real-time data. This

method is preferred because when airborne contamination reaches unacceptable levels at the work site or

perimeter locations, work practices can be changed or engineering controls can be implemented

immediately.

3.0 ACTION LEVELS AND ASSOCIATED RESPONSE ACTIONS

This section presents action levels and associated response actions for air monitoring activities at the DM

site.

3.1 PARTICULATE MATTER

As shown in Table 1, the current Occupational Safety and Health Administration (OSHA) limit for total

particulate matter (PM) is 15 milligrams per cubic meter (mg/m3) for an 8-hour work period (integrated air

monitoring). This will be verified and measured by an analytical lab using pre-weighed filter cassettes and

a Gillian GilAir-5 Sampler, or an approved equal. All equipment operators around soil disturbance areas,

such as excavation or contaminated material handling areas, will be required to participate. Permanent

monitoring sta tions will also be established outside and inside the TPSD vehicle maintenance

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TABLE 1

SITE-SPECIFIC AIR MONITORING REQUIREMENTS AND ACTION LEVELS

Contamin ant or Ha zard Task Mon itoring Device Action Level Mon itoring Frequ ency Action

Organic vapo rs Ground water or

soil with a very

strong odor

PID Background to 5 ppm Every 30 to 60 minutes Use modified Level D PPE

5 to 100 ppm Every 30 m inutes Use Level C PPE (unless specific chem icals are

identified and evaluated using detector tube)

> 100 ppm NA Stop work and evacuate area; implement vapor

sup pres sion con trols

Hydrogen sulfide Stabilization/

Solidification area

02/CO/LE L/H 2S monitor > 20 ppm 2

Hou rly Stop work, evacuate area, and evaluate source

< 20 ppm 2

Continu e work

Sulfur dioxide Stabilization/

Solidification area

S02 monitor > 5 ppm 2

Hou rly Stop work, evacuate area, and evaluate source

< 5 ppm 2

Continu e work

Lead in dust Soil disturbance

(excavation and

material handling)

Personal air sampling > 0.05 mg/m3 1

8-hour work period Stop work, evacuate area, and evaluate source

0.03 - 0.0 5 mg/m3 1

Continue work with extreme caution

0 - 0.03 m g/m3 1

Continu e work

Oxygen-deficient or

enriched atm osphere

Confirmation

sampling

02/CO/LE L/H2S monitor $19.5 to #23.5% oxygen Hou rly Continu e work

<19.5% or >23.5% oxygen Stop work and evacuate area

Particulate Soil disturbance

(excavation and

material handling)

Personal air sampling >15 m g/m 3 1

8-hour work period Stop work and implement dust suppression

activities

7.0 - 15.0 mg/m3 1

Use Level C PP E and implemen t dust

suppression activities

0 - 7.0 m g/m3 1

Continu e work

Soil disturbance

(excavation and

material handling)

Particulate meter > 0.5 m g/m3 1

Hou rly Stop work and implement dust suppression

activities

0.3 - 0.5 m g/m3 1

Use Level C PP E and/or implement du st

suppression activities

0 -

0.3 m g/m3

1Continu e work

5

TABLE 1 (Continued)

SITE-SPECIFIC AIR MONITORING REQUIREMENTS AND ACTION LEVELS

Notes:

1 OSHA Recommended Exposure Limit (REL) through a time-weighted average (TWA) for up to an 8-hour period 2 OSHA Ceiling REL; value should not be exceeded at any time

CO Carbon monoxideLEL Lower explosive limit mg/m3 Milligram per cubic meterNA Not applicableOSHA Occupat ional Safety and Health Administra tionPEL Permissible exposure limitPID Photoionizat ion detectorPPE Personal protective equipmentppm Part per mi llion

6

operations building and designated perimeter monitoring locations. In addition, real-time air monitoring

will be used to provide immediate results. Generally, most real-time air monitors measure respirable

particulates between 1.0 and 10 micrometers in size (PM-10). The current hourly OSHA limit for

respirable particulate matter (PM-10) is 0.5 mg/m3.

3.2 LEAD

As shown in Table 1, the current OSHA limit for respirable lead dust is 0.05 mg/m3 for an 8-hour work

period (integrated air monitoring). This will be verified and measured by an analytical lab using

pre-weighed filter cassettes and a Gillian GilAir-5 Sampler, or an approved equal. All equipment operators

around soil disturbance areas, such as excavation or contaminated material handling areas, will be required

to participate. Permanent monitoring stations will also be established outside the TPSD vehicle

maintenance operations building and other designated perimeter monitor locations. To decrease cost, both

analyses will be obtained using the same pre-weighed filter cassette and air sampler. A time-weighted

average (TWA) for an 8-hour period of sampling will determine the particulate level, and a subsequent

analysis will be considered to determine lead content.

3.3 HYDROGEN SULFIDE

The current OSHA limit for hydrogen sulfide real-time air monitoring is 20 parts per million (ppm).

During RA activities, the SHSO will administer all real-time measurements.

3.4 SULFUR DIOXIDE

The current OSHA limit for sulfur dioxide real-time air monitoring is 5 ppm. During RA activities, the

SHSO will administer all real-time measurements.

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3.5 OTHER

The current OSHA limit for other possible air emissions are listed in Table 1. During RA activities, the

SHSO will administer all real-time measurements.

4.0 MONITORING CRITERIA

Air monitoring will occur during active periods of the RA and will include hand-held equipment for both

real-time and integrated air monitoring. The integrated air monitoring equipment will be located on or near

personnel who are near soil disturbance areas, such as excavation or contaminated soil handling areas.

Permanent monitoring stations will also be established outside and inside the TPSD vehicle maintenance

operations building and designated perimeter monitoring locations. Real-time air monitoring will be

administered by the SHSO when requested by RA personnel or when possible air emissions may be

present.

5.0 INTEGRATED AIR MONITORING

As discussed in Section 4.0, ambient air will be monitored for personnel participating in soil disturbance

activities at excavation or contaminated soil handling areas. Permanent monitoring stations will also be

established outside and inside the TPSD vehicle maintenance operations building and designated perimeter

monitoring locations. Any deviation or variations in the sampling frequency or the number of personnel

involved in the air monitoring plan will be dependent upon the analytical results and EPA approval.

Initially, all personnel working around soil disturbance activities will be required to participate.

Background samples, field blanks, and field duplicates will also be implemented initially.

5.1 PARTICULATE MATTER

Airborne dust will be present during RA and soil disturbance activities.

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5.1.1 Equipment

Total airborne PM concentrations will be collected during an 8-hour work schedule using hand-held air

sampling equipment on or near personnel. Using pre-weighed filter cassettes and a Gillian GilAir-5

Sampler, or an approved equal, air samples above the OSHA action limit for total dust (15 mg/m3) will be

determined. The air sampler will be calibrated once a day to a flow rate of 1,000 milliliters per minute

(ml/min) using a Gillian Gilbrator Calibrator, or equivalent.

5.1.2 Frequency

PM will be monitored continuously during RA activities at the soil disturbance areas, outside and inside the

TPSD vehicle maintenance operations building, and at designated perimeter monitoring locations unless

rain occurs during the 8-hour sampling period. In the case of rain, air monitoring will continue after the

rain has ceased, for the duration of the scheduled 8-hour sampling period or as advised by the construction

manager (CM). In addition, air monitoring will cease when fog or heavy mist is present. Initially, all

personnel around soil disturbance areas and the permanent areas outside the TPSD vehicle maintenance

operations building and designated perimeter monitoring locations will be required to participate in air

monitoring on a daily basis. Any deviation or variat ions in the sampling frequency or the number of

personnel involved in the air monitoring plan will be dependent upon the analytical results and EPA

approval. If the action levels are not exceeded for one month, the sampling frequency may change.

5.1.3 Procedures

Monitoring equipment will be operated in accordance with the manufacturer’s operating instructions. For

each air monitoring event, the following data processing procedures will be completed:

• The SHSO will complete, sign, and date the air monitoring log (Tables A-1 andA-2) immediately following each monitoring event.

• At a minimum, one field duplicate sample must be obtained on a weekly basis.

• At a minimum, one field blank and background sample must be obtained on a daily basis.

9

• Each sampler must be calibrated at least once a day to the flow rate of 1,000 ml/min. Thebattery for each sampler will be recharged overnight to ensure no power failure during the8 hours of air sampling.

• The sampling line, from the sampler to the pre-weighed filter cassettes, will be attached topersonnel by tape or other means.

• PM air monitoring data will be evaluated by the SHSO to determine if action levels wereexceeded.

• If action levels were not exceeded, the SHSO will sign, date, and file the log.

• If action levels were exceeded, the SHSO will inform the CM. The SHSO and CM willdevelop response actions for reducing emissions.

• Proposed response actions will be written on the logs, and the CM and the SHSO will signand date the log.

• After necessary signatures have been obtained, the PM monitoring log will be bound in athree-ring binder in chronological order and consecutively numbered by hand.

5.1.4 Quality Assurance and Quality Control Requirements

PM monitoring equipment will be calibrated in accordance with the manufacturer’s operating instructions.

Field blanks, field duplicates, and background samples will help provide a quality assurance and quality

control (QA/QC) basis for data interpretation.

5.2 LEAD

Airborne dust with high levels of lead may be present during RA and soil disturbance activities.

5.2.1 Equipment

The same equipment used for PM monitoring will be used to collect samples for lead analysis. To decrease

cost, PM and lead analysis will be obtained using the same pre-weighed filter cassette and air sampler. A

TWA for an 8-hour period of sampling will first determine the PM level followed by an analysis for lead.

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5.2.2 Frequency

Lead will be monitored continuously during RA activities at the soil disturbance areas, outside and inside

the TPSD vehicle maintenance operations building, and at designated perimeter monitoring locations unless

rain occurs during the 8-hour sampling period. In the case of rain, air monitoring will continue after the

rain has ceased for the duration of the scheduled 8-hour sampling period or as advised by the CM. In

addition, air monitoring will cease when fog or heavy mist is present. Initia lly, all personnel around soil

disturbance areas and the permanent areas outside and inside the TPSD vehicle maintenance building and

designated perimeter monitoring locations will be required to participate in air monitoring on a daily basis.

Any deviation or variations in the sampling frequency or the number of personnel involved in the air

monitoring plan will be dependent upon the analytical results and EPA approval. If the action levels are

not exceeded for one month, the sampling frequency may change.

5.2.3 Procedures

Monitoring equipment will be operated in accordance with the manufacturer’s operating instructions. For

each air monitoring event, the following data processing procedures will be completed:

• The SHSO will complete, sign, and date the air monitoring log (Tables A-1 andA-2) immediately following each monitoring event.

• At a minimum, one field duplicate sample must be obtained on a weekly basis.

• At a minimum, one field blank and background sample must be obtained on a daily basis.

• Each sampler must be calibrated at least once a day to the flow rate of 1,000 ml/min. Thebattery for each sampler will be recharged overnight to ensure no power failure during the8 hours of air sampling.

• The sampling line, from the sampler to the pre-weighed filter cassettes, will be attached topersonnel by tape or other means.

• Lead air monitoring data will be evaluated by the SHSO to determine if action levels wereexceeded.

• If action levels were not exceeded, the SHSO will sign, date, and file the log.

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• If action levels were exceeded (0.05 mg/m3), the SHSO will inform the CM. The SHSOand CM will develop response actions for reducing emissions.

• Proposed response actions will be written on the logs, and the CM and the SHSO will signand date the log.

• After necessary signatures have been obtained, the PM monitoring log will be bound in athree-ring binder in chronological order and consecutively numbered by hand.

5.2.4 Quality Assurance and Quality Control Requirements

Lead monitoring equipment will be calibrated in accordance with the manufacturer’s operating instructions.

Field blanks, field duplicates, and background samples will help provide a QA/QC basis for data

interpretation.

6.0 REAL-TIME AIR MONITORING

The SHSO will conduct real-time air monitoring during active RA activities. Areas monitored will include

the S/S area, areas where ground water or sediment is encountered, and outside the TPSD vehicle

maintenance operations building and designated perimeter monitoring location. The SHSO will also

conduct real-time air monitoring during the RA activities in other areas of concern when requested by RA

personnel or when air emissions may be present.

6.1 PARTICULATE MATTER

This section presents real-time air monitoring requirements for quantifying the levels of airborne particulate

particles in ambient air near site personnel or at locations designated by the SHSO. Based on previous data

obtained from the RI (Tetra Tech 2000), high levels of airborne particulate particles may be present

(1) during the S/S process, and (2) in or around soil disturbance areas.

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6.1.1 Equipment

A MIE pdr DataRAM™ monitor , or an approved equal, will be used to measure PM. Generally, real-time

air monitoring equipment measures respirable dust concentrations in the 1.0 to 10 micrometer size range

(PM-10). The OSHA permissible exposure level for respirable dust is 0.5 mg/m3.

6.1.2 Frequency

The SHSO will administer particulate readings once an hour during the S/S operation or soil disturbance

activities, unless rain is encountered during that period.

6.1.3 Procedures

Monitoring equipment will be operated in accordance with the manufacturer’s operating instructions. For

each air monitoring event, the following data processing procedures will be completed:

• Air monitoring personnel will complete, sign, and date the air monitoring log(Table A-6) immediately following each monitoring event.

• At a minimum, the air monitor will be calibrated once a day or before use with itscalibration gas.

• At a minimum, one duplicate instantaneous reading per week will be taken with aseparate monitor to compare instantaneous data from both meters . Theinstantaneous readings from both meters will be recorded on the log.

• The battery for the air monitor will be recharged to ensure no power failure.

• The SHSO will evaluate particulate air monitoring data to determine if actionlevels were exceeded (0.5 mg/m3).

• If action levels were not exceeded, the SHSO will sign, date, and file the log.

• If action levels were exceeded, the SHSO will inform the CM. The SHSO andCM will develop response actions for reducing emissions.

• Proposed response actions will be written on the logs, and the CM and the SHSOwill sign and date the log.

13

• After necessary signatures have been obtained, the PM monitoring log will bebound in a three-ring binder in chronological order and consecutively numbered byhand.

6.1.4 Quality Assurance and Quality Control Requirements

PM-10 monitoring equipment will be calibrated in accordance with the manufacturer’s operating

instructions. At least weekly, instantaneous PM-10 readings from the monitor will be verified with

instantaneous readings from a second air monitor. Both instantaneous meter readings will be recorded,

along with the check date on the air monitoring log, to document that the QA/QC check was performed and

to provide a QA/QC basis for data interpretation.

6.2 HYDROGEN SULFIDE

This section presents real-time air monitoring requirements for quantifying the levels of hydrogen sulfide in

ambient air near site personnel or at locations designated by the SHSO. Based on previous data obtained

from the RI (Tetra Tech 2000), hydrogen sulfide air emissions may be present during the S/S process.

6.2.1 Equipment

A Biosystems PHD Ultra O2/LEL/CO/H2S monitor, or an approved equal, will be used to measure all of

the following: (1) oxygen (O2); (2) carbon monoxide (CO); (3) lower explosive limit (LEL); and

(4) hydrogen sulfide (H2S).

6.2.2 Frequency

H2S readings will be administered by the SHSO once an hour during the S/S operation.

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6.2.3 Procedures

Monitoring equipment will be operated in accordance with the manufacturer’s operating instructions. For

each air monitoring event, the following data processing procedures will be completed:

• Air monitoring personnel will complete, sign, and date the air monitoring log(Table A-5) immediately following each monitoring event.

• At a minimum, the air monitor will be calibrated once a day or before use with itscalibration gas.

• At a minimum, one duplicate instantaneous reading per week will be taken with aseparate monitor to compare instantaneous data from both meters . Theinstantaneous readings from both meters will be recorded on the log.

• The battery for the air monitor will be recharged to ensure no power failure.

• The SHSO will evaluate H2S air monitoring data to determine if action levels wereexceeded.

• If action levels were not exceeded, the SHSO will sign, date, and file the log.

• If action levels were exceeded, the SHSO will inform the CM. The SHSO andCM will develop response actions for reducing emissions.

• Proposed response actions will be written on the logs, and the CM and the SHSOwill sign and date the log.

• After necessary signatures have been obtained, the PM monitoring log will bebound in a three-ring binder in chronological order and consecutively numbered byhand.

6.2.4 Quality Assurance and Quality Control Requirements

H2S monitoring equipment will be calibrated in accordance with the manufacturer’s operating instructions.

At least weekly, instantaneous PM readings from the monitor will be verified with instantaneous readings

from a second air monitor. Both instantaneous meter readings will be recorded, along with the check date

on the air monitoring log, to document that the QA/QC check was performed and to provide a QA/QC

basis for data interpretation.

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6.3 SULFUR DIOXIDE

This section presents real-time air monitoring requirements for quantifying the levels of sulfur dioxide in

ambient air near site personnel or at locations designated by the SHSO. Based on previous data obtained

from the RI (Tetra Tech 2000), sulfur dioxide air emissions may be present during the S/S process.

6.3.1 Equipment

An ISC SO261 Sulfur Dioxide Monitor, or an approved equal, will be used to measure sulfur dioxide.

6.3.2 Frequency

The SHSO will administer sulfur dioxide readings once an hour during the S/S process.

6.3.3 Procedures

Monitoring equipment will be operated in accordance with the manufacturer’s operating instructions. For

each air monitoring event, the following data processing procedures will be completed:

• Air monitoring personnel will complete, sign, and date the air monitoring log(Table A-3) immediately following each monitoring event.

• At a minimum, the air monitor will be calibrated once a day or before use with itscalibration gas.

• At a minimum, one duplicate instantaneous reading per week will be taken with aseparate monitor to compare instantaneous data from both meters . Theinstantaneous readings from both meters will be recorded on the log.

• The battery for the air monitor will be recharged to ensure no power failure.

• The SHSO will evaluate sulfur dioxide air monitoring data to determine if actionlevels were exceeded.

• If action levels were not exceeded, the SHSO will sign, date, and file the log.

• If action levels were exceeded, the SHSO will inform the CM. The SHSO andCM will develop response actions for reducing emissions.

16

• Proposed response actions will be written on the logs, and the CM and the SHSOwill sign and date the log.

• After necessary signatures have been obtained, the PM monitoring log will bebound in a three-ring binder in chronological order and consecutively numbered byhand.

6.3.4 Quality Assurance and Quality Control Requirements

Sulfur dioxide monitoring equipment will be calibrated in accordance with the manufacturer’s operating

instructions. At least weekly, instantaneous PM readings from the monitor will be verified with

instantaneous readings from a second air monitor. Both instantaneous meter readings will be recorded,

along with the check date on the air monitoring log, to document that the QA/QC check was performed and

to provide a QA/QC basis for data interpretation.

6.4 OTHER SOURCES

Although it is hard to identify and quantify air emissions from excavation areas, there are monitoring

devices that will detect different types of air emissions. The monitor used to measure hydrogen sulfide will

also be used to measure areas where CO might be present. During confirmation sampling, an O2 or LEL

reading will also be collected by the same monitoring device. Daily calibration with calibration gasses

should be administered by the SHSO to provide a QA/QC basis for data interpretation.

7.0 PREVENTIVE MEASURES

Preventive measures to control airborne dust emissions include frequent watering of on- and off-facility

roads. In addition, dust masks and respirators should be used by all personnel on dry, windy days when

there are soil disturbances around areas with high levels of contamination.

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8.0 HEALTH AND SAFETY PLAN

The air monitoring plan will be used in conjunction with the HASP (Tetra Tech 2001). Results from both

the integrated and real-time air monitoring will determine the level of protection for personnel working in

soil disturbance areas. In addition, the frequency and continuation of biological monitoring for lead will be

dependent upon analytical results.

9.0 ANALYTICAL ANALYSIS

Ambient air will be sampled and analyzed in accordance with National Institute for Occupational Safety

and Health (NIOSH) method number 0500, Particulates Not Otherwise Regulated, Total and NIOSH

method number 7300, Elements by ICP to determine total dust and lead emissions, respectively

(Attachment A).

10.0 AIR SAMPLING AND MONITORING REPORT

Daily Air Monitoring/Sampling Summary Form 0401 will be completed on each day of air sampling or

monitoring. Form 0401 will be attached to individual monitoring data sheets as part of a daily air

monitoring report. Daily air monitoring reports will be bound and consecutively numbered in chronological

order to form a comprehensive air monitoring report. Following completion of the RA, the comprehensive

air monitoring report will serve as the record of the air monitoring and sampling activities conducted during

the RA. In addition, daily meteorological conditions will also be included in the report.

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REFERENCES

Ecology & Environment, Inc. 1996. “Removal Support Report, Ponchatoula Battery, Ponchatoula,Tangipahoa Parish, Louisiana.” January.

National Institute of Occupational Safety and Health. 1997. Manual of Analytical Methods, FourthEdition.

Tetra Tech EM Inc. 2000. “Remedial Investigation Report, Delatte Metals, Ponchatoula, TangipahoaParish, Louisiana.” January.

Tetra Tech EM Inc. 2001. “Health & Safety Plan, Delat te Metals, Ponchatoula, Tangipahoa Parish,Louisiana.” December.

APPENDIX A

AIR MONITORING DATA SHEETS

(Seven Sheets)

TABLE A-1

DELATTE METALSTETRA TECH EM INC

PERSONNEL PUMP FIELD DATA SHEET

A-1-1

DateTime

(on/off)

Pre-TestCalibration Flow (l/min)

Pre-TestCalibration

Average Flow (l/min)

Post-TestCalibration

Flow(l/min)

Post-TestCalibration

AverageFlow

(l/min)

AverageCalibration

Flow(l/min)

TotalTestTime

(mins)

TotalSample Volume (liters)

PumpSerial

NumberFilter

NumberSample ID

NumberEmployee

Wearing Sampler

Calibrated by:_________________________

Chain of Custody #:_____________________

Date sent to Lab:________________________

Valid Pre-Test and Post-Test leak check: ____ yes ____ no All samples were sent to Pace Analytical Laboratory (504-469-0333) in St. Rose, LA for analysis

A-2-1

TABLE A-2

SUMMARY OF ANALYTICAL TESTING OF PERSONNEL AIR SAMPLINGFOR PM and TOTAL LEAD

DELATTE METALS

Sample Identifi cation PM (mg/m3)OSHA 8-HourTWA for PM Total Lead (mg/m3)

OSHA 8-HourTWA for

LeadPersonnel Wearing

Sampler Activity

Date:

15.0 mg/m3 0.05 mg/m3

Date:

15.0 mg/m30.05 mg/m3

A-3-1

TABLE A-3

DELATTE METALSTETRA TECH EM INC

SULFUR DIOXIDE DATA SHEET

Date Time Actual Reading Action Limit Administered by Activity

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

A-4-1

TABLE A-4

DELATTE METALSTETRA TECH EM INC

OXYGEN/LEL MONITORING DATA SHEET

Date Time Actual Reading Action Limit Administered by Activity

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

< 19.5 % or >23.5% O2

A-5-1

TABLE A-5

DELATTE METALSTETRA TECH EM INC

HYDROGEN SULFIDE MONITORING DATA SHEET

Date Time Actual Reading Action Limit Administered by Activity

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

20 ppm

A-6-1

TABLE A-6

DELATTE METALSTETRA TECH EM INC

HOURLY PARTICULATE MONITORING DATA SHEET

Date Time Actual Reading Action Limit Administered by Activity

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

0.5 ppm

A-7-1

TABLE A-7

DELATTE METALSTETRA TECH EM INC

PID DATA SHEET

Date Time Actual Reading Action Limit Administered by Activity

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

5 ppm

ATTACHMENT A

ANALYTICAL ANALYSIS METHODS

(18 Sheets)