FINAL REPORT AIR MONITORING PROGRAM Securement Of .

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VELSICOL CHEMICAL CORPORATIONFINAL REPORTAIR MONITORING PROGRAMSecurement of Wasteburning S.Bolf Course SiteSt. Loula, Michigan13

VELSICOL CHEMICAL CORPORATIONFINAL REPORTAIR MONITORING PROGRAMSecurement of WasteburningGolf Course SiteSt. Loula, MichiganJune, 19829-0996CONESTOQA-ROVERS Ik ASSOCIATES LIMITED

TABLE OF CONTENTSPAGE1.0INTRODUCTION12.0AIR MONITORING PROGRAM22.1SCOPE22.2CONTROL OF FUGITIVE EMISSIONS2TOTAL SUSPENDED PARTICULATES AMPLING DATA93.04.05.06.0ORGANIC VAPOR MONITORING134.1COMBUSTIBLE GAS MONITORING134.2SPECIFIC COMPOUND MONITORING15PUBLIC COMPLAINTS175.1DUST175.2NOISE175.3TELEVISION RECEPTION INTERFERENCE18CONCLUSIONSAPPENDIX A - LETTER TO CITY OF ST. LOUIS RESIDENTSAPPENDIX B - TOTAL SUSPENDED PARTICULATE DAILYCONCENTRATIONSAPPENDIX C - WIND SPEED - WIND DIRECTION MONITORINGAPPENDIX D - EXPLOSIVITY/FLAMMABILITY MONITORINGAPPENDIC E - SPECIFIC COMPOUND MONITORING19

LIST OF FIGURESPAGEFIGURE 1MONITORING STATION LOCATIONS - PLANT SITEFIGURE 2MONITORING STATION LOCATIONS - GOLF COURSE SITE

I1-0INTRODUCTIONSecurement of the waste burningIand disposal area, located at the Edgewood Hills Golf Coursein St. Louis, Michigan, began in early January, 1982.Allwork proceeded in accordance with the provisions containedwithin the report entitled "Protocol - Securement of WasteIBurning and Disposal Area, Golf Course Site - St. Louis,Michigan", dated December, 1981. The Protocol was reviewedand approved by both the United States EnvironmentalProtection Agency, (USEPA) and the Michigan Department ofNatural Resources (MDNR) During all activities involvingthe excavation, transport, handling or disposal of wastes,an ambient air monitoring program was implemented.IiiiiiiThisreport details the air monitoring program and provides allsampling data for the construction period.

2.0AIR MONITORING PROGRAM2.1SCOPEAll active work areas at the GolfCourse excavation site were continuously monitored forexplosivity and flammability, and were periodicallymonitored for the presence of five specific compounds(described in Section 4).Monitoring for particulateemissions was undertaken on a continuous basis at twolocations adjacent to the Golf Course Site, and at fourlocations adjacent to the Plant Site, during allperiods of construction activity (described inSection 3).2.2CONTROL OF FUGITIVE EMISSIONSThe release of fugitiveparticulates from both the Golf Course and Plant siteswas minimized by application of calcium chloridesolution and/or water to all haul roads and work areasduring construction activities.

[A mechanical sweeper and construction equipment was available at all times to'effect road cleaning or collection of spilledImaterial.IPrior to commencing constructionactivities, each household located within one cityIblock of any haul road was visited by two Velsicoljrepresentatives.The scope of forthcoming work wascarefully explained to each resident and each householdIwas provided with a letter which detailed theforthcoming work and included a telephone number whichIcould be called in the event a resident perceived.elevated levels of air borne particulate matter, odors,'or noise, during construction activities.Ithe home telephone numbers of the Velsicol,In addition,Conestoga-Rovers & Associates Limited (CRA), andIContractor's on-site supervisors were provided to theCity of St. Louis Fire and Police Departments in theIevent that odors or air borne particulate matter proved to be a concern during non-working hours.IiiiA copy of the letter provided toeach household is contained within Appendix A.coNrs;-;:-,'.'-. L'.hrs i AS;-".';IAM:C. LIMITED

3' TOTAL SUSPENDED PARTICUIATES MONITORING3,1SCOPEThe monitoring network consistedof four monitoring stations located adjacent to thePlant Site and two monitoring stations located adjacentto the excavation area at the Golf Course Site.Figures 1 and 2 illustrate monitoring station locationsat the Plant Site and the Golf Course Site,respectively.A meteorological station wasutilized to monitor wind speed and direction.Thisstation was located atop the project site office nearithe main entrance to the Plant Site.IThe location of each monitoringstation and the meteorological station was fieldIinspected and approved by the MDNR prior tocommencement of air monitoring.3.2IIEQUIPMENTEach monitoring station wasequipped with an Accu-Vol, Model GMWS-2310 Air Sampler- 4

rLEGENDPARTICULATEMONITORING STATIONfigure IPARTICULATE MONITORING STATIONSCRA9 - 0 9 9 6 - 24/OB/82ST. LOUIS PLANT SITEVelsico/ Chemical Corporation

PROPOSED1X(Am

Air flow through the sampler wasmaintained by a Kurz Model 310 flow controller.Theflow controller incorporated an electronic probe whichwas located in the orifice between the filter paper andthe electric motor.The probe automatically adjustedmotor speed to correct for variations in line voltage,temperature, pressure and filter loading.Air flow through the sampler wasmonitored by a pressure transducer and flow meter whichwas connected to a pressure tap at the exhaust end ofthe motor. The flow meter continuously recorded airflow over the twenty-four hour sampling period.An electronically operated minutecounter was incorporated into each sampler.Thisallowed an accurate determination of each samplingperiod.Filters measured 8 inches by 10inches in size and were of heavy duty glass fibreconstruction.Air samplers were housed inanodized aluminum shelters located on wooden platformsat a height of 10 feet to 15 feet above ground level.Each sampler was provided with an electrical servicefrom the City of St. Louis grid.- 7 -

The meteorological stationconsisted of an R. M. Young Co. Model 6301 wind vaneand Model 6101 3 cup anemometer, and a direct currentpowered Rustrac twin recording translator.3.3iOPERATIONAll sampling units were calibratedI* -to 40 cfm (field) with an oil manometer prior to1commencing monitoring operations.IEach sampler was manually servicedat an interval of 1440 10 minutes as determined by theIsampler minute counter.For each daily servicingIperiod, the operator removed the spent filter andpressure transducer chart, installed a new filter andI pressure transducer chart, set the minute counter atzero, noted the time of day, and restarted theIsampler.*the pressure tranducer chart indicated a variance in*flow rate of 2 cfm from original calibration.iISampling units were recalibrated at any timeExposed filters were stored inindividual folders in the site project office.Filterswere shipped to the laboratory for dessication andIfinal weighing on a weekly batch basis.- 8 s & A ? S C C I A : E S LIMITED

Electric motor brushes werereplaced routinely at approximately monthly intervalsBrush replacement was staggered for all samplers inorder that not more than one monitoring station wasinactive on any given day. Following each brushreplacement, the sampler was recalibrated to 40 cfm(field).The meteorological station wascalibrated in accordance with the manufacturersinstructions prior to commencing monitoring.3-4SAMPLING DATAPre-weighed heavy duty glass fiberfilters were provided by the laboratory to the projectoffice in lots of fifty filters.The exposed filtersand pressure transducer charts for seven sampling dayswere shipped to the laboratory each week end. Uponreceipt by the laboratory, each filter was dessicatedfor twenty-four hours and re-weighed.Total suspendedparticulate concentrations were calculated according tothe following formulas:V FR x T x 0.0283SP - WF - Wi x 106V- 9 CONESTOGA-KOVtRS & ASSOCIATES LIMITED

where:pVIi Air volume sampled (m3)FR Flow rate (SCFM)TI Sampling time (minutes)SP Mass concentration of suspended particulate(ug/m3)1V/i initial weight of filter (gm)Wp Final weight of filter (gm))Calculated suspended particulatematter concentrations were reported to CRA field(personnel within forty-eight hours of receipt of the,filters by the laboratory and are tabulated in AppendixB for the period January 19, 1982 to April 22, 1982.IWith the exception of routine maintainance, samplingwas conducted continuously in any area when excavation,Ihandling, transport, or disposal of waste occurredX -during this period,Ii)On March 4, 1982, the flow controller at StationP2 failed,IIiiiExceptions were as follows:A replacement was installed and thestation resumed operation on March 10, 1982.ii)During the period March 12 to March 14, 1982,Station P8 was inaccessible due to a severe snowstorm.- 10 C O N E S T O G A - R O V F - h S & A S S O C I A T E S LIMITED

iii) The flow controller failed at Station P3 onJanuary 29th.A replacement was obtained and theStation resumed operation on February 10th.Theflow controller again failed on February 19th, andwas replaced on February 24th.During the duration ofconstruction activity, a single excursion above thespecified limit occurred ( 150 ug/m3).This was onMarch 8, 1982 at Station P7 with a reported value of259 ug/m3.All other monitoring stations reportedvalues ranging from 37 to 93 ug/m3 for that day.Station P7 is located immediately adjacent to a gravelhaul road.The elevated level of suspended particulatematter was identified visually by CRA personnel on theday of occurance and was immediately controlled byapplication of calcium chloride solution to the haulroad.In general, suspended particulateconcentrations were normally reported in the range of10 ug/m3 to 70 ug/m3 for the duration of themonitoring program.The strip chart from the Rustracrecorder translator was removed weekly for datareduction.Integrated hourly averages for wind speed- 11 C O N E S T O G A - R O V E R S & A S S O C I A T E S LIMITED

and direction are contained within Appendix C for theperiod January 18th to March 21, 1982. Equipmentdifficulties were encountered during the period March7th to March 13th, and reported data is incomplete forthis period.- 12 C O N E S T O G - R O V F F S & A S S O C I A T E S LIMITED

4.0ORGANIC VAPOR MONITORING4.1COMBUSTIBLE GAS MONITORINGDuring the course of theexcavation of the waste burning and disposal area,flammability/explosivity was monitored continuously atthe excavation face with a Bendix Combustion AlertMulti-Channel Gas Detection System complete with tworemote sensors .The system was programed to soundan alarm siren should flammable vapors be present at aconcentration above 20% of the lower explosive limit(LEL).The system was also equipped with a FisherRecordall Recorder which provided the operator with astrip chart print-out of monitored LEL percentages.x The operator also had the capability of interrogatingthe system at will, which provided an LEL display ofthe highest and lowest values since the previousinterrogation.This operation was performed routinelyat least twice in each twenty- four hour period . A\continuous LEL display of the current percentage forithe highest reading sensor was also provided .Il C - M O V r P S & ASSOC Ei- LIMITED

Two remote sensors were employedfor the duration of the excavation phase of theproject.These were relocated as required to remain inclose proximity to the excavation face.Generally onesensor was located at a lower elevation and one at ahigher elevation near the face in order that heavierand lighter than air vapors would both be monitored.iInitially the sensors were each jfactory equipped with 250 linear feet of signal cable.This was found to be inappropriate due to the proximityof heavy equipment.]The sensor cables were modified toa total length of 400 linear feet each.This enabledthe operator to locate the sensors much more*effectively.Calibration of the system was]routinely checked on a daily basis using a calibrationkit supplied by the manufacturer.IThe entire system, which includedthe electronic controller, two sensors, one Fisher\recordall recorder, one space heater, and one poweralarm was housed in an enclosed trailer equipped withIfluorescent lighting.This enabled the operator toperform routine or emergency service at any time of the1day or night.iC O N E S T O G A - R O V C h S & A S S O C I A T E S LIMITED

Very low LEL percentages wereapparent throughout the monitoring program.Generally,constant readings of zero were reported by the system.On two occasions, 2% of the lower explosive limit wasreported at the excavation face.This occurred foronly a short period of time and in both instances wasconsidered insignificant,Recorded LEL values are tabulatedin Appendix D for the period February 3 to April 2,1982.4.2SPECIFIC COMPOUND MONITORINGSampling for specific compoundswas performed on an approximately weekly basis or atany time odors were present.Compounds sampled forwere:1)Benzene2)Carbon Tetrachloride3)Phenol4)Chloroform5}1, 2 - Dichloroethane- 15 C O N E S T C ' G A - R C V E R S & A S S O C I A T E S LIMITED-16 C O N E S T O G A 4 - O V E R S & A S S O C I A T E S LIMITED

5.0PUBLIC COMPLAINTS5.1DUSTOver the duration of the project,two complaints pertaining to elevated levels of dustfrom haul roads were received from City of St. Louisresidents.In both instances, application of calciumchloride solution combined with additional streetcleaning efforts by the mechanical road sweeper,immediately eliminated the source of the problem.5.2NOISEOver the duration of the project,numerous complaints pertaining to elevated noise levelswere received from City of St. Louis residents.Without exception, complaints centered on project trucktraffic travelling City owned roadways during nighttime hours.An agreement was eventually reachedwith the City of St. Louis which limited operation ofhaulage units to a period from 5:00 a.m. to 10:00 p.m.on any working day. Though not eliminating the noiseproblem, the limit on working hours proved to be asatisfactory compromise between City residents and theContractor.- 17 C O N E S 7 0 G A - K O V E R S & A S S O C I A ' T S LIMITED

5.3TELEVISION RECEPTION INTERFERENCESeveral complaints were receivedfrom City of St. Louis residents which related tomomentary interference with television reception bypassing project haulage trucks.No solution to thisproblem was identified.- 18 CONESTOGA-ROVfP.S & A S S O C I A T F S LIMITED

6.0CONCLUSIONSThe comprehensive air monitoringprogram implemented by Velsicol during remedial constructionat the waste disposal and burning area, Edgewood Hills GolfCourse, has identified that remedial construciton activitiesdid not adversely impact air quality within the City of St.Louis.In addition, the air monitoringprogram has identified that workmen at the excavation sitewere not exposed to threat of explosion or fire, or toexcessive concentrations of chemical compounds for whichmonitoring was implemented.Close liaison and cooperation byVelsicol with City of St. Louis Municipal Officialsminimized the impact of construciton activities upon Cityresidents.- 19 C O N E S T O G A - R O V F R S & ASSOCIATES LIMITED

All of Which is Respectfully Submitted,CONESTOGA-ROVERS & ASSOCIATES LIMITEDRichard G. Shepherd, P. EngFrank A. Rovers, P. EngDonald Robinson-20 C O N E S T O G A - R O V E R S & A S S O C I A T E S LIMITED

APPENDIX ALETTER TO CITY OF ST.LOUIS RESIDENTSC O N E S T O G A - R O V E R S & A S S O C I A T E S LIMITED

VELBICOLCHEMICALCORPORATIONSOD BANKSQN STREET ST. LOUIS. MICHIGAN 4BBBO * S17-BB1-2141Dear Resident,As you are probably aware, a contract to excavate an area of thegolf course property and transport material to the old plant sitewill commence in the near future. During the period of constructionactivity, every effort will be taken to limit to a minimum disturbanceof persons residing in areas adjacent to the construction site andhaul routes.A comprehensive dust and odor control program has now beenimplemented. In the unlikely event you are inconvenienced by dust orodor arising from construction activities, you are to inform the DustControl Center (681-2141) of your problem. Upon receipt of a complaint,Velsicol will investigate the source of the problem and immediatelyinstitute appropriate remedial measures.Due primarily to the time of the year, we will of necessity, betransporting material over long hours in order to excavate all of thematerial prior to the spring thaw when we would be limited to halfloads and very muddy conditions. This will make it necessary onoccasions to work nights.During the course of the project, we will initiate a safety planwhich will require us to post guards at the site entrances so that thegeneral public will be excluded for their own safety. The workmenwill all wear disposable coveralls, rubber boots, and gloves, andwill be required to carry a respirator while on site. These are onlyprecautions for the workers safety "just in case".The projected completion dates, weather permitting, are March 5,1982, for excavation, March 20, 1982 for backfill, and April 15, 1982for final clean up.These dates are of course tenative, contingent upon variablesbeyond our control.We do realize that the truck noise is sometimes a source ofannoyance, but it is something which is quite unavoidable on a projectof this nature and we hope you will bear with us until we complete theproject.

RESIDENTPAGE 2Should you have any questions, comments or complaints, please donot hesitate to contact either Mr. Ed Smith or Mr. Don Robinson at681-2141 at your convenience.Thank you.iiiiiiii

APPENDIX BTOTAL SUSPENDED PARTICULATEDAILY CONCENTRATIONSC O N E S T O G A - R O V E R S & A S S O C I A T E S LIMITED

AVERAGEFILTERNUMBERSAMPLINGSITESAMPLINGDATEFLOW 11.6CR-024P-l1/23/82 - 637.0013.710. 2.736.336.536.0062.657.510.5C Q N E S T O G 4 - R G V E R S & A S S O C I A T E S LIMITED

AVERAGEFILTERNUMBERSAMPLINGSITEFLOW /28/821/28/821/28/821/28/821/28/82 CR-054CR-055CR-056 CR-061CR-062P-lP-2P-4P-7P-81/30/82 1/30/82 1/30/82 1/30/82 1/30/82 R-066CR-067P-lP-2P-4P-7P-82/1/82 - 2/2/822/1/82 - 2/2/822/1/82 - /82 - 2/6/822/5/82 - 2/6/822/5/82 - 2/6/822/5/82 - 2/6/822/5/82 - 31/29/822/1/82 - 2/2/822/1/82 - 2/2/82C O N E S T O G A - R O V E PS & A S S O C I A T E S UMITED

GFLCW P-2P-4P-7P-82/8/82 - 2/9/822/8/82 - 2/9/822/8/82 - 2/9/822/8/82 - 2/9/822/8/82 - 7CR-101CR-102CR-103CR-104P-lP-4P-7P-82/9/82 - 2/10/822/9/82 - 2/10/822/9/82 - 2/10/822/9/82 - 2/10/822/9/82 - .32/10/82 - 2/11/822/10/82 - 2/11/822/10/82 - 2/11/822/10/82 - 2/11/822/10/82 - 2/11/822/10/82 - -2-C O N E S T O G A - R O V T P S & A S S O C I A T E S LIMITED

5/82 - CR-160CR-161CR-162P-lP-2P-4P-7P

Air flow through the sampler was maintained by a Kurz Model 310 flow controller. The . Air flow through the sampler was monitored by a pressure transducer and flow meter which was connected to a pressure tap at the exhaust end of the motor. The flow meter continuously recorded air

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