Ambient Air Monitoring Protocol - ergweb.com1.1 Purpose of the Project/Air Monitoring Program The...

Ambient Air Monitoring Plan CONFIDENTIAL

Prepared by Strategic Technology Enterprises, Inc. & Shaw Environmental & Infrastructure Inc.

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Ambient Air Monitoring Plan for Fumigation of Department of State SA-32 Diplomatic Pouch and Mail Facility Sterling, VA



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Table of Contents 1 Introduction ........................................................................................................................6

1.1 Purpose of the Project/Air Monitoring Program........................................................6 1.2 Facility Description....................................................................................................7 1.3 Fumigation Process....................................................................................................7 1.4 Negative Air System..................................................................................................8

2 Source Environment and Meteorology...............................................................................9 2.1 Topographical Description.........................................................................................9 2.2 Land Use ....................................................................................................................9 2.3 Climatological Description ........................................................................................9 2.4 Dispersion Modeling................................................................................................10 2.5 Background Air Quality...........................................................................................11

3 Monitoring Program Description .....................................................................................11 3.1 Monitoring Areas .....................................................................................................11 3.2 Air Monitoring Objectives.......................................................................................16 3.3 Protective Measure Criteria .....................................................................................17 3.4 Parameters to be Measured ......................................................................................18 3.5 Implementation Schedule/Duration of Program ......................................................19 3.6 Sampling Frequency by Parameter ..........................................................................20 3.7 Monitoring Program Organization...........................................................................20

4 Monitoring Site Description.............................................................................................25 4.1 Monitoring Site Criteria - 40 CFR 58 ......................................................................25 4.2 Specific VHP Instrument Locations ........................................................................26 4.3 Meteorological Monitoring Station Location ..........................................................29

5 Monitoring Equipment Description..................................................................................30 5.1 Stationary, Continuous-Reading Instruments ..........................................................30 5.2 Mobile Instruments ..................................................................................................31 5.3 Known Interference Factors.....................................................................................32 5.4 Other Equipment for Routine Operation..................................................................32 5.5 Calibration and Checks of Instruments .....................................................................37

6 Data Collection Assessment and Reporting .....................................................................41 6.1 Data Assessment and Review ..................................................................................42



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6.2 Validation of Data....................................................................................................46 6.3 Data Report Format ...................................................................................................47 6.4 Final Data Submittal..................................................................................................48 6.5 Ambient Air Monitoring Data Evaluation.................................................................49

7 Other Quality Assurance Elements ..................................................................................49 7.1 Corrective Actions ...................................................................................................49 7.2 EPA Contingency Plans ............................................................................................54 7.3 Performance and System Audits..............................................................................60 7.4 Reports to Management.............................................................................................62

8.0 References.........................................................................................................................63

ATTACHMENTS

1. Negative Air Machine Catalyst Scrubber Technical Information 2. SA-32 Facility Site Schematic 3. Annual Wind Rose for Dulles Airport Meteorological Station 4. Draeger Hydrogen Peroxide Polytron 2 Product Information & Technical Data 5. Zellweger Single Point Monitor Product Information 6. Draeger PacIII Hydrogen Peroxide Handheld Monitor Product Information 7. Zellweger Single Point Monitor Verification Log and Field Monitoring

Worksheet 8. EPA-ERT Meteorological Instrument Specifications



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List of Figures Figure 1. SA-32 Facility Immediate Building Area Monitoring Locations................................. 13

Figure 2. SA-32 Facility Support Zone Area Monitoring Locations........................................... 13

Figure 3. SA-32 Facility Off-Site Area Monitoring Locations.................................................... 14

Figure 4. Ambient Air Monitoring Project Team ........................................................................ 21

Figure 5. SE&I/STE Corrective Action Request Form ............................................................... 51

Figure 6. SE&I/STE Corrective Action Request Tracking Log .................................................. 51

Figure 7. EPA Non-Conformance/Corrective Action Form........................................................ 58

Figure 8. EPA Work Assignment Field Change Form ................................................................ 59

List of Tables

Table 1. Support Zone Persistent Readings Action Criteria ........................................................ 17

Table 2. Off-Site Area Persistent Readings Action Criteria ........................................................ 17

Table 3. Data Quality Measures and Criteria............................................................................... 40


List of Acronyms AAMP Ambient Air Monitoring Plan AMC Ambient Monitoring Coordinator CFM Cubic Feet per Minute CFR Code of Federal Regulations DAS Data Acquisition System DoS Department of State DQO data quality objective EPA U.S. Environmental Protection Agency FADL Field Activity Daily Logs ft foot or feet HEPA High Efficiency Particulate Air [Filter] ICS Incident Command System LCFR Loudoun County Department of Fire, Rescue and Emergency Services LDL Lower Detection Limit MET meteorological NAM Negative Air Machine NO2 nitrogen dioxide NWS National Weather Service OHSA Occupational Safety and Health Administration PM Project Manager ppbv parts per billion by volume ppmv parts per million by volume QA quality assurance QAC Quality Assurance Coordinator QAPP Quality Assurance Program Plan QC quality control SE&I Shaw Environmental & Infrastructure, Inc. SOP standard operating procedure SPM Single Point Meter STE Strategic Technology Enterprises, Inc. TD Technical Director USGS U.S. Geological Survey VADEQ Virginia Department of Environmental Quality VHP Vaporized Hydrogen Peroxide UC Unified Command


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1 Introduction This Ambient Air Monitoring Plan (AAMP) has been prepared by Shaw Environmental & Infrastructure, Inc. (SE&I), the U.S. Environmental Protection Agency (EPA), and Strategic Technology Enterprises, Inc. (STE) for use and reference during the fumigation of the DoS SA-32 Diplomatic Pouch and Mail Facility (“SA-32 Facility”) in Sterling, VA. STE, a subsidiary of STERIS Corporation, will perform the fumigation of the SA-32 Facility by employing STERIS’ Vaporized Hydrogen Peroxide (VHP®) technology. While fumigation levels of hydrogen peroxide vapor are at relatively low concentrations and will be contained within the partitioned zone, additional hydrogen peroxide instruments will be placed around the facility and beyond the facility boundaries to monitor for any potential hydrogen peroxide release. This AAMP contains the plan for monitoring these areas. Specifically, this plan includes the following sections:

1. Source Environment and Meteorology 2. Monitoring Program Description 3. Monitoring Site Description 4. Monitoring Equipment Description 5. Data Collection Assessment and Reporting 6. Additional Quality Assurance Elements

The scope of this project does not represent a typical application of an ambient monitoring program, as the potential release in the event of a fumigation incident will not exceed the Virginia Department of Environmental Quality (VADEQ) de minimus levels of emissions as stated in 9 VAC 5;60. However, Federal ambient monitoring regulations found in 40 CFR Part 58 have been referenced where relevant. 1.1 Purpose of the Project/Air Monitoring Program The project task entails the fumigation of the SA-32 Facility with VHP1. STE will perform this fumigation by utilizing a large-scale optimized VHP System to systematically fumigate partitioned zones of the SA-32 Facility, sized appropriately to match the VHP System’s capabilities. The SA-32 Facility will be partitioned into seven (7) zones, with each zone approximately 200,000 cubic feet, and the VHP System generator will be installed outside the northwest corner of the building. Ducting will be used to deliver and return VHP throughout the building. Fumigation will be performed in a step-wise fashion for each of the seven partitioned zones. The fumigation process is expected to take 7-9 weeks at an estimated enclosure fumigation rate of one enclosure for every 5 days. Since there is the potential for release of VHP, an irritant, during routine fumigation operations and if problems arise, this AAMP has been developed to monitor and record any VHP concentrations outside of and beyond the facility. The AAMP’s intended purpose is to determine VHP concentrations in real-time in the interest of public health protection and for purposes of 1 Note: For a detailed description of the fumigation process, please refer to the STE’s Remedial Action Plan for Fumigation of the SA-32 Diplomatic Pouch and Mail Facility, Sterling, VA.


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documenting any potential exposures or the absence of such events. This Plan also describes air monitoring action criteria designed to minimize any potential exposure to the public. The elements of the AAMP will be executed throughout the fumigation of each of the seven zones. 1.2 Facility Description The SA-32 Facility, is the sorting, collection, and distribution point for U.S. mail and parcels destined for U.S. Embassies and Institutes abroad. The building is a privately owned space located in a commercial/warehouse park at 44132 Mercure Circle in Sterling, Virginia. The facility covers approximately 70,000 square ft with 20 ft ceilings resulting in a total volume of approximately 1.4 million cubic ft. At the time of the fumigation virtually all of the removable and porous materials will have been removed and decontaminated or destroyed. Therefore, during the fumigation phase, the building interior shell will be all that remains. A security fence surrounds the property at an average perimeter distance of 75 ft from the building. 1.3 Fumigation Process The fumigation will be sequentially performed for each of the seven (7) partitioned zones of the SA-32 Facility. The process is expected to take approximately 7-9 weeks, based upon an assumed pace of one fumigated zone per five days. The fumigation will be performed by generating vaporized hydrogen peroxide within a VHP generator system, which is then circulated to and from the zone by ducting. Within each zone, circulation fans will be employed to effectively distribute the VHP throughout the zone, including difficult to reach areas.

The VHP cycle includes four phases:

1. Dehumidification,

2. Conditioning,

3. Decontamination, and

4. Aeration.

[These four phases are discussed in detail in the RAP.] Throughout the VHP cycle, the air is circulated from the zone back to the VHP generator system where it is passed through a catalytic bed that reduces any remaining hydrogen peroxide to non-toxic by-products of oxygen and water. After the VHP decontamination phase is complete, the cycle enters the fourth phase, Aeration, in which the VHP introduction is stopped and the VHP within the zone is reduced to safe levels [less than 1.0 ppmv (0.0014 mg/L)], as measured in the return line of the VHP system. The VHP is reduced during this phase by the continued air circulation through the VHP system’s catalytic bed, which reduces the hydrogen peroxide to non-toxic constituents, water and oxygen. The ambient air monitoring will be performed throughout this entire VHP cycle and will end when the VHP concentration inside a fumigate zone has reached less than 1.0 ppmv.


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Conceptually, the fumigation process will consist of the following steps:

• All building openings have been sealed with QC tested critical enclosures.

• The HVAC units have been removed and their roof openings sealed with QC tested critical enclosures.

• All porous and non-fixed materials, except some plumbing fixtures, water heaters, and similar items have been removed from the building and either sanitized and relocated for use or disposed of.

• During fumigation each zone will be pre-conditioned to maintain desired temperature of ≥70ºF and humidity of ≤40%.

• VHP produced in a generator system outside the building will be pumped through a ducting system into the building and to and from the enclosed zone being fumigated

• After the VHP concentration inside the zone has reached ≥0.3 mg/L (ramp-up time), the concentration will be maintained for a minimum of 240 minutes (4 hours).

• After the treatment, VHP injection will be stopped and the VHP contained in the enclosure will be circulated through the VHP system’s catalyst scrubber converting the VHP to non-toxic water and oxygen.

• The process will be concluded after the VHP inside the enclosure reaches acceptable levels for site workers to re-occupy, established as less than 1 ppmv (0.0014 mg/L). In total, the VHP dehumidification and conditioning, decontamination and aeration phases of the cycle are expected to be completed within 10-14 hours, depending on ambient conditions and zone configuration and circulation.

1.4 Negative Air System While each partitioned area is being fumigated, the portions of the building not being fumigated will be subjected to a slight negative pressure by exhausting approximately 5,000 cfm through a HEPA-filtered Negative Air Machine (NAM). The HEPA filter will capture any submicron particulates that might become entrained in the “negative” air. This NAM is the same one that has been utilized during the waste removal and processing stages of the cleanup. The NAM has and will remain in operation 24/7 and fumigation will only be conducted if the NAM is fully operational. The NAM will be modified with the addition of a catalytic scrubber, provided by STE, to remove fugitive VHP from the building air before it is exhausted. This scrubber will be sized to convert the amount of VHP that would possibly be present in the building in the event of enclosure wall failure while at maximum VHP concentration. See Attachment 1 for a description of the catalytic scrubber.


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2 Source Environment and Meteorology This section describes key features within the vicinity of the SA-32 Facility that influence the selection of ambient monitoring locations. See Attachment 2 for a schematic of the SA-32 Facility and refer to Figures 2 and 3 for photographs of the surrounding areas. 2.1 Topographical Description The facility property is generally flat. However, the facility sits on a small plateau approximately 20 feet below the property to the south. The property to the north is on the same plain and separated by the facility fence. The property to the north is located approximately 200 feet from the building itself. The topography of the surrounding area is gently rolling and slopes towards the northeast. Fencing and a foliage barrier separate the commercial properties above the facility. Dense vegetative growth and trees separate the residential properties approximately 500 feet to the north. 2.2 Land Use Land use in the vicinity of the building is commercial to the northeast, east, and southeast, with a residential area approximately 500 feet to the northwest. The area to the west is currently undeveloped. 2.3 Climatological Description The climatic pattern of the area is typical of the Mid Atlantic region. There are no special terrain features near the facility affecting the wind pattern or temperature. The Atlantic Ocean is located approximately 140 miles due east and has no significant effect on the wind pattern. Similarly, the Delaware River Bay, located approximately mid-way between the site and the Atlantic coast, is not expected to affect the wind pattern. Two metropolitan cities, Washington D.C. and Baltimore, are located within 50 miles of the facility. These urban areas may influence the atmospheric mixing height in the area, especially in summer, due to the urban heat island effect. Several meteorological monitoring stations in Virginia, Washington D.C., and Maryland were evaluated for availability of representative meteorological data. National Weather Stations (NWS) closest to the facility are:

• Dulles International Airport • Reagan National Airport

Meteorological data from Dulles International Airport (Dulles) was considered most representative of the SA-32 Facility due to its proximity (within six kilometers of the facility)


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and overall similarity in terrain. Dulles or Sterling, VA meteorological data are available from the following sources:

• NWS data as supported by the USEPA Office of Air Quality Planning and Standards • NWS data as supported by the Southeast Regional Climate Center • NWS data as supported by on-line resources, such as, Weather Undergound, Inc. and

Accuweather, Inc. • National Oceanic and Atmospheric Administration (NOAA) data as supported through

the National Climatic Data Center (NCDC) A summary of the data available from these sources (primarily as published in Climatic Averages and Extremes for U.S. Cities, May 1991, NOAA) is presented below. Annual precipitation in the area averages 40.4 inches. Average precipitation for the months of May through August ranges from 3.6 to 4.1 inches per month. Maximum precipitation for the same period is between 7 and 10 inches per month. Fog/mists occur mostly in the winter months but occasional foggy/misty days can occur anytime in the year including in the months of May-August. Visibility in the vicinity of Dulles ranges from 10 miles during clear days to 0.1 miles during foggy days. Winds are routinely from the south and are variable from the south-southeast to the south-southwest. During the summer months there is a variability of the average wind direction on a diurnal basis. During the day the winds are directly out of the south, but shift to the southeast during nighttime hours. Attachment 3 contains a five-year wind rose for the years 1984 – 1992. This wind rose represents the most recently available data supported by the USEPA through the NWS. The wind parameters show northeasterly winds during one-minute observations peaking to 55 miles per hour (mph), but the predominant southerly winds are on average in the range of 6 to 8 mph during the summer months. Calm conditions are routinely near 9 percent. This same wind profile is expected at the SA-32 Facility primarily because of its close proximity to Dulles, and additionally that there are no significant terrain differences between the two locations. 2.4 Dispersion Modeling The development of an effective ambient air monitoring system is dependent in large part on predictive atmospheric dispersion modeling of emitted pollutants from sources under consideration. Dispersion coefficients are required to model atmospheric dispersion. The selection of the dispersion coefficients (rural/urban) and wind profile exponents was based on the “land-use” procedure. The procedure requires characterizing the land-use of the area (Ao), circumscribed by a 3-kilometer radius from the mid-point. The characterization is based on a simplification of Auer’s land-use typing scheme presented in 40 Code of Federal Regulations (CFR) Part 266, Appendix IX, section 6 (Boilers and Industrial Furnace Regulations). This simplified procedure is based on interpreting percent land-use from color-


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code designations on United States Geological Survey (USGS) maps. The Sterling, VA area has clear-cut rural or urban land-use classification making the simplified procedure appropriate for this analysis. Based upon this analysis, rural dispersion coefficients would be appropriate if the dispersion model was for complex sources emitting plumes that would impact receptors at significant distances from the source. But, in the case of SA-32 Facility, the source is a simple volume or point source emitting a plume that would impact receptors at locations at or near the facility boundary. As the immediate area surrounding the SA-32 Facility is commercial to the northeast, east, and southeast, with a residential area approximately 500 feet to the northwest, urban dispersion coefficients would be more appropriate for this modeling scenario. Based on the results of this analysis, urban dispersion coefficients were used in the atmospheric dispersion modeling. The results of dispersion modeling performed on VHP release scenarios from the SA-32 Facility are discussed in Section 4.2.1. During the SA-32 Facility fumigation and air monitoring operation, EPA will have the ability to perform real-time air dispersion modeling using the Areal Locations of Hazardous Atmospheres (ALOHA) program. That modeling can be predictive with assumption inputs or can be based any actual release and meteorological data available at the time of modeling. 2.5 Background Air Quality The primary pollutant that will be released into the SA-32 Facility during the fumigation process is VHP, which is a non-criteria pollutant and therefore no background air quality data are available. Hydrogen peroxide vapor is not anticipated to be present as an ambient or background contaminant. Therefore, all references in this document to the hydrogen peroxide readings action criteria pertain to concentrations above background, to account for potential deviant instrument readings due to interferent compounds or possibly from ambient hydrogen peroxide emissions of unknown origin. 3 Monitoring Program Description 3.1 Monitoring Areas Three geographic areas in and around the SA-32 Facility have been identified as locations of interest where air monitoring will performed throughout each of the 7 planned fumigation events. The three areas are: • Immediate Building Area2 – includes zones adjacent to the one being fumigated as well

as select locations immediately outside the SA-32 Facility

2 Note: In addition to the sensors for the immediate building area, six VHP sensors will be placed within the zone being fumigated to monitor VHP levels throughout the fumigation cycle. A description of these sensors, fumigation cycle criteria and placement is presented in the RAP.


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• Support Zone Area - outside the SA-32 Facility extending up to the SA-32 perimeter fenceline

• Off-site Area – at the SA-32 Facility fenceline and outward to surrounding properties. See Figures 1, 2, and 3 for depictions of these monitoring areas. The following pages describe the objectives for each monitoring area. Sections 4 and 5 describe the sensor locations for each area and the instrument equipment types, respectively.


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Figure 1. SA-32 Facility Immediate Building Area Monitoring Locations

Figure 1Immediate Building AreaAir Monitoring Locations

KEYZellweger SPM Instrument

Drager Polytron 2 Instrument

FumigatedZone (example)

Negative AirSystem Ducting

VHP SupplyDucting

VHP ReturnDucting

Roof-TopMonitor

Adjacent-ZoneMonitors

VHPGenerator

NAM Exhaust(post-catalyst)

NAM Exhaust(pre-catalyst)


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Figure 2. SA-32 Facility Support Zone Area Monitoring Locations

Figure 2Support Zone

Air Monitoring Locations

Key

Zellweger SPM Instrument

Roving Air Monitoring Area

Location-adjustable instrumentsdeployed downwind of the fumigated

zone

SA-32


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Figure 3. SA-32 Facility Off-Site Area Monitoring Locations

Figure 3Off-Site Air Monitoring Locations

CTI

ExPlusSA-32

JK Moving& Storage

Westwind CrossingSubdivision

KeyAir Monitoring Instrument

Data Acquisition Station

Meteorological Station

Data Transmission Cable


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3.2 Air Monitoring Objectives 3.2.1 Immediate Building Area The objective of Immediate Building Area air monitoring is the early detection of potential VHP releases resulting from operational difficulties (such as with the VHP production and circulation system or the NAM) or structural difficulties (such as containment structure breaches or building air leaks). This monitoring will allow for evaluating the functional status of the fumigation effort through detection at the point of VHP generation and release. The goal is the qualitative assessment of potential VHP releases, and the results will be utilized by the Unified Command (UC; see Section 3.7.1) in operational or corrective action decision-making. Specific exposure or action criteria have not been established for these monitoring locations; rather these data will be used for informational purposes by the UC. Planned Immediate Building Area air monitoring locations are shown in Figure 1 and are discussed further in Section 4. 3.2.2 Support Zone Area The objective of Support Zone air monitoring is the detection of potential VHP releases for protecting on-site personnel during the fumigation and for protecting the off-site public through the early detection of airborne VHP emissions. Rapid mobility to respond to emission investigation incidents is an element of this objective. The goal is the quantitative assessment of potential VHP releases, and the results will be utilized by the UC in making operational or corrective action decision-making. Planned Support Zone Area air monitoring locations are shown in Figure 2 and are discussed further in Section 4. Protective measure criteria developed for the SA-32 Facility fumigation project on responding to persistent hydrogen peroxide readings in the Support Zone are outlined in the Protective Measure Criteria section below. 3.2.3 Off-Site Area The objective of Off-Site air monitoring is protection of the off-site public. This will be accomplished by monitoring for hydrogen peroxide at potential receptor locations and comparing readings to concentration ranges established as protective measure criteria for the SA-32 Facility fumigation project (see below). The goal is the quantitative assessment of any potential VHP releases, and the results will be utilized by the UC in making operational or corrective action decision-making. Off-Site Area air monitoring locations are shown in Figure 3 and are discussed further in Section 4. The protective measure criteria developed for the SA-32 Facility fumigation project on responding to potential off-site, persistent hydrogen peroxide emissions are discussed below.


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3.3 Protective Measure Criteria The existing regulatory exposure threshold for hydrogen peroxide is 1 ppm as a time-weighted 8-hour average (TWA), as established by OSHA, NIOSH, and ACGIH. The Immediately Dangerous to Life and Health concentration for hydrogen peroxide is 75 ppm. A key objective of the SA-32 Facility air monitoring program is the identification and tracking of hydrogen peroxide releases that could potentially impact on-site personnel and the off-site public. This will be accomplished through a network of on- and off-site air monitoring sensors and the implementation of protective measures for exposure prevention and emissions control. To establish the protective measures, the TWA for hydrogen peroxide vapor (1 ppm) was used as a baseline to adopt site-specific hydrogen peroxide action criteria, to be measured using the instrumentation and procedures outlined in the AAMP. Separate action criteria have been established for the Support Zone and for the Off-Site Area and are shown in the tables below. These criteria use both concentration and duration-related trigger levels designed to allow for the investigation of low-level releases without interrupting the fumigation process and before any emissions increase to problematic levels or durations. The 10-minute rolling average periods are intended to lower emission problem recognition and response times and thus lower any potential exposures times.

Table 1. Action Criteria for Support Zone

Support Zone Air Monitoring:

Persistent Readings Action Criteria Air

Monitoring Reading

From instrument’s lower detection limit to 0.5 ppmv* hydrogen peroxide, 10-minute rolling average

> 0.5 ppmv* hydrogen peroxide, 10-minute rolling average

Resulting Action

- Confirm readings with a 2nd instrument - Locate and investigate emission source - Initiate corrective action as necessary

- Continue fumigation, pause fumigation or stop fumigation, as determined by the UC based on threat evaluation

- Initiate corrective action as necessary * above background Data control systems will be utilized to collect and process air monitoring readings being transmitted on a real-time basis from the stationary, continuous-reading air monitoring instruments. Data processing will include the calculation of rolling 10-minute averages periods, to be continuously updated with every new instrument reading. The data control systems software will be programmed to signal an alarm if any action criteria are exceeded. Under the Support Zone’s lower persistent readings level, an investigation will be initiated using mobile detectors to verify the initial result and locate the source. Under the higher persistent readings level, a source investigation will occur and the UC will evaluate the threat and determine an appropriate action (continue fumigation, pause fumigation or stop fumigation).


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Table 2. Action Criteria for Off-Site Area

Off-Site Area Air Monitoring: Persistent Readings Action Criteria

Caution Level Action Level

Air Monitoring Reading

From instrument’s lower detection limit to <1 ppmv* hydrogen peroxide, 10-minute rolling average

> 1 ppmv* hydrogen peroxide, 10-minute rolling average

Resulting Action

- Investigate the problem - Evaluate the threat - Pause or stop operations - Initiate corrective action as necessary

- Investigate the problem - Evaluate the threat - Stop operations - Initiate corrective action as necessary

* above background Under the Off-Site Area’s lower persistent readings level, the source will be investigated via additional instrument surveys, the UC will evaluate the threat posed by the readings, and the fumigation system will be paused or stopped to initiate corrective actions as necessary. Under the higher persistent readings level, a source investigation will occur, the UC will evaluate the threat posed by the readings, and the fumigation system will be stopped to initiate corrective actions as necessary. A “pause” consists of a temporary system stop (such as suspending VHP injection and the fumigant blowers) in response to persistent, low-level readings, the source of which would then be investigated and corrected as necessary prior to resuming fumigation. A “stop” consists of an orderly system shutdown (such as shutting down the VHP injector but running the blower system to exhaust the VHP) with the purpose of resolving a source of persistent, elevated fugitive emissions. Pause and stop determinations will be made by the Unified Command (UC), as will the appropriate corrective actions to be taken. 3.4 Parameters to be Measured 3.4.1 Vaporized Hydrogen Peroxide Ambient air will be monitored for VHP during each fumigation cycle. In addition, key meteorological parameters will be monitored. Other than the VHP generator to be brought to SA-32 during the fumigation operation in Summer 2003, no other hydrogen peroxide sources are known to exist in the vicinity of SA-32. The ambient monitoring program will be conducted utilizing stationary, continuous-reading instruments as well as mobile sensors. Some of the stationary, continuous-reading instruments inside the SA-32 Facility (Immediate Building Area) will be operated by STE and will be hard-wired into STE’s VHP control system computer located at the SA-32 Facility. The remainder of the stationary, continuous-reading instruments to be situated in the Immediate Building Area, as well all of those to be operated in


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the Support Zone and Off-Site Areas, will be operated by EPA and will be hard-wired into a separate EPA Data Acquisition System (DAS) at the SA-32 Facility. Each data control system will electronically receive and store air monitoring data from the networked sensors so that real-time calculations can be made to develop the data, determine any trends, calculate rolling and block averages, and determine instrument operational status. The systems will be programmed to sound alarms if action criteria are reached (see previous section). Air monitoring data control systems are described further in Section 5. 3.4.2 Meteorological Data The following meteorological parameters will be measured on-site during the project via an EPA-operated meteorological monitoring station:

• Ambient temperature • Barometric pressure • Relative humidity • Wind direction • Wind speed • Sigma theta

A standard meteorological station will be used and will be set up in accordance with EPA guidance as described in Section 5.0. Meteorological data will be relayed via telemetry to a central EPA monitoring data collection area at the SA-32 Facility. 3.5 Implementation Schedule/Duration of Program The fumigation process is scheduled to take place in summer of 2003. Although the total duration of this process is estimated to be 7-9 weeks, VHP generation will only take place approximately every 5 days, or about one day per calendar week. The other days will be used to set-up the next fumigation partition and to collect and compile fumigation process data (refer to the RAP for further information). Therefore VHP monitoring will only occur when a partition is in the fumigation cycle. The overall Ambient Air Monitoring Program will commence the day prior to the fumigation processes’ Readiness Demonstration (a pre-fumigation test event) and will end on the day that data indicates successful completion of the last enclosure fumigation. Actual VHP monitoring will only be conducted during active fumigation events.


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3.6 Sampling Frequency by Parameter The stationary, continuous-reading VHP process instruments will collect and transmit data continuously, and computer systems at the SA-32 Facility will store and process the results. The sensors will be calibrated and/or checked each day of use prior to commencement of the fumigation cycle. Each fumigation cycle will not be allowed to proceed until all sensors have been successfully calibrated or checked, and deployed. For each fumigation event, the ambient air monitoring instruments will be operated continuously beginning 1 hour before the start of fumigation through the entire VHP fumigation cycle, which is completed when the hydrogen peroxide concentrations inside the fumigated zone have dropped to less than 1 ppmv, as measured by the STE sensor inside the fumigated zone. This practice ensures that instruments continue monitoring until the source level of VHP inside the SA-32 Facility has diminished to concentrations that no longer pose an exposure threat. 3.7 Monitoring Program Organization The project team organization structure for the ambient air monitoring effort is presented in Figure 4. Note that only those individuals or organizations that have direct responsibility in performing the air monitoring during the SA-32 Facility fumigation are shown on this figure. The key task team members and their responsibilities are discussed in the subsections below.


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START Contractor:Ecology and Environment, Inc.

UNIFIED COMMANDU.S. Department of State

U.S. Army Corps of EngineersU.S. Environmental Protection Agency

State of Virginia Department of Environmental QualityLoudoun County

PRIMARY CONTRACTORShaw Environmental & Infrastructure, Inc.

VHP FUMIGATIONStrategic Technology Enterprises, Inc.

Quality Assurance CoordinatorG. Gallello, Chemist

Program ManagerL. Schwartz, VP Operations

Project ManagerI. McVey, Senior Scientist

STE Fumigation Project Team

EPA EPA - ERT

REAC Contractor:Lockheed Martin, Corp.

Ambient Air Monitoring

SA-32 Facility Ambient Air Monitoring Project Team

Fumigation Program Management & VHP Process Monitoring

Figure 4. Ambient Air Monitoring Project Team


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3.7.1 Incident Command System The Incident Command System (ICS) is a standardized emergency management system developed as a framework for the management of a multi-jurisdictional and multi-agency incident or event. The principles of ICS enable Federal, State and local emergency response agencies to utilize a common terminology and common management and procedural techniques such as span of control, organizational flexibility, personnel accountability, comprehensive resource management, unified command and incident action plans. ICS is the preferred incident or event management system utilized by a wide variety of local, state, and federal agencies in both emergency and non-emergency situations. Under the SA-32 Facility Ambient Air Monitoring Program, a Unified Command (UC) structure as followed under ICS will be applied as a management team to collectively address and, if necessary, remedy air monitoring issues during the SA-32 Facility fumigation. The UC will consist of lead personnel from the DoS, the U.S. Army Corps of Engineers (UASCE), EPA, VADEQ, and Loudoun County. The UC members will serve as the data review and decision-making body regarding air monitoring results obtained during the fumigation operation to ensure that the operation occurs effectively and according to safety protocols outlined in this document. The UC members or their representatives will evaluate air monitoring and meteorological data on a real-time basis as it is relayed into the site’s data control and display systems. 3.7.2 AAMP Project Team The AAMP Project management team, consisting of STE, SE&I and EPA and its contractors is responsible for implementing the ambient air and meteorological monitoring program in accordance with this Program. . The project management organization has been in place on this project since operations began in August 2002 and is discussed in detail in the SE&I Work Plan. For this fumigation effort that structure will remain with the addition of STE , as well as certain personnel and/or responsibilities intended solely for the Ambient Air Monitoring Plan execution. Field monitoring specialists will be responsible for routine inspection of each of the remote monitoring stations, and will be responsible for maintaining these instruments and their associated communication links in properly functioning condition. They will also be responsible for calibration and checking of each unit. Field-monitoring specialists inspect system performance and operation of each monitoring station at 30-minute intervals. Field monitoring specialists will report directly to the Ambient Air Monitoring Coordinator (AMC) who is also the Fumigation Project Manager. Central monitoring area personnel will be located at the unit and will be responsible for continuous review and assessment of the trends and coordination with the field monitoring specialists as well as monitoring the status/input from the weather station. Personnel staffing the central monitoring area will report directly to the AMC.



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3.7.2.1 Quality Assurance Coordinator (Guy Gallello, Jr- Shaw E&I) The Quality Assurance Coordinator (QAC) is responsible for the overall Quality of all aspects of the Ambient Air Monitoring Program performed within the facility boundary. He is the principal author of the Ambient Monitoring Plan and will perform all facility-specific QA activities required by this plan. Specific responsibilities of the QAC include:

• Coordinating the inspection and confirmation of the proper location of all stationary instruments

• Confirming the traceability/certification of all standards • Reviewing and approving all related monitoring SOPs • Coordinating a readiness audit of the Ambient Air Monitoring program prior

to commencement • Ensuring that all required Ambient Air Checks, Accuracy Checks, and

Precision Checks specified in this document are performed and documenting their results

• Ensuring compliance with quality control (QC) criteria contained in this document

• Instituting, monitoring, documenting, and reporting any Corrective Actions needed during this effort to ensure adequate quality and data usability

• Producing a Quality Assurance Report at the end of this effort 3.7.2.2 Ambient Air Monitoring Coordinator (Iain McVey/Matt Lawes- STE/STERIS) Ambient Monitoring Coordinator (AMC) will be responsible for the overall execution and quality of the VHP process monitoring effort during each fumigation event. He will be the direct supervisor of the technicians responsible for this monitoring task and will be responsible for ensuring that this monitoring is performed in accordance with the approved procedures and in compliance with the quality procedures presented in this document. The AMC will also be responsible for executing any Corrective Actions deemed necessary by the QAC including the reassignment of personnel if required. 3.7.2.3 USEPA Organization Ambient air monitoring activities will be conducted by a team consisting of EPA, EPA–Emergency Response Team (EPA-ERT), and contracted personnel. An on-site EPA On-Scene Coordinator (OSC) will manage this team. Team personnel will be responsible for all aspects of the preparation and operation of the ambient air monitoring program, including equipment set-up, off-site property access approval, air monitoring instrument maintenance, meteorological station operation, and data management. The EPA OSC is a member of the



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UC, which functions as a review and decision-making body for air monitoring results obtained during the fumigation operation. 3.7.3 Contingency Planning Loudoun County Department of Fire, Rescue and Emergency Services (LCFR), involved in earlier phases of the SA-32 Facility cleanup project, has been designated a member of the fumigation air monitoring program UC. LCFR is responsible under Title 44 of the Code of Virginia for implementing the Loudoun County’s Emergency Operation Plan (EOP). The EOP is a contingency plan that identifies and coordinates County, State and Federal resources, participant roles and responsibilities, and mechanisms for responding to major public emergency and disaster incidents. In the event of a persistent or high-concentration hydrogen peroxide release from the SA-32 Facility that would affect the public, LCFR would activate applicable portions of the EOP. The EOP in place for Loudoun County has been approved by the Loudoun County Board of Supervisors and the Commonwealth of Virginia. County response measures that could potentially be implemented for an SA-32 Facility incident include remediation-support activities (such as dispatching a local or regional fire department HazMat team or public works personnel or equipment), coordinating public notifications (such as making public notifications via door-to-door visits or via media or law enforcement alert notification systems already in place), or conducting public protection actions (such as implementing evacuations, shelter-in-place actions, or other protective measures). LCFR officials have been briefed by EPA on the SA-32 Facility fumigation air monitoring program and have reviewed this AAMP. A LCFR representative will be at the SA-32 Facility during the VHP injection period of each fumigation event. The Department will also be available to the UC at all times through a 24-hour contact number, and when not on-site, will be kept informed by the UC of any hydrogen peroxide detections of concern or other situations potentially warranting their involvement. The response time for fire and rescues resources to arrive at the SA-32 Facility is estimated to be 5-10 minutes. 3.7.4 Project Communication During the fumigation of the SA-32 Facility, notification to the on-site UC and other fumigation management, operational, and ambient air monitoring personnel will occur via:

• Ambient air monitoring results, electronically transmitted by the stationary, continuous-reading instruments and displayed on computer monitors

• Verbal notification concerning instrumental issues, situational updates, or action criteria exceedances



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In addition to these notification methods during the fumigation, the following communication methods will be employed to assure that the information is relayed efficiently and effectively:

• Verbal [or check-list] progress reports for fumigation days

• Brief monitoring reports of the zone fumigation prior to fumigating next zone, including result status of prior fumigation zone

• Periodic briefings at health and safety meetings

• Periodic team meetings

• Quality Assurance (QA) communications, including any Corrective Action Reports (CARS) [See Section 7 for more detail on QA.]

• Other communication, as required

4 Monitoring Site Description 4.1 Monitoring Site Criteria - 40 CFR 58 The requirements of 40 CFR Part 58 have been referenced for establishing the specific locations of the ambient air instruments. The requirements of this part were used as guidance because the monitoring program for these specific criteria pollutants does not address the specific purposes for which 40 CFR Part 58 was written, namely, long-term Prevention of Significant Deterioration (PSD), state and local monitoring systems (SLAMS), etc. Using 40 CFR 58 terminology, the selected monitoring sites would be considered “microscale”, and diffusion sensors will be used to collect all of the ambient air samples. Accordingly, the following monitoring site criteria will be followed for placement of the sensors: • Air will be sampled at the ambient breathing height. Probe inlets will be set to sample air

at a height of 5 feet (1.5 meters), with the exception of most of the SA-32 Facility fenceline air monitoring instruments, to be placed at the top of the fence (10 feet above grade).

• The probe must have unrestricted airflow and be located away from obstacles so that the distance from the probe is at least twice the height than an obstacle protruding above the probe. (This includes trees and shrubs).

• The probe must have unrestricted airflow in an arc of at least 270 degrees around the inlet probe, or 180 degrees, if the probe is on the side of a building. This arc must include the predominant wind direction for the greatest pollutant concentration potential.



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• To prevent undue influence from traffic, monitors should be placed at least 15 feet from the edge of the nearest traffic lane.

4.2 Specific VHP Instrument Locations 4.2.1 Instrument Location Support Data Locations for stationary air monitoring instruments were initially selected based upon the need to monitor potential VHP emission receptors (such as on-site personnel, adjacent businesses, and nearby residences). To determine the need to extend the air monitoring instrument network, predictive air modeling was conducted to assess the potential behavior and extent of fumigation-related VHP releases from the SA-32 Facility. Various release scenarios ranging from low-concentration, low-duration VHP releases emanating from the SA-32 Facility to a worst-case release caused by building failure were modeled using the Screen3 dispersion modeling program. Because the meteorological conditions that might occur at the time of fumigation cannot be accurately predicted, historical meteorological data (wind speed and wind direction) obtained from Dulles International Airport were used as weather inputs. Multiple models were produced based upon variable criteria such as the release source type (a continuous point source versus a set volume), differing VHP degradation rates, differing wind speeds and directions, varying levels of air dilution based upon either interior or exterior building releases, and the presence or absence of emission engineering controls (such as an exhaust system catalyst). Overall, the modeling results support the receptor-derived placement of air monitoring instruments (which is the configuration addressed in this AAMP) as appropriate to detect the potential VHP emissions as estimated under modeling. Under the most likely scenarios modeled (minor building air leaks or minor operational releases), VHP concentrations remain well below 0.5 ppmv immediately outside the SA-32 Facility. More unlikely scenarios, involving greater structural failure situations, reveal hydrogen peroxide readings of up to 2 ppmv extending as far as the adjoining businesses. However, emissions above the off-site action criteria of 1 ppmv are not anticipated to impact the Westwind Crossing residential area north of the SA-32 Facility except under the very unlikely worst-case scenario (complete building failure during fumigation).



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4.2.2 Stationary, Continuous-Reading VHP Instrument Locations Stationary, continuous-reading VHP instruments will be deployed at and around the SA-32 Facility to determine if any VHP has been released from the building and has migrated off the facility boundary towards potential off-site receptors. Planned air monitoring locations are described below and are shown in Figure 1 (Immediate Building Area), Figure 2 (Support Zone), and Figure 3 (Off-Site Area). Immediate Building Area Instrument Locations (6 total): • VHP Process Instruments (STE-provided):

o Two instruments outside of the enclosure being treated but inside the building- these instruments will be used to detect potential enclosure leaks- one in each adjacent zone

o One instrument sampling the NAM line air, pre-exhaust- to tell if other fumigation zones are picking up VHP and to estimate the catalyst loading rate

• Ambient Air Instruments (EPA-provided): o One instrument in the vicinity of the VHP generator- this instrument will detect

any fugitive emissions from the VHP Generator o One instrument at the output of the building NAM-this instrument will indicate if

any VHP is escaping the building through the NAM o One instrument on the roof of the facility, directly over the zone being fumigated

Support Zone (Ambient Air) Instrument Locations (2 total) (EPA-provided): • Two instruments located half-way between the building and the fence line, slightly

downwind of the zone being fumigated as based on the prevailing wind direction of the day. These instruments will detect potential building releases. Towards the end of each fumigation cycle, one of these instruments may be moved to monitor the VHP concentration in the airstream being exhausted from the fumigated zone, to aid in determining when a concentration of 1 ppmv or less is reached in that zone.

Off-Site (Ambient Air) Instrument Locations (16 total) (EPA-provided): • Eight instruments along the SA-32 Facility fence line: four at the cardinal compass points

(i.e., North, South, East, and West) and four at the inter-cardinal points • One instrument on the roof of the ExPlus building adjacent to the SA-32 Facility, at the

closest ventilation intake point to the SA-32 Facility and facing the SA-32 Facility • Two instruments at the JK Moving & Storage business adjacent to the SA-32 Facility.

One will be placed in front of the maintenance bay that faces SA-32 Facility in the closer of the two buildings, and one will be placed on the roof of the further building, at the closest ventilation intake point to the SA-32 Facility and on side of the intake facing the SA-32 Facility

• One instrument on the roof of the Cargo Transport Inc. (CTI) building east of the SA-32 Facility, at the closest ventilation intake point to the SA-32 Facility and on side of the intake facing the SA-32 Facility



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• Four instruments in the Westwind Crossing subdivision north of the SA-32 Facility, with one at each of four residences on the southernmost border of the subdivision that faces the SA-32 Facility

The eight stationary, continuous-reading instruments to be placed on the SA-32 Facility fenceline are intended to detect any fumigation-related emissions approaching off-site areas, including the adjacent businesses and areas where their employees may congregate. The approximate building-to-building distance from the SA-32 Facility to the ExPlus and JK Moving & Storage businesses is 150 feet (see Figure 3). However, some personnel at these businesses come into closer proximity to the SA-32 Facility while in parking areas, foot traffic routes, or outdoor work or break areas. The fenceline instruments will identify any potential hydrogen peroxide readings at these closer locations, while other sensors will monitor for readings right at the neighboring buildings. Three fenceline instruments will be situated between the SA-32 Facility and ExPlus and three instruments will be situated between the SA-32 Facility and JK Moving and Storage (see Figure 3). On the eastern SA-32 Facility fenceline facing ExPlus, the air monitoring instruments will be placed at an approximate five-foot height, due to ExPlus being at approximately the same grade height as the SA-32 Facility and the interest in monitoring the breathing zone in that direction. All other SA-32 Facility fenceline monitors will be placed an approximate 10-foot height (the full height of the fence) to aid in the detection of potential roof-top emissions (a possible release point) or to account for grade increases away from the SA-32 Facility, such as on the southern fenceline (approximate 20 foot grade increase to JK Moving and Storage from the SA-32 Facility). The approximate building-to-building distance from the SA-32 Facility to the CTI business is 600 feet, and the sensors on the eastern SA-32 Facility fenceline will detect emissions potentially migrating towards that business. All SA-32 Facility fenceline instruments will be affixed directly to the fence in accordance with the obstruction prevention guidelines explained in Section 4.1. In addition to the SA-32 Facility fenceline air monitoring instruments, one roof-top air monitoring instrument will be placed at each of the ExPlus, JK Moving & Storage, and CTI businesses. These SPM’s will be located at the closest roof-top ventilation intakes to the SA-32 Facility and will be placed in front of (on the SA-32 side of) the intake. One additional sensor will be placed near the entrance to the maintenance bay at JK Moving & Storage. The maintenance bay is located at the building closest to the SA-32 Facility and also faces the SA-32 Facility, and the bay doors are often open for the workers inside. The approximate statute distance from the SA-32 Facility to the Westwind Crossing subdivision north of the SA-32 Facility is 500 feet. To address the potential migration of fumigation emissions there, four monitoring sensors will be placed in the subdivision. These sensors will be placed along the subdivision’s southernmost side, which is the portion closest to the SA-32 Facility. The southern border of the subdivision currently extends



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approximately 2,000 feet in an east-to-west, semi-circular pattern. The four instruments will be placed approximately equidistant along the subdivision southern border, resulting in a spatial distance between sensors of approximately 300 to 400 feet. The air monitoring instruments will be positioned within open areas in the subdivision (i.e., in residential yards or common areas) that are closest to and face the SA-32 Facility and which do not have nearby obstructions that could interfere with airflow coming from the direction of the SA-32 Facility. The sensors will be installed on tripods or similar stands to sample air at the approximate 3-5 foot height above grade. The property between the SA-32 Facility and the subdivision consists of undeveloped, uninhabited woods and a perennial creek (Broad Run), and is not considered an air monitoring area of interest. See Figure 3 for a depiction of these air monitoring locations. The off-site instruments will be direct-reading, stationary units continuously operated during each fumigation event in accordance with the monitoring period parameters discussed in Section 3.3. Each sensor will be hardwired into the EPA’s on-site DAS and will have at least 100 feet of extra cable, allowing for placement flexibility within the designated monitoring location. All off-site air monitoring instruments described above will remain at the same locations throughout the fumigation operation. However, additional sensors will be available during the SA-32 Facility fumigation to serve as replacement units if necessary or for deployment to additional locations as either stationary or roving sensors, as determined appropriate at the time. 4.2.3 Mobile VHP Instrument Locations In addition to the stationary instruments, mobile sensors will be available for air monitoring use during each fumigation event. These sensors will be used as needed to gather additional information as to VHP concentrations and also to allow for rapid mobility and greater ability to case individual areas. Applications include using the instruments for health and safety, release investigation, or detection verification use in the Support Zone, and for roving air monitoring activities at Off-Site areas. 4.3 Meteorological Monitoring Station Location USEPA guidance for locating meteorological monitoring instruments as described in Meteorological Monitoring Guidance for Regulatory Modeling Applications (EPA-454/R-99-005, February 2000) and Quality Assurance Handbook for Air Pollution Measurement Systems; Volume IV: Meteorological Measurements (EPA/600/R-94/038d, March1995) was consulted for determination of the EPA meteorological station placement. An on-site station location that met all guidance criteria was not available at the SA-32 Facility due to physical limitations and site use patterns. Other criteria, such as positioning the station to detect the predominant weather conditions likely affecting off-site areas, was applied to the location



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selection process and resulted in the SA-32 roof being selected as the location for the EPA-ERT’s meteorological station.

5 Monitoring Equipment Description This project involves the monitoring of ambient air within the vicinity of the SA-32 Facility for VHP during the fumigation of the facility’s interior. This section provides a detailed description of the monitoring and associated ancillary equipment that will be used in the ambient air monitoring program. 5.1 Stationary, Continuous-Reading Instruments 5.1.1 Fumigation Process VHP Instruments VHP is not a criteria pollutant. As such, there are no recognized EPA reference or equivalent methods for the monitoring this chemical in ambient air. There is an OSHA method. However this method is not yet fully validated for use and it does not provide real time (continuous) results. The Draeger Polytron 2 system was chosen for stationary continuous VHP process monitoring within the facility boundary [three locations within the Immediate Building Area, Figure 1]. Specifically, the hydrogen peroxide sensors are DraegerSensor [no space between words] H2O2 LC- 68 09 705, used with Draeger Polytron 2 Universal Transmitter, 83 14 400. The sensors have a measuring range up to 50 ppmv H2O2 (0.07 mg/L H2O2). Refer to Attachment 4 for detailed product information and technical data. These instruments will be connected via a 4-20 mA signal cable directly to the main control system. The instruments will interface with the control system via additional analog I/O cards. The control system will be modified to accommodate the additional I/O cards and connectors. 5.1.2 Ambient Air Monitoring VHP Instruments Ambient air monitoring will be conducted using Zellweger Analytics MDA Single Point Monitors (SPM) instruments. This instrument detects hydrogen peroxide through a reaction on the hydrogen peroxide Chemcassette® detection system. The Chemcassette® technology is based on classic colorimetry and uses a dry reagent medium to collect and analyze the sampled air. When the Chemcassette® is exposed to a target gas, it changes color in direct proportion to the concentration of gas present. The SPM’s internal optical reader detects color intensity changes and determines the gas concentration by comparison to a known gas response pre-programmed into the sensor. The color intensity changes are read as an



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electrical current. The current output signal is measured and amplified, with the concentration of hydrogen peroxide displayed on the instrument’s internal analog meter. The signal is also converted to a 4-20 mA output. Manufacturer specifications for the hydrogen peroxide SPM list the lower detection limit (LDL) as 0.1 ppmv and full scale on the unit as 3 ppmv. The sampling period for hydrogen peroxide on this unit is 15 seconds, and the instrument continuously updates readings at this interval. The instrument has an internal power supply (12V battery) but will be run off of a 110 volt AC power source, where electricity is available. The instrument functions as an active sampling device (versus passive sampling) by drawing in a sample via an internal pump at a rate of approximately 0.5 liters per minute. The air sampling tube attached to the sensor inlet is mounted on a mast, allowing the sample to be drawn at breathing height if the sensor is placed at ground level. The Zellweger SPM instruments are rated for operation in ambient temperatures ranging from –20 degrees Celsius to 40 degrees Celsius and in humidity conditions ranging up to 95% relative humidity. The instrument is housed in a weather resistant case, and an additional rain shield can be installed to the sampling inlet to block rain intrusion. Further Zellweger SPM specifications are given in Attachment 5. The Zellweger SPM instruments will be hard-wired into an EPA DAS that will receive, process, and store air monitoring readings. Each instrument will be tethered with at least 100 feet of extra cable, allowing it to be moved around the designated monitoring location within this additional distance. Four additional Zellweger SPM instruments will be maintained on-site for use as back-up or replacement units, for roving air monitoring use, or for tests with active SPM’s to estimate the analytical precision of the instruments. 5.2 Mobile Instruments Handheld, Draeger PAC III instruments will be used to supplement the continuous-reading, stationary instruments. The PAC III’s will be used as roving or mobile air monitoring sensors to obtain hydrogen peroxide detections readings away from the stationary instrument locations. PAC III applications will include being carried by site personnel as they perform work activities in the Support Zone, using the sensors for additional on or off-site air monitoring roving duties, and being used as mobile sensors for release investigation purposes. The PAC III instruments are a hand-held, direct reading hydrogen peroxide detection sensor with a manufacturer’s listed detection range of up to 20 ppmv, with a reported resolution of 0.1 ppmv. The instrument detects the target compound via an electrochemical cell, the same technology used on the Draeger Polytron 2 sensors. The instrument features two alarm levels that are pre-set according to the ACGIH exposure threshold for the target compound. The PAC III’s are powered by an internal battery and will not be wired for direct data transmission to the site’s data collection systems. Instead, site personnel carrying these detectors will monitor the sensor’s display and report readings back to the data collection



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centers via radio or cellular telephone, where those readings will be input into the data collection system for storage and consolidation into the overall air monitoring readings database where direct-feed instrument readings are processed. Attachment 6 presents the product information and technical data.

5.3 Known Interference Factors Published interferences for the Draeger hydrogen peroxide sensors include acetone, chlorine, hydrogen sulfide and nitrogen dioxide. Published interferences for the Zellweger MDA SPM and the hydrogen peroxide Chemcassette® detection system include halogens and several halogen oxides and other compounds which exhibit a positive but weaker response, such as nitrogen oxides (example: 10 ppmv NO2 = 0.3 ppmv hydrogen peroxide), ozone, and xenon difluroride. The hydrogen peroxide Chemcassette® detection system will not respond to acids, alcohols, amines, ammonia, freons, hydrides, hydrocarbons, hydrogen, hydrogen cyanide, hydrogen sulfide, isocyanates, phosgene, and solvents. It is not anticipated that the known interferent compounds will be present at levels that will significantly interfere with the hydrogen peroxide readings. 5.4 Other Equipment for Routine Operation Certain other equipment will be necessary for the proper implementation of the ambient monitoring program. This equipment includes instrument calibration and performance check equipment, data communication equipment, data processing software and computer hardware, field power supply, and field weatherproofing. 5.4.1 Calibration Equipment Due to the instability of hydrogen peroxide, particularly at lower concentrations, this compound is not available as a calibration standard. As a result, the Draeger hydrogen peroxide sensors are designed to have field performance/challenge tests conducted using sulfur dioxide, and Zellweger hydrogen peroxide SPM’s are designed to be field challenged against nitrogen dioxide. Each surrogate performance check compound produces an instrument reaction similar to that of the target compound at a set, known ratio, with the challenge result used to measure any deviation in the sensor’s anticipated reading.



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Other equipment associated with the calibration includes, but is not limited to; specially designed black tedlar/PTFE bags used to contain the final calibration standards, syringes, a calibrated flow control box to provide the required volume of air to the calibration bags, carbon filters to filter the ambient air for zero and calibration standards, and small vacuum pumps. Zellweger hydrogen peroxide SPM’s are designed to be performance challenged against nitrogen dioxide, which produces a detection response similar to, but weaker than, hydrogen peroxide. A certified calibration gas standard of nitrogen dioxide formulated to give a 1 ppmv response as hydrogen peroxide on the SPM’s will be utilized to challenge the Zellweger SPM instruments. Other calibration equipment includes tedlar bags, a regulator, and connector tubing. 5.4.2 Monitor Communication Equipment The stationary, continuous-reading Draeger Polytron 2 sensors used for VHP process monitoring inside the SA-32 Facility will be hard-wired into STE’s VHP control system computer. The computer will receive the data and then send it on to further processing and archiving. The instruments will be connected via a 4-20 mA signal cable directly to the main STE VHP control system. The instruments will interface with the control system via additional analog I/O cards. The control system will be modified to accommodate the additional I/O cards and connectors. Each stationary, continuous-reading Zellweger SPM instrument will be hard-wired directly into the EPA’s on-site DAS using armored, shielded, single twisted pair cable. The DAS will allow for the receipt, storage, and processing of all received data coming from connected sensors. Data-transmission D1000 modules attached to each SPM converts the sensor’s 4-20 mA output signal to a RS-485 data stream. The DAS computer requests and stores the received data from all networked instruments in a database onboard the DAS. 5.4.3 Data Acquisition and Archival System Continuous readings from each the Draeger Polytron 2 stationary instruments will be transmitted at one-minute intervals to the STE computer at the central monitoring area for storage and processing. Batch data will be monitored during and analyzed after the fumigation cycle. The SPM’s will be hard-wired directly into an on-site EPA DAS consisting of an IBM PC with a Windows 2000 operating system running DASYLab Plus software. The DAS computer serial port is connected to an RS-485 repeater/converter. Multiple D1000 modules are connected to the repeater/converter via cabling from remote points. The DASYLab DAS



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computer displays the data from the modules as it archives all data into a database. The DAS will allow for the receipt, storage, and processing of all received data coming from all connected instruments, on an individual and collective sensor basis, over their entire period of operation. Every 15 seconds, a 10-minute moving block average will be calculated for the accumulated hydrogen peroxide gas concentrations. This will be done automatically by subtracting the oldest result, adding the most recent result, and recalculating the average as a new data point. The DAS used with the off-site Zellweger SPM instruments will be programmed to sound an initial alarm at 0.5 ppmv, and a second alarm level at 1.0 ppmv during rolling 10-minute averaging periods. Data received at the base telemetry unit will be processed using appropriate software. Data from the manual/roving instruments will be called into the UC, documented in a logbook, and then downloaded for processing. Data from the meteorological station will also be hard-wired into the main control computer. The DAS is configured to display the following:

• the most recent raw concentration (as numerical values);

• the most recent 10-minute moving average for the raw concentration (as numerical values); and,

• a graphical representation of the last two hours of the corrected concentration’s 10-minute moving average (to display any trends).

5.4.3.1 Data Storage and Archiving All sensor calibration and performance challenge information, ambient air monitoring results, and air modeling results will be stored. Hard copies, where applicable, along with digital records in electronic format, will be archived.

5.4.4 Meteorological Equipment EPA-ERT will operate a meteorological monitoring station at the SA-32 Facility during the fumigation operation. Meteorological data, consisting of wind speed, wind direction, and other atmospheric conditions, will be collected continuously from this station and will be used as input for on-site predictive modeling, if a release is measured. The meteorological data will also be utilized to ensure proper placement of the air monitoring instruments.

The following meteorological parameters will be measured on-site during the project:

• Ambient temperature • Barometric pressure • Relative humidity



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• Wind direction • Wind speed • Sigma theta

Proper installation of the meteorological station and subsequent collection, validation, and quality control of the meteorological data is addressed in the following subsections. Meteorological monitoring per prescribed EPA methodologies requires a 10-meter tower for the meteorological sensors and housing for the data acquisition system (a 3-meter tower placed on the roof of the SA-32 Facility will be utilized). Data validation and assessment is discussed in Section 6.0, and QA/QC features are described in Section 7.0 Wind speed, wind direction, relative humidity, temperature, and barometric pressure sensors are included with the Met One Auto Met 466A System (or equivalent), which will be utilized during this project. The meteorological station specifications are presented in Attachment 8. 5.4.4.1 Instrumentation The EPA-ERT meteorological station is a Met One system manufactured by Met One Instruments of Grant Pass, Oregon. Specific sensors and their performance specifications are shown in Attachment 8. The horizontal standard deviation for the wind direction (sigma theta) will be calculated by the software. Continuous meteorological monitoring will begin at least one week prior to the planned fumigation start so that baseline, site-specific data can be collected and compared with off-site meteorological station data. Continuous meteorological monitoring and data collection will then be maintained until all fumigation activities have been completed for the entire site. 5.4.4.2 Location USEPA guidance for siting meteorological monitoring sensors as described in Meteorological Monitoring Guidance for Regulatory Modeling Applications (EPA-454/R-99-005, February 2000) and Quality Assurance Handbook for Air Pollution Measurement Systems; Volume IV: Meteorological Measurements (EPA/600/R-94/038d, March1995) was consulted for determination of the meteorological station placement. An on-site location for the monitoring station that met all guidance criteria was not available at the SA-32 Facility due to physical limitations and site use patterns. Based upon other suitability criteria, such as positioning the station to detect the predominant weather conditions likely affecting off-site areas, the SA-32 Facility roof was selected as the location for the EPA-ERT’s meteorological station. The wind speed and wind direction sensors are on the top of the Met One’s integral 3-meter tripod, which will be fully deployed. As the SA-32 Facility roof is 8 meters above grade, the wind speed and direction sensors will be at an overall height of 11 meters above grade.



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5.4.4.3 Data Acquisition/Logging Data from each meteorological sensor is captured and stored in an AutoMet 466A datalogger (Met One Instruments). This data logger is located at the base of the meteorological tower and powered via 12V DC battery. Each sensor is sampled once every second. Every 10 seconds, the instantaneous reading from each sensor is transferred over hardwire connection or a 900 MHz spread spectrum radio modem system via RS-232 link to the meteorological DAS. In addition, the datalogger automatically transfers 15-minute averages, including sigma theta, every fifteen minutes. If communications are disrupted between the datalogger and meteorological DAS, data will be retained by the datalogger until communication has been reestablished and all the data has been successfully transferred. The meteorological DAS will be co-located with the off-site air monitoring DAS in the on-site ERT Command Station. 5.4.4.4 Data Interpretation and Use The real-time meteorological information will be used as input for evaluation and for selecting and adjusting monitoring locations as determined appropriate by the UC. 5.4.4.5 Back-up Meteorological Data As a contingency and QC check of the on-site meteorological system, communication will be established with the Dulles Airport meteorological station at Dulles International Airport during the fumigation operations. Comparison of the most recent averages for wind speed and wind direction will be made to confirm the operation of the on-site meteorological system. If significant differences exist between the two sets of data, corrective action will be implemented to investigate and correct the anomaly. If the on-site meteorological station is determined to be faulty, meteorological data will be obtained from the Dulles meteorological station at the Dulles International Airport, which operates USEPA-compliant sensors for measuring ambient temperature, wind speed, wind direction, and sigma theta. 5.4.5 Ancillary Equipment Ancillary equipment includes the monitor mounting posts, weather shields, and power supply. It is anticipated that if a reliable source of power can not be found at a given site, that a generator will be used to provide power to the monitors and telemetry equipment. Generators will be located at least 50 feet from the monitors. It is anticipated that weather shielding will consist of a sun shield over the unit and sensor. However, if rain occurs a tent will be placed over the unit that will provide the minimum obstruction to airflow.



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5.5 Calibration and Checks of Instruments Real-time air monitoring equipment will be used throughout this monitoring event. Documented and approved methods will be used for calibration, test, measuring, and reference equipment. Whenever possible, widely accepted methods (such as those published by ASTM or EPA, or methods provided by manufacturers) will be adopted. Where pre-established information is not available, methods will be developed considering the type of equipment, stability characteristics of the equipment, required accuracy and precision, and the effect of error on the quantities measured. 5.5.1 Meteorological Station Calibration of the meteorological sensors are conducted by the manufacturer. A separate calibration/audit of the sensors is not planned due to the short duration of the program. 5.5.2 Real-Time Ambient Air Monitoring Equipment 5.5.2.1 Draeger Instruments The Draeger process monitoring equipment will be calibrated using the manufacturer’s methods and supplied standards. 5.5.2.2 Zellweger SPM Instruments A verification routine will be conducted on each Zellweger SPM according to manufacturer’s criteria. The verification routine checks the operating system of the SPM optical system through use of an optical test card. Additionally, at least once every two hours during active fumigation periods, an EPA team member will inspect operating SPM’s, and via radio or telephone contact with EPA personnel at the ERT Command Station, verify that instrument display and DAS readings are identical. If a discrepancy is discovered, an EPA team member will troubleshoot the sensor to determine and/or resolve the problem. If the instrument is determined to be malfunctioning, that unit will be taken off-line for maintenance and replaced with a certified and challenged spare instrument. Due to the instability of hydrogen peroxide, particularly at lower concentrations, Zellweger hydrogen peroxide SPM’s are designed to be field challenged against nitrogen dioxide, which produces a detection response similar to, but weaker than, hydrogen peroxide. A certified gas standard of nitrogen dioxide formulated to give a 1 ppmv response as hydrogen peroxide on the SPM’s will be utilized to performance challenge the Zellweger SPM instruments on-site. Each Zellweger SPM used on this project will have a certificate issued



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by Zellweger documenting the accuracy of the unit to read hydrogen peroxide at the 0.5 and 1.0 ppmv levels. The certificates will be maintained by EPA on-site during the air monitoring project (not yet available at the time of AAMP submittal). Field performance challenging using nitrogen dioxide will be performed daily on each sensor during active fumigation periods, before instruments are positioned for reading at their stations. The SPM Verification Log and Field Monitoring Worksheet (Attachment 7) will be used to document field challenge tests and any maintenance work. The Zellweger Chemcassettes have a shelf life of approximately three to four months. The necessary Chemcassettes will be purchased as close to the start of fumigation as possible to maximize the utility period. Additionally, hydrogen peroxide Chemcassettes will be obtained for this project from the same production lot in order to minimize any potential variability between lots. Hydrogen peroxide Chemcassettes must be stored in a freezer to maintain optimum sensitivity (32 degrees Fahrenheit or less). Surplus or unused Chemcassettes will be stored in accordance with the manufacturer’s recommendation. 5.5.3 Field Calibration or Performance Challenge Failure If a piece of equipment fails field calibration or performance challenge checks, it will be checked once again against the check cylinder/standard. If it fails to calibrate or will not meet the challenge criteria, that instrument will be removed from service and tagged as inoperable. Such equipment will be repaired and recalibrated or performance challenged, as appropriate. Equipment that cannot be repaired will be replaced. 5.5.4 Calibration Records Each instrument will have its own Sensor Log where calibration results and real-time readings will be recorded. The calibration standards themselves will be tracked and documented in a Standards Tracking Log. Each calibration standard will be assigned a unique standard identifier. The Standards Tracking Log will contain information as to:

• date received

• manufacturer

• manufacturer’s lot number

• manufacturer’s bottle/cylinder number

• compounds

• concentrations

• acceptance criteria



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The Instrument and Standards logbooks will be completed in indelible ink and have bound and numbered pages. All instrument and calibration records will become part of the project file.


Table 3. Data Quality Measures and Criteria

MEASUREMENT‡ Analysis Detection

Limit (ppmv) QC

Frequency Goal

Accuracy Goal

Precision Completeness

Determine VHP concentration within SA-32 (Draeger Polytron 2 instruments) and in ambient air (PAC III instruments)

Real-time sensor

0.1-0.25 ppmv –manufacturer’s

specs

Calibrated per manufacturer’s instructions N/A N/A N/A

Determine VHP concentration in ambient air - Zellweger SPM instruments

Real-time sensor

0.1 ppmv - manufacturer’s

specs. (each individual

instrumentr to have a factory-

determined detection limit)

Pre-Sampling Optic Verification Post-Sampling Optic Verification

Field Challenge Test Pre-Certification Test Post-Certification Test

Duplicate (Co-Located SPM’s)

Pass/Fail Pass/Fail

+/-25% tolerance +/-10% tolerance +/-10% tolerance

30% RPD

90%

METEOROLOGICAL STATION Wind Speed Peak Time

Avg. Hourly 0-69 m/s By Manufacturer/Supplier, Annually +/- 0.1 m/s N/A 90%

Wind Direction Peak Time Avg. Hourly

1 degree By Manufacturer/Supplier, Annually +/- 4.0 m/s N/A 90%

Temperature Peak TimeAvg. Hourly

-50 to 50° C By Manufacturer/Supplier, Annually +/- 0.1° C N/A 90%

Relative Humidity Peak Time Avg. Hourly

0 to 100% By Manufacturer/Supplier, Annually +/- 2 to 3% N/A 90%

Barometric Pressure Peak Time Avg. Hourly

26 to 32 in Hg By Manufacturer/Supplier, Annually +/- 0.125% N/A 90%

‡ NOTE: Performed for each Fumigation Cycle N/A: Not applicable.


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6 Data Collection Assessment and Reporting This section describes data assessment activities, including flow of data, that will be conducted both during the sanitization process, and during final reporting of the data. The Data Quality Objectives (DQO), specific data validation requirements, and other quality control and assurance parameters that will be considered in this assessment process are presented in Section 7. As previously described, continuous instruments will be operated per manufacturer's instructions and SOPs provided in this AAMP. If any modifications to the accepted practices are necessary, these will be noted prior to the commencement of the VHP fumigation. If modifications become necessary during the fumigation events, these will be addressed with the UC and regulatory and project management personnel. The continuous monitoring systems used for this effort will store collected readings (data) and transmit to a central receiving station. Download will be actuated via physical hook up to a computer serial port for calculations and documentation.

All sensor calibration, certification, and performance challenge information, ambient air monitoring results, and air modeling results will be stored. Hard copies, where applicable, along with digital records in electronic format, will be archived. If these techniques are not going to be used to document data and instrument tapes, or equivalent paper evidence is used, these paper tapes will be removed and placed into a hardbound logbook at regular intervals. Each time this is performed, the tape will be attached to a clean page of the logbook and the person taking custody of the tape will sign the page with the date and time.

Whenever a Calibration check, Blank check, Accuracy check, or Precision check (Duplicate) is performed, the readings will be recorded into the instrument logbook and the entry will include:

• Type of QC performed

• Date and time of the reading(s)

• Recorded values

• Calculated QC measures

• Signature of person recording data



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6.1 Data Assessment and Review 6.1.1 Definitions Data will be evaluated in order to determine its quality and suitability for use in decision making. Due to the dynamic nature of the air monitoring program and potential consequences of obtaining inaccurate data, procedures will be implemented to ensure data quality. This section (Section 6) describes QC procedures to be used by the air monitoring program team to quickly identify potential instrument problems or bias in the data. The following six terms are frequently used to describe data quality:

• Precision

• Accuracy

• Representativeness

• Comparability

• Completeness

• Sensitivity

6.1.1.1 Precision Precision measures the reproducibility of measurements. It is strictly defined as the degree of mutual agreement among independent measurements as the result of repeated application of the same process under similar conditions. Analytical precision is the measurement of the variability associated with duplicate (two) or replicate (more than two) analyses. Analytical precision will be estimated by comparing the results from two co-located sensors. The precision measurement is determined using the relative percent difference (RPD) between the duplicate sample results. 6.1.1.2 Accuracy Accuracy is a statistical measurement of correctness and includes components of random error (variability due to imprecision) and systemic error. It therefore reflects the total error associated with a measurement. A measurement is accurate when the value reported does not differ from the true value or known concentration of the spike or standard. For this monitoring program analytical accuracy will be measured during instrument calibration by comparing the sensors response to a calibration standard. The analytical accuracy measurement is determined using the percent recovery (%R). Accuracy determinations for the Zellweger SPM instruments will be determined as percent tolerance.



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6.1.1.3 Representativeness Representativeness expresses how closely a sample reflects the characteristics of the substance for which it is surrogate. Since problems with uniformity are not typically an issue with ambient air monitoring, the main consideration with respect to representativeness will be ensuring the appropriateness of the sampling design, and, more specifically, to make sure that samples are collected from correct locations. Wind direction will be monitored closely to make sure monitoring equipment and personnel are positioned correctly to assess downwind areas. 6.1.1.4 Comparability Comparability is the confidence that one data set can be compared to another. In general, comparability will be achieved by using standard methods for sampling and monitoring, reporting data in standard units of measure and using standard reporting formats. Complete field documentation will support the generation the generation of comparable data. Comparability of meteorological data will be documented through the comparison of on-site data with Dulles International Airport data during baseline monitoring period. 6.1.1.5 Completeness Completeness is a measure of the amount of valid data obtained compared with what is expected to be obtained under normal operating conditions. The completeness goal for the project is to collect the highest percentage of valid results as possible in order to support good decision making. 6.1.1.6 Sensitivity Sensitivity is the ability of the method or sensor to detect the contaminant of concern at the desired level of interest. For this project, instrument sensitivity will be assessed during initial and follow-up calibration checks. Calibration checks will be performed as required based on sensor performance. A loss in instrument sensitivity will require an instrument recalibration. 6.1.1.7 Acceptance Criteria for Quality Control Measurements The criteria that will be used to determine if corrective action is necessary during data acquisition is summarized in Table 3. If QC results are outside the control limits listed, appropriate corrective action will be taken as required. These actions may consist of repeating the QC check, co-locating another sensor to confirm readings, troubleshooting the



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equipment and/or sensors, confirming the field challenge or calibration using another standard, or replacing the instrument and returning the original for recalibration. 6.1.2 VHP Process Monitoring VHP data generated during the ambient monitoring program will be relayed to a computer located in the central monitoring area. Data review and assessment will be conducted at the central monitoring area. UC personnel, project management and regulatory observers will have access to the computer display screens at this location. A project specialist will be assigned the task of continuously monitoring trends and alarms displayed on this system. This specialist will typically monitor the main screen that provides the alarm status of all sensors, and summary statistics. No formal data validation will occur since these analyses will be field measurements. However, the specialist(s) responsible for the central monitoring area will closely observe the data and trends for consistency, zero drift, and operational status. Summary reports will be prepared, reviewed and signed by the AMC and the QAC prior to release to project management, USACE, and the DoS. 6.1.3 Mobile Instruments These instruments will serve as mobile, roving sensors during the fumigation events and as replacement instruments if any of the stationary instruments cease operation for any reason, or fail the calibration check standard analysis. Results from the roving sensors will be called in the UC on a real-time basis, recorded in a logbook, and the included in the post-fumigation summary report. Documented information will include the location of the roving sensor and its functioning status (roving instrument, temporary replacement, etc.) During checks or upon visual observations made at least every 2 hours on the stationary, continuous-reading instruments, if a stationary instrument is found to be malfunctioning it will have a calibration or field challenge test performed at the time of discovery. If the sensor is still found to be out of calibration or otherwise malfunctioning, it will be replaced by a back-up unit within 30 minutes following observation of a malfunction. An additional instrument will be calibrated, accuracy checked, and continually operated as a standby replacement for any potentially malfunctioning unit. Thus, the new instrument will be ready for service immediately upon connecting to the data logger/transmitter. 6.1.4 Calibration Data Calibration and calibration check standards will be generated on-site for VHP or the appropriate calibrant. The generation of these standard will include a verification component. The AMC will be responsible for reviewing and approving standard/check verification QC data including initial calibration, continuing calibration, and results of each check.



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Documentation of analysis activities will be maintained in a field log book, and analytical results will be provided on a results form. Each analysis will be identified by a unique number. The form will provide the results for each field and QC sample, and will provide a reference to associated QC and calibration data. The backup will be attached to each analytical result, and the result approved by the AMC prior to data use. The routine calibration schedule will start the day of the Readiness Demonstration for the Fumigation process. The Draeger instruments will be calibrated upon installation, and the first calibration check will be performed prior to the start of the Readiness Demonstration period. Each instrument will be calibrated to each fumigation event. Calibration technicians will document calibration checks and calibrations on calibration forms. These forms will be maintained at the mobile laboratory and will be available for review onsite during the sanitization, and will be submitted in the final report. The QAC, or designee, will review the calibration records daily, and will witness the initial round of calibrations and will observe at least 2 subsequent calibrations as they are performed for each fumigation event. 6.1.5 Meteorological Monitoring Equipment Assessment of meteorological data will be conducted each day of the fumigation process. Problematic meteorological data will be reported to the UC for further review and determination of corrective action. Data will be validated according to the rejection criteria listed in Attachment 8. The continuous instruments will be programmed to collect data and transmit it to the central computer at regular intervals. The central computer will be capable of calculating the required 1-hour and 8-hour averages from the stored data. Data reduction will consist of printing this data in a spreadsheet-type format.

Each of the instruments will transmit data at set intervals to a processor. The processor will then determine the average conditions for these blocks of data and store this information for eventual download to a computer or other data receiving devices.

Once this data is downloaded into a workable form (spreadsheet), it will be reviewed for consistency and completeness. The data will then be graphed or plotted to show the conditions over the entire event and/or defined blocks of time. Statistical averages, standard deviations, and minimum/maximum values will also be determined through spreadsheet programming.

Prior to use, each program and/or spreadsheet calculation algorithm will be checked using trial data to ensure that calculations are being performed properly.



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6.1.6 Air Monitoring Data Collection Data will be stored continuously on the two computers for all air monitoring instrument networks- the STE system for VHP process air monitoring instruments and the EPA DAS system for ambient air monitoring instruments. For non-networked data loggers, such as mobile sensors, the data will be entered into a field logbook and called in to the UC on a real time basis. If possible, data stored on the sensor will be downloaded to the data collection system at the end of each VHP fumigation cycle. The data from the VHP process instruments locations will be transmitted as one-minute averages to the central computer. The VHP process central computer will contain software that will allow the calculation of 10-minute averages, 1-hour averages, 6-hour rolling averages and 8-hour rolling averages. Prior to use each sensor program and/or spreadsheet calculation algorithm will be checked using trial data to ensure that calculations are being performed properly. The data from the ambient air monitoring instruments will be transmitted to the EPA’s DAS every 15 seconds and processed via software into continuously-updated 10-minute rolling averages. The DAS will also process the data into longer-period averages as well as compare readings from individual or grouped sensors. 6.2 Validation of Data The Data Validation process for this event will be performed using the Manual Method. It will consist of reviewing the downloaded sensor data for continuity and completeness, verifying that QC measures have been performed and are acceptable, and in some instances comparing results to reference conditions. 6.2.1 Meteorological Manual validation of this data will consist primarily of review of the initial calibrations and/or reference set-up conditions during installation and a review of all data for unusual points. During this validation and review process the validator will be looking for readings inconsistent with conditions (40-mph gusts on an otherwise “calm” day) and large fluctuations over very short time periods (temperature spikes of >5 degrees °F in a 15-minute period). If any of these conditions are found in the data, the readings will be compared to those of the nearest real-time weather station, if available, to confirm whether those conditions existed. If they cannot be confirmed, the suspect data points will be replaced with the average of the reading(s) before and after the suspect value. New averages and other statistical calculations will be performed in addition to new condition graphs and plots.



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The data validator will double-check any instrument program and/or spreadsheet calculation algorithm by performing manual calculations from the raw readings and comparing to the calculated values for at least 1 percent of the calculations performed. 6.2.2 Ambient Air Instruments Manual validation of this data will consist primarily of review of the initial calibrations, calibration checks and accuracy/precision checks for compliance with the QAPP requirements. The data validator will also look for inconsistent readings and spikes or drops over very short time frames. Each of these will be evaluated against the conditions at the nearest upwind and downwind stations within ± 10 minutes to determine whether the actual conditions may have existed at anytime within the hour before the reading. If they cannot be confirmed, the suspect data points will be replaced with the average of the reading(s) before and after the suspect value. New averages and other statistical calculations will be performed.

The data validator will double-check any instrument program and/or spreadsheet calculation algorithm by performing manual calculations from the raw readings and comparing to the calculated values for at least 1 percent of the calculations performed.

6.3 Data Report Format 6.3.1 Field Reports Field reports will be generated to relay information to project management, the UC, and appropriate agencies. Scheduled written reports will be provided on a predesigned form, and will be updated hourly during the fumigation cycle. The forms will include information regarding the last hour’s maximum rolling averages for one-hour and eight-hour rolling time periods for each sensor, pertinent meteorological conditions, calibration information, and operational notes. Nonconformances will be documented on nonconformance forms. Such forms will be signed by the originator, the originators direct project management team member, and the QAC. These reports will be provided to the project manager or OSC within a timely manner upon completion. Nonconformances potentially affecting data quality will be relayed immediately to the UC by the QAC. All SPM air monitoring data will be transferred automatically and electronically to the DAS, at which point the data becomes available for viewing, electronic storage, and reports compilation. Optic verification and field challenge checks on the Zellweger SPM’s will be performed daily when fumigation is occurring and will be documented on individual SPM



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Verification Log and Field Monitoring Worksheets (see Attachment 7 for an example worksheet). The worksheets will be used to document and track the performance of each SPM over the course of the air monitoring project. Results from non-networked instruments will be called in to the UC on a real-time basis, and will be documented into a field logbook and later entered electronically to form a spreadsheet that can be combined and compared with networked sensor results. 6.3.2 Final Report A final report will provide full documentation and backup. The anticipated contents are as follows:

Section 1: Introduction Section 2: Monitoring Methodology Section 3: Results Section 4: QA/QC Assessment Section 5: Conclusions APPENDICES Appendix A: Calibration Documentation Appendix B: Field Logs Appendix C: Raw Instrument Data Appendix D: Copies of Field Reports Appendix E: Deviations and Nonconformances

6.4 Final Data Submittal A full report on the fumigation process will be submitted by STE within 60 days following the end of the last successful fumigation cycle-including receipt of acceptable BI/CI data. The Final Report will include all quality assurance information and statistics, as described in the Quality Assurance Project Plan.



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6.5 Ambient Air Monitoring Data Evaluation All data will be compared to the established action-levels listed below, which are averages based upon rolling 10-minute monitoring periods. Support Zone • Lower Warning Level - from instrument’s LDL to 0.5 ppmv • Upper Warning Level – greater than 0.5 ppmv Off-Site Area • Caution Level - from instrument’s LDL to 1.0 ppmv • Action Level - greater than 1.0 ppmv [See Section 3 for a detailed description of exposure and action criteria.] 7 Other Quality Assurance Elements During the monitoring event a comprehensive quality assurance (QA) effort will be utilized to provide confidence in the data collection, analysis, and interpretation processes. This QA program includes the elements already discussed and procedures for auditing/assessment, corrective action, and reporting. 7.1 Corrective Actions 7.1.1 VHP Process Monitoring Corrective Actions [SE&I/STE] An essential element to any functioning QA system is the ability to identify and correct systematic quality affecting issues and to document and communicate their resolution. This will be accomplished through SE&I’s Corrective Action Reporting (CAR) system. [Figure 5 presents a sample SE&I CAR form.] This CAR system will be instituted during the phase start-up process and will remain in place until the gaseous sanitization and all associated monitoring have been completed. Due to the short time frame of the entire task, CARs will be initiated and closed within the time frame of the VHP fumigation process.

Corrective actions will be initiated whenever a non-compliance with SOPs, instrument siting, instrument performance or data documentation requirements specified in this plan is found. The CAR will consist of the following critical steps, executed within a very short time frame:

• The problem will be defined



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• The cause of the problem will be investigated and determined

• A corrective action to eliminate the problem will be determined

• Responsibility for implementing the corrective action will be assigned and completed

• The effectiveness of the corrective action will be established and the correction implemented

• The corrective action will be verified and its solution communicated to the staff such that similar actions can be taken elsewhere

All SE&I/STE CAR activities will be fully documented and reported to the UC, Project Manager, USACE, and DoS. CARs will be tracked using the Corrective Action Request Tracking Log (Figure 6). Corrective actions may entail the retraining of personnel, re-locating of instrument stations, creation of new standards, replacement of instruments, or in extreme case, reassignment of personnel.



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Figure 5. SE&I/STE Corrective Action Request Form

SA-32 Facility Fumigation SE&I/STE CORRECTIVE ACTION REQUEST (CAR)

CAR Number: Date of Discovery: Activity: Evaluated Org/Rep: Location: Project Number: Requirement(s) Not Met: Description of Condition: Classification: Significant ? Yes No (If Yes, Corrective Actions 1, 2, 3 ,& 4 Below Apply) Is Stop Work Warranted ? Yes No______ Corrective Action Required: 1. Remedial Action Required and, (always) 2. Root Cause Determination Yes No_____ 3. Action to Prevent Recurrence Yes No_____ 4. Action Regarding Similar Work Yes No_____ Response Due Date: Initiator: Date: Proposed Corrective Action: Proposed Completion Date: Responsible Individual: Date: Evaluated By: Date: Completed Corrective Action Verification & Closure: Verification Method: Verified By: Date: .



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Figure 6. SE&I/STE Corrective Action Request Tracking Log

CAR Number

Issue Date

Response Due

Date

Response Accepted

Date

Date of

Verification & Closure



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7.1.2 EPA Corrective Action Activities Assessments described in preceding sections are designed to evaluate data acquisition procedures for the purpose of identifying deficiencies that may impact the quality of the data generated. The corrective action process provides for prompt detection and correction of conditions adverse to quality. It is particularly important that deficiencies are quickly identified and corrected during the fumigation process. Corrective action measures shall emphasize root cause determination and the prevention of recurrences. The following corrective action procedures identify the responsibilities and describe the system for documenting conditions adverse to quality and achieving corrective action. This system includes the method for identifying and tracking deficiencies from the time of discovery through resolution and verification. 7.1.2.1 Responsibilities EPA-ERT contract personnel (REAC) will be responsible for the implementation of the following procedures and will serve as the initiator of the corrective action process for the SPMs and the meteorological station. The Task Leader shall be responsible for ensuring the necessary degree of responsiveness by the site personnel, subcontractors and suppliers. 7.1.2.2 General Conditions adverse to quality shall be documented and reported to the EPA Work Assignment Manager (WAM). The condition will be investigated immediately and appropriate corrective action taken. Significant conditions adverse to quality will prompt action to prevent recurrence, evaluation regarding similar work, and root cause determination. Each deficiency will be tracked from its identification to verification of the completion of all corrective actions and closure. For the purpose of this procedure, the Initiator is the EPA WAM. EPA-ERT contract personnel who discover a deficiency will report it to the REAC Task Leader who may complete a Corrective Action Form (see Figure 7). Management of the evaluated person/organization is responsible to investigate and document a timely response, and perform the required corrective actions to resolve the deficiency. Deficiencies will be addressed immediately during preparation for an event requiring air monitoring and during the event itself. Refer to Section 2.0 for additional information on responsibilities and lines of communication.



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7.1.2.3 Corrective Action Process The following sections describe the corrective action process.

7.1.2.3.1 Initiation REAC or the other Program personnel may identify the deviation or deficiency during an assessment or while performing normal work activities. REAC personnel will confirm the existence of the condition adverse to quality with the EPA WAM, and discuss any immediate corrective action to be taken, if needed. REAC personnel will document the condition by completing the information required on the Corrective Action Form (Figure 7) or in the Field Change Form (Figure 8). REAC personnel will compare the condition to activity-specific project requirements, evaluate the impact of the condition, and recommend appropriate classification, significant or not, as well as the necessary applicable corrective action.

7.1.2.3.2 Response If a Corrective Action Form is issued, it will request for the corrective action elements identified, including completion dates, and identify the individual responsible for completing the corrective action. Once the response has been reviewed, the REAC personnel will evaluate the response to assure that all identified corrective action elements have been addressed, and that planned corrective actions will adequately resolve the condition. If unacceptable, REAC personnel will request additional information. Once corrective action is found to be acceptable, REAC personnel will sign the evaluation portion of the Corrective Action Form and verbally notify the evaluated organization of the acceptability of the proposed corrective actions. REAC personnel will monitor the progress of the corrective action. When the corrective action is completed in a satisfactory manner, the Initiator will verify the corrective action and approve the Corrective Action Form for closure. This status shall also be entered in the Field Change Form. All records, including the Field Change Form, will be maintained by the quality assurance personnel and shall be available for review. 7.2 EPA Contingency Plans Situations may arise that require implementation of a contingency plan. These situations can include failure of instruments or instrument components, communications failures, vehicle breakdowns or malfunctions, data processing failures, or other conditions requiring correction. In the following charts, the nature of the events requiring a response are coded as follows:



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Code Explanations C Critical system component such as background sampling instruments. If

component fails, monitoring objectives cannot be achieved. S Serious component failure. If a component such as a communication cable

fails, achievement of the monitoring objective can be compromised if prompt corrective action is not taken.

N Non-critical component such as a temperature. If component fails, monitoring objectives are still attainable.

7.2.1 Instrument Failures Instrument failures may occur in a number of the ambient monitoring systems. It is not possible at this point to define the precise number of ambient air monitoring units that must fail before attainment of the air monitoring objectives is seriously compromised. During the monitoring program, the predicted air dispersion modeling results will be overlain by and compared with actual ambient hydrogen peroxide gas monitoring results. If the predicted results are substantially verified by the ambient air monitoring results, the predictive modeling results may be viewed with a high degree of confidence. As a result , the number of monitoring units that must fail before the air monitoring objectives are compromised will be correspondingly high. This determination will be made by the UC in conjunction with the on-site monitoring and modeling personnel. 7.2.2 Data Processing Failures Data processing failures could occur at two points within the program. The DAS computer is setup with DASYLab software, while the Modeling computer is programmed with several kinds of predictive air models. Both computers will be supported by similar computer system loaded and tested with DASYLab and Modeling software



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7.2.3 Other Conditions Requiring Corrective Action .

System Component Code Contingencies

Electrical power failure onsite

Grid C 1. All REAC vehicle have onboard generators capable of providing full service for an indefinite amount of time

Interaction with Public Field monitoring equipment and crews

C 1.Curious onlookers, nearby residents, or local business owners/employees/ workers may be informed concerning the purpose of air monitoring. 2. All other questions by the public should be directed to site management by presenting the interested party with the contact name and telephone numbers. 3. In the event of a confrontational situations, or other potentially violent situations, immediately alert the police and allow the officers to resolve the situation. 4. If police personnel are not present when a potentially violent situation occurs, the personnel must immediately relocate themselves and their vehicle while contacting 911 and requesting police assistance. 5. Notify Air Monitoring Coordinator about the situation after notifying the police.

Wind direction C

1. Switch out with spare unit 2. Receive data from Dulles Airport 3. Use compass to determine wind direction manually

Wind speed C

1. Switch out with spare unit 2. Receive data from Dulles Airport 3. Use hand-held anemometer to determine wind speed manually

Temperature N 1. Collect temperature from H&S Monitors 2. Collect temperature from local source

Relative humidity N 1. Collect temperature from H&S Monitors 2. Collect RH from local source

Solar Radiation N No action required - non-critical parameter

Meteorological

Total system failure C 1. Receive data from Dulles Airport and enter it manually

Data Processing and Acquisition Formatting DAS Computer C

1. Diagnose problem and correct 2. If problem cannot be corrected, DAS operations will be transferred to a prepared backup computer.



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Predictive air dispersion modeling Modeling Computer C

1. Diagnose problem and correct 2. If problem cannot be corrected, dispersion modeling operations will be transferred to a prepared backup computer.

Zellweger Analytics MDA SPM C 1. Switch out with spare unit

2. Reconfigure monitoring network achieve complete coverage

Omega Engineering D1000 Module C

1.Switch out with spare unit

Background Monitoring

Rs-485 repeater/converter C 1.Switch out with spare unit

Zellweger Analytics MDA SPM C 1. Switch out with spare unit

2. Reconfigure monitoring network achieve complete coverage

Omega Engineering D1000 Module C 1.Switch out with spare unit

Ambient Air Monitoring Units

Rs-485 repeater/converter C

1.Switch out with spare unit

System Computer C 1.Switch out with spare unit

Data Acquisition System

Data Cables C 1. Replace with new cable



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Figure 7. EPA Non-Conformance/Corrective Action Form

EPA Non-Conformance/Corrective Action Form Lockheed Martin Corp., Edison, NJ

EPA Contract No. 68-C99-223

NONCONFORMANCE/CORRECTIVE ACTION FORM Date: _________________ This form is part of the quality assurance corrective action system and is used to track the progress of corrective actions. The nonconformance and corrective action sections are to be completed by the originator of this form. It is the QAO’s responsibility to verify corrective action. NONCONFORMANCE (State nature and reason for the deviation) CORRECTIVE ACTION TAKEN (State plan for correcting deviation) Signature ___________________________________Title____________________________ VERIFICATION OF CORRECTIVE ACTION (to be completed by the QAO) Signature______________________________________Title________________________



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Figure 8. EPA Work Assignment Field Change Form

Work Assignment Field Change Form (must be completed to initiate any on-site change in the scope of a Work Assignment)

Date: Time: Location:

Work Assignment #:

Person Initiating Change:

Work Assignment Title: Original Scope Being Changed (e.g., Work Assignment requests 5 samples): Changed Scope (e.g., WAM requests 30 samples): Task Leader Signature/Date: Work Assignment Manager Signature/Date: Other Applicable Signature(s)/Date: cc: Rajeshmal Singhvi, EPA Project Officer Dennis Miller, REAC Program Manager Gary Newhart, REAC Operations Manager Deborah Killeen, REAC QAO Vinod Kansal, REAC Analytical Section Leader Please note: 1) Additional resources (hours and/or dollars) may be required to fulfill the requested change in scope, 2) the schedule and milestones for this project as well as other projects may be modified as a result of the requested change in scope, and 3) these requirements/changes will be communicated in writing to the WAM as soon as a resource evaluation is made.



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7.3 Performance and System Audits Assessment activities ensure that data quality is adequate for its intended use and that appropriate responses are taken to address non-conformance and deviations from plans or specifications. Appropriately scheduled assessments will allow management to implement corrective action measures in a timely manner, thereby minimizing the impact of non-conformance on DQOs. DQOs dictate the type, frequency and extent of assessments to be performed. An audit is defined as a systematic check to determine the quality of specific activities and assists in determining if each element within a system is functioning properly. Due to the compressed schedule of this ambient monitoring event, the audit process will be accelerated to allow for the completion of ongoing Performance Audits and a System Audit during the event. 7.3.1 Performance Audits Performance audits will be performed each day of fumigation by the QAC. They will consist of an in-process check of the execution and documentation of the various measurement tasks. The areas that will be addressed include;

• Zero span checks/blanks- the QAC will evaluate the sensors logbooks and observe each analyst to verify whether the blanks are being performed and whether the results are as expected

• Calibrations/Performance Checks- the instrument logs and analyst observations will be utilized to determine whether the instrument calibrations are being checked properly and whether the results are within the QAPP criteria. In addition, where applicable, the QAC will audit the gas standard generation, certification, and documentation process to ensure that viable standards are being used in calibrations and calibration checks

• Precision Checks- the QAC will audit logs and observe analysts to ensure that the required checks are being performed, properly calculated and documented, and that the criteria are being met

7.3.2 On-Site System Audits The QAC will perform a system audit during the Readiness Demonstration for the Fumigation Process. This audit will be documented and any deficiencies discussed and addressed to completion before the effort will be allowed to commence. The System audit



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will be performed to ensure that working procedures are in place, all equipment is in working condition, and all sensors are properly sited. Specific areas that will be addressed include:

• SOPs exist and have been approved for all tasks

• All instruments are set-up and sited in the approved locations

• Logbooks exist for all instruments

• All instruments have been calibrated

• The Accuracy check has been performed on all instruments

• Extra instrument(s) are available and fully operational in case of the failure or interruption of a monitoring station

• Any instrument download and calculation algorithms have been verified for proper execution

• Level of efficiency for monitoring team activities

7.3.3 Instrument System Audits Technical system audits of the stationary, continuous-reading air monitoring instruments will be performed by the designated representative daily to ensure that the air monitoring program is functioning properly. Critical items for review include the following:

• Calibration and documentation procedures

• Completeness of data forms, notebooks and other reporting requirements

• Data review and verification procedures

• QC procedures and documentation

• Operating conditions of facilities and equipment

• Documentation of training and maintenance activities and

• Systems and operation overview

After each audit, a debriefing session will be held with the responsible participants to discuss the preliminary audit results. The auditor will then complete the audit report including observations of deficiencies and the necessary recommendations for corrective actions. Magnetic tape audits involve the examination of the electronic media (tapes, floppy discs, hard drives, compact discs, etc.) used to collect, analyze, report, and store data. At a



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minimum, a check will be made to ensure that the air monitoring data coming into the main data acquisition system is accurate and is backed up daily. 7.4 Reports to Management Due to the highly compressed schedule of this activity, all QA information and results will be incorporated into one Quality Assurance Report at the end of the fumigation phase. This report will be compiled and written by the project QAC. It will contain a summary of the overall QA/QC activities and data and will include copies of all pertinent records and results. Specific elements of this report include:

• Assessment of measurement data precision, accuracy, and completeness

• All calibration checks

• All blank checks

• Accuracy checks for all monitors

• Calibration/accuracy check source information

• Records produced to verify concentrations of calibration standards

• Instrument siting diagrams and comparison to Plan directives

• System and performance audit results

• All Corrective Actions and details of solutions implemented

The report will be reviewed by the Project CQM, USACE, DoS, and EPA before it is incorporated into the Fumigation Final Report and submitted for further distribution.


8.0 References 1. Code of Federal regulations, 40 CFR Part 58 - Ambient Air Quality Surveillance. 2. Code of Federal regulations, 40 CFR Part 53 - Ambient Air Monitoring Reference and

Equivalent Methods. 3. Meteorological Monitoring Guidance for Regulatory Modeling Applications (EPA- 454/R-99-005, February 2000) 4. Quality Assurance Handbook for Air Pollution Measurement Systems; Volume IV:

Meteorological Measurements (EPA/600/R-94/038d, March1995)


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ATTACHMENTS

1 Negative Air Machine Catalyst Scrubber Technical Information 2 SA-32 Facility Site Schematic 3 Annual Wind Rose for Dulles Airport Meteorological Station 4 Draeger Hydrogen Peroxide Polytron 2 Product Information & Technical Data 5 Zellweger Single Point Monitor Product Information 6 Draeger Pac III Hydrogen Peroxide Handheld Monitors 7 Zellweger Single Point Monitor Verification Log and Field Monitoring Worksheet 8 EPA-ERT Meteorological Instrument Specifications


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Attachment 1 Negative Air Machine Catalyst Scrubber Technical

Information


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Attachment 2 SA-32 Facility Site Schematic


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Attachment 3 Annual Wind Rose for Dulles Airport Meteorological Station


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Attachment 4 Draeger Hydrogen Peroxide Polytron 2 Product Information

& Technical Data


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Attachment 5 Zellweger Single Point Monitor Product Information

Advantages: • Fast response monitor specific to target gas only

• Gas sensitivity to ppb levels with physical evidence • Minimum maintenance and no dynamic calibration

• Customized for harsh industrial environments • More than 50 gas calibrations available

Applications: • Outdoor locations • Corrosive areas

• Remote sampling areas • Gas storage areas

• Survey work • Perimeter/fencelines

• Ventilation and exhaust systems

Options: • Z-purge system

• Duty cycle • ChemKey

• RS422 • Remote reset

• Portable • Extended sample

• Heater option (operate from -20°C to ±40°C)

t o t a l e n v i r o n m e n t a l s o l u t i o n s

SPM Technical Data Specifications


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This publication is not intended to form the basis of a contract, and the company reserves the right to amend the design and specifications of the instruments without notice. NORTH AMERICA Zellweger Analytics, Inc. Corporate Headquarters 405 Barclay Boulevard Lincolnshire, IL 60069 Toll-Free 800-323-2000 (US/Canada) Tel. 847-634-2800 Fax 847-634-1371 http://www.zelana.com

A company of the Zellweger Luwa Group

Catalog No. 1998-0147 10/97 2M Copyright 1997 Zellweger Analytics, Inc.


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DETECTABLE GASES RANGEAmines Ammonia (NH 3 ) 2.6-75.0 ppm Ammonia (NH 3 )-II 2.6-75.0 ppm Dimethylamine (DMA) 0.1-6 ppm n-Butylamine (n-BA) 0.4-12 ppm Methylene Dianiline (MDA) 3-60 ppb p-Phenylene Diamine (PPD) 2-60 ppb Toluene Diamine (TDA) 4-60 ppb Trimethylamine (TMA) 1.1-30.0 ppm Diisocyanates (CHDI, HDI, HMDI, IEM, IPDI, MDI, NDI, PPDI, TDI, TMDI, TMXDI, XDI) 2-60 ppb Hydrazines MMH* 3-30 ppb N 2 H 4 * 20-300 ppb UDMH* 5-30 ppb Hydrides Arsine (AsH 3 ) 15-150 ppb Diborane (B 2 H 6 ) 31-300 ppb Disilane (Si 2 H 6 ) 1.5-15 ppm Germane (GeH 4 ) 141-600 ppb Hydrogen Selenide (H 2 Se) 20-150 ppb Phosphine (PH 3 ) 32-900 ppb Silane (SiH 4 )* 0.5-15 ppm Stibine (SbH 3 ) 20-300 ppb tert-Butylarsine (TBA) 15-150 ppb tert-Butylphosphine (TBP) 60-900 ppb Hydrogen Cyanide (HCN) 1.1-30.0 ppm Hydrogen Sulfide (H 2 S)* 1.1-30.0 ppm Mineral Acids Hydrogen Bromide (HBr)* 0.3-9.0 ppm Hydrogen Chloride (HCI)* 0.5-15.0 ppm Hydrogen Flouride (HF) 0.6-9.0 ppm Hydrogen Iodide (HI) 0.3-9.0 ppm Nitric Acid (HNO 3 ) 0.2-6.0 ppm Sulfuric Acid (H 2 SO 4 ) 26-750 ppb Oxidizers Bromine (Br 2 ) 11-300 ppb Chlorine (Cl 2 ) 0.05-1.5 ppm Chlorine (Cl 2 )-II 0.05-1.5 ppm Chlorine Dioxide (CI0 2 ) 11-300 ppb Hydrogen Peroxide (H 2 O 2 )* 0.1-3 ppm Nitrogen Dioxide (NO 2 )* 0.3-9.0 ppm Ozone (O 3 ) 31-300 ppb Phosgene (COCI 2 )* 11-300 ppb Sulfur Dioxide (SO 2 )* 0.2-6.0 ppm * other ranges available

SPECIFICATIONS Detection Technique: Chemcassette Detection System Alarm Point: Dual level alarms typically set at 1/2 TLV and TLV Response Time: As fast as 10 seconds Alarm Indication: Local audio/visual alarms; remote capability optiona Signal Outputs: SPDT concentration alarm relays; SPDT fault relay; 4-20 mA; digital display Relay Rating: 120VAC@10amps; 240VAC@5amps Operating Temperature Range: 32° to 104°F; 0° to 40°C (basic unit); heating/cooling optional Power Requirements: 115/230 VAC 50/60 Hz, battery operation optional Enclosure: NEMA 4X fiberglass (basic unit) Dimensions: 12"(H) x 12"(W) x 7"(D) (30.5 x 30.5 x 17.8 cm) (basic unit) Weight: 14.5 pounds (6.6 kg) (basic unit) Note: options may vary the specifications

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Attachment 6 Draeger Pac III Hydrogen Peroxide Handheld Monitors


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Attachment 7 Single Point Monitor (SPM) Verification Log and

Field Monitoring Worksheet

Response Engineering Analytical Contract Lockheed Martin Corp., Edison, NJ

EPA Contract No. 68-C99-223

Date : Site Name: WA #: Unit Number Type of Chemcassette H2O2

Serial Number Manufacturer Zellweger

EPA Tag Number Lot Number

Maintenance Last Performed (Date)

Expiration Date

Sample Location Range of Detection Calibration Information Gas Type H2O2 Gas Type H2O2

Pre-Sampling Meter Verification

Pass/Fail

Pre-Sampling Meter Response (ppb)

Date Performed Date Performed

REAC Air Team (Signature)

Tolerance (± 10%)

Sample Start Date Performed By Zellweger Analytics

Sample Start Time Certificate Available Y/N Post-Calibration

Post-Sampling Meter Verification

Pass/Fail

Post-Sampling Meter Response (ppb)

Pass/Fail

Date Performed Date Performed

REAC Air Team (Signature)

Tolerance (± 10%)

Sample End Date Performed By Zellweger Analytics

Sample End Time Certificate Available Y/N


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Attachment 8 MET One Meteorological Station Specifications

Met One Model

Meteorological Variable

Parameter Specification USEPA Recommended Criteria

Starting Threshold 0.9 mph = 1.1 mph

Accuracy Less than 22.7 mph

0.25 mph 0.4 mph

Accuracy greater than 22.7 mph

± 1.1% of true ± 5% of true

Wind Speed

Resolution 0.01 mph 0.2 mph

Accuracy ± 4° ± 5°

Damping Ratio 0.25 * 0.4 – 0.7

Resolution 0.5° 1.0°

034A

Wind Direction

Starting Threshold 0.9 mph = 1.1 mph

Range -50 °C to +50 °C (-58 °F to 122 °F)

Accuracy ± 0.10 °C (± 0.18 °F) ± 0.5 °C (± 0.9 °F)

Resolution 0.1 °C (± 0.18 °F)

0.1 °C (± 0.18 °F)

Ambient Temperature

Time Constant 10 seconds = 60 seconds

Accuracy Better than ± 2% RH between 10% RH and 100% RH

± 1.5 °C (± 2.7 °F) for dew-point calculation

Response Time 15 seconds at 20 °C (68 °F) 90% of final RH value

= 30 minutes 63% of step change

083D

Relative Humidity

Operating Temperature Range

-20 °C to +60 °C (-4 °F to +140 °F)

Equivalent to dew point range of -30 °C to +30 °C (-22 °F to +86 °F)

Accuracy

± 0.04” Hg (± 1.35 mb) or ± 0.125% full scale

± 3 mb 091 Barometric Pressure

Resolution Infinite 0.5 mb

NOTES: mph = miles per hour RH = relative humidity mb = millibar * Meeting criteria would require use of foam fins, which would make the instrument significantly less rugged. No impact on detected wind direction over a 15-minute averaging period would be detected.

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